AI Hair Color & Style — Privacy Policy

Effective Date: September 28, 2026

AI Hair Color & Style ("the App") is developed by Mobile Card Games & Travel Apps LLC. This Privacy Policy explains what data the App collects, how it is used, and how your privacy is protected.

1. Data We Collect

The App collects the following data that you provide directly:

• Photos: Photos that you select from your photo library or take with your camera. These photos typically contain your face and hair, as the App is designed for hair color visualization.
• Hair color preferences: The hair color, technique, tone, and other styling options you select within the App.
• Purchase information: Transaction records for in-app credit purchases, managed by Apple or Google Play together with RevenueCat.
• Anonymous account identifier (Android only): A randomly generated account ID, created without any sign-in, that holds your look (credit) balance. It is not linked to your name, email, or Google account.
• Device integrity and abuse-prevention signals: See section 5.

The App does not collect your name, email address, location, or advertising identifiers. It contains no analytics SDKs, serves no ads, and does not track you.

2. How We Collect Data

All data is collected directly from you through your explicit actions within the App:

• You choose to take a photo or select one from your photo library.
• You select your desired hair color options.
• You tap the Create button (for example, "Create Golden Blonde") to start the AI transformation.

During onboarding, before your first use, the App discloses that your photo is processed by OpenAI and asks you to agree before continuing.

3. How We Use Your Data

Your photo and hair color preferences are used solely to generate an AI-powered hair color visualization. Specifically:

• Your photo is resized and compressed, then sent to OpenAI's image editing API to produce a modified image showing your selected hair color. On iOS the request travels through AIProxy; on Android it is relayed through our own backend, running on Google Cloud Functions in the United States, which holds the API key in Google Secret Manager, checks and updates your look balance, and forwards the request to OpenAI. Your photo passes through that backend in memory only, for the duration of the request; it is never written to disk or to any storage bucket we operate.
• The AI changes only the hair color in your photo. No facial recognition, face mapping, biometric identification, or facial feature analysis is performed.
• Your face is preserved exactly as-is in the generated result — it is not analyzed, classified, or identified.

4. Face Data

Because the App is designed for hair color visualization, the photos you provide typically contain your face. We want to be transparent about how this data is handled:

• What face data is collected: Photos you select or take that contain your face and hair.
• How face data is used: Your photo (including your face) is sent to OpenAI solely so the AI can identify your hair in the image and apply the selected color change. The face itself is not the subject of analysis — it is preserved unchanged.
• No facial recognition: The App does not perform facial recognition, face mapping, biometric scanning, or facial feature extraction. The App does not use Apple's Vision framework, ARKit face tracking, Android face detection, or any other face detection APIs.
• Face data sharing: Your photo (which contains your face) is shared with OpenAI for processing. See the Third-Party Data Sharing section for details.
• Face data retention: Your photos exist in transit only during the API request — they are not stored on any server we operate. On your device, photos and results are stored locally until you delete them from the App's gallery or uninstall the App. For OpenAI's data retention practices, see their usage policies.

5. Third-Party Data Sharing

Your photo is shared with the following third-party services:

• OpenAI (openai.com): Your photo and hair color preferences are sent to OpenAI's image editing API to produce the hair color visualization. On iOS the data is transmitted through AIProxy (aiproxy.com), a secure API relay service; on Android it is relayed through our own backend described in section 3. Both use encrypted HTTPS connections. According to OpenAI's API data usage policies, data sent through the API is not used to train their models.
• RevenueCat (revenuecat.com): Manages in-app credit purchases. Payment is processed entirely by Apple or Google — the App never sees your payment card details. RevenueCat receives purchase transaction tokens from Apple or Google Play and a random anonymous app-user ID — never your name, email, or photos.
• Google (firebase.google.com, Android only): Firebase provides the anonymous account, the look ledger, and the abuse-prevention checks described below, and Google Play processes purchases and confirms them to our backend.

We do not sell, rent, or share your data with any other third parties.

Abuse prevention: generating an image costs us money on every request, so both versions verify that requests come from a genuine installation of the App. On iOS, every AI request includes your device's Apple identifier-for-vendor and an Apple DeviceCheck token. On Android, each request includes a Google Play Integrity attestation, obtained through Firebase App Check, which confirms the request comes from an unmodified copy of the App; separately, when the App starts it sends our backend two one-way cryptographic hashes: one of the Android device identifier, and one of a random restore key that the App keeps in Google Block Store, which travels with your device backup. They let us restore your look balance after a reinstall or on a new phone set up from your backup, and grant the one free look only once per device. We receive only the hashes, never the identifier or the key itself, and we hash them again before storing them. These signals are used solely to prevent abuse, restore purchases, and rate-limit AI requests; they are not linked to your name or identity and are not used for advertising or tracking.

6. Data Storage and Retention

• On your device: Original photos and AI-generated results are stored locally for the in-app gallery. Results you choose to save are written to your photo library.
• In your iCloud (iOS only): Your credit balance and related purchase state are synced across your devices via Apple's iCloud key-value storage, tied to your Apple ID. We cannot access this data. Your photos are never synced to iCloud by the App.
• On our servers (Android only): Because Android has no equivalent of iCloud key-value storage, the Android version keeps your look balance on a server we operate, so that a reinstall or a new phone does not cost you looks you paid for. We store an anonymous account record containing your look balance; counts of the looks you have received, bought, and used; the hashed identifiers described in section 5; and a balance history with one dated entry for each look added, used, or removed after a refund (for purchases, the product and the Google Play order number). This record is kept for as long as the account exists. We also keep a more detailed record of each try-on request — its anonymous account ID, timestamps, output size, processing time, and whether it succeeded — and of each purchase confirmation for 30 days, so that a failed generation can be refunded and abuse can be detected; these are then deleted automatically. None of these records include your photos, your hair color choices, or the generated images. Your gallery on Android stays on your device only.
• Photos: On neither platform do we operate any server that stores your photos. Your photo exists in transit only, during the encrypted request to OpenAI.
• Deletion: You can delete individual results from the App's gallery at any time. Uninstalling the App removes all locally stored data.

7. Data Security

All data transmitted to third-party services is sent over encrypted HTTPS connections. API keys are never embedded in the App: on iOS they are protected through the AIProxy relay service, and on Android they are held in Google Secret Manager on our backend.

8. Your Rights

You have the right to:

• Delete your locally stored photos and results at any time through the App's gallery.
• Remove all App data by uninstalling the App.
• On iOS, deny camera or photo library permissions to prevent the App from accessing your photos. The Android version asks for neither permission: it uses the system camera and photo picker, which give the App only the photo you choose.
• Request deletion of your anonymous account (Android): Email us at the address below. Because the account is anonymous, we cannot look it up by name or email: if you bought looks, include the Google Play order number (it starts with GPA.) from your purchase receipt, and we will delete the account record, its balance history, and its hashed identifiers. Deleting the account forfeits any unused looks on it. An account that never made a purchase is not linked to anything that identifies you, so we cannot tell which one is yours; it holds only a look count and the hashed identifiers.

Depending on where you live, privacy laws such as the European Union's General Data Protection Regulation (GDPR) and the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) give you rights over your personal data, including the rights to know, access, correct, and delete it. On iOS we hold no data on servers we operate, so there is typically nothing for us to access or delete on request — deleting the App deletes your data. On Android, the anonymous account record described in section 6 is data we hold, and you may contact us at the email below to access or delete it. Where the App does process data in transit, or a third-party service described above collects data, you may contact us at the email below to exercise your rights, and we will respond as required by applicable law.

9. Children's Privacy

The App is not directed at children under 13, and we do not knowingly collect data from children under 13. In some regions, including the European Union, a higher minimum age applies to consent for data processing; the same statement applies there — we do not knowingly collect data from anyone under the applicable age.

10. Data Breach Notification

In the unlikely event of a data breach affecting user data on any system we operate, we will notify affected users as required by applicable law.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be reflected by updating the "Effective Date" at the top of this page.

12. Contact Us

If you have questions about this Privacy Policy or your data, please contact us at:

v5cqpsj4e3u4@opayq.com