Privacy Policy

1. Introduction and Scope

This privacy policy informs you about the processing of personal data when using our website and our AI picture generator service. It covers both your interaction with our website and the use of our AI-powered image generation tool.

2. Data Controller

The data controller for the purposes of the General Data Protection Regulation (GDPR) is Arne Strickmann (referred to as we, us, or our).

3. Data Collection and Use

We collect and process the following types of data:

• Website usage data: IP address, date and time of access, pages visited, browser type and version, operating system.
• Account data: Name, email address, password (encrypted).
• AI service data: User-uploaded images, User preferences for generated images, Metadata associated with generated images.

This data is used to provide and improve our services, generate AI pictures, and ensure the security of our platform.

4. AI-Specific Processing

Our AI pipeline processes user-uploaded images and preferences to generate headshots. This process involves:

• Analyzing facial features from uploaded images
• Applying user-specified preferences
• Generating new images based on this input

We retain user-specified preferences for ongoing service improvement. We do not retain user-uploaded images after processing.

5. Legal Basis for Processing

We process your data based on the following legal grounds:

• Consent (Article 6(1)(a) GDPR)
• Performance of a contract (Article 6(1)(b) GDPR)
• Legitimate interests (Article 6(1)(f) GDPR)

6. User Rights

You have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data (right to be forgotten)
• Restrict processing
• Data portability
• Object to processing

To exercise these rights, please contact us at arne.strickmann@googlemail.com. Note that some rights may be limited for AI-generated content due to technical constraints.

7. Data Sharing and Third-Party Services

We use the following third-party services in our AI image generation process:

• Fal.ai (Compute related topics)

Data shared with these services is governed by their respective privacy policies.

8. Image Usage and Ownership

Users retain ownership rights to their uploaded images. For AI-generated images:

• Users are granted a non-exclusive license to use the generated images
• We retain the right to use generated images for service improvement and marketing purposes, without identifying individual users

9. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encryption of data in transit and at rest
• Regular security audits
• Strict access controls

10. Biometric Data

Our AI may process biometric data from user images. By using our service, you consent to this processing. This data is used solely for image generation and is not stored separately from the images.

11. Data Retention

We retain data as follows:

• Account data: Until account deletion
• User-uploaded images: Until account deletion
• Generated images: Until account deletion
• Website usage data: Not time-limited

12. International Data Transfers

Your data may be transferred to countries outside your residence, including to the United States. We ensure appropriate safeguards are in place, such as Standard Contractual Clauses.

15. Intellectual Property

While users own their uploaded content, the AI-generated images are subject to a shared intellectual property model. Users receive a license to use the images, while we retain rights for service improvement and promotional uses.

16. Marketing and Analytics

We may use data and generated images for marketing and analytics purposes. You can opt out of these uses by expressing your preferences with an email to arne.strickmann@googlemail.com.

17. Updates to Privacy Policy

We may update this policy to reflect changes in our practices or for legal reasons. We will notify users of significant changes via email or website notice.

18. Contact Information

For any questions about this privacy policy or our data practices, please contact: arne.strickmann@googlemail.com

19. Compliance with AI Regulations

We are committed to complying with emerging AI regulations and ethical AI principles. This includes:

• Transparency about AI use
• Fairness and non-discrimination in AI outputs
• Regular audits of our AI systems

Last updated: 07.10.2024