Privacy Policy for Viby AI

1. Introduction

Viby AI ("we," "our," or "us") respects your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you use our mobile application.

2. Information We Collect

2.1 Photos and Images

• What: You upload selfie photos to generate AI portraits
• Purpose: To generate personalized AI images based on selected templates
• Storage: Photos are temporarily stored on Google Cloud Storage (USA) for processing
• Retention: All uploaded photos are automatically deleted within 24 hours after processing

2.2 Account Information

• Email address (for account creation and communication)
• Payment information (processed securely by Apple App Store)
• Subscription status and credits balance

2.3 Usage Data

• App usage statistics (features used, generation frequency, template preferences)
• Device information (device model, operating system version)
• Error logs and crash reports to improve app stability

2.4 Advertising and Tracking Data

• Device Identifiers: Advertising Identifier (IDFA), Device ID
• Ad Interactions: Ads viewed, clicked, conversions
• In-App Activity: Pages visited, features used, time spent in app
• Purpose: To display personalized advertisements and measure campaign effectiveness

2.5 Cookies and Analytics

• We may use analytics tools to understand app usage and improve our service
• You can opt-out of analytics tracking in your device settings

3. How We Use Your Information

We use your information to:

• ✅ Generate AI photos based on your selfies using Google's Gemini AI technology
• ✅ Process payments and manage subscriptions through Apple payment systems
• ✅ Send service updates, support messages, and subscription notifications
• ✅ Improve app performance, features, and user experience
• ✅ Display personalized advertisements through third-party advertising networks
• ✅ Measure and analyze advertising campaign performance
• ✅ Track user activity across different apps and websites for targeted advertising
• ✅ Comply with legal obligations and enforce our terms of service

4. Advertising and User Tracking

4.1 TikTok for Business (ByteDance)

We use TikTok Ads to display advertisements and measure marketing campaign performance.

Data Collected by TikTok:

• 📱 Device Identifiers: Advertising ID (IDFA), Device ID
• 👆 In-App Interactions: Screens viewed, buttons clicked, features used, time spent
• 📊 Ad Data: Ads you viewed, clicked, or interacted with
• 💰 Conversion Events: App installs, purchases, subscriptions
• 🌐 Cross-App Tracking: Your activity across other apps and websites

How TikTok Uses Your Data:

• 🎯 Display personalized advertisements based on your interests
• 📈 Measure advertising campaign effectiveness
• 🔄 Retarget you with relevant ads on TikTok and partner platforms
• 📊 Analyze user behavior to optimize ad performance

Data Sharing:

• Your data is shared with TikTok (ByteDance) servers located primarily in the United States and Singapore
• TikTok may share anonymized/aggregated data with advertisers
• Data is linked to your identity through your device identifier

TikTok Privacy Policy: https://www.tiktok.com/legal/privacy-policy

TikTok Ads Terms: https://ads.tiktok.com/i18n/official/policy/terms

4.2 Your Tracking Choices

On iOS 14.5 and later:

• When you first open Viby AI, a system prompt will ask: "Allow Viby AI to track your activity across other companies' apps and websites?"
• If you tap "Allow": TikTok and other advertising services can track your activity for personalized ads
• If you tap "Ask App Not to Track": We cannot access your IDFA, and tracking is limited (you'll still see ads, but they won't be personalized)

To change your tracking preference later:

1. Open iPhone Settings
2. Scroll to Privacy & Security
3. Tap Tracking
4. Find Viby AI and toggle tracking on or off

To limit ad tracking system-wide:

1. Open iPhone Settings
2. Go to Privacy & Security → Apple Advertising
3. Turn on Personalized Ads toggle to OFF

Note: Even if you opt out of tracking, you will still see advertisements in the app, but they will be less relevant to your interests.

5. Data Sharing and Third Parties

We share data with the following service providers:

AI Processing

Google Cloud AI (Gemini 2.5 Flash Image) - for AI image generation

• Your photos are transmitted securely via encrypted HTTPS connections to Google Cloud servers located in the USA
• Google processes images according to their Cloud Platform Terms and does not use your data to train their models
• Photos are processed in-memory and not permanently stored by the AI service

Backend Infrastructure (Firebase by Google)

Viby AI uses Firebase, Google's mobile application development platform, which includes:

• Firebase Authentication - Secure user login and account management
• Cloud Firestore - NoSQL database storing user account information, subscription status, and credits balance
• Cloud Storage for Firebase - Temporary storage for uploaded photos during processing (automatic 24-hour deletion)
• Google Cloud Run - Hosting our backend API services

All Firebase services operate on Google Cloud infrastructure (USA-based servers) with:

• 🔒 Encryption in transit (HTTPS/TLS)
• 🔒 Encryption at rest
• 🔒 Enterprise-grade security standards
• 🔒 Compliance with GDPR, CCPA, and other privacy regulations

Advertising Partners

• TikTok for Business (ByteDance) - for personalized advertising and campaign measurement
  • Privacy Policy: https://www.tiktok.com/legal/privacy-policy
  • Data Processing: USA and Singapore servers
  • Opt-out: Through iOS tracking settings (see section 4.2)

Payment Processing

• Apple App Store (for iOS users) - for subscription management
• We do NOT store or have access to your credit card information

Analytics Services (if applicable)

• Anonymized usage data only to improve app functionality
• No personally identifiable information is shared

Legal Requirements

We may disclose information if required by law, court order, or to protect our legal rights

Third-Party Data Processing

All third-party services used by Viby AI are bound by data processing agreements that ensure your data is handled securely and in compliance with applicable privacy laws.

6. Data Security

We implement industry-standard security measures:

• 🔒 HTTPS/TLS encryption for all data transmission
• 🔒 Secure Google Cloud Storage with access controls and encryption at rest
• 🔒 Firebase Security Rules to restrict unauthorized database access
• 🔒 Automatic deletion of photos after 24 hours (no exceptions, enforced by automated systems)
• 🔒 Regular security monitoring and updates
• 🔒 Limited employee access to personal data

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

7. Your Rights and Choices

You have the right to:

• ✅ Access your personal data stored in our systems
• ✅ Request deletion of your account and associated data
• ✅ Opt-out of personalized advertising (via iOS tracking settings)
• ✅ Opt-out of promotional communications (account-related emails will still be sent)
• ✅ Withdraw consent for data processing at any time
• ✅ Request a copy of your data (data portability)
• ✅ Correct inaccurate personal information

To exercise these rights: Contact us at vibyaigeneration@gmail.com

Response time: We will respond to your request within 30 days.

8. Children's Privacy

Viby AI does not have a specific age restriction, but we recommend parental supervision for users under 13 years old.

If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately at vibyaigeneration@gmail.com, and we will delete such information promptly.

We do not knowingly collect or solicit personal information from children under 13 in a manner that violates applicable laws.

Advertising to Minors: We do not knowingly serve personalized advertisements to users under 13 years old.

9. International Data Transfers

Your data is processed on servers located in the United States (Google Cloud infrastructure) and may be transferred to Singapore (TikTok servers).

For European Union Users

• Data transfers from the EU to the USA and Singapore are conducted in compliance with applicable data protection laws
• Google Cloud complies with the EU-US Data Privacy Framework
• TikTok has implemented Standard Contractual Clauses (SCCs) for data transfers
• You have the same privacy rights regardless of where data is processed

For Other International Users

• By using Viby AI, you consent to the transfer of your data to the USA and Singapore
• We ensure appropriate safeguards are in place for international transfers

10. Data Retention

• Photos: Stored temporarily in Cloud Storage for Firebase and automatically deleted after 24 hours (enforced by automated cleanup systems)
• Account data (Firestore): Email, subscription status, credits balance - retained while your account is active
• Advertising data (TikTok): Retained according to TikTok's data retention policy (typically up to 18 months)
• After account deletion:
  • Firestore account data is deleted immediately from the active database
  • Photos (if any remaining) are purged within 24 hours
  • Some data may be retained in backups for up to 90 days for legal, accounting, or fraud prevention purposes
  • Advertising data remains with TikTok according to their retention policy
• Payment records: Managed by Apple/Google and retained as required by tax and financial regulations (typically 7 years)

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.

We will notify you of significant changes via:

• Email notification to your registered address
• In-app notification upon next app launch
• Updated "Last Updated" date at the top of this policy

Your continued use of Viby AI after changes are posted constitutes your acceptance of the updated policy. We encourage you to review this policy periodically.

13. Legal Compliance

This Privacy Policy complies with:

• GDPR (General Data Protection Regulation - European Union)
• CCPA (California Consumer Privacy Act - USA)
• Apple App Store Guidelines
• App Tracking Transparency (ATT) framework - iOS 14.5+
• Google Cloud Platform Terms of Service
• Firebase Terms of Service
• TikTok Ads Terms of Service

Additional Information for Specific Jurisdictions

For European Union Users (GDPR)

• Data Controller: Viby AI
• Legal Basis for Processing:
  • Performance of contract (to provide AI generation service)
  • Consent (for tracking and marketing communications)
  • Legitimate interests (to improve our service and display non-personalized ads)
• Your Rights: You have the right to lodge a complaint with your local data protection supervisory authority
• Data Protection Contact: vibyaigeneration@gmail.com
• Advertising Consent: We rely on your explicit consent (via iOS ATT prompt) for personalized advertising

For California Residents (CCPA)

In the past 12 months, we have collected the following categories of personal information:

• Identifiers (email address, device ID, IDFA)
• Visual information (photos - deleted after 24 hours)
• Commercial information (subscription status, purchase history)
• Internet activity (app usage data, ad interactions)

Categories of Third Parties We Share With:

• Advertising networks (TikTok for Business)
• Cloud service providers (Google Cloud/Firebase)
• Payment processors (Apple)

Your California Rights:

• Right to know what personal information is collected, used, or disclosed
• Right to request deletion of personal information
• Right to opt-out of sale of personal information (we do not sell personal information)
• Right to opt-out of sharing for cross-context behavioral advertising (via iOS tracking settings)
• Right to non-discrimination for exercising your rights

To exercise these rights, contact us at vibyaigeneration@gmail.com with "CCPA Request" in the subject line.