Privacy Policy for CoupleLens
Effective Date: April 27, 2026
Data Controller: Ewout Marissens, individual developer based in Finland
Contact: [email protected]
1. Introduction
CoupleLens ("we", "our", or "us") respects your privacy and is committed to protecting your information. This Privacy Policy explains how we collect, use, and store data when you use our AI photo generation app.
CoupleLens is a mobile application that allows users to upload photos, select backgrounds, and generate stylized AI portraits for couples.
2. Information We Collect
We collect only the data necessary to provide core app functionality:
- Account Information
When you use the app, you may:
- Sign in with Apple: We receive your name (if you choose to share it) and a unique anonymous identifier from Apple Sign In. Your email address may be relayed through Apple's private email relay service.
- Use as Guest: No account creation is required. We generate a local anonymous user ID on your device to support basic functionality.
- Uploaded Photos
To generate AI portraits, you voluntarily upload photos from your device. These images are:
- Temporarily transmitted to our servers for AI processing
- Original photos are deleted immediately after processing is complete
- Generated output images are stored to be displayed in your in-app Gallery
The app requests access to your photo library only so you can select photos to upload for AI portrait generation. We access only the photos you select. We do not scan, index, or upload your entire photo library.
- Face Data
Uploaded photos and generated portraits may contain visible faces. We process uploaded photos as whole images and do not extract, create, or store face templates, faceprints, biometric identifiers, facial recognition identifiers, face embeddings, or face geometry data. For full details, see Section 6 (Face Data).
- Usage Data
We store:
- Generated AI images (for your Gallery history)
- Generation timestamps and status
- In-app credit/balance information for paid features
- Purchase Data
If you make in-app purchases, payment processing is handled by Apple through the App Store. We do not receive or store your full credit card information. We only receive transaction confirmation and your purchased credit balance.
We do NOT intentionally collect:
- Precise location data
- Health records
- Financial information beyond basic purchase confirmations
- Contact lists or address book data
3. How We Use Information
We use collected data to:
- Process and generate AI portraits based on your uploaded photos and selected backgrounds
- Display your generation history in the in-app Gallery
- Manage your in-app credit balance
- Provide customer support if needed
Face data is used only as part of the uploaded image content to generate the AI portrait you requested. We do not use face data for identification, authentication, face recognition, face matching, user tracking, advertising, profiling, or AI model training.
4. Legal Basis for Processing (GDPR)
We process your personal data under the following legal bases as defined by the EU General Data Protection Regulation (GDPR):
| Data Type | Legal Basis | Purpose |
|---|---|---|
| Apple Sign In account information | Contract performance (Art. 6(1)(b)) | To provide the App's core services |
| Uploaded photos | Contract performance (Art. 6(1)(b)) | To generate AI portraits as requested |
| Generated images | Contract performance (Art. 6(1)(b)) | To provide the Gallery feature |
| Purchase/credit records | Contract performance (Art. 6(1)(b)) | To manage paid features |
| Usage data (timestamps, status) | Legitimate interest (Art. 6(1)(f)) | Service maintenance and troubleshooting |
You have the right to object to processing based on legitimate interest. To do so, please contact us at the email address above.
5. AI Processing
CoupleLens uses a self-hosted AI model deployed on our own servers for image generation. We do not use any third-party AI service providers for image generation.
When you initiate a generation:
- Your uploaded photo and selected background are sent to our servers
- The AI model processes the images and generates the output
- All original uploaded files are deleted immediately after the generated image is returned
- Generated images are stored for your access in the app Gallery
We do not use your uploaded photos or generated images to train our AI models. Processing is performed solely to provide the service you requested.
International Data Transfers
Our servers are located in the United States. When you use the App, your data (including uploaded photos and generated images) is transferred to and processed in the United States. This transfer is made under the EU-US Data Privacy Framework where our hosting provider is certified, or under Standard Contractual Clauses as adopted by the European Commission. By using the App, you acknowledge that your data may be transferred to and processed in the United States in accordance with applicable data transfer mechanisms.
6. Face Data
CoupleLens generates AI portraits from user-uploaded photos. These photos and the resulting portraits may contain visible faces. This section explains how we handle face data.
What Face Data We Collect
We collect only the image content voluntarily selected and uploaded by the user. Uploaded photos may contain visible facial features such as face shape, facial appearance, pose, and expression. We process uploaded photos as whole images and do not extract, create, or store face-specific feature data separate from the image itself.
We do not create or store:
- Face templates or faceprints
- Biometric identifiers
- Facial recognition identifiers
- Face embeddings or face geometry data
- Any other data that could identify a specific person by their face
How We Use Face Data
Face data is used only as part of the uploaded image content to generate the AI portrait you requested. The AI system processes the uploaded photo as a whole image to create a stylized couple portrait.
We do not use face data for:
- Identifying or verifying the identity of users
- Face recognition, face matching, or face tracking
- User profiling or behavioral targeting
- Advertising or marketing
- Training, improving, or developing AI models
Sharing of Face Data
We do not share face data with third-party AI providers, advertisers, analytics providers, data brokers, or any other third parties for their own purposes.
Retention of Face Data
- Face data in uploaded original photos: Retained only temporarily during AI processing and deleted immediately after processing is complete.
- Face data in generated images: Stored only as part of the generated image in your in-app Gallery. Generated images are retained until you delete them or delete your account.
- Face templates, faceprints, biometric identifiers, or facial recognition data: We do not create, store, or retain any such data at any time.
7. Third-Party Services
We do not use any third-party AI service providers for the AI image generation feature. All AI processing is performed using a self-hosted AI model operated by us.
We use the following third-party services:
- Apple Sign In – for authentication (if you choose to sign in)
- Apple App Store / StoreKit – for processing in-app purchases
- Cloud hosting infrastructure – to host our servers, run the self-hosted AI model, process uploaded photos, and store generated images. Our cloud hosting provider acts solely as our infrastructure processor on our behalf and under our instructions.
These services may process data in accordance with their own privacy policies. We do not share your personal data (including uploaded photos, generated images, or face data) with any third parties for their own purposes, and we do not integrate any analytics or advertising SDKs.
8. Data Storage & Retention
- Uploaded original photos: Deleted immediately after AI processing is complete
- Face data in uploaded original photos: Retained only temporarily during AI processing and deleted immediately after processing is complete
- Generated images: Stored on our servers and associated with your account until you delete them or delete your account
- Face data in generated images: Stored only as part of the generated image in your in-app Gallery, under the same retention period as generated images
- Account data: Retained until you choose to delete your account
- Face templates, faceprints, biometric identifiers: We do not create, store, or retain any such data
9. Data Deletion
You can delete your account and all associated data at any time using the "Delete My Account" feature in the app Settings.
This will permanently remove:
- Your account information
- All generated images in your Gallery
- Your usage history and credit balance
- Any remaining personal data associated with your account
After deletion, you may continue using the app as a guest or create a new account.
10. Your Rights
Depending on your location, you may have the following rights:
- Access: Request a copy of the personal data we hold about you
- Deletion: Request deletion of your data (via the in-app Delete My Account feature or by contacting us)
- Data portability: Request your personal data in a structured, commonly used, and machine-readable format
- Object: Object to processing of your data based on legitimate interest
- Restriction: Request restriction of processing of your data in certain circumstances
- Withdraw consent: Withdraw consent where processing is based on consent
To exercise these rights, you can:
- Use the account deletion feature directly within the app, or
- Contact us via email
We will respond to requests within 30 days.
11. Age Requirements
CoupleLens is intended for users aged 16 and older. We do not knowingly collect personal information from individuals under 16. If we become aware that we have collected data from a user under 16, we will promptly delete it. If you are under 16, please do not use this App.
12. Security
We take reasonable measures to protect your data during transmission and storage. However, no method of transmission over the Internet or electronic storage is 100% secure.
13. Changes
We may update this Privacy Policy from time to time. When we make material changes, we will notify you via an in-app prompt before the updated policy takes effect. Your continued use of the app after acknowledging the changes constitutes acceptance of the updated policy.
14. Contact
If you have any questions about this Privacy Policy, please contact us at: