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

Topic

In short

See

Who is responsible

SofoApp OÜ, Tallinn, Estonia, acting as a data controller.

2

Your photos

Used only for editing and generating images you request; sent via our servers to AI providers and back.

5, 6

AI providers

OpenAI, Google, Replicate, fal and Deep-Image. They receive the photo and a pre-set prompt only — no user identifiers, email, payment or analytics data.

6, 9

Face recognition

Not used. Your face is not identified or matched against any database; no biometric data is processed.

5.5

Consent

Before your photo is sent to AI providers for the first time, the app asks for your explicit consent on a separate consent screen.

6.6

Generation results

Stored on our server so you can access your works; you can delete them at any time.

6.7

Onboarding answers

Age group, gender and AI-generation preferences — optional; used for personalization and analytics.

5.3, 7

Account

Not required. Email sign-in will be available soon

5.3

Selling data

We will not rent or sell your Personal Data.

4.2, 9.1

Age

Our app is intended only for persons aged 18 and over.

1.3

Your rights

EU/EEA and UK rights; California privacy rights.

3, 4

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:

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:

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.

Photo Glow Up app

you upload a photo

→

Our server

adds the filter’s prompt

→

AI provider

generates the result

→

Our server

stores your result

→

Photo Glow Upapp

you see the result

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:

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

Data

Purpose of use

Photo files (uploaded from the gallery or taken with the camera, including a reference image)

Use of the main function of the app: the photo is transmitted to our server for AI generation of an image with the selected filter, and the result is returned to you

Results of generations (generated images, text recommendations of analyzers)

Giving you access to your works in the app; you can delete them at any time

Transaction data (information about purchased products and subscriptions)

Verification of purchases on our server to give you access to the features of the app

Age (age group indicated during onboarding)

Personalization of content and selection of filters; analytics (analysis of our audience and onboarding conversion)

Gender (indicated during onboarding and when choosing a filter)

Personalization of content and selection of filters; generation of the image with the corresponding variant of the filter; analytics (analysis of our audience)

Preferences regarding AI generations (the goal selected during onboarding)

Personalization of onboarding and selection of filters; analytics (analysis of the interests of our audience and onboarding conversion)

User ID

Identification of the user, verification of subscriptions and purchases, handling of support requests

Email address (this option will be added soon)

Sign-in to the app; answering your support requests

Country of your location, mobile device model

Provision and improvement of the app, diagnosing technical problems, analytics

Device identifiers (IDFV; IDFA only with your permission), activity in the app, crash logs and diagnostics

Analytics of the use of the app, diagnosing technical problems, verification of the subscription status, measuring the effectiveness of advertising campaigns

Details of the request (time of the request and of the result, chosen filters and features, reason for the rejection)

Execution of your request, diagnosing errors

Information provided when you contact our Support Team (subject of your request)

Resolving your support request

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

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:

Purpose

Data used

Legal basis

Providing the app and executing your requests (upload, AI generation, analysis, delivery and storage of results)

Photos, generation results, request details, user ID

Performance of contract (Art. 6(1)(b) GDPR)

Transmission of your photos to AI providers

Photos (including a reference image)

Your explicit consent given on the consent screen in the app (Art. 6(1)(a) GDPR)

Verifying purchases and managing subscriptions

Transaction data, user ID

Performance of contract; legal obligation (Art. 6(1)(c))

Personalization of content and filter variants

Onboarding answers, user ID

Performance of contract; legitimate interests (Art. 6(1)(f))

Support and notifications about changes

Email, support requests, user ID

Performance of contract; legitimate interests; consent

Analytics, diagnostics and improvement of the app

Onboarding answers, in-app activity, device data, crash logs

Legitimate interests; consent where required by law

Measuring advertising campaigns

IDFA, IDFV, install and purchase events

Consent (App Tracking Transparency)

Security, compliance with law and enforcement of our Terms

Any relevant data

Legal obligation; legitimate interests

Promotions and surveys

Your answers and contact details

Consent

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.

Service provider

Data

Purpose

Our own server (backend)

Photo files, results of generations, transaction data, User ID

Use of the functions of the app: AI generation of images from the photo of the user, storage of results, verification of subscriptions and purchases, identification of the user

Hosting providers

Data stored on our server (photo files, results of generations, transaction data, User ID)

Hosting of our server and databases (servers or databases co-located with hosting providers)

OpenAI OpCo, LLC / OpenAI Ireland Limited

Photo uploaded by the user and the pre-set text prompt of the selected filter

Generation of images based on the photo uploaded by the user

Google LLC

Photo uploaded by the user and the pre-set text prompt of the selected filter

Generation of images based on the photo uploaded by the user

Replicate, LLC (inference platform)

Photo uploaded by the user and the pre-set text prompt of the selected filter

Generation of images based on the photo uploaded by the user through models of third parties (the model developer acts as a sub-processor)

fal — Features & Labels Inc. (inference platform)

Photo uploaded by the user and the pre-set text prompt of the selected filter

Generation of images based on the photo uploaded by the user through models of third parties (the model developer acts as a sub-processor)

Deep-Image

Photo uploaded by the user and the pre-set text prompt of the selected filter

Generation of images based on the photo uploaded by the user

Analytics, attribution, crash-reporting and subscription-management tools integrated into the app (SDKs)

Device identifiers (IDFV; IDFA only with your permission), activity in the app, crash logs and diagnostics, purchase events

Analytics of the use of the app, diagnosing errors, verification of the subscription status, measuring the effectiveness of advertising campaigns

Tableau

Analytics data (for example, age group, gender, preferences regarding AI generations, onboarding conversion)

Analytics: analysis of our audience, its interests and onboarding conversion

Apple (App Store)

Transaction data

Processing of payments and management of subscriptions (under Apple’s own privacy policy)

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:

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:

Data

Retention period

Generation results (and original images shown with them in your history)

Until you delete them in the app or ask us to delete your data

Photos sent for processing

As long as necessary to process the request

Copies held by AI providers

According to the providers’ policies and our API settings

Onboarding answers

While you use the app, or until you ask us to delete them

Transaction data

While your subscription is active, then as long as required by tax and accounting laws

Technical and analytics data

For the retention period set in the relevant tool, then deleted or aggregated

Support requests

As long as necessary to resolve your request

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.

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