Privacy Policy

1. Summary of Key Points (for quick reference)

• We collect account information, the photos/videos you choose to submit for AI generation, and basic usage/device data.
• Glowid's own systems do not perform facial recognition, facial detection, or biometric identification, and do not collect or retain biometric identifiers as defined under applicable law (e.g., Illinois BIPA, Texas CUBI, Washington's biometric privacy law, or the CCPA/CPRA). See Section 2.3 for how this applies to the third-party AI providers we use.
• We do not use your photos, videos, prompts, or generated content to train, fine-tune, or otherwise improve any AI/machine learning model — ours or any third party's.
• Original photos/videos you upload are deleted immediately after your generation task is completed. We do not retain your original Input Media.
• We use third-party AI providers solely as data processors to perform the generation task you request; they are contractually barred from using your data for their own purposes, including model training.
• Users can report generated content or templates directly in the app; reported content is reviewed and may be removed. See Section 5.
• We do not sell your personal information.

The sections below provide full detail.

2. Information We Collect

2.1 Information You Provide

• Account Information: email address, phone number, or identifiers received from third-party sign-in (e.g., Sign in with Apple, Google Sign-In); display name/avatar if provided.
• Input Media: photos and videos you select from your photo library or capture with your camera, and text prompts you type, for the purpose of AI generation/editing.
• Customer Support Communications: information you provide when contacting support@glowid.ai.
• Payment-related information: subscription/purchase status and transaction identifiers received from Apple App Store or Google Play. We do not receive or store your full payment card number; payments are processed entirely by Apple/Google.

2.2 Information Collected Automatically

• Usage Data: features used, number of generations, in-app interactions, crash logs, and diagnostic data.
• Device Information: device model, operating system and version, language and region settings, advertising identifier (IDFA/GAID, only where you have provided the applicable platform-level consent, e.g., Apple's App Tracking Transparency), and approximate location inferred from IP address (country/region level only — we do not collect precise GPS location).

2.3 Facial Processing and Biometric Information

Glowid's own systems do not perform facial detection, facial landmark extraction, or facial/identity recognition. We do not independently analyze, derive, or store biometric identifiers or biometric information (including facial geometry, faceprints, or voiceprints) from your photos or videos, and Glowid does not intentionally collect precise geolocation, government ID numbers, financial account numbers, health information, genetic data, or contacts/address book data.

To produce certain AI-generated effects, your Input Media is transmitted to the third-party AI providers described in Section 4, which perform the actual image or video generation on our behalf. Depending on the specific model or effect you select, the underlying image-generation technology used by those providers may involve automated analysis of facial or other regions of the image as a technical step in rendering the requested effect. Where this occurs:

• such analysis is performed by the third-party provider as part of fulfilling your request, not independently by Glowid;
• it is used solely to generate the output you requested and for no other purpose;
• it is not used by Glowid or, to our knowledge, by our AI providers, to determine, verify, or authenticate your real-world identity;
• it does not result in Glowid creating, receiving, or retaining a biometric identifier, faceprint, or persistent facial profile; and
• any such data is deleted by the provider upon completion of the processing task, consistent with Section 3.2 and that provider's applicable data-processing terms.

If you have questions about how a specific AI provider's technology processes facial or bodily regions of an image, you may refer to that provider's privacy documentation, linked in Section 4.

3. Input Media: Processing and Retention

3.1 When you submit a photo or video for AI generation or editing, it is transmitted securely to our processing systems and to the third-party AI provider(s) described in Section 4 solely to produce the output you requested.

3.2 We delete your original Input Media immediately upon completion of the generation/editing task. We do not keep a copy of your original uploaded photos or videos in our production systems after the task is complete, and we do not maintain backup copies of your Input Media. Deletion is immediate and permanent.

3.3 Generated Content that you choose to save is stored on your device and, if you enable cloud sync/history features (if applicable), in your account's history within our systems until you delete it or delete your account.

3.4 We do not use Input Media, prompts, or Generated Content to train, fine-tune, evaluate, or otherwise improve any AI or machine learning model, whether operated by us or by any third party. We do not grant our AI processing vendors any right to use your data for their own model development.

4. Third-Party AI Processing Providers

To generate your requested content, Glowid transmits your Input Media and prompts to third-party AI infrastructure and model providers acting strictly as our data processors, specifically BytePlus Pte Ltd, OpenAI, and Google.

These providers:

• process data solely to return generated output to Glowid;
• are contractually prohibited from using your data for their own purposes, including advertising or model training;
• are required to delete or not retain your data beyond what is needed to fulfill the processing request, consistent with Section 3.2.

5. AI Content Safety and Reporting

Glowid provides in-app reporting functionality that allows users to report a template or any generated content directly within the application, without leaving the app.

When content is reported, we conduct a secondary review of the reported content. Where appropriate, we may:

• remove or restrict the reported content;
• remove, disable, or restrict the associated template or effect;
• restrict access to affected functionality;
• prevent further distribution of violating content; or
• suspend or terminate the account responsible for violating content, where applicable.

This reporting and review process is part of how we detect, prevent, and respond to prohibited content described in Section 6, including content that may violate our Terms of Service or applicable law (such as CSAM or non-consensual explicit content). Users may also contact support@glowid.ai regarding content safety, copyright, or other content-related concerns.

6. How We Use Information

We use the information described above to:

• Provide, operate, and maintain the AI generation and editing features;
• Create and manage your account, and authenticate you;
• Process subscriptions and purchases via Apple/Google;
• Detect, prevent, and respond to fraud, abuse, and violations of our Terms of Service (including prohibited content such as CSAM or non-consensual explicit content), including through the reporting and review process described in Section 5;
• Provide customer support;
• Analyze aggregated, de-identified usage trends to improve app stability and features;
• Comply with legal obligations.

We do not use your Input Media or Generated Content for advertising targeting or AI model training.

7. How We Share Information

We do not sell your personal information. We may share information with:

• Third-party AI processing providers (BytePlus Pte Ltd, OpenAI, Google) — Input Media, prompts — to perform the AI generation task you requested;
• Cloud hosting/storage providers — account data, Generated Content you choose to save — to host and store the Service and your data;
• Apple / Google — subscription and transaction identifiers — to process in-app purchases and subscriptions;
• Google Firebase — device identifiers, app usage/interaction data, crash logs, IP address — for analytics, crash reporting, and app performance monitoring;
• AppsFlyer — device/advertising identifiers (e.g., IDFA/GAID, only with your consent), install source, app usage events — for marketing attribution;
• Law enforcement or regulators — information as required — to comply with a legal obligation, protect rights, or respond to lawful requests.

If Sparking Labs Limited is involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction, subject to this Policy or a policy providing at least equivalent protection.

8. Data Storage and International Transfers

Your information is stored on servers located primarily in the United States, operated by our cloud service providers. Because we use third-party AI processing providers described in Section 4, your Input Media and prompts may also be processed on infrastructure operated by those providers in other countries in which they operate.

Where information is transferred internationally — for example, to a third-party AI processor located outside your country of residence — we take reasonable steps to ensure an adequate level of protection consistent with applicable law, which may include contractual protections, standard contractual clauses, or other legally recognized safeguards.

9. Your Privacy Rights

Depending on where you live, you may have rights including:

• Access — request a copy of the personal information we hold about you;
• Deletion — request deletion of your personal information or your account;
• Correction — request correction of inaccurate information;
• Opt-out of “sale” or “sharing” — we do not sell or share personal information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA; to the extent any activity qualifies, you may opt out;
• Non-discrimination — we will not discriminate against you for exercising your privacy rights;
• Withdraw consent — for example, by revoking photo library/camera access in your device settings, or disabling advertising tracking permissions (e.g., Apple ATT).

California Residents (CCPA/CPRA): We do not sell or share (as defined by the CCPA) your personal information. Categories of personal information collected in the past 12 months are described in Section 2. To exercise your rights, contact support@glowid.ai; we may need to verify your identity before fulfilling your request. You may designate an authorized agent to submit a request on your behalf.

To exercise any right, contact us at support@glowid.ai. We will respond within the timeframe required by applicable law.

10. Children's Privacy

Glowid is not directed to children under 13, and we do not knowingly collect personal information from children under 13 (or the applicable minimum age in your jurisdiction) without verifiable parental consent, consistent with the U.S. Children's Online Privacy Protection Act (COPPA). If we learn that we have collected personal information from a child under 13 without appropriate consent, we will delete that information promptly. Parents who believe their child has provided us with personal information may contact support@glowid.ai to request deletion.

11. Data Security

We implement industry-standard technical and organizational measures — including encryption in transit, access controls, and routine security review — designed to protect your information from unauthorized access, disclosure, alteration, or loss. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

12. Advertising Identifiers and Tracking

Glowid integrates Google Firebase (analytics and crash reporting) and AppsFlyer (marketing attribution). On iOS, before either SDK accesses your device's advertising identifier (IDFA) or is used to track you across apps or websites owned by other companies, we will request your permission through Apple's App Tracking Transparency (ATT) framework. You may decline this permission, or later change your choice at any time in Settings > Privacy & Security > Tracking. On Android, Firebase and AppsFlyer may access the Google Advertising ID (GAID) subject to your device-level ad personalization settings, which you can manage in your device's Google Settings > Ads.

If you decline tracking permission, Firebase and AppsFlyer will still receive basic, non-tracking app usage/crash data necessary for app functionality and aggregated install-attribution reporting, but will not use your advertising identifier for cross-app/cross-site tracking.

13. Data Protection Contact

Sparking Labs Limited has not appointed a formal Data Protection Officer. For any privacy-related question, request, or complaint, please contact our support team directly at support@glowid.ai, and we will route it to the appropriate team internally.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the app or other reasonable means, and, where required by law, obtain your renewed consent before the changes take effect. Please review this page periodically.

15. Contact Us

• Company: Sparking Labs Limited (智象星實有限公司)
• Registered Address: Room A08, 2/F, Lee Ka Industrial Building 8, Ng Fong Street, San Po Kong, Hong Kong
• Business Registration No.: 80564496-000-06-26-2
• Email: support@glowid.app