Legal
Privacy Policy
What we collect, why we collect it, who else touches it, how long we keep it, and what you can ask us to do with it.
Privacy Policy
1. Who is responsible
[Legal Entity Name], [Company Number], [Country of Incorporation], at [Street Address], [City], [Postal Code], [Country], is the data controller for the personal data described here. Privacy questions and rights requests go to support@eluvana.com.
2. What we collect
Account data
Your email address, and — if you sign in with Google — your name and Google account identifier. That is the whole account record. We do not ask for a postal address, a phone number, or a date of birth.
Uploaded product images
The photographs you upload, plus their file metadata. Photographs of products are not normally personal data, but a photo can incidentally contain a person, a reflection, a document or embedded EXIF location. We treat uploads as confidential content regardless. If an upload contains a person, you are responsible for having their consent.
Generated images
The images the service produces from your uploads, together with the generation parameters — preset, output size, mask region, and the prompt text you supplied for a local edit.
Usage and technical logs
Timestamps, which features you used, credit deductions and returns, error and latency records, IP address, browser user agent and approximate country derived from IP. These exist to keep the service working, prevent abuse, and let us resolve a disputed credit balance.
Billing data
Handled by Polar. We receive a record that a purchase happened — package, amount, timestamp, billing country — but we never receive or store card numbers.
What we do not collect
- No advertising or cross-site tracking identifiers.
- No third-party analytics cookies, and no data sold or shared with data brokers.
- No special-category data is requested. Do not upload it.
3. Why we use it, and on what legal basis
- To provide the service — authenticate you, process uploads into generated images, store your library, track your credit balance. Basis: performance of a contract.
- To take payment — process purchases and issue invoices through Polar. Basis: performance of a contract, and legal obligation for tax records.
- To keep the service secure and available — rate limiting, abuse detection, debugging, fraud prevention. Basis: legitimate interests in running a secure service.
- To communicate with you — sign-in links, receipts, service and policy notices. Basis: performance of a contract. Marketing email is sent only with consent and can be withdrawn at any time.
- To comply with law — accounting records, and responding to lawful requests. Basis: legal obligation.
We do not train AI models on your uploads or generated images, and we do not use your content in marketing, without your separate explicit opt-in.
4. Who else processes your data
We use the sub-processors below. Each is bound by a data processing agreement, may use your data only on our instructions, and may not use it for its own purposes.
| Sub-processor | Role and data received |
|---|---|
| Polar | Payments — Merchant of RecordReceives your billing email, billing country, payment details and purchase history. Acts as seller of record and handles tax and invoicing. Card details are entered on Polar and never reach us. |
| Sign-in (OAuth)Used only if you choose Google sign-in. We receive your email address, name and account identifier. We do not receive your Google password and request no other Google data. | |
| Third-party AI model providers | Image generationYour uploaded photo and the generation request are transmitted to the model provider that produces the image. Providers vary by feature and change as models improve, which is why they are named generically here; the current list is available on request from support. |
| Cloud hosting and object storage | InfrastructureRuns the application and stores uploaded and generated images, encrypted at rest. The provider has no independent right to use your content. |
| Transactional email provider | Account emailDelivers sign-in links, receipts and service notices. Receives your email address and the message content. |
AI model providers are named generically because the set changes as models are added, replaced or deprecated. Email support for the list current at the time of your request. We will give notice by email before adding a sub-processor that materially changes how your content is handled.
Beyond these, we disclose personal data only where required by law or valid legal process, or to a successor entity in a merger or acquisition — in which case this policy continues to apply until you are given notice of any change.
5. How long we keep it
| Data | Retention |
|---|---|
| Uploaded product photos | Until you delete themDeleted from object storage within 30 days of deletion, including from backups. |
| Generated images | Until you delete themKept in your library so you can re-export at other resolutions. Same 30-day backup window on deletion. |
| Account record | Until account deletion + 14 daysDeletion is reversible for 14 days, then the record and all associated images are removed. |
| Usage and generation logs | 12 monthsRetained for abuse prevention, debugging and credit-ledger disputes, then deleted or aggregated beyond re-identification. |
| Security logs (IP, user agent) | 90 daysRetained for intrusion detection and rate-limit enforcement. |
| Purchase and tax records | Up to 7 yearsHeld by Polar as Merchant of Record to meet statutory accounting and tax obligations. This period survives account deletion because the law requires it. |
Account deletion and the 14-day grace period
When you request deletion, your account is immediately deactivated and your images become inaccessible. The data is then held for 14 days, during which you can contact support to reverse the deletion — this exists to protect against mistakes and against deletion by someone who has gained access to your account.
After 14 days, the account record, uploaded photos, generated images and unspent credit balance are permanently deleted from live systems. Encrypted backups are rotated, so residual copies are removed within a further 30 days. Purchase and tax records held by Polar survive deletion, because accounting law requires it.
6. Your rights
Depending on where you live, you can ask us to:
- Access — get a copy of the personal data we hold about you.
- Export — receive your data in a portable, machine-readable format.
- Correct — fix inaccurate account data.
- Delete — erase your account and content, subject to the retention periods above.
- Restrict or object — to processing based on legitimate interests.
- Withdraw consent — where we relied on consent, at any time, without affecting processing already carried out.
How to exercise them: account deletion is available in the app.For access, correction and export, emailsupport@eluvana.com from your account address — self-service export has not shipped yet, so these are handled manually.We respond within 30 days and do not charge for reasonable requests.
If you are in the UK, EU or EEA and you think we have mishandled your data, you can complain to your national supervisory authority. We would rather you told us first.
7. Cookies
The marketing site sets no cookies at all. The application sets onlyfunctional cookies — a session cookie and a refresh token — that are strictly necessary to keep you signed in. There are no advertising cookies and no cross-site tracking.
Any analytics we run is cookieless and aggregate: no cookie, no persistent identifier, no cross-site profile. Full detail is in theCookie Policy.
8. International transfers
Our sub-processors operate internationally, so your data — including uploaded images sent to AI model providers — may be processed outside your country, including in the United States.
Where data leaves the UK, EU or EEA, we rely on an adequacy decision covering the recipient country where one exists, and otherwise on the European Commission'sStandard Contractual Clauses (with the UK International Data Transfer Addendum where relevant), together with a transfer risk assessment and technical measures including encryption in transit and at rest.
9. Security
- TLS on all connections; encryption at rest for stored images and database records.
- Passwordless sign-in — no password database to breach.
- Least-privilege access controls; staff access to user content is restricted and logged.
- Content is scoped per account; one user's library is not reachable from another's session.
No system is perfectly secure. If a breach affects your personal data and poses a risk to you, we will notify you and the relevant supervisory authority without undue delay, and within 72 hours of becoming aware where the law requires it.
10. Children
The service is not for anyone under 18. We do not knowingly collect data from children. If you believe a child has created an account, email us and we will delete it.
11. Changes to this policy
We will update this policy as the service changes. For material changes we will give at least 14 days' notice by email or in-app before they take effect. The "last updated" date at the top always reflects the current version.
12. Contact
[Legal Entity Name], [Company Number], [Country of Incorporation]
[Street Address], [City], [Postal Code], [Country]
support@eluvana.com