Feinnr Privacy Policy

Release Date • 2025-03-13

Welcome to Feinnr! Your privacy is paramount to us.

This Privacy Policy ("Policy") applies exclusively to Feinnr products and services ("Services") provided by FEINNR AI Inc. ("we", "our", "us"). Please read carefully to understand how we collect, use, share, and protect your personal information. Important terms related to sensitive personal data and your rights are highlighted in bold.

I. What Personal Information We Collect

When you use Feinnr, we may collect personal information that you provide directly, that we automatically collect, or that third-party platforms share with us. This information is necessary for the normal operation of the Services.

  1. Account Information: When you register or log in, we collect your mobile phone number, e-mail address, user ID, and password, plus any avatar and date-of-birth details you choose to provide. If you log in with a third-party platform (e.g., Apple ID, Google, Facebook), we will, with your permission, receive basic profile information such as your avatar, nickname, and third-party user ID.
  2. AI Interaction Data: Text prompts, feedback (likes, reports, re-inputs), and conversation context are processed so that our AI can respond appropriately and improve over time. Because conversation content may contain personal data, please avoid submitting sensitive data unless necessary or legally authorized.
  3. Transaction Information: Purchase receipts, recharge and consumption records, virtual coin balances, order IDs, payment method, and amount.
  4. Device & Log Data: Device model, OS & version, unique identifiers (IMEI, IDFA/OAID, etc.), carrier, language, screen resolution, IP address, crash logs, login logs, browsing and search history, feature usage, and violation records—collected to secure the Service and diagnose issues.
  5. Face Data (Photos): If you choose to upload a photo to generate AI-based images, the image may contain your facial features ("Face Data").
    • We do not collect biometric identifiers or perform facial recognition or identity verification.
    • The photo is processed solely to generate the requested AI image(s).
    • Your uploaded photo is stored securely on our servers in encrypted form, never shared with third parties, and automatically deleted within 24 hours after processing is complete.
    • We do not use your Face Data for advertising, profiling, or model training without your explicit opt-in.
    • You can request earlier deletion of your uploaded photos from Settings → Delete Uploaded Photos.

II. How We Use Personal Information

  • Service Operation: Create and manage your account, deliver content and features, process payments, and provide support.
  • AI Personalization: Generate tailored conversational responses, remember preferences, and continuously enhance AI quality.
  • Security & Stability: Detect fraud, secure accounts, ensure network integrity, and debug crashes.
  • Analytics & Improvements: After aggregation/anonymization, analyze usage to optimize features and develop new ones.
  • Marketing: With your consent, send e-mails or in-app messages about updates, promotions, or events; deliver relevant ads.
  • Legal Compliance: Fulfill obligations under applicable laws, regulations, subpoenas, or court orders, and resolve disputes.

III. How We Share or Disclose Your Information

We may engage trusted third-party processors under strict data-processing agreements; share data with affiliates for legitimate, specified purposes; or disclose data when required by law. We do not sell your personal information. For details, see the SDK & third-party list in our App Settings.

IV. Data Storage Location

Your data is stored on secure servers in Singapore and the United States. Depending on your location, data may be transferred internationally under Standard Contractual Clauses or equivalent safeguards.

V. How We Protect Your Information

We deploy industry-standard security measures—TLS/SSL encryption in transit, AES-256 at rest, firewalls, role-based access controls, and 24×7 monitoring. In the unlikely event of a breach, we will notify affected users and regulators in accordance with applicable law.

VI. Your Rights & Choices

You have the right to:

  • Access, correct, delete, or export your personal data;
  • Restrict or object to certain processing activities;
  • Withdraw consent at any time without affecting prior lawful processing;
  • Permanently delete your account in Settings → Account Deletion (or via the direct link provided in the Settings page). Deletion is irreversible and will remove all personal data—including any stored photos, Face Data, and generated images—from our systems within 24 hours, except where retention is legally required;
  • Request data portability to another controller.

We do not require you to contact customer service to delete your account. If we cannot fulfill your request (e.g., it would jeopardize others' rights, impose excessive technical burden, or fall under statutory exemptions), we will explain why.

VII. Children's Privacy

Feinnr is intended for users aged 13 and older. We do not knowingly collect data from children under 13. Parents or guardians may contact us to delete a minor's data.

VIII. Data Retention Schedule

Data Category Purpose Retention Deletion Method
Uploaded Photos & Face Data Generate AI images ≤24 hours post-processing (or immediate on user request) Secure deletion from storage/services
Generated Images saved by user User content continuity Until user deletes or account deletion User-initiated or account deletion
Account Identifiers (email/phone, login records) Auth & security Life of account + up to 90 days logs Rolling deletion/anonymization
Payment Records (IAP receipts) Tax/audit As required by law (typically 3–7 yrs) Scheduled purge post–legal window
Analytics/Crash Logs App quality & security 24 months (aggregated thereafter) Aggregation/anonymization pipeline

IX. Subscriptions & Terms of Use

If you purchase an auto-renewable subscription:

X. Regional Supplements

1) California Privacy Notice (CPRA)

  • We do not sell personal information. We do not share personal information for cross-context behavioral advertising.
  • If this changes, we will provide a clear "Do Not Sell or Share My Personal Information" link and honor Global Privacy Control (GPC) signals.
  • At or before the point of collection, we disclose categories, purposes, retention, and whether data is sold/shared; consumers can opt-out without creating an account.
  • We do not use sensitive personal information for purposes requiring a "Limit the Use" link; if this changes, we will provide that control.

2) EEA/UK GDPR Notice

  • Controller: FEINNR AI Inc. (contact in Section XII).
  • Lawful Bases:
    • Account & core features: Contract (Art.6(1)(b))
    • Payments/fraud/security: Legal obligation / Legitimate interests (Art.6(1)(c)/(f))
    • AI image generation (processing your uploaded photos): Consent / Contract
    • Marketing/analytics requiring consent: Consent (Art.6(1)(a))
  • Transfers: We use SCCs and appropriate safeguards for transfers outside the EEA/UK.
  • Rights: Access, rectification, erasure, portability, restriction, objection, withdraw consent, and lodge complaints.

3) Illinois Biometric Information Privacy Act (BIPA) Notice

  • We do not collect "biometric identifiers" as defined by BIPA for the purpose of identifying a person. If Face Data is deemed "biometric information," we maintain a public retention and destruction schedule (see Data Retention Schedule) and do not sell or profit from biometric data. Data is deleted at the earliest of (i) purpose completion; or (ii) the retention limit stated above.

XI. Policy Updates

We may revise this Policy to reflect service updates. Material changes will be announced via in-app pop-ups or e-mail at least seven (7) days in advance. Continuing to use Feinnr indicates acceptance of the updated Policy.

XII. Contact Us

E-mail: contact@feinnr.com
Contact: FEINNR AI Inc.
We aim to respond within 15 business days. If dissatisfied with our reply, you may lodge a complaint with your local data-protection authority.