PRIVACY POLICY

Last Updated: July 15, 2026

At Glam Labs, Inc. (“Glam Labs”, “us”, we”, or “our”), protecting your privacy and maintaining absolute data transparency is our core priority. We comply with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and other global privacy standards.

This Privacy Policy explains how we collect, process, secure, and retain your personal information when you access our mobile applications (iOS and Android), desktop applications, websites, and web platforms (collectively, “GLAM” or the “Services”).

1. Definitions of Core Processing Terms

• “Face Data” refers to any facial landmarks, coordinates, or mathematical representations of facial geometry extracted from your uploaded photos. Initial face detection is executed locally on your device via Apple Vision strictly in volatile system memory. It is dropped immediately after successful processing, is never serialized, is not written to persistent disk storage, and is not transmitted to our servers. We retain only a non-biometric indicator that a face is present and an associated photo identifier.
• “Glam Community Feed” means the voluntary, user-facing, interactive community space and discovery showcase operated within the App where Users can voluntarily publish, share, and display their generated Output Content, along with any associated text prompts, style settings, or filter configurations, to other Users of the Services.
• “Input Content” refers to the photos, videos, prompts, configurations, and metadata you upload to the App.
• “Output Content” (or “Generated Content”) refers to the final artistic avatars, edited files, or video assets returned to you.
• “Metadata” includes technical file characteristics (such as dimensions, file format, device details, and upload timestamps) generated during processing.
• “Prompts” refers to the text descriptions or artistic style instructions you submit to steer the generative AI models.

2. Information We Collect and Process

To provide our editing and generative AI services, we collect several categories of information:

2.1 Personal Information Provided Directly by You:

• Contact information, such as your email address.
• Profile information, including your name, profile picture, or login metadata from third-party social media integrations.
• Demographic characteristics, specifically your gender selection. Note: Your gender selection is processed solely to guide the generative AI model in rendering conventionally matching artistic styles (e.g., more masculine or feminine avatars) and is retained by default as part of our platform’s data retention policy.

2.2 Processing of Uploaded Photos and Videos:

Most standard image and video editing features are processed directly on your local device. However, utilizing generative AI features (including the AI Avatars feature) requires cloud processing.

• The AI Pipeline & Storage Infrastructure: To generate personalized avatars, you upload 10 to 20 photos. These photos are processed within containerized private cloud instances hosted on specialized GPU nodes provided by RunPod (whose Terms of Service are available at  and whose Privacy Policy is available at ) and Fal AI (whose Terms of Service are available at  and whose Privacy Policy is available at ).
• Our core storage systems, general server infrastructure, and persistent user databases are hosted on DigitalOcean Spaces (S3) in the United States (whose policies are available at ). 
• Personalized Face-Based Models: A personalized neural network model (a “LoRA”) is trained using your uploaded photos to personalize the network. Both the uploaded source photos and the persistent personalized model weights (LoRAs) are retained on our DigitalOcean cloud servers by default. This allows continuous platform utilization and model retraining when migrating to new base model versions without requiring you to manually re-upload photos.
• Explicit Biometric Disclosure: Because the platform generates and stores a persistent mathematical representation of your face (the LoRA model weights) to generate your custom avatars, this constitutes persistent facial data storage under applicable laws (such as BIPA, CCPA, and GDPR). By uploading your photos and utilizing the AI Avatar generator, you explicitly consent to the persistent storage of this face-based model on our DigitalOcean cloud servers.

3. Apple App Store Privacy Disclosures (Guidelines 5.1.1 & 5.1.2)

To comply with Apple’s developer requirements regarding “Face Data” and user transparency, we establish the following operational rules:

3.1 On-Device Alignment Analysis:

Any facial characteristics, landmark coordinates, or alignment geometry analyzed on your device (collectively, “Face Data”) are processed locally utilizing Apple Vision. This landmark data is processed strictly in volatile system memory, is dropped following alignment, is never serialized, written to disk, or saved, and is never used for user tracking, behavioral profiling, marketing, or biometric identification.

3.2 Data Storage and Recipients:

• Infrastructure Hosts: All cloud-based GPU compute processing occurs on secure containerized instances hosted by our compute partners, RunPod (runpod.io) and Fal AI (fal.ai), located in the United States. File storage, photos, and personalized models are stored on DigitalOcean Spaces.
• No Third-Party AI Data Transfer: We do not share, sell, or rent your information, photos, videos, or Face Data with external consumer AI networks (such as OpenAI or Midjourney). All processing occurs within secure containerized environments managed by Glam Labs under strict confidentiality agreements. No user data is ever utilized for third-party model training.
• Zero Commercial Trading: We never sell, rent, or trade your information, photos, videos, Face Data, or generated Output Content with third parties for their commercial purposes.

3.3 Platform-Specific Data Sharing for Refunds:

If you request a refund for an in-app purchase through Apple’s App Store, we may provide Apple with certain consumption metrics. This metadata is shared solely to help Apple make informed refund decisions and includes:

• Time elapsed since app installation and total active usage time.
• Anonymous account identifiers.
• Whether the purchased subscription, in-app Coins, or features were consumed.
• Whether a free trial was utilized and historical refund records.

4. Data Retention and Deletion

We maintain the following data retention policy:

5. Your Rights and Choices

5.1 Account Deletion and File-Level Erasure Limitations:

• Account Deletion: You can initiate an account deletion directly within the App’s settings menu (for iOS users) or by emailing [email protected] (for Android, Web, and Desktop users).

CRITICAL LIMITATION DISCLOSURE: When you initiate account deletion, we permanently delete your profile and active records from our production databases, rendering your account inaccessible and removing the association between your identity and your uploaded content from our active systems. Although immediate file level deletion from all cloud storage and backup infrastructure may not be technically feasible, any remaining source photos, personalized model weights (including LoRAs), generated outputs, or encrypted backup copies that temporarily remain within our or our service providers' secure cloud infrastructure are permanently inaccessible, cryptographically orphaned or otherwise disassociated from your account, cannot reasonably be associated with you or used to identify you, and are not used for any business, operational, or AI training purposes following account deletion. Such residual copies are retained solely as part of secure backup or storage processes and are automatically overwritten or permanently destroyed in accordance with our data retention and backup policies. We process account deletion requests in accordance with applicable privacy laws, including the GDPR and the CCPA/CPRA, subject to any applicable legal exceptions.

5.2 Data Portability and Access Requests:

You have the right to request a complete, machine-readable copy of your personal data. To exercise this right, email your request to [email protected]. Following identity verification, our privacy compliance team will deliver your secure data package via electronic mail within forty-five (45) days.

5.3 Community Feed Control:

5.5 Community Feed

GLAM features a voluntary community space where users can share their artistic creations. If you choose to publish your Output Content to the Glam Community Feed, you grant us a non-exclusive, royalty-free, worldwide, transferable, and sub-licensable license to display, store, reproduce, and make such materials available to other users. Other users may use your shared assets as reference or inspiration for their own generations. You can toggle these sharing permissions or delete your public feed posts at any time within your in-app settings.

6. Security Safeguards

We implement robust administrative, physical, and electronic security measures to safeguard your personal data. All database records and stored cloud assets are protected behind a Virtual Private Network (VPN) and encrypted in transit and at rest. Access is strictly limited to authorized personnel subject to binding confidentiality agreements.

7. Global Compliance Addenda

California Privacy Rights (CCPA/CPRA):

We do not sell or “share” (for cross-context behavioral advertising) your personal information. California residents have the right to request disclosures regarding collected data categories, request deletion (subject to the cloud-storage limitations disclosed in Section 5.1), and opt out of any future data sales by contacting [email protected].

United Kingdom & European Union (GDPR):

Our European legal basis for processing is the performance of our contract with you or your explicit, informed consent. You have the right to lodge complaints with your local supervisory authority (e.g., ICO in the UK, Garante in Italy, AEPD in Spain, CNIL in France, BfDI in Germany, or FDPIC in Switzerland).

In compliance with the UK GDPR and EU GDPR, Glam Labs, Inc. has appointed its corporate legal counsel to act as its designated representative:

• Designated Legal Representative & GDPR Agent: Sutter Law, P.C.
• Address: 51 Moraga Way, Suite 2, Orinda, CA 94563
• Inquiries Contact: https://sutterlegal.com/contact/ or [email protected]

Canadian (PIPEDA) & Australian (APP) Privacy Laws:

Your data may be transferred to and stored on servers in the United States. By using our Services, you consent to this cross-border transfer. You may contact our designated Privacy Officer at [email protected] with any compliance inquiries.

8. Privacy Policy Updates

We reserve the right to revise this Privacy Policy. Material updates will be communicated to you via email or through prominent notifications within the App prior to the changes taking effect. Continued use of the App following update notifications constitutes your acceptance of the revised policy.

9. Privacy Support Contacts

• Corporate Address: Glam Labs, Inc., 769 Monterey Blvd., Suite #5A, San Francisco, CA 94127
• General Privacy Inquiries: [email protected]
• Designated Privacy Officer: [email protected]