1. Who We Are

This Privacy and Cookies Policy explains how LIMITED LIABILITY COMPANY "SSSTIK", registered at 2B Mykilsko-Slobidska Street, Room 277, Kyiv, Ukraine 02002 ("Phototune", "we", "us", or "our"), collects, uses, shares, and protects personal data when you use phototune.ai and related Phototune services (the "Service").

For purposes of applicable data protection law, LIMITED LIABILITY COMPANY "SSSTIK" is the controller of personal data described in this Policy, except where a Merchant of Record or another provider acts as an independent controller for its own payment, fraud-prevention, tax, or legal purposes.

Privacy questions and requests may be sent to contact@phototune.ai.

2. Scope

This Policy applies to visitors, free users, registered users, purchasers, and people who contact support. It covers the Phototune website and web-based tools that link to this Policy. Third-party websites, payment portals, app stores, and services have their own privacy notices.

3. Personal Data We Collect

3.1. Account and Profile Data

email address, display name, account identifier, authentication method, and account status;
login, verification, security, and account-recovery information;
language, country or region, preferences, subscription status, and credit balance.

3.2. Uploaded Content and Processing Data

images and files you upload;
text prompts, masks, selections, processing options, and instructions;
generated or edited Outputs and temporary previews;
technical metadata necessary to process the request, such as file type, dimensions, size, task ID, model or tool selected, processing time, and error status.

Images may contain personal data or sensitive information about you or other people. Do not upload content unless you have the necessary rights, permissions, and lawful basis. Avoid uploading documents, images, or information that are not necessary for the requested editing task.

3.3. Usage, Device, and Log Data

IP address, approximate location derived from IP, browser, device type, operating system, language, and identifiers;
pages viewed, buttons used, features selected, referring page, session information, timestamps, and interaction events;
performance, diagnostic, security, fraud, crash, and server logs;
cookie, local-storage, pixel, and similar technology data.

3.4. Purchase and Billing Data

Payments may be handled by a Merchant of Record or payment provider. Phototune may receive transaction ID, plan or credit pack, price, currency, tax status, purchase and renewal dates, payment status, refund or chargeback status, billing country, and limited payment-method details. We do not normally receive or store the full payment-card number or security code.

3.5. Communications and Support Data

When you contact us, we collect your contact details, message, attachments, account and task information you provide, and our response. If you submit feedback or rate an Output, we collect the rating and related comments.

3.6. Data from Third Parties

We may receive data from authentication providers, the Merchant of Record, payment providers, analytics services, anti-fraud providers, referral partners, or public sources, depending on the features you use and your choices.

4. How We Use Personal Data

provide, operate, and personalize the Service;
process uploaded content and generate the requested Output;
create and manage accounts, subscriptions, credits, purchases, and processing history;
authenticate users and maintain account and platform security;
restore credits or investigate failed tasks, fraud, abuse, and payment disputes;
provide support and communicate about transactions, security, service changes, and policy updates;
measure performance, diagnose errors, develop features, and improve usability using usage metrics, aggregated information, and de-identified data;
comply with law, enforce terms, protect rights and safety, and respond to valid legal requests;
send marketing messages where permitted and according to your preferences;
provide analytics, personalization, or advertising where enabled and consented to as required.

5. Legal Bases

Where data protection law requires a legal basis, we rely on one or more of the following:

Contract: processing necessary to provide the Service you request, manage your account, and administer purchases.
Legitimate interests: securing and improving the Service, preventing fraud, understanding usage, supporting users, and protecting legal rights, balanced against your rights and expectations.
Consent: optional cookies, certain marketing, and other processing where consent is required. You may withdraw consent at any time without affecting prior lawful processing.
Legal obligation: tax, accounting, consumer, sanctions, law-enforcement, and regulatory obligations.
Legal claims and vital interests: establishing, exercising, or defending claims, or protecting a person where permitted by law.

6. How AI Processing Works

To provide a requested feature, Phototune may send an uploaded image, prompt, settings, and related technical information to third-party AI processing providers. Providers may change over time depending on availability, quality, geography, feature, security, and cost.

Phototune does not intentionally use uploaded images or Outputs to train its own artificial intelligence models.

We may use third-party artificial intelligence providers to perform the processing requested by users. Depending on the provider, its applicable terms, and the technical configuration used, submitted images, prompts, settings, and Outputs may be processed or used by that provider to operate, maintain, evaluate, improve, or train its models or services.

We may use aggregated or de-identified usage metrics, performance data, error information, and voluntary feedback to analyze, maintain, develop, and improve Phototune. Where required by applicable law, we will provide additional notice or obtain consent before identifiable User Content is used for purposes beyond providing the requested functionality.

7. Uploaded Images, Outputs, and Processing History

We retain uploaded originals, temporary processing files, Outputs, previews, and related processing records for as long as reasonably necessary to provide the requested functionality, make recent processing results available, maintain and secure the Service, provide support, investigate technical issues, prevent fraud or abuse, resolve disputes, and comply with applicable law.

The applicable retention and history-availability period may vary depending on the feature used, whether the user is signed in, the user's account or subscription status, technical requirements, storage capacity, and operational needs. Where applicable, more specific availability periods may be displayed in the relevant plan description, account interface, processing page, or other part of the Service.

Files and history entries may be automatically deleted, overwritten, or made inaccessible when they are no longer required for the relevant purposes. Deletion may occur through periodic cleanup processes rather than immediately.

We may retain limited copies or related information for longer where reasonably necessary to investigate a user-reported issue, prevent fraud or abuse, comply with law, resolve a dispute, protect the Service, or complete deletion from backups.

Deleting content or an account may not delete transaction records, security logs, or other records that we must or reasonably need to retain for legal, financial, security, or dispute-resolution purposes.

Phototune is not intended to serve as a permanent storage or backup service. Users should download any Outputs they wish to retain.

8. How We Share Personal Data

We may disclose personal data to the following categories of recipients only as reasonably necessary:

AI processing providers that perform the requested image processing or generation;
cloud hosting, content-delivery, storage, database, and infrastructure providers;
authentication, email, customer support, monitoring, error-tracking, analytics, security, and anti-fraud providers;
the Merchant of Record, payment providers, banks, tax providers, and chargeback or fraud partners;
professional advisers, auditors, insurers, and contractors under confidentiality obligations;
law-enforcement authorities, courts, regulators, or other parties where disclosure is legally required or necessary to protect rights, safety, and security;
a buyer, investor, successor, or adviser in a merger, acquisition, financing, reorganization, bankruptcy, or transfer of all or part of the business, subject to appropriate safeguards.

We do not sell uploaded images or Outputs. We do not disclose them to third parties for their independent advertising purposes.

9. Merchant of Record and Payments

Purchases may be processed by CLINK, acting as Merchant of Record, or by another payment provider or Merchant of Record disclosed at checkout. The Merchant of Record may independently collect billing details, payment information, tax information, device and fraud signals, and transaction records under its own privacy notice. Phototune receives the information necessary to activate access, provide support, reconcile transactions, and manage refunds and disputes.

10. Cookies and Similar Technologies

Phototune uses cookies, local storage, pixels, browser identifiers, and similar technologies to operate, secure, analyze, and improve the Service. These technologies may store or access information on your browser or device.

Cookies are small text files placed on a device when a website is visited. Local storage allows information to be stored in a browser for a longer period or in a different format. Similar technologies may perform comparable functions even if they are not technically cookies.

10.1. Strictly Necessary Technologies

We use technologies that are necessary to provide and secure the Service. These may be used to:

maintain user sessions and keep users signed in;
authenticate accounts and support account recovery;
protect forms and requests against fraud, abuse, and security threats;
apply free usage, processing, and credit limits;
associate processing requests and results with a browser, session, or account;
balance traffic and maintain website availability;
support purchases, billing sessions, and account management;
maintain other functionality specifically requested by the user.

Because these technologies are necessary for the Service to function or to provide a feature requested by the user, they may be used without separate consent where permitted by applicable law.

Disabling or blocking strictly necessary technologies may prevent login, credit accounting, image processing, checkout, security features, or other parts of the Service from functioning correctly.

10.2. Preferences and Functional Technologies

We may use technologies to remember choices and improve convenience, including:

language and regional preferences;
interface settings;
recently selected tools or processing options;
account and display preferences;
information entered into forms during a session.

Depending on their purpose and applicable law, some functional technologies may be considered necessary, while others may be optional.

10.3. Analytics and Performance Technologies

We may use analytics and performance technologies to understand how the Service is used and to identify technical or usability issues. These technologies may collect information such as:

pages visited and features used;
referring pages and traffic sources;
session duration and interaction events;
device, browser, operating system, and approximate location;
processing success, failure, and performance information;
errors, crashes, and diagnostic events;
aggregated information about purchases and conversions.

We use this information to measure performance, maintain the Service, diagnose problems, improve user experience, and develop features.

Where required by applicable law, optional analytics and performance technologies will be used only after obtaining the appropriate consent.

10.4. Advertising and Measurement Technologies

We may use advertising, attribution, or measurement technologies to:

understand whether advertising campaigns lead users to Phototune;
measure campaign performance and conversions;
prevent advertising fraud;
limit repeated advertisements;
provide or measure advertising that may be relevant to users.

These technologies may be provided by third-party advertising or analytics partners and may allow those providers to recognize a browser or device across different websites or services.

Where required by applicable law, advertising and similar optional technologies will be used only after obtaining the appropriate consent.

Phototune does not disclose uploaded images or Outputs to third parties for their independent advertising purposes.

10.5. Third-Party Technologies

Some cookies and similar technologies may be placed or accessed by third-party service providers that help us operate the Service. These may include providers of:

analytics and performance measurement;
cloud infrastructure and content delivery;
authentication and security;
customer support;
fraud prevention;
payment processing and Merchant of Record services;
advertising and campaign measurement.

Third-party providers may process information under their own privacy notices and terms. The providers and technologies used by Phototune may change as the Service develops.

10.6. Retention

Cookies and similar technologies may remain active for different periods depending on their purpose.

Some technologies operate only during the current browser session and expire when the browser is closed. Others may remain for a limited period to maintain login status, remember preferences, enforce usage limits, prevent fraud, record consent choices, or measure website activity.

We retain information collected through these technologies only for as long as reasonably necessary for the purposes described in this Policy, subject to legal, security, fraud-prevention, and dispute-resolution requirements.

11. International Data Transfers

Phototune is based in Ukraine, and Phototune and its service providers may process personal data in countries other than the country in which you live. Depending on the operator and providers selected, those countries may have different data-protection laws. Where required, we may rely on recognized safeguards such as adequacy decisions, standard contractual clauses, contractual protections, and security measures.

12. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy and Cookies Policy, including providing the Service, maintaining security, preventing fraud and abuse, resolving disputes, and complying with legal, tax, accounting, and regulatory obligations.

Uploaded images, temporary processing files, Outputs, previews, and related processing records are retained according to the purposes and criteria described in Section 7. Retention periods may vary depending on the feature, account or subscription status, technical requirements, operational needs, security considerations, and any period displayed through the Service.

Other categories of personal data are retained according to the following criteria:

account data is generally retained while the account remains active and for a limited period afterward where necessary to complete deletion, maintain security, resolve disputes, or comply with legal obligations;
transaction, billing, refund, chargeback, and tax records are retained for the periods required by applicable financial, accounting, tax, and consumer-protection laws;
security, fraud-prevention, diagnostic, and technical logs are retained for as long as reasonably necessary to protect the Service, investigate incidents, diagnose errors, and establish or defend legal claims;
support communications are retained for as long as necessary to address the request, maintain an appropriate support history, resolve disputes, and comply with legal obligations;
consent records and records of acceptance of our policies may be retained for as long as reasonably necessary to demonstrate compliance and resolve disputes.

Residual copies of deleted data may remain temporarily in backups or disaster-recovery systems until they are overwritten or deleted in accordance with our normal backup procedures.

We may retain personal data for a longer period where required by law, necessary for an ongoing dispute, investigation, security incident, payment issue, or legal claim. When personal data is no longer required, we delete or anonymize it in accordance with our retention procedures.

13. Security

We use administrative, technical, and organizational safeguards designed to protect personal data, including access controls, encryption in transit, monitoring, input validation, and retention limits. No service or storage system can be guaranteed completely secure. You are responsible for protecting your account credentials and device.

14. Your Privacy Rights

Depending on where you live, you may have the right to:

request access to personal data and information about its processing;
correct inaccurate or incomplete data;
request deletion of data;
restrict or object to certain processing;
receive certain data in a portable format;
withdraw consent at any time where processing relies on consent;
opt out of certain marketing or targeted advertising activities;
appeal a refusal where local law provides an appeal right;
complain to a data-protection or consumer authority.

To exercise a right, contact contact@phototune.ai. We may ask for information necessary to verify your identity and authority. We will respond within the period required by applicable law. Rights may be limited where an exception applies, such as legal retention obligations, protection of others, security, or legal claims.

15. Marketing Communications

You can unsubscribe from promotional emails using the link in the message or by contacting us. We may still send non-promotional messages about your account, purchases, security, support requests, or material service changes.

16. Children

The Service is not intended for use by children without the permission and supervision of a parent or legal guardian where such authorization is required by applicable law. We do not knowingly collect personal data from children in violation of applicable law.

If you believe that a child has provided personal data without the required authorization, please contact us so that we can investigate and take appropriate action.

17. Automated Processing

AI tools automatically process images and instructions to produce an Output. This processing is initiated by you and is not intended to make legal or similarly significant decisions about individuals. We may use automated security and anti-fraud signals to protect accounts and payments, with human review where appropriate and required.

18. Changes to This Policy

We may update this Policy to reflect changes in the Service, providers, law, or business practices. We will post the updated version and change the effective date. We will provide additional notice for material changes where required.

19. Contact and Complaints

Contact: contact@phototune.ai

Controller: LIMITED LIABILITY COMPANY "SSSTIK", 2B Mykilsko-Slobidska Street, Room 277, Kyiv, Ukraine 02002