Privacy Policy — Photo AI Generator
Effective date: July 16, 2026
Company: MobileXApps MB
Address: Eduardo Andre g. 14-5, 02231 Vilnius, Lithuania
Contact: expertaichat@gmail.com
Website: https://mobilexapps.com/sway-ai-privacy-policy
Introduction
This Privacy Policy explains how MobileXApps MB ("we", "us", "our"), a company registered in the Republic of Lithuania and operating under the laws of the European Union, collects, uses, and protects your personal data when you use the Photo AI Generator mobile application ("App").
As a company established in the EU, we are subject to the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). For users in the United States, we additionally comply with the California Consumer Privacy Act (CCPA) and applicable US state privacy laws. For all other users worldwide, we apply the same high standard of data protection.
The most important things to know:
- We do not use your photos to train AI models — ours or anyone else's.
- Your photos and associated Face Data are deleted from our servers immediately after processing.
- We do not sell your personal data.
By using the App, you agree to the practices described in this Policy.
1. Data Controller
The data controller responsible for your personal data is:
MobileXApps MB
Eduardo Andre g. 14-5, 02231 Vilnius, Lithuania
Email:expertaichat@gmail.com For GDPR-related requests, contact us at: expertaichat@gmail.com
2. What Data We Collect
TL;DR: We collect only what is strictly necessary to run the App. We do not collect your name or email unless you contact us.
Category Data Legal Basis (GDPR) Purpose
Photos Photos you upload Contract performance (Art. 6(1)(b)) AI generation only
Face Data Facial coordinates, facial mesh data, and other data derived from uploaded photos. Contract performance (Art. 6(1)(b)) AI generation only
Device info OS version, device model, language Legitimate interest (Art. 6(1)(f)) App stability
Purchase data Subscription status, purchase date (via StoreKit) Contract performance (Art. 6(1)(b)) Access control
Usage analytics Feature usage, session duration (anonymized) Legitimate interest (Art. 6(1)(f)) Product improvement
Device ID Keychain Device ID Legitimate interest (Art. 6(1)(f)) Free tier limit enforcement
We do not collect: your name, email address (unless you contact support), precise location, contacts, or biometric identifiers for the purpose of identifying you as an individual.
3. How We Process Your Photos and Face Data
TL;DR: Your photo goes to our server, AI generates the result, the photo and Face Data are deleted immediately. We never use it to train AI.
When you upload a photo for AI generation, the following occurs:
4. Your photo is transmitted over an encrypted connection (TLS 1.3) to our cloud servers (hosted on AWS, EU region).
5. From your uploaded photo, we extract Face Data, which includes facial coordinates and facial mesh data. This Face Data is used solely for the purpose of generating AI images that accurately reflect your unique facial features.
6. The AI model processes your photo and Face Data to generate the requested image.
7. The generated result is returned to your device.
8. Your original photo and all associated Face Data and intermediate processing data are permanently deleted from our servers immediately after the AI generation is completed. We do not retain copies of your original photos or Face Data on our servers.
9. Generated images are stored only on your device. We do not retain copies on our servers.
We do not use your photos or Face Data to train, fine-tune, or improve any AI model — neither our own nor any third party's. All third-party AI providers we work with are bound by contractual Data Processing Agreements (DPA) that explicitly prohibit the use of user data for model training, advertising, profiling, or any other purpose beyond providing the requested AI generation service.
We do not collect facial geometry, facial recognition templates, or any biometric identifiers for the purpose of identifying you as an individual.
10. How We Share Your Data
TL;DR: We share data only with essential service providers. We never sell your data.
We may share data with:
- Cloud infrastructure providers (AWS, EU region) — to host and process your photos and Face Data as described above, under a signed DPA that includes explicit Zero Data Retention clauses for Face Data.
- AI generation providers — under DPA with explicit Zero Data Retention clauses, prohibiting the use of Face Data for advertising, profiling, or any other purpose beyond providing the requested AI generation service.
- Anonymized analytics providers — only non-identifiable, aggregated data.
- Apple — purchase and subscription data is processed by Apple through StoreKit. We receive only subscription status, not your payment details.
We do not sell, rent, or share your personal data, including Face Data, with advertisers, data brokers, or any third parties for commercial purposes.
In the event of a merger, acquisition, or sale of assets, we will notify you at least 30 days before your data is transferred and becomes subject to a different Privacy Policy.
11. Data Retention
Data Type Retention Period
Uploaded photos and Face Data Deleted immediately after AI generation is completed
Generated images Stored only on your device; not retained by us
Purchase / subscription records Duration of subscription + 5 years (EU tax law compliance)
Anonymized analytics Up to 2 years
Device ID (free tier counter) Until you request deletion or uninstall the App
12. Your Rights
TL;DR: You can ask us to show, correct, or delete your data at any time. We respond within 30 days.
Under GDPR, you have the following rights:
- Right to Access (Art. 15): Request a copy of the personal data we hold about you.
- Right to Rectification (Art. 16): Request correction of inaccurate data.
- Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your data. Because we do not retain photos or Face Data after processing, the primary data to delete is your Device ID counter and purchase records.
- Right to Restriction of Processing (Art. 18): Request that we limit how we use your data.
- Right to Data Portability (Art. 20): Request your data in a machine-readable format.
- Right to Object (Art. 21): Object to processing based on legitimate interests.
- Right to Lodge a Complaint: You have the right to lodge a complaint with the Lithuanian State Data Protection Inspectorate (VDAI): www.vdai.lrv.lt , or with the supervisory authority of your country of residence within the EU.
For California residents (CCPA): We do not sell personal information. You may submit a "Do Not Sell My Personal Information" request to expertaichat@gmail.com to confirm this in writing.
To exercise any of these rights, or for any questions regarding your Face Data, contact us at expertaichat@gmail.com. We will respond within 30 days.
13. International Data Transfers
Our servers are located in the AWS EU (Frankfurt) region. If any data is transferred outside the European Economic Area (EEA), we ensure it is protected by appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission.
14. Children
TL;DR: The App is for users 13+ (16+ in the EU). We do not knowingly collect data from children.
The App is not directed at children under the age of 13. For users in the European Economic Area, the minimum age is 16 years, in accordance with GDPR Article 8. We do not knowingly collect personal data from children below these age thresholds.
Upon first launch, users are required to confirm their date of birth. If a user indicates they are below the minimum age, access to the App is blocked. If you believe a child has provided us with personal data, please contact us at expertaichat@gmail.com and we will delete it promptly.
15. Security
We implement industry-standard security measures, including TLS 1.3 encryption for data in transit and AES-256 encryption for data at rest. Access to user data is restricted to authorized personnel only. We conduct regular security reviews.
No method of transmission over the Internet is 100% secure. We cannot guarantee absolute security, but we commit to notifying you of any data breach within 72 hours of becoming aware of it, in accordance with GDPR Article 33.
16. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via an in-app notification at least 7 days before the changes take effect. The updated Policy will be posted in the App and on our website. Your continued use of the App after the effective date constitutes acceptance of the updated Policy.
17. Contact
MobileXApps MB
Eduardo Andre g. 14-5, 02231 Vilnius, Lithuania
Email: expertaichat@gmail.com
Website: https://mobilexapps.com/sway-ai-privacy-policy
For GDPR data subject requests: expertaichat@gmail.com
Company: MobileXApps MB
Address: Eduardo Andre g. 14-5, 02231 Vilnius, Lithuania
Contact: expertaichat@gmail.com
Website: https://mobilexapps.com/sway-ai-privacy-policy
Introduction
This Privacy Policy explains how MobileXApps MB ("we", "us", "our"), a company registered in the Republic of Lithuania and operating under the laws of the European Union, collects, uses, and protects your personal data when you use the Photo AI Generator mobile application ("App").
As a company established in the EU, we are subject to the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). For users in the United States, we additionally comply with the California Consumer Privacy Act (CCPA) and applicable US state privacy laws. For all other users worldwide, we apply the same high standard of data protection.
The most important things to know:
- We do not use your photos to train AI models — ours or anyone else's.
- Your photos and associated Face Data are deleted from our servers immediately after processing.
- We do not sell your personal data.
By using the App, you agree to the practices described in this Policy.
1. Data Controller
The data controller responsible for your personal data is:
MobileXApps MB
Eduardo Andre g. 14-5, 02231 Vilnius, Lithuania
Email:expertaichat@gmail.com For GDPR-related requests, contact us at: expertaichat@gmail.com
2. What Data We Collect
TL;DR: We collect only what is strictly necessary to run the App. We do not collect your name or email unless you contact us.
Category Data Legal Basis (GDPR) Purpose
Photos Photos you upload Contract performance (Art. 6(1)(b)) AI generation only
Face Data Facial coordinates, facial mesh data, and other data derived from uploaded photos. Contract performance (Art. 6(1)(b)) AI generation only
Device info OS version, device model, language Legitimate interest (Art. 6(1)(f)) App stability
Purchase data Subscription status, purchase date (via StoreKit) Contract performance (Art. 6(1)(b)) Access control
Usage analytics Feature usage, session duration (anonymized) Legitimate interest (Art. 6(1)(f)) Product improvement
Device ID Keychain Device ID Legitimate interest (Art. 6(1)(f)) Free tier limit enforcement
We do not collect: your name, email address (unless you contact support), precise location, contacts, or biometric identifiers for the purpose of identifying you as an individual.
3. How We Process Your Photos and Face Data
TL;DR: Your photo goes to our server, AI generates the result, the photo and Face Data are deleted immediately. We never use it to train AI.
When you upload a photo for AI generation, the following occurs:
4. Your photo is transmitted over an encrypted connection (TLS 1.3) to our cloud servers (hosted on AWS, EU region).
5. From your uploaded photo, we extract Face Data, which includes facial coordinates and facial mesh data. This Face Data is used solely for the purpose of generating AI images that accurately reflect your unique facial features.
6. The AI model processes your photo and Face Data to generate the requested image.
7. The generated result is returned to your device.
8. Your original photo and all associated Face Data and intermediate processing data are permanently deleted from our servers immediately after the AI generation is completed. We do not retain copies of your original photos or Face Data on our servers.
9. Generated images are stored only on your device. We do not retain copies on our servers.
We do not use your photos or Face Data to train, fine-tune, or improve any AI model — neither our own nor any third party's. All third-party AI providers we work with are bound by contractual Data Processing Agreements (DPA) that explicitly prohibit the use of user data for model training, advertising, profiling, or any other purpose beyond providing the requested AI generation service.
We do not collect facial geometry, facial recognition templates, or any biometric identifiers for the purpose of identifying you as an individual.
10. How We Share Your Data
TL;DR: We share data only with essential service providers. We never sell your data.
We may share data with:
- Cloud infrastructure providers (AWS, EU region) — to host and process your photos and Face Data as described above, under a signed DPA that includes explicit Zero Data Retention clauses for Face Data.
- AI generation providers — under DPA with explicit Zero Data Retention clauses, prohibiting the use of Face Data for advertising, profiling, or any other purpose beyond providing the requested AI generation service.
- Anonymized analytics providers — only non-identifiable, aggregated data.
- Apple — purchase and subscription data is processed by Apple through StoreKit. We receive only subscription status, not your payment details.
We do not sell, rent, or share your personal data, including Face Data, with advertisers, data brokers, or any third parties for commercial purposes.
In the event of a merger, acquisition, or sale of assets, we will notify you at least 30 days before your data is transferred and becomes subject to a different Privacy Policy.
11. Data Retention
Data Type Retention Period
Uploaded photos and Face Data Deleted immediately after AI generation is completed
Generated images Stored only on your device; not retained by us
Purchase / subscription records Duration of subscription + 5 years (EU tax law compliance)
Anonymized analytics Up to 2 years
Device ID (free tier counter) Until you request deletion or uninstall the App
12. Your Rights
TL;DR: You can ask us to show, correct, or delete your data at any time. We respond within 30 days.
Under GDPR, you have the following rights:
- Right to Access (Art. 15): Request a copy of the personal data we hold about you.
- Right to Rectification (Art. 16): Request correction of inaccurate data.
- Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your data. Because we do not retain photos or Face Data after processing, the primary data to delete is your Device ID counter and purchase records.
- Right to Restriction of Processing (Art. 18): Request that we limit how we use your data.
- Right to Data Portability (Art. 20): Request your data in a machine-readable format.
- Right to Object (Art. 21): Object to processing based on legitimate interests.
- Right to Lodge a Complaint: You have the right to lodge a complaint with the Lithuanian State Data Protection Inspectorate (VDAI): www.vdai.lrv.lt , or with the supervisory authority of your country of residence within the EU.
For California residents (CCPA): We do not sell personal information. You may submit a "Do Not Sell My Personal Information" request to expertaichat@gmail.com to confirm this in writing.
To exercise any of these rights, or for any questions regarding your Face Data, contact us at expertaichat@gmail.com. We will respond within 30 days.
13. International Data Transfers
Our servers are located in the AWS EU (Frankfurt) region. If any data is transferred outside the European Economic Area (EEA), we ensure it is protected by appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission.
14. Children
TL;DR: The App is for users 13+ (16+ in the EU). We do not knowingly collect data from children.
The App is not directed at children under the age of 13. For users in the European Economic Area, the minimum age is 16 years, in accordance with GDPR Article 8. We do not knowingly collect personal data from children below these age thresholds.
Upon first launch, users are required to confirm their date of birth. If a user indicates they are below the minimum age, access to the App is blocked. If you believe a child has provided us with personal data, please contact us at expertaichat@gmail.com and we will delete it promptly.
15. Security
We implement industry-standard security measures, including TLS 1.3 encryption for data in transit and AES-256 encryption for data at rest. Access to user data is restricted to authorized personnel only. We conduct regular security reviews.
No method of transmission over the Internet is 100% secure. We cannot guarantee absolute security, but we commit to notifying you of any data breach within 72 hours of becoming aware of it, in accordance with GDPR Article 33.
16. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via an in-app notification at least 7 days before the changes take effect. The updated Policy will be posted in the App and on our website. Your continued use of the App after the effective date constitutes acceptance of the updated Policy.
17. Contact
MobileXApps MB
Eduardo Andre g. 14-5, 02231 Vilnius, Lithuania
Email: expertaichat@gmail.com
Website: https://mobilexapps.com/sway-ai-privacy-policy
For GDPR data subject requests: expertaichat@gmail.com