Privacy Policy

1. Introduction

This Privacy Policy describes how the 80s Filter iOS application ("80s Filter", the "App", "we", "us", "our") collects, uses, and shares information when you use the App. The App is published by TRY2APP LTD, the data controller for the purposes of this Policy.

We designed the App to collect as little personal information as possible. You do not need to create an account. We do not ask for your name, email, phone number, or any other personally identifying information. The App uses an anonymous Firebase installation identifier only, to keep your weekly render allowance and your in-app history attached to your device.

2. Plain-English Summary

3. Face Data (Photos You Choose)

80s Filter's purpose is to show you a 1980s version of yourself, so the photos you choose will usually show a face — most often your own. Apple's guidelines require us to be explicit about how that "face data" is handled, so this section answers each question directly.

4. App Store Privacy Label

Apple requires every app to disclose its data-collection practices in the "App Privacy" label on its App Store listing. The following mirrors the disclosures we make to Apple.

5. App Tracking Transparency (ATT)

80s Filter does not track you across other apps or websites. We do not present the ATT prompt, do not access the IDFA, and share no data with advertisers or data brokers.

6. Information We Collect (Detailed)

The Photo You Select

When you choose a photo through Apple's standard picker, that single photo is uploaded — over encrypted TLS, through our relay — to fal.ai so OpenAI's GPT Image 2 model can generate the 80s version. Apple's picker sandboxes selection to the one image you pick; the App has no other access to your library. See Section 3 for how any face in the photo is treated.

Generated Images and History

The generated image is streamed from fal.ai to the App and shown on the result screen. Its URL is stored in your private per-device history in Firebase Firestore so you can view past renders in the App's "Vault". When you tap "Save to Photos", iOS writes the image to your own Photo Library with your permission.

Subscription Purchase Data

Apple processes the transaction entirely. RevenueCat verifies and syncs your purchase status against an anonymous app-installation identifier. We never see your Apple ID, card number, or billing address.

Weekly Render Allowance

Your subscriber render counter and the timestamp of its last weekly refill are stored in a per-device Firestore document keyed to your anonymous Firebase installation identifier.

Diagnostic & Device Data

We may receive aggregated crash logs and performance metrics, and log non-identifying signals such as iOS version, device model, and app version. We do not use the IDFA and run no advertising trackers.

7. How We Use Your Information

• To provide the AI 80s-photo generation service you requested
• To store and display your private in-app render history
• To meter your weekly subscriber render allowance
• To validate and track your subscription through Apple's StoreKit and RevenueCat
• To prevent fraud and abuse, comply with legal obligations, and improve stability through aggregated diagnostics

We do not sell your personal information, share it with advertisers, run facial recognition, or use your photos or generated images to train AI models.

8. Legal Basis for Processing (GDPR)

• Consent (Art. 6(1)(a); Art. 9(2)(a) for any data revealing your likeness) — for sending your chosen photo to our AI provider, which you give on the in-app consent screen before your first render, and can withdraw at any time (Section 11).
• Performance of a contract (Art. 6(1)(b)) — providing the App and fulfilling purchases.
• Legitimate interests (Art. 6(1)(f)) — stability, fraud prevention, security.
• Legal obligation (Art. 6(1)(c)) — retention of purchase records for tax and accounting.

9. Third-Party Providers & SDKs

fal.ai (AI generation)

Purpose: running the image edit that applies the 80s look. Model: openai/gpt-image-2/edit — OpenAI's GPT Image 2, hosted and run by fal.ai. Data sent: the single photo you selected plus generation parameters (prompt, image size, quality, output format). fal.ai does not train on user input and does not retain images beyond serving the request.

fal.ai privacy policy: fal.ai/legal/privacy-policy · OpenAI API data usage: openai.com/policies/api-data-usage-policies

Our relay server (Cloudflare Workers)

Your photo is not sent to fal.ai directly. It passes through a small relay we operate on Cloudflare Workers, which injects our fal.ai key server-side (so the key never ships in the App) and forwards the request unchanged. The relay does not log or store your image. Cloudflare privacy policy: cloudflare.com/privacypolicy

Google Firebase (Authentication & Firestore)

Purpose: anonymous authentication (a random per-install identifier, no personal data) and a Firestore database storing your weekly render counter and the URLs of your past renders, readable only by your own installation. Firebase privacy: firebase.google.com/support/privacy

RevenueCat

Purpose: subscription purchase validation. Data: anonymous app-user ID, Apple transaction identifier, purchase state. Privacy: revenuecat.com/privacy

Apple

Purpose: App Store distribution and StoreKit billing. Apple processes all payments directly. Privacy: apple.com/legal/privacy

10. Data Retention

• The photo you select (including any face it shows): Not stored on any server we operate, at any point. Passed through our relay to fal.ai in memory only, for the duration of generation. fal.ai's and OpenAI's own retention practices are described in their policies (Section 9).
• Generated images: The file is hosted by fal.ai. We store only its URL, in your private per-device history, until you delete that entry or uninstall the App.
• Render counter & timestamps: Retained in your per-device Firestore document until you uninstall or request deletion.
• Subscription records: Retained by RevenueCat and Apple for the duration of your subscription plus the period required by tax and consumer-protection law (typically up to 7 years).
• Crash/diagnostic data: Aggregated form, up to 90 days.

11. Your Rights

EU / UK (GDPR)

• Access, rectification, erasure, restriction, portability, objection
• Right not to be subject to solely automated decision-making
• Right to withdraw consent at any time (on the in-app consent screen, or by uninstalling, or by contacting us)
• Right to lodge a complaint with a supervisory authority

California (CCPA / CPRA)

• Right to know, delete, and correct personal information
• Right to opt out of sale or sharing (we do not sell or share)
• Right to limit use of sensitive personal information (we do not use it beyond generating your requested image)
• Right to non-discrimination for exercising your rights

How to exercise your rights

Email [email protected] with the subject line "Privacy Request — 80s Filter". We respond within the timeframe required by applicable law (typically within 30 days).

12. Data Deletion

Uninstalling the App orphans your anonymous Firestore document. To have it deleted proactively, email [email protected] with the subject "80s Filter — Delete my data". We confirm receipt within 2 business days and complete deletion within 30 days. Apple and RevenueCat retain purchase records they are legally required to keep. Since we never store your original photos, there is nothing on our servers to delete on that front.

13. Children's Privacy

The App is not intended for children under 13 (or the minimum digital consent age in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact [email protected] and we will delete it promptly.

14. AI Processing Disclosure (EU AI Act)

In compliance with Regulation (EU) 2024/1689 (the "EU AI Act") and global best practices for transparent AI:

• The App uses generative artificial intelligence to transform a user-supplied photo into a 1980s-styled image. The output is synthetic content generated by an AI system.
• The AI model is openai/gpt-image-2/edit (OpenAI's GPT Image 2), run through our AI provider fal.ai.
• AI generation is initiated only by your explicit action — selecting a photo, agreeing to the data-sharing disclosure, and tapping "Apply 80s". The App does not generate content automatically.
• Generated images may include provenance markers embedded by the AI provider.
• You are responsible for the lawful use of any content generated by the App. Using it to deceive, harass, or impersonate is prohibited by our Terms.

15. In-App Consent & Transparency

Apple's App Review guidelines (5.1.1(i) and 5.1.2(i)) require that, before any personal data is shared with a third-party AI service, the App disclose what data is sent, identify who it is sent to, and obtain your permission — inside the App itself, not only in this Policy. 80s Filter complies through the following:

• A dedicated consent screen, shown before your first photo is ever sent anywhere. A "Before the filter runs" screen states, in plain language: what's sent (only the single photo you chose, including any face it shows), who it's sent to (fal.ai, our third-party AI provider, over an encrypted connection, reached through our own relay), and how it's used (solely to generate the requested image — never to train AI models, never stored on servers we operate, no facial recognition). You must tap "Agree & Continue" before the App proceeds; tapping "Not now" sends nothing.
• Always reachable. The same disclosure is available any time from Settings → "How your photo is used".
• Explicit action required. A transmission only occurs after you have selected a photo through Apple's picker, agreed to the disclosure, and tapped "Apply 80s" as a subscriber.
• No generation before purchase. If you are not a subscriber, the App shows the subscription paywall and sends no photo to fal.ai until you complete a purchase.
• Revocability. Decline on the consent screen itself, or withdraw consent afterward by uninstalling the App or contacting [email protected].

16. International Data Transfers

Our service providers (fal.ai, OpenAI, Cloudflare, Google Firebase, RevenueCat) operate from data centers in the United States and the European Union. For transfers of personal data from the EU/UK, we and our processors rely on Standard Contractual Clauses and other appropriate safeguards (Art. 46 GDPR).

17. Security

• TLS 1.2+ encryption for all data in transit
• Our AI-provider key held server-side on our relay, never shipped in the App binary
• No server-side storage of your photos; generated-image URLs readable only by your own anonymous installation
• Regular security review of third-party providers and their privacy manifests

No system is perfectly secure. If you become aware of a security incident affecting your data, contact us immediately at [email protected].

18. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes we update the "Last updated" date and, where appropriate, notify users in-app. Continued use after changes are posted constitutes acceptance.

19. Contact Us

Email: [email protected]
Subject: 80s Filter — Privacy Inquiry
Data controller: TRY2APP LTD

We typically respond within 7 business days.