Privacy Policy
Last Updated: 2025.07.15
Major Updates: Enhanced facial data disclosures per Apple Guideline 2.1
1. Facial Data Handling Summary
Aspect |
Details |
Policy Section |
Data Collected |
Facial contour features (eye/nose/lip positions and relative distances) |
Section 2.1 |
Purpose of Use |
Generate personalized animated images |
Section 3.1 |
Third-Party Sharing |
OpenAI (AI image generation), AWS (temporary processing) |
Section 4.1-4.3 |
Retention Period |
Processing: ≤24hrs • Account Deletion: ≤72hrs • Backups: ≤30 days |
Section 5 |
User Control |
In-app deletion • Email requests • Automatic deletion on logout |
Section 7.3 |
2. Information Collection and Use
2.1 Facial Data Collection
We collect precise facial contour data including:
- Relative positions of eyes, nose, and lips
- Geometric distances between facial landmarks
- Facial feature coordinates
This data:
- Is collected via camera input during animation creation
- Is never used for identification, tracking, or profiling
- Is processed exclusively for generating personalized animations
3. Use of Data
3.1 Facial Data Processing
Collected facial data is used solely for:
- Generating AI-powered animated images through algorithmic processing
- Creating personalized visual effects and transformations
- Improving animation quality through machine learning optimization
Processing Workflow:
- Camera capture of user’s face
- Local extraction of facial contour features
- Secure encryption of facial data
- Transmission to OpenAI for image generation
- Automatic deletion after animation delivery
4. Disclosure & Sharing
4.1 Third-Party Processors
We share facial contour data with:
- OpenAI: Required for AI-based image generation under contractual obligations that:
- Prohibit data retention beyond processing time
- Forbid secondary use of facial data
- Require TLS 1.3 encryption during transfer
- Amazon Web Services (AWS): Temporarily stores raw facial data during processing with automatic deletion after 24 hours
- Amplitude: Receives only behavioral analytics (never facial data)
4.2 Security Protocols
All facial data sharing follows:
- AES-256 encryption during transmission
- Zero-retention policy with processors
- Annual audits of third-party compliance
- Token-based authentication for API access
4.3 Your Control Over Sharing
You may:
- Disable facial data sharing in Settings > Privacy
- Request sharing history via privacy@rovel.cc
5. Data Retention
5.1 Facial Data Retention
Scenario |
Retention Period |
Verification Method |
After processing |
≤24 hours |
Automated system logs |
After account deletion |
≤72 hours |
Deletion confirmation email |
System backups |
≤30 days |
Monthly audit reports |
5.2 Other Data Retention
- Anonymous usage data: Up to 12 months
- Error logs: 7 days
- Behavioral analytics: 6 months (aggregated only)
6. Security Measures
We implement:
- End-to-end encryption for all facial data
- Contractual safeguards with all processors (DPA available on request)
- Automated deletion cron jobs verified daily
- ISO 27001-compliant infrastructure
- Bi-annual penetration testing
7. User Rights & Controls
7.1 Access & Deletion Rights
You may at any time:
- View collected facial data: Settings > Privacy > Face Data Report
- Delete facial data immediately: Settings > Privacy > Delete Face Data Now
- Request full erasure: Email privacy@rovel.cc (processed ≤72hrs)
7.2 Account Deletion
Upon account deletion:
- All facial data is queued for immediate deletion
- Deletion completion confirmation sent via email
- Third-party processors notified simultaneously
7.3 Children’s Privacy
Enhanced protections:
- Facial data collection blocked for users <13 via age gating
- Parental consent required for ages 13-17
- Special deletion protocol for minor accounts
8. Third-Party Services
8.1 Processor Agreements
All third parties (including OpenAI) are contractually bound to:
- Process data only for specified services
- Implement equivalent security measures
- Delete data immediately after processing
- Provide annual compliance certifications
8.2 External Links
We explicitly:
- Disclaim responsibility for non-partnered third parties
- Recommend reviewing OpenAI’s privacy policy at https://openai.com/policies
9. Policy Changes
9.1 Notification Method
We notify users of changes via:
- In-app banner (7 days before changes)
- Email to registered accounts
- Version history at https://rovel.cc/privacy/versions
9.2 Material Changes
For significant updates (e.g., new data sharing):
- Require re-consent through in-app prompt
- Provide opt-out option before enforcement
10. Contact Information
10.1 Data Protection Officer
For facial data requests:
10.2 Response Time
- Data access requests: ≤72 hours
- Deletion requests: ≤48 hours
- Complaints: ≤24 hour acknowledgment
11. Governing Law
This policy adheres to:
- California Consumer Privacy Act (CCPA)
- General Data Protection Regulation (GDPR)
- Apple App Store Guideline 5.1.1
Effective Immediately
This version supersedes all previous privacy policies