Privacy Policy

Privacy Policy for LookLab AI

Effective Date: 2/05/2025

1. Introduction

Welcome to LookLab AI! This Privacy Policy explains how LookLab AI ("we," "us," or "our") collects, uses, shares, and protects information in relation to our mobile application LookLab AI (the "App"). We are committed to protecting your privacy and handling your data in an open and transparent manner.

By downloading, accessing, or using the App, you agree to the terms of this Privacy Policy. If you do not agree with the practices described in this policy, please do not use the App.

2. Information We Collect

We may collect the following types of information:

• a) Information You Provide Directly:

  • Photos and Images: When you use the App's features, you will upload photos or images from your device's gallery or capture new ones using your camera. These images are necessary for the App's core functionality (editing, fixing, enhancing, transforming).
  • [Optional: Account Information]: If you create an account (if applicable), we may collect information such as your [email address, username, password, etc.].
  • [Optional: Communications]: If you contact us for support or feedback, we may collect your name, email address, and the content of your communication.

• b) Information from AI Processing:

  • The photos you upload are processed using Artificial Intelligence (AI) algorithms to enable the editing features (e.g., identify facial features for fixes, segment areas for style changes).
  • This processing may occur [Choose one or explain hybrid: on your device OR on our secure servers OR a combination of both]. [Be precise here - this has significant privacy implications].
  • We [Choose one: do / do not] store intermediate data generated during AI processing (such as facial landmarks or segmentation maps) after the edit is complete. 
  • Face Data (Facial Landmarks & Embeddings)
    When you edit a portrait, our on-device model detects up to 468 facial landmarks (points that outline eyes, nose, mouth, etc.) and creates a short numerical embedding so the app can apply effects precisely. These data never leave your device, are kept only in volatile memory during that edit session, and are irreversibly deleted as soon as processing finishes.

• c) Information Collected Automatically (Usage Data):

  • When you use the App, we may automatically collect certain information about your device and usage patterns. This may include:
    • Device Information: Device model, operating system version, unique device identifiers (e.g., IDFA, Android Advertising ID), IP address, mobile network information.
    • Usage Information: Features you use within the App, interactions with the interface, frequency and duration of usage, crash reports, performance data.
  • We may use third-party analytics tools (like [List examples if known, e.g., Google Analytics for Firebase, Amplitude, Mixpanel]) to help us measure traffic and usage trends. These tools collect information sent by your device or our App.

3. How We Use Your Information

We use the information we collect for various purposes, including:

• To provide, operate, maintain, and improve the App and its features (e.g., processing your photos for edits, fixes, enhancements, virtual try-ons, style changes).
• To understand how users interact with the App and identify areas for improvement (analytics).
• To respond to your comments, questions, and provide customer support.
• To monitor and analyze trends, usage, and activities in connection with our App.
• To detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of LookLab AI and others.
• To comply with legal and regulatory obligations.
• [Crucial Point - Be VERY clear]: We do NOT use your personal photos or derived data to train our AI models unless we obtain your explicit, separate consent to do so. 
• To perform face-aware edits: We use the temporary facial landmarks and embedding solely to align filters, retouch skin, and apply virtual style effects you request.

4. Data Sharing and Disclosure

We do not sell or rent your personal information to third parties without your consent, except as described in this Policy. We may share information in the following circumstances:

• With Service Providers: We may share information with third-party vendors, consultants, and other service providers who need access to such information to carry out work on our behalf (e.g., cloud hosting providers for server-side processing [if applicable], analytics providers, customer support tools). These providers are obligated to protect your data and use it only for the services they provide to us. 
• For Legal Reasons: We may disclose information if required to do so by law or in the good faith belief that such action is necessary to comply with legal obligations, protect and defend our rights or property, prevent fraud, act in urgent circumstances to protect the personal safety of users, or protect against legal liability.
• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your information may be transferred as part of that transaction.
• Face data (landmarks & embeddings) are never shared with any third parties because they never leave your device.

5. Data Retention

We will retain your information only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Photos: We retain photos you upload [Explain your specific policy: e.g., only temporarily on our servers while processing is active, until you delete them from the app, for a specific period like X days after upload, etc.]. [Be specific and accurate about your actual practice].
• Usage Data: We may retain aggregated or anonymized usage data for longer periods for analytics and improvement purposes.
• [Optional: Account Data]: Account information is retained as long as your account is active or as needed to provide you services.
• Photos and derived face data exist only for the duration of the active editing session. They are destroyed automatically when you exit the editor, delete the photo, or close the app—whichever happens first. No backups or server copies are kept.

6. Data Security

We implement reasonable technical and organizational measures designed to protect the security of any personal information we process. However, please remember that no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. Your Privacy Rights

Depending on your location (e.g., GDPR in Europe, CCPA in California, PDPA in Thailand), you may have certain rights regarding your personal information. These may include the right to:

• Access the personal information we hold about you.
• Request correction of inaccurate personal information.
• Request erasure of your personal information.
• Object to or restrict processing of your personal information.
• Request portability of your personal information.
• Withdraw consent at any time (where processing is based on consent).

To exercise these rights, please contact us using the details provided below. You may also be able to manage some information directly within the App settings [if applicable]. We will respond to your request in accordance with applicable law.

8. Children's Privacy

The App is not intended for or directed at children under the age of [Specify age, e.g., 13 in the US under COPPA, 16 for GDPR unless member state specifies lower, check local laws like Thailand's PDPA]. We do not knowingly collect personal information from children under this age. If we become aware that we have collected personal information from a child under the relevant age without verification of parental consent, we will take steps to remove that information from our servers.

9. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside [Your Country/Region, e.g., the United States] and choose to provide information to us (e.g., by using server-side processing features), please note that we transfer the data, including Personal Data, to [Location of Servers, e.g., the United States] and process it there. We will take appropriate safeguards to protect your personal information in accordance with this Privacy Policy and applicable law. [Specify safeguards if applicable, e.g., Standard Contractual Clauses].

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy²⁴ Policy within the App and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted. Your continued use of the App after the effective date will constitute your acceptance of the revised policy.