PRIVACY POLICY

We may change this Privacy Policy from time to time as our business changes or legal requirements change. The date of the last revision appears at the top of this page.

This Privacy Policy describes how we may collect, use, share, and otherwise process your personal information when you use or otherwise access our photo editing application (“App”), our website, any other part of our services, or otherwise interact with us, including via email or any other communication channel.

“Personal information” means any information provided to or collected by us about an identifiable individual, or an individual whose identity may be reasonably inferred from the information. Aggregated information—data about multiple individuals where no single person can be identified—is not subject to this Privacy Policy, and we may use such aggregated data at our discretion. Likewise, this Privacy Policy does not extend to business contact information used for business purposes, or other information excluded by applicable privacy laws.

We collect, use, and share your personal information in accordance with applicable privacy laws, and our processing is based primarily on your consent, which may be express or implied depending on the sensitivity of the information and the circumstances of its collection.

Any paid features of our App (such as our Pro subscription) are not dependent on or conditional upon you granting access to data beyond what is necessary for those features to function.

In cases where your information was initially collected for one purpose but needs to be used for another, we will seek your consent before doing so, unless otherwise explicitly permitted by law. There are also instances where we may collect, use, or disclose your information without your consent, as permitted or required by law.

We may gather personal information in various contexts. The types of information we may collect include, the following:

• •Identifiers, such as: email address (where you provide it in connection with our user waitlist), Apple App Store account identifier, device identifiers, IP address, and other similar identifiers.
• •Account and subscription information, such as: subscription status, purchase history, and transaction information processed through the Apple App Store.
• •User content, such as: photos you select from your device library for editing within the App, and videos created using the App’s features.
• •Usage information, such as: the editing controls and features you use within the App, the frequency and duration of your use, button interactions, and other analytics data.
• •Device information, such as: device type, operating system, browser type, and technical information about how you access our App or website.
• •Contact information you choose to provide, such as: your email address for our user waitlist or for future account creation purposes.
• •Your communication preferences (e.g., marketing subscription or opt-out status).
• •Any other personal information you choose to share with us.

At the time we collect your personal information, we will tell you the purposes for which we will use it and direct you to this Privacy Policy for more details.

We collect your personal information in two ways, directly from you when you provide it to us or when you automatically generate it, or indirectly when we obtain it from third parties.

Directly: We collect your personal information when you provide it to us in the course of using our services. For instance, you may provide your email address when signing up for our user waitlist, or you may select photos from your device library to edit within our App.

We also collect certain personal information automatically when you access our App or website. For example, we may collect information such as your IP address, device type, and how you interact with our services. We use cookies and other tracking technologies on our website, and analytics tools within our App to understand how users interact with our services. See Section 7 for more information about cookies and analytics.

From third parties: We may also collect personal information from third parties, such as:

• •Apple, in connection with your App Store purchases and subscriptions;
• •Analytics providers, such as Google Analytics; and
• •Our third-party AI service providers, who may process photos you edit using our App.

Visiting our Website: In general, you can visit our website without telling us who you are or submitting any personal information. However, we collect the Internet Protocol (IP) addresses of all visitors to our website and other related information such as page requests, device identifier, screen size, browser type, operating system and average time spent on our website. We use this information to help us understand website activity and to monitor and improve our website.

Cookies: Our website uses a technology called “cookies”. A cookie is a small element of data that our website sends to a user’s browser, which may then be stored on the user’s hard drive or the local storage of your browser so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to decline certain cookies. Our website sets a session cookie that helps us enforce security rate limits. This cookie is not used for advertising. However, if you decide not to accept cookies from our website, you may not be able to use all website or App features.

Analytics: We may use third parties, such as Google Analytics, to help us gather and analyze information about use of the website and the App, such as the pages most frequently read, features used, time spent, search terms and other engagement data, in order to evaluate and improve the user experience, the website and the App. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data, including your IP address, by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

You can also obtain additional information about Google Analytics’ data privacy and security at the following links:

• •https://policies.google.com/technologies/partner-sites; and
• •https://support.google.com/analytics/topic/2919631.

Do Not Track

We do not respond to “Do Not Track” (“DNT”) signals sent from your web browser. DNT signals are an HTTP header field that specifies a user’s preference about data collection. There is no consensus on how to respond to DNT signals because there is no uniform technology standard for recognizing and implementing DNT signals, and a DNT standard has never been formally adopted. The World Wide Consortium (“W3C”) formally withdrew support of their recommendation for a standard in 2019, and while some browsers will transmit the DNT signal to our Website, other browsers (such as Safari and Firefox) no longer support DNT signals.

Third-Party Links: Our website may contain links to other websites that we do not own or operate. We provide links to third-party websites as a convenience to users. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate them may collect, use, disclose, secure or otherwise handle personal information. We encourage you to read the privacy policy of every website you visit.

We handle personal information in compliance with this Privacy Policy and under no circumstances will we sell any such data.

We may use and share personal information for the following reasons:

• •Service Delivery: To provide our photo editing services, including processing your photos using AI-powered editing features, enabling you to create photos and videos, and allowing you to share or export your edited content.
• •Subscription Management: To manage your Pro subscription, process transactions through the Apple App Store, and provide subscription-related support.
• •Service Improvement & Development: To analyze how users interact with our App (including which editing controls are used), improve our services, develop new features, and understand usage patterns and trends.
• •AI Processing: To process your photos using third-party AI models and services to provide editing features.
• •Internal Management: For record-keeping, analyzing our processes, improving efficiency, and maintaining our services.
• •User Support: To respond to your inquiries and provide support for our services.
• •Marketing & Communications: To send you information about our services, updates, and promotional materials if you have opted in to receive such communications.
• •Contractual Purposes. We may disclose your personal information to enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• •Account Creation: We may use contact information you provide to facilitate account creation in the future, should we introduce account-based features.
• •Security & Fraud Prevention: To protect our services, detect and prevent fraud, and ensure the security of our systems.
• •Complying with the Law: To comply with our legal obligations, respond to legal process, or protect our rights and the rights of others.
• •Other Purposes: For any other purpose that you consent to or that is permitted or required by law.

Transfer to Third Parties: We may share your personal information with trusted third parties to assist in delivering our services. These third parties are contractually required to protect your personal information to the same or equivalent standards as set out in this Privacy Policy. These include:

• •AI Service Providers: We use third-party AI services to power our photo editing features. Photos you edit using AI features may be processed by these providers.
• •Analytics Providers: We use Google Analytics to understand how users interact with our App and website. These providers may collect information about your usage of our services.
• •Email and Marketing Service Providers: We use email and marketing services to manage our user waitlist and marketing communications.
• •Cloud Infrastructure and Database Providers: We use cloud services to store and process data.
• •Apple: As our App is distributed through the Apple App Store and subscriptions are processed through Apple, Apple may receive information about your use of our App and your subscription.

Disclosures to Third Parties: In some cases, we disclose your personal information to third parties. Where your personal information is sensitive, we will seek your consent to disclosure, unless it is not required by law. Where we obtain your consent to disclose your personal information to another business, your personal information will be governed by that business’ privacy policy after disclosure. Please read their privacy policy before you provide your consent.

There are also situations in which we do not need your consent to disclose to third parties:

• •Transaction: In the event of a corporate transaction (like a merger or sale), your personal information may be shared—but only under agreements that restrict its use to purposes related to that transaction and preserve the privacy protections originally provided.
• •Compliance with warrants, court orders, etc.: In exceptional circumstances, we may share personal information with government agencies and other third parties if we believe it is reasonable and necessary to comply with law, regulation, legal process or governmental request.

We may also share personal information with other parties as directed by you or subject to your consent.

We or our service providers may access, store and otherwise process your personal information outside Canada and, for residents of Quebec, outside Quebec, including in the United States, where we or our service providers are located. If we do transfer personal information to outside of your region, it will be protected in the same way as if it was being used in your region.

All marketing emails from us include an option to unsubscribe or adjust your preferences. To stop receiving such communications, simply use the unsubscribe link in any marketing email or contact us directly using the information provided in our communications. Please note that you may continue to receive transactional or account-related communications from us.

We collect personal information only through lawful means and exclusively for purposes that have been clearly disclosed in this Privacy Policy or otherwise communicated to you, or as permitted under applicable laws.

We practice data minimization and only request access to data that is relevant to the core functionality of our App. We collect and use only the data required to accomplish the relevant task. For example, we request access to your photo library only when you choose to edit photos, and we use Apple’s system photo picker where possible rather than requesting full access to your entire photo library.

We retain your personal information for as long as it is required for our business purposes that have been disclosed to you or as required by law. Personal information that is no longer required to be retained is destroyed or deleted in a safe and secure manner in accordance with our policies, or anonymized.

We implement physical, procedural, and technical safeguards to protect your personal information.

In some cases, your personal information may be stored outside your region, especially if we work with third-party providers located elsewhere. In such scenarios, your information may be governed by the local laws of the jurisdiction where it is stored or accessed, including possible access by government or law enforcement agencies.

We use AI-powered features within our App to provide photo editing capabilities. These features use third-party AI models to process your photos based on the editing controls you select. The AI processing is automated, but we do not use AI to make decisions about you.

We do not market the App to, and do not knowingly collect or maintain personal data from, individuals under the age of 14. We do not intend the App for individuals under 14 years of age. We do not use personal data collected from children for marketing or promotional purposes, and we do not disclose such information to any third-party for any purpose whatsoever. No one under 14 years of age may provide any personal information to or on the App.

If you are under 14 years of age, do not provide any information on the website or on or through any of the features of the App, register on the App, make any purchases through the App, use any of the interactive or public comment features of the App, or provide any information about yourself to us. If we learn that we have collected or received personal data from an individual under 14 years of age without verification of parental consent, we will delete that information.

If you believe we might have any information from or about an individual under 14 years of age, please contact us using the details provided in Section 18 below and we will use all reasonable efforts to delete that information.

We strive to ensure your personal information is accurate, up to date, and sufficient for the purposes it serves. Please contact us if there are any changes or updates to your personal information.

You have the right to request access to your personal information and ask for corrections if you believe it’s inaccurate. You can make such requests using the contact details provided below.

Where the basis of our processing was consent, you have the right to withdraw your consent to our collection, use, or disclosure of your personal information, subject to certain exceptions provided by law or contractual restrictions. You can do this by contacting our Privacy Officer using the contact details provided below. However, this may limit our ability to provide certain services. If this occurs, we’ll explain why the information is necessary and how withdrawing consent may affect our ability to assist you.

In Quebec, you have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that information to another controller, where technically feasible.

In all cases, while we aim to respond promptly, we may require identity verification before granting access. Access may be denied in certain situations—such as when disclosure would compromise another person’s privacy, or if the information is protected by legal privilege. In these cases, we will inform you of the reason.

You can reach our privacy officer at:

Privacy Officer

Alexander Ivanov

sasha@axl.vc