I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)
Face Up (“we,” “us” or “our”) takes your privacy seriously. This Privacy Policy (“Privacy Policy”) explains our data protection practices and describes the types of information we may process when you install and/or use the “Face Up” software application for mobile devices (the “App,” “our App”).
When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social status.
Our Privacy Policy applies to all users, and others who access the App (“Users”). For the purposes of the GDPR, we are the data controller, unless otherwise stated.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. WHEN YOU USE THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.
If You Are A California Resident
Under the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request:
- The categories of personal information that are processed
- The categories of sources from which personal information is obtained
- The purpose for processing user personal data
- The categories of third parties with whom we may share personal information
- The specific pieces of personal information that we might have obtained about a user, provided that the data in the request is reliable enough to identify the user
Please use the navigation links in this Privacy Policy:
- PERSONAL INFORMATION
- SHARING
- OPT-OUT OPTIONS
- REQUESTS
Note that according to the CCPA, personal information does not include de-identified or aggregated consumer information.
PERSONAL INFORMATION
All about the categories of information, its sources, and purposes of processing.
Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of an agreement and for a business purpose.
SHARING
How your information can be shared.
All third parties engaged in processing user data are service providers that use such information on the basis of an agreement and for a business purpose.
OPT-OUT OPTIONS
If you do not want us to process your personal information anymore, please contact us at info@funy.ai. In most cases, we cannot maintain further operation of the App without functional data, and you may be advised to remove the App from your device.
If you do not want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described in Section VIII.
REQUESTS
To submit a verifiable consumer request for access, portability, or deletion of personal data, please contact us through info@funy.ai. Include “Your rights to maintain confidentiality in the state of California” in your message.
When submitting a verifiable request, you should be prepared to:
- Provide sufficient information to allow us to verify you are the person about whom we collected personal information or an authorized representative (e.g., name, address, city, state, zip code, email address). An authorized agent must provide written authorization or power of attorney signed by you.
- Describe your request in sufficient detail that allows us to understand, evaluate, and respond properly.
We will not be able to respond to your request or provide personal information if we cannot (i) verify your identity or authority to make the request, or (ii) confirm that the personal information relates to you. We may request additional information or documents to verify your identity, and we may use third-party identity verification services. This is a safeguard against disclosing personal information under a fake request.
We ensure that personal information provided in a verifiable consumer request is used only for verification and not for any other purpose. It is retained only as long as reasonably necessary and then deleted.
We endeavor to respond to a verifiable consumer request within forty-five (45) days. If more time is required, we will inform you of the reason and extension period in writing. We are only required to respond to two requests per customer each year.
EQUAL RIGHTS
We will not discriminate in response to your exercise of privacy rights. However, certain services may not be provided if you delete your personal information.
SALE OF DATA
We do not sell any of your personal data to third parties.
II. INFORMATION WE PROCESS
1. Functional Information
We ask for and process the following information when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information, it is impossible to provide complete functionality of the App.
- User Content (e.g., text you enter and send to the App, as well as any AI-generated content via the App). You may use, share, or otherwise exploit your User Content at your own risk, and you are responsible for compliance with applicable laws. We engage the third-party service provider OpenAI, L.L.C. for processing and creating AI-generated User Content. See Section IV for more on OpenAI’s practices.
- Contact Information (e.g., name, email address, and any other content you include in emails or support forms). We collect and store it via our cloud storage provider (Amazon.com, Inc.). We use this information to respond to inquiries, fulfill requests, send communications you request, and provide our services.
2. Information That Is Processed Automatically
With your permission, we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device (e.g., IDFA for iOS, Advertising ID or Android ID for Android). Some tools may perform automated processing of personal data, including profiling, to analyze or predict personal preferences, interests, behavior, location, or movements. Processing begins once you allow the App to track your activity. You can withdraw your permission at any time in your device settings (see Section VIII).
We may process certain device and user behavior information under our legitimate interest. This generally includes aggregated non-personal data that helps us improve the App.
Examples of automatically processed information include:
- Device Details such as the type, operating system/version, model, manufacturer, screen size, memory usage.
- Internet Connection details such as mobile carrier, network provider, IP address, timestamps, session durations.
- Location-Related Information such as IP address, country/region/state/city based on the SIM card or device.
- Other Device Identifiers including any user identifiers set by the App’s developer.
- Information About Applications including the name, API key, version, and properties of our App. Some services may record a list of apps or processes on your device.
- Cookies and Similar Technologies used to operate the App effectively, understand usage, and measure advertising.
- Log File Information automatically recorded each time you access the App.
- Ad-Related Information such as the dates/times ads are served, clicks, or conversion events.
- In-App Events data on tutorial steps, levels, purchases, or custom events within the App.
3. Face Data Collection and Usage
Our App may collect facial images from users for features such as style photo generation via face swapping and personalized avatar creation. These facial images are securely stored on servers located in Silicon Valley, USA, owned and operated by us. We do not share face data with any third parties. The data is retained for up to 7 days, during which users can retrieve or edit their creations, after which it is permanently deleted.
By using the App, you agree to the collection and use of your facial images as described above. We are committed to protecting your privacy and ensuring the security of your data.
4. Payment Information
Our e-commerce provider (Apple) handles billing, processing, and charging for in-app purchases. We do not access or store credit or debit card details. You can review the applicable “in-app” purchase rules and policies through the App Stores.
III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA
We use your information for the following purposes:
- To make our service available: We use functional and automatically processed data to provide requested services.
- To improve, test, and monitor the App: We use automatically processed data to understand user behavior, detect issues, and optimize performance.
- For interest-based advertising or other targeted content: We may use automatically processed data to show ads that may be relevant to you.
- To communicate with you: We use contact information to send newsletters, marketing notifications, respond to inquiries, and inform you about our policies and terms.
- To prevent fraud and spam, and to enforce the law: We use information to investigate fraud, protect trademarks, and enforce our Terms of Use.
If we need to process your personal data for new purposes, we will update this Privacy Policy accordingly.
IV. SHARING OF YOUR INFORMATION
We share your information with third parties only as described in this Privacy Policy, and we adhere to the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment.
We choose third parties that apply technical and organizational measures to protect personal data. However, we cannot guarantee the absolute security of information once transmitted, and we are not responsible for accidental loss or unauthorized access via a third party’s fault.
We do not rent or sell your personal data. Certain information (e.g., cookies, log files, device identifiers, location data) may be shared with third-party organizations that provide automatic data processing for the App. We do not control how these third parties use their tracking technologies. We may also share certain information (e.g., cookie data) with third-party advertising partners to deliver targeted advertising.
Below are examples of third-party service providers we engage:
Entity name | Services performed | Location | Link to Privacy Policy |
---|---|---|---|
AppsFlyer Inc. | Analytics service provider | U.S.A. | https://www.appsflyer.com/legal/services-privacy-policy/ |
Firebase (Google LLC) | User authentication, analytics, and marketing | U.S.A. | https://policies.google.com/privacy, https://firebase.google.com/support/privacy?hl=en |
OpenAI, L.L.C. | AI-generated content provider | U.S.A. | https://openai.com/privacy/, https://openai.com/terms/ |
Our App may contain links to third-party sites or be accessed from a third-party site. We are not responsible for the privacy practices of those sites or services.
We may disclose personal information if required by law, to protect rights and safety, investigate fraud, or in connection with a merger, acquisition, or sale of assets. You will be notified via the App of any change in ownership or personal information usage.
V. INTERNATIONAL DATA TRANSFERS
We operate worldwide and may transfer information across borders. If you are in the EU or another region with different data laws, please note that we may transfer information to jurisdictions where data protection laws differ. We endeavor to ensure that recipients of your personal data provide adequate protection. By using the App, you consent to these transfers.
For storage, we use hosting services and, where possible, encrypt personal data before sending it. We only cooperate with hosting organizations that meet our security standards.
VI. HOW LONG WE USE YOUR PERSONAL DATA
We retain personal information as long as necessary to operate the App and to comply with legal obligations. If you no longer wish to have your information stored, you can request deletion and account closure. Some data may be kept longer if needed for legal obligations, safety, or backups.
Face data, as noted in Section II.3, is retained for a maximum of 7 days and then permanently deleted.
VII. EXERCISING YOUR RIGHTS
Depending on applicable data protection laws, you may have rights regarding your personal information:
- Data Access and Portability: Request copies of your personal information.
- Change or Correct Data: Request corrections or updates if you cannot do so yourself.
- Data Retention and Deletion: Request deletion of your personal data.
- Restriction of Processing: In certain circumstances, limit how your data is used.
To exercise these rights, contact us at info@funy.ai. We can only address data we physically access and store.
If data is processed automatically by third-party services, consult their privacy policies for details on exercising your rights. If you are in the EU, you may also contact our representative at info@funy.ai.
VIII. OPT-OUT OF MARKETING TRACKING
If you prefer not to receive personalized ads, you can:
- iOS: Select “Limit Ad Tracking” in Settings > Privacy > Advertising (Apple Support)
- Visit https://youradchoices.com
You may still see contextual ads based on non-personal information.
IX. SECURITY
We follow industry standards to protect your personal information during transmission and storage. However, no method of transmission or storage is completely secure. If a security breach compromises your data, we will notify you promptly, in compliance with applicable law.
For any security questions, contact info@funy.ai.
X. CHILDREN’S PRIVACY
The App is not intended for children under 18. We do not knowingly collect personal information from children under 18. If we learn we have done so without parental consent, we will delete it immediately. If you believe we may have data from a child under 18, please contact us.
XI. CHANGES TO THE PRIVACY POLICY
We update this Privacy Policy regularly. We will post changes here or elsewhere we deem appropriate. Additional notice may be provided in certain circumstances.
XII. HOW TO CONTACT US
If you have any questions about this Privacy Policy, please reach us at info@funy.ai.
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