Privacy Policy

Last updated: January 2025

Effective Date: January 2025

1. Introduction

Welcome to EnvyMe ("App", "Service", "we", "us", or "our"). This Privacy Policy explains how ABI SERVICES LTD ("Company", "Data Controller") collects, uses, discloses, and safeguards your information when you use our mobile application EnvyMe.

Data Controller:

• Company: ABI SERVICES LTD
• Address: Artemidos, 3 6025 Larnaca, Cyprus
• Contact: raukuts@abiservices.dev

Please read this Privacy Policy carefully. By using the App, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

2. Age Restriction

EnvyMe is intended for users who are 18 years of age or older. We do not knowingly collect personal information from anyone under 18 years of age. If you are under 18, please do not use the App or provide any personal information.

If we learn that we have collected personal information from a user under 18, we will delete that information as quickly as possible. If you believe we have collected information from a user under 18, please contact us immediately at raukuts@abiservices.dev.

3. Information We Collect

3.1 Information You Provide

Account Information:

• Email address (for account creation and communication)
• Authentication credentials (managed securely via Apple Sign-In or Google Sign-In)

User Content:

• Photos and selfies you upload for AI processing
• Facial features and biometric data extracted from your photos for image generation purposes

Payment Information:

• Subscription status and purchase history (processed by Apple App Store or Google Play; we do not store your payment card details)

3.2 Information Collected Automatically

Device Information:

• Device type, model, and operating system
• Unique device identifiers
• Mobile network information

Usage Data:

• App features accessed
• Generation requests and scene selections
• Time spent in the App
• Crash logs and performance data

Analytics Data:

• Aggregated usage statistics
• Feature engagement metrics
• Conversion and retention data

3.3 Biometric Data Notice

When you upload a photo, our AI systems analyze facial features to generate composite images. This constitutes processing of biometric data under certain jurisdictions. By using EnvyMe, you explicitly consent to this processing for the purpose of providing the Service.

4. How We Use Your Information

We use the information we collect for the following purposes:

Service Delivery:

• Process your photos using AI to generate composite images
• Provide, maintain, and improve the App
• Process transactions and manage your subscription

Communication:

• Send service-related notifications
• Respond to your inquiries and support requests
• Send promotional communications (with your consent)

Analytics and Improvement:

• Understand how users interact with the App
• Identify and fix bugs and technical issues
• Develop new features and improve existing ones

Legal Compliance:

• Comply with applicable laws and regulations
• Enforce our Terms of Service
• Protect against fraudulent or illegal activity

5. AI Processing and Third-Party Services

5.1 AI Image Generation

EnvyMe uses artificial intelligence to generate images. When you submit a photo:

1. Your photo is securely transmitted to our servers
2. The photo is processed by AI models to generate a composite image
3. The generated image is returned to you
4. Original photos are retained for a limited period (see Section 7)

AI Service Providers:

By using EnvyMe, you acknowledge that your photos may be processed by these third-party AI services for the sole purpose of image generation.

5.2 Other Third-Party Services

6. Data Storage and Security

6.1 Data Location

Your data is stored on servers located in Frankfurt, Germany (EU region), provided by Vultr. This ensures compliance with GDPR data residency requirements for EU users.

6.2 Security Measures

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

• Encryption of data in transit (TLS 1.3)
• Encryption of data at rest (AES-256)
• Access controls and authentication
• Regular security assessments
• Secure API communications

While we strive to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

After the retention period expires, data is securely deleted or anonymized.

8. Your Rights (GDPR)

If you are located in the European Economic Area (EEA) or United Kingdom, you have the following rights under GDPR:

8.1 Right of Access

You can request a copy of the personal data we hold about you.

8.2 Right to Rectification

You can request correction of inaccurate personal data.

8.3 Right to Erasure ("Right to be Forgotten")

You can request deletion of your personal data. To delete your account and all associated data, email us at raukuts@abiservices.dev.

8.4 Right to Restrict Processing

You can request restriction of processing of your personal data.

8.5 Right to Data Portability

You can request your data in a structured, machine-readable format.

8.6 Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes.

8.7 Right to Withdraw Consent

You can withdraw consent at any time where processing is based on consent.

8.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. For Cyprus, this is the Commissioner for Personal Data Protection (www.dataprotection.gov.cy).

To Exercise Your Rights: Contact us at raukuts@abiservices.dev. We will respond within 30 days.

9. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request disclosure of personal information collected
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt out of sale of personal information (Note: We do not sell personal information)
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

To exercise these rights, contact us at raukuts@abiservices.dev.

10. Children's Privacy

EnvyMe is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. When we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the European Commission
• Certification mechanisms

12. Cookies and Tracking Technologies

The App may use local storage and similar technologies to enhance your experience. We use:

• Essential Storage: Required for App functionality
• Analytics: To understand usage patterns (with consent where required)
• Preferences: To remember your settings

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new Privacy Policy in the App
• Updating the "Last updated" date
• Sending an email notification (for significant changes)

Your continued use of the App after changes constitutes acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

ABI SERVICES LTD

• Email: raukuts@abiservices.dev
• Address: Artemidos, 3 6025 Larnaca, Cyprus

For data protection inquiries, please include "Privacy" in your email subject line.

15. Legal Basis for Processing (GDPR)

We process your personal data on the following legal bases:

By using EnvyMe, you acknowledge that you have read, understood, and agree to this Privacy Policy.