HeyPicAI Privacy Policy
Last Updated: Dec 17, 2025
This Privacy Policy explains how HeyPic (“Company”, “we”, “us”), a company based in Turkey, collects, uses, discloses, and protects your information when you use the HeyPic mobile application (“App” or “Service”). This Policy complies with the General Data Protection Regulation (GDPR) and the Turkish Personal Data Protection Law (KVKK).
By using the App, you agree to the terms of this Policy. If you do not agree, please do not use the App.

1. Definitions
Personal Data: Any information that relates to an identified or identifiable individual.
Usage Data: Data collected automatically during app usage (e.g., session duration, filter usage).
Face Data: Visual information contained in user-uploaded photos that include a human face. Face Data is processed only to apply user-requested visual effects and does not include biometric identifiers, face templates, or data used to identify or verify an individual.
Device: Any device capable of accessing the App, such as a smartphone or tablet.
Service Providers: Third parties who process data on our behalf under contractual and confidentiality obligations (e.g., hosting, analytics).

2. What Data We Collect
a. Personal Data
When you use the App, we may collect:

• Email address (optional or required for subscriptions)

• Photos uploaded by you

• Face-related visual data, such as facial regions and non-identifying landmarks, derived from uploaded photos solely for applying user-requested visual transformations

• Payment information (processed by the Apple App Store; not stored by us)

• In-app purchase and subscription history
   

b. Usage Data
Automatically collected information may include:

• Device type, operating system, and general region

• Session timestamps and interaction logs

• Feature usage and filter preferences

• Credit balance and generation activity logs
   

c. Device Permissions

HeyPic AI may request access to:

• Camera

• Photo gallery (read and write access)

Permissions are used only to enable core app functionality.

3. How We Use Your Data
We use collected data to:

• Provide AI-powered photo and visual transformation features

• Apply filters, styles, and motion effects requested by the user

• Temporarily process and deliver generated results

• Analyze usage patterns to improve app performance and features

• Manage subscriptions and in-app purchases via Apple

Face Data is processed only to perform visual transformations explicitly requested by the user.
HeyPic AI does not use Face Data for identity recognition, authentication, user tracking, profiling, advertising, or marketing purposes.
Face Data is not used to identify individuals, create biometric profiles, or build face recognition databases.
Face Data is not used to train AI models using identifiable user images. Any system improvements rely solely on non-identifiable, aggregated technical performance data, not on user photos or facial content.

4. Legal Basis for Processing
We process personal data based on:

• Your explicit consent (GDPR Art. 6(1)(a); KVKK Art. 5/1)

• Performance of a contract (e.g., providing subscription features)

• Legal obligations (e.g., financial record keeping)

• Legitimate interests (e.g., service improvement and security)

You may withdraw your consent at any time by contacting us or deleting your account.

5. Data Retention
Personal data is retained only for as long as necessary to:

• Provide the requested services

• Maintain an active account

• Fulfill legal obligations

• Prevent misuse or abuse

After the Photos are generated, the uploaded face data is permanently deleted from our servers within 14 days.
Users may request deletion of their data at any time.

6. User Rights (GDPR & KVKK)
You have the right to:

• Access your personal data

• Correct inaccurate or incomplete data

• Request deletion of your data (“right to be forgotten”)

• Restrict or object to certain processing activities

• Request data portability where applicable

• Lodge a complaint with a supervisory authority

To exercise these rights, contact us at:
mrdugal@icloud.com

7. Data Transfers & Storage
HeyPic AI uses secure cloud infrastructure for data processing and storage. Data may be processed outside your country of residence.
All international data transfers comply with GDPR and KVKK requirements through:

• Data Processing Agreements (DPAs)

• Standard Contractual Clauses (SCCs), where applicable
   

8. Security Measures
We implement appropriate technical and organizational measures, including:

• TLS/SSL encryption

• Access control and audit logging

• Secure server-side storage controls

• Crash and error monitoring

• Limited and temporary retention of face-related data

In the event of a data breach, users and authorities will be notified in accordance with applicable laws.

9. Children’s Privacy
HeyPic AI is not intended for children under the age of 13. We do not knowingly collect personal data from children. If such data is identified, it will be deleted promptly.

10. Analytics and Tracking Tools
We may use trusted third-party tools such as:

• Firebase (analytics and performance monitoring)

• Appsflyer (attribution and campaign measurement)

• Mixpanel (event-based usage analysis)

These services process anonymized or aggregated usage data only.

11. Third-Party Services
HeyPic AI may integrate with third-party services such as Apple In-App Purchases or cloud processing providers. These parties act solely as data processors and are not permitted to use personal data for their own purposes.

12. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via:

• In-app notifications

• Email (if provided)

Continued use of the App indicates acceptance of the updated policy.

13. Apple Face Data Compliance Statement
HeyPic AI processes face-related data only as part of user-initiated actions and strictly in accordance with Apple App Store privacy and face data guidelines.

14. Contact Us
If you have any questions regarding this Privacy Policy or your data rights, contact us at:
mrdugal@icloud.com