Face A.I. Privacy Policy
Updated : 16.09.2025
This Privacy Notice is designed to help you understand how Wellborn Creative Ltd. Face A.I. (“Face A.I.”, “we”, “us,” and “our”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.
We are committed to protecting and respecting your privacy and will use your personal information only after obtaining your consent to the collection and processing of your personal data on the terms specified below and in strict accordance with the General Data Protection Regulation (the “GDPR”), the California Consumer Privacy Act of 2018 (the “CCPA”), California Privacy Rights Act (the “CPRA”) and other applicable laws, regulations and guidelines.
Content:
1. Scope of Our Privacy Policy
2. Updates to Our Privacy Notice
3. Types of Personal Data We Gather
3.1. Data You Share With Us Directly
3.2. Data We Obtain Automatically
3.3. Data Acquired from Third Parties
4. Purposes for Processing Your Data
4.1. Delivering Our Services
4.2. Administrative Functions
4.3. Promotion and Advertising of Our Offerings
4.4. Additional Uses
5. Sharing of Your Personal Information
5.1. Sharing for Service Provision
5.2. Sharing for Legal Protection and Safety
5.3. Sharing During Business Transfers
6. Your Options and Rights Regarding Privacy
6.1. Available Privacy Choices
6.2. Your Rights Concerning Privacy
7. Protecting Your Data
8. Transferring Data Internationally
9. Keeping Your Personal Data
10. Specific Information for California Residents
11. Specific Information for Nevada Residents
12. Specific Information for Virginia Residents
13. Information for Children
14. External Sites and Applications
15. Regulatory Authorities
16. How to Contact Us
1. Scope of Our Privacy Policy
This Privacy Notice governs the processing of personal information by our Face A.I. mobile application (“App”). For simplicity, the App and all related services are collectively referred to as “Services.”
2. Updates to Our Privacy Notice
We reserve the right to modify this Privacy Notice at our discretion. Should there be any significant changes, we will inform you as mandated by law. By continuing to use the Services after an update, you are accepting the revised Privacy Notice. We advise you to review this notice periodically for any changes.
3. Types of Personal Data We Gather
The personal information we collect varies based on your interaction with us, our Services, and the requirements of applicable law. This includes information you provide directly, information we collect automatically through your use of our Services, and information we obtain from third parties and other sources as outlined below.
3.1. Data You Share With Us Directly
The personal information you provide can include:
(a) Photos. We collect photos you upload from your device when using our App to perform the requested face swap functionality. Access to your device’s camera or gallery is necessary to upload content.
(b) Temporary Processing. Uploaded photos are processed solely to generate the requested result. We do not collect or store any other personal information such as names, emails, or voice data.
(c) Deletion. After processing is completed, uploaded photos are automatically and permanently deleted within a short period of time.
(d) Purchase Information. We collect information related to your purchases, including billing details. Payment processing is conducted by third-party services; we do not collect or store payment card information directly.
(e) Communications with Us. We collect information such as your email address when you inquire about our Services, seek customer or technical support, or communicate with us in other ways.
(f) Surveys. If you participate in surveys, you may provide certain information, which could include personal information.
3.2. Data We Obtain Automatically
When using our Services, we may collect limited technical data (such as device type, operating system, crash logs) strictly to maintain functionality and security of the App.
We do not collect advertising identifiers, precise geolocation, or tracking data.
3.3. Data Acquired from Third Parties
We may receive information about you from external sources, such as app stores or third-party login services, but only if you have agreed to share this information under their privacy settings.
4. Purposes for Processing Your Data
We use your data exclusively to:
We do not use your data for personalized advertising, profiling, or tracking across services.
4.1. Delivering Our Services
Your information is utilized to honor our agreement with you and deliver our Services, such as:
(a) Offering features like face swapping, face restoring, avatar creation, and other similar functionalities;
(b) Handling your data, subscription models, and accounts;
(c) Enabling access to specific areas, functionalities, and features within our Services;
(d) Responding to requests for customer or technical assistance;
(e) Communicating with you regarding your account, activities within our Services, terms of service, privacy notices, and other policy updates; and
(f) Processing financial transactions and different payment methods for purchased Services.
4.2. Administrative Functions
We employ your data for a range of administrative tasks, including:
(a) Advancing our legitimate interests, such as direct marketing, research and development (including market research), network and information security, and fraud prevention;
(b) Identifying and acting upon security incidents, safeguarding against harmful, deceptive, fraudulent, or unlawful activities, and prosecuting those accountable for such actions;
(c) Gauging interest and participation in our Services;
(d) Short-term, non-permanent applications, like ad customization based on context;
(e) Enhancing, upgrading, or adding to our Services;
(f) Innovating new products and services;
(g) Guaranteeing internal quality control and safety measures;
(h) Authenticating and verifying identities;
(i) Troubleshooting to identify and rectify errors within our Services;
(j) Conducting audits related to interactions, transactions, and other compliance actions;
(k) Enforcing our agreements and policies; and
(l) Adhering to our legal responsibilities.
4.3. Promotion and Advertising of Our Offerings
We may leverage personal data to customize and deliver promotional and advertising content to you, in accordance with applicable laws.
Marketing methods may include email campaigns, targeted advertising to create custom audiences, and “interest-based” or “personalized advertising,” potentially via cross-device tracking.
For inquiries about our marketing strategies or to opt out of having your personal data used for marketing purposes, you can contact us anytime as outlined in Section 16 (“Contact Us”).
4.4. Additional Uses
We may also use your information for reasons you request or as allowed by law, including:
(a) Consent: Utilizing personal information for purposes clearly communicated to you when you provide your data or with your consent.
(b) De-identified and Aggregated Data: Creating de-identified and/or aggregated data, such as demographic insights, anonymized location data, device usage information, or other analyses.
(c) Sharing with Friends or Colleagues: Our Services may include tools that let you share content with others, such as through our referral programs, allowing you to send content or service invitations to friends or colleagues.
5. Sharing of Your Personal Information
We share information only in very limited circumstances, such as to provide our Services, ensure protection for us and others, or during significant business dealings like mergers, acquisitions, or asset sales, as detailed below.
5.2. Sharing for Legal Protection and Safety
We may access, preserve, and disclose information if required to comply with legal obligations, protect our rights or the safety of others, or enforce our agreements.
5.3. Sharing During Business Transfers
In the event of a merger, acquisition, reorganization, or asset transfer, your information may be included as part of the transferred assets, as allowed by law.
5.4. Data Management and Security with Third-Party Service Providers
Uploaded photos are processed exclusively on secure servers operated and controlled by Wellborn Creative Ltd. We do not transfer user photos to any third-party servers for processing.
All uploaded photos remain under our direct control during processing and are permanently deleted shortly after the requested face swap operation is completed.
All data transfers between the App and our servers are protected using SSL (Secure Socket Layer) encryption to ensure confidentiality and security during transmission.
6.Your Options and Rights Regarding Privacy
6.1. Available Privacy Choices
Your privacy preferences regarding your personal information are determined by applicable laws and include:
(a) Device Settings. You may receive push notifications through our App, which you can opt out of by modifying your device settings. With consent, we may collect precise location data, which you can opt out of via your device settings.
(b) “Do Not Track” Signals. We do not acknowledge or respond to browser-initiated DNT signals or similar mechanisms.
(c) Cookies and Ad Choices. You can control or block tracking tools or remove them based on your browser/device settings. Adjustments may affect our Services' functionality. On mobile applications, you can opt out of personalized ads following specific instructions for Android, iOS, and other platforms. To opt out from targeted ads by certain partners, visit industry websites like the Network Advertising Initiative or the Digital Advertising Alliance. Opt-outs must be done separately for each browser and device.
6.2. Your Rights Concerning Privacy
Depending on the law, you may have rights such as:
(a) Accessing your personal data, including confirmation of its processing, access, or portability;
(b) Correcting inaccuracies or incomplete data;
(c) Deleting your personal data;
(d) Transferring your data to you or a third party;
(e) Restricting or objecting to data processing;
(f) Revoking consent for data processing.
For exercising these rights, please contact us as indicated in Section 16 (“Contact us”). We will handle these requests according to applicable regulations.
7. Protecting Your Data
We implement technical and organizational measures (including SSL encryption, secure servers, and strict deletion policies) to safeguard your data. While no system is 100% secure, we take all reasonable steps to protect your information against unauthorized access, disclosure, or misuse.
8. Transferring Data Internationally
Your data is processed and stored exclusively on secure servers under our control. We do not transfer user photos to third parties outside our infrastructure.
If any future international transfers are required (e.g., for lawful compliance), we will ensure they meet GDPR and other applicable standards.
9. Keeping Your Personal Data
We do not permanently store any personal data, including uploaded photos. Photos are automatically and permanently deleted shortly after processing is completed.
Generated content (e.g., output images) may remain temporarily available to you in the App, but is not retained by us once deleted by the user or after the App session ends.
10. Specific Information for California Residents
This section is exclusively for California residents, in line with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These laws grant California residents the right to be informed about the categories of personal information collected and whether such information was disclosed for business purposes (like to service providers) in the last twelve months. For details specific to California residents, please refer below.
Category of Personal Information Collected by Face A.I. | Categories of Third Parties Personal Information is Disclosed to for a Business Purpose |
Identifiers | - Service providers - Other users or third parties you share with - Advertising partners |
Personal information categories listed in Cal. Civ. Code § 1798.80(e) | - Service providers - Other users or third parties you share with |
Commercial information | - Service providers - Other users or third parties you share with |
Biometric information | - Service providers |
Internet or other electronic network activity | - Service providers - Other users or third parties you share with - Advertising partners |
Sensitive Personal Information | - Service providers - Third parties your share with |
Sensory data | - Service providers - Other users or third parties you share with |
Geolocation data | - Service providers - Other users or third parties you share with - Advertising partners |
Professional or employment-related information | - Service providers - Other users or third parties you share with |
Inferences drawn from other personal information to create a profile about a consumer | - Service providers - Other users or third parties you share with - Advertising partners |
Additional Privacy Rights for California Residents
- “Sales” of Personal Information: In alignment with the CCPA and CPRA, Face A.I. does not engage in the “sale” of personal information and is not aware of any “sale” of personal data of minors under 16.
- Non-Discrimination: California residents are entitled to not face discrimination for exercising their rights under the CCPA and CPRA.
- Authorized Agents: Only you or a legally authorized individual on your behalf can make requests related to your personal information. For appointing an authorized agent, contact us as described below.
- Verification Process: Requests will prompt verification steps to ensure the requester is the subject of the requested personal information or their authorized representative.
- Sensitive Personal Information: Requests can be made to limit the use and disclosure of sensitive personal information to the minimum necessary for providing requested services.
California residents wishing to exercise their CCPA rights can contact us as specified below.
11. Specific Information for Nevada Residents
Nevada residents have the right to opt-out of the sale of certain personal information. Though we do not sell personal information as defined by Nevada law, residents can submit a request by contacting us with the specified subject line.
12. Specific Information for Virginia Residents
Virginia residents, under the Virginia Consumer Data Protection Act, have rights to access, correct, obtain copies of their personal data, and opt-out of processing their personal data for targeted advertising, the sale of personal data, or profiling in significant decision-making. We currently do not engage in the sale of personal information as defined by Virginia law.
13. Information for Children
Our Services are not intended for children under 13 years of age (or the applicable age threshold in certain jurisdictions), and we do not knowingly collect personal data from children. If you discover that your child has provided us with personal information without your consent, please contact us using the information provided in Section 16. Should we become aware that we have inadvertently collected personal data from a child in violation of applicable laws, we will take immediate actions to remove that data from our records.
14. External Sites and Applications
Our Services might include links to third-party websites or applications, and similarly, third-party websites or applications may link to our Services. We do not have control over the privacy practices of these external services. We advise users to familiarize themselves with the privacy policies of any third-party websites or applications they engage with. We do not endorse or take responsibility for the privacy practices or content of such external platforms. Sharing personal data with any third-party websites or applications is done at your own discretion and risk.
15. Regulatory Authorities
For individuals in the European Economic Area (EEA), Switzerland, or the United Kingdom, you possess the right to submit a complaint to a supervisory authority if you believe our processing of your personal data infringes upon applicable law. A comprehensive list of data protection authorities in EU member states can be found here: https://digital-strategy.ec.europa.eu/en/library/list-personal-data-protection-competent-authorities.
16. How to Contact Us
Wellborn Creative Ltd.,, operating under the trade name Face A.I., is responsible for the management of your personal data. Should you have queries regarding our privacy practices, this Privacy Notice, or if you wish to exercise your rights as outlined herein, please reach out to us at:
Wellborn Creative Ltd. / Face A.I.
8 Clock House Parade, North Circular Road, London, England, N13 6BG
Email: support@wellborncreative.com
We are committed to addressing any concerns or questions you may have regarding your privacy and our data handling practices.