Photo Glow Up

Privacy Policy

Last updated: 15 October 2026  ·  Data controller: SofoApp OÜ  ·  support@blyk.online

This Privacy Policy explains how we collect, use, share and protect your information when you use Photo Glow Up.

AT A GLANCE

This summary is for convenience only; the full Privacy Policy below applies.

01 General

1.1.        Photo Glow Up is operated by SofoApp OÜ, legal address: Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 3, 10145. Throughout the Site, the terms “we”, “us”, “our” refer to SofoApp OÜ. The use of our app is governed by the following Terms of Use and Privacy Policy.

1.2.        This Privacy Policy is meant to explain how we collect, use, share and protect your user information, including information that can identify you (“Personal Data”). Please read the following carefully to understand our views and practices regarding user information and Personal Data.

1.3.        We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at support@blyk.online.

1.4.        If any questions remain unanswered or you would like to exercise your privacy rights, please also contact us at support@blyk.online.

02 Who We Are

2.1.        Acting as a data controller, we are committed to protecting and respecting your privacy. If you have any questions regarding this Privacy Policy or requests concerning your Personal Data, you may contact via email at support@blyk.online.

03 Your EU Rights

3.1.        You have the right to access, update, correct or delete your Personal Data that we store on our systems. You also have the right to obtain from us your Personal Data (excluding data we obtained from other sources) and transmit those data to another data controller. If you wish to exercise any of these rights, contact support@blyk.online.

3.2.        You also have the right to restrict or object to the processing of your Personal Data, to withdraw your consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal), and to lodge a complaint with a supervisory authority — the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or the authority of your country of residence.

3.3.        In the app, you can delete your generation results at any time, skip the onboarding questions, choose which photos to upload and manage camera, photo and tracking permissions in iOS Settings. We respond to requests within one month (this period may be extended by two months for complex requests). As the app works without an account, we may ask for details that help us find your data, such as a purchase receipt.

04 Your California Privacy Rights

4.1.        If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), provides you with the right to:

• know what personal information we collect, use and disclose, and access that personal information;
• correct inaccurate personal information;
• delete your personal information;
• opt out of the sale of your personal information and of its sharing for cross-context behavioral advertising;
• limit the use and disclosure of sensitive personal information; and
• not be discriminated against for exercising any of these rights.

4.2.        We do not sell your personal information. Measuring the effectiveness of our advertising campaigns with your tracking permission may qualify as “sharing” under the CCPA; you can opt out at any time by denying tracking in iOS Settings or by contacting us. We do not sell or share personal information of consumers we know are under 16 years of age without the opt-in consent required by law.

4.3.        In the preceding 12 months, we collected the following categories of personal information: identifiers (user ID, IDFV, IDFA with your permission, IP address); commercial information (transaction data); internet or other electronic network activity information (in-app activity, crash logs and diagnostics); audio, electronic, visual or similar information (photos and generation results); characteristics of protected classifications (age group and gender, if you provide them); and general geolocation (country). The sources, purposes and recipients of this information are described in Sections 5, 8 and 9, and retention periods in Section 10. We do not use sensitive personal information to infer characteristics about you.

4.4.        To exercise your rights, contact us at support@blyk.online. We will verify your request and respond within 45 days. You may designate an authorized agent to submit a request on your behalf. If we decline your request, you may appeal by replying to our decision. Residents of other U.S. states with comprehensive privacy laws have similar rights and may exercise them in the same way.

05 Information We Collect

5.1.        In order to provide and improve the Services, we collect the following user information, including Personal Data: We do not share or use any information from photos, except for transmitting photos to our AI providers for the purpose of editing (see Section 6). Information from user photos is used only for editing within the application.

5.2.        Information provided by you. You may give us information and your Personal Data, when you use our app, by filling in forms (such as the sign-up or sign-in form), when you enter into any of our promotions or surveys, when you correspond with us by e-mail and when you use “Report a mistake” form in our app.

5.3.        The information you give us may include:

• User image. While using our service, you understand and agree that we must upload your image to our server for processing and returning retouched images to you for the purposes of providing such service to you. Your image (including a reference image, if you add one) is transmitted to our AI providers for processing (see Section 6).
• Your image is stored on the user’s device during the retouching processing of the image and permanently deleted after the order is done.
• Results of generations (generated images and text recommendations of analyzers), which are stored on our server so that you have access to your works in the app; you can delete them yourself at any time.
• Signature to identify Client on the app (Client id).
• Mandatory information is required to Sign up or Sign in on our app including your email address (only for users who purchased a subscription on our website; this option will be added soon).
• Age (age group), which you indicate during onboarding.
• Gender, which you indicate during onboarding and when choosing a filter.
• Your preferences regarding AI generations (the goal you select during onboarding).
• Transaction data (information about purchased products and subscriptions), which we verify on our server to give you access to the features of the app. We do not receive your payment card details, which are processed by Apple.
• Country of your location.
• Mobile device model.
• The time when the Order was sent and received by the Customer.
• The reason for the rejection in case the Order was rejected.
• The list of services that the Customer chooses in the Order.

For the purposes of this Privacy Policy, “Order” means your request to edit or generate an image in the app, and “Customer” means you.

Information we may require from you when you report a problem to our Support Team, such as the subject of your request for support.

5.4.        Information collected automatically. Through the software development kits (SDKs) integrated in our app, we automatically collect technical information: device identifiers (IDFV; IDFA only if you allow tracking via Apple’s App Tracking Transparency), operating system and app version, language, IP address, in-app activity (screens opened, taps, features used, onboarding steps), crash logs and diagnostics.

5.5.        Information related to user Face. To provide some functionalities of the Services (such as change of hairstyle, hair color, makeup and retouching), faces of people in the image are processed. We may detect and use facial marks to provide facial manipulation features for each person in the image. We do not use face recognition technology: the user’s face is not identified and is not matched against any database, and biometric data is not processed.

5.6.        Information related to the user’s face cannot be used to identify a specific person, and cannot be shared with any third parties, except for our AI providers as part of the image you submit for processing.

5.7.        Information related to the user’s face data is stored on the user’s device during the retouching processing of the image and permanently deleted after the order is done. On our server and on the side of our AI providers, such data is processed as described in Section 6.

06 How We Process Your Photos with AI

6.1.        Image generation is performed through third-party AI APIs. A request always follows the route: app → our server → AI provider’s API → our server → app; the app never contacts AI providers directly.

6.2.        We use the following AI providers: OpenAI OpCo, LLC / OpenAI Ireland Limited, Google LLC, Replicate, LLC, fal — Features & Labels Inc., and Deep-Image. All of them perform one function — processing an image at your request — and act as our processors.

6.3.        The provider receives the photo you uploaded and a text prompt that we prepared in advance and embedded in the configuration of the selected filter; you do not enter or see the prompt. The provider returns the generated image (or the text recommendation of an analyzer). User identifiers, email, payment and analytics data are not transferred to the providers.

6.4.        Replicate and fal are inference platforms: they are not the authors of the models but provide access to models of third parties. In such requests, the platform acts as our processor and the model developer acts as a sub-processor.

6.5.        The list of models is fixed in each version of the app: changes to prompts and models are released together with an app update and are not replaced remotely. If we add a new provider, we will update this Privacy Policy.

6.6.        Consent. Before your photo is sent to our AI providers for the first time, the app shows you a separate consent screen explaining that your photo will be transmitted to third-party AI providers for processing. Your consent is explicit: the photo is sent only after you confirm it by tapping the consent button on this screen. If you do not give your consent, the AI features of the app are not available to you. You may withdraw your consent at any time by contacting us at support@blyk.online; the withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

6.7.        The results of generations are stored on our server so that you can access your works in the app; you can delete them yourself at any time. Your original image is kept only as long as necessary to process the request or, where it is shown next to its result in your history, until you delete it. On the providers’ side, retention periods are determined by their own policies and our API settings.

6.8.        We do not use your photos or generation results for advertising, analytics or personalization, and we do not use them to train AI models.

6.9.        If a photo shows another person (for example, in a couple filter), you may upload it only with that person’s permission. Their image is processed in the same way as yours and only to fulfil your request. A person shown in a photo may ask us to delete it by contacting support@blyk.online.

6.10.        AI providers may automatically check submitted images and decline a request. We record the outcome and the reason for the rejection to fix errors and prevent misuse.

07 Personalization

7.1.        Content personalization is part of the current development of the app and is being introduced gradually. Only the order in which existing content is displayed is personalized, not the content itself.

7.2.        During onboarding, you answer one question about your interests. Your answer is matched against static editorial tags that we manually assigned to each filter, and the number of matches determines the order of collections on the home screen and the block of similar styles under a generation result. Your age group and gender are used to personalize the content and the selection of filters, and the gender you choose for a filter determines which variant of that filter is generated.

7.3.        Behavioral profiles, data from third-party sources and the content of uploaded photos are not used for personalization.

7.4.        If you skip onboarding, the default editorial order is shown.

7.5.        There is no automated decision-making that produces legal or similarly significant effects for you.

08 How We Use the Information

8.1.        We use the information we collect:

• to execute the order and provide retouching app, including AI generation of images and text recommendations of analyzers;
• to provide you with the information and services that you requested from us;
• to verify purchases on our server and give you access to the features of the app;
• to personalize onboarding, the order of content and the selection of filters, and to generate an image with the filter variant you choose;
• to give you access to our support services. By providing your email address you consent to our using the email address to answer your question or resolve your problem;
• to notify you about changes in our app;
• to purposes such as analyzing how the app is used, diagnosing service or technical problems;
• to analyze our audience (age group, gender, interests) and the conversion of onboarding;
• to improve the app to ensure that content is presented in the most effective manner for you and for your device;
• to measure the effectiveness of our advertising campaigns, only with your permission;
• as part of our efforts to keep our app safe and secure;
• to ensure compliance with (i) applicable laws, (ii) our Terms of Use, and (iii) our Privacy Notice. Certain breaches that we regard as inappropriate may lead to the suspension of your Account profile.

8.2.        The table below shows which data we use and for what purposes:

8.3.        Also, we use cookies and log file information to:

• provide custom, personalized content and information;
• monitor the effectiveness of our app;
• monitor aggregate metrics such as total number of visitors and traffic;
• diagnose or fix technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP.

8.4.        If the app asks for permission to track (Apple’s App Tracking Transparency), we access your device’s advertising identifier (IDFA) only if you allow it. You can change your choice at any time in iOS Settings → Privacy & Security → Tracking.

8.5.        Where the GDPR applies, we rely on the following legal bases:

09 How We Share the Information

9.1.        We will not rent or sell your Personal Data to others and will not share it with others except as provided herein.

9.2.        We may share your personally identifiable information with third parties solely for the purpose of providing services to you. If we do this, such third parties’ use of your information will be bound by this Privacy Policy. We may store personal information in locations outside the direct control of our app (for instance, on servers or databases co-located with hosting providers).

9.3.        For the operation of the app, we use the following service providers, which process the data listed below. User identifiers, email, payment and analytics data are not transferred to the AI providers.

9.4.        As we develop our business, we may buy or sell assets or business offerings. Information we collect is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution.

9.5.        When you use our app, some of your Personal Data is shared with our Support team.

9.6.        Except as otherwise described in this Privacy Policy, we will not disclose your Personal Data to any third party unless required to do so by law or subpoena or if we believe that such action is necessary to:

• conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities;
• enforce our rights, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our Service;
• exercise or protect the rights, property, or personal safety of our Service, our Customers or others.

9.7.        We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them and us understand the usage of the Service.

10 Data Retention and International Transfers

10.1.        We keep Personal Data only as long as necessary for the purposes described in this Privacy Policy:

10.2.        Deleted data may remain in backups for a limited time. We may keep data longer where required by law or to establish, exercise or defend legal claims.

10.3.        Some recipients, including AI providers and analytics tools, process data outside the European Economic Area, mainly in the United States. In such cases, we rely on adequacy decisions of the European Commission (including the EU–U.S. Data Privacy Framework for certified recipients) or on Standard Contractual Clauses, together with additional safeguards where necessary.

11 How We Protect Your Information

11.1.        We work hard to protect your privacy and collect only the data we need to make your experience better. We make commercially reasonable efforts to ensure the security of our systems. However, no Internet, email or other electronic transmission is ever fully secure or error free and while we strive to use commercially acceptable means to protect data, we cannot guarantee its absolute security.

12 Changes to Privacy Policy

12.1.        The app may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

13 How to Contact Us

13.1.        If you have any questions about this Privacy Policy or our app, please contact us using one of the following means: via email support@blyk.online.

SofoApp OÜ, Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 3, 10145, Estonia.