PRIVACY POLICY Promptogram

Version 1.1. Effective 7 September 2026.

1. WHO PROCESSES YOUR DATA

The data controller is Roman Romanov, sole proprietor, Airport Highway 186, Batumi 6000, Georgia. Contact for data matters: ahoneyhunters@gmail.com.

2. WHAT DATA WE PROCESS

The video you record or upload for generation, including your face and voice.
Face frames: to preserve your appearance, the App extracts up to three still frames showing your face from your video and sends them to the AI provider together with the video as a reference of your look. We do not store them and do not use them to establish your identity.
The prompt text and the styles you choose.
Technical data: the notification token (APNs), app and OS version, device model, a random installation identifier, and anonymised diagnostic lines. Links to your clips are never included in diagnostics.
When the App contacts our server: the IP address and basic request attributes (country, device type, the function called). This is needed to protect the service from misuse and to prevent third parties from using our access to the AI provider.
The text of reports and suggestions you send from the App, together with the app version and the clip identifier.
Purchase information reaches us from Apple without payment details: we do not receive or store your card data.

We do not ask for your name, phone number or email address and we keep no accounts. Data is not used for advertising; we do not track you across other apps or websites and we do not sell data.

3. WHY AND ON WHAT BASIS

Creating your clip, purchases and notifications — performance of our contract with you (the User Agreement).
Transferring the video and face frames to the AI provider outside your country — your explicit consent, given on a separate screen before your first generation. You may withdraw consent by no longer using generation; withdrawal does not affect processing already carried out.
Diagnostics, protection from misuse, counting free generations and handling reports — our legitimate interest in a working and safe service.

4. WHO RECEIVES YOUR DATA

fal.ai (USA) — the AI provider; processes the video and face frames with the Kling model (developed by Kuaishou Technology) solely to create your clip. Generation is impossible without this transfer.
Cloudflare, Inc. (USA) — our server: proxies requests to the provider, stores diagnostics, counters and clip balances, delivers notifications.
Apple — App Store purchases, notifications (APNs) and speech recognition for captions where your device does not support offline recognition.

These companies' servers are located outside your country, including in the USA. The USA is not on the list of countries with adequate data protection safeguards approved by Georgia's Personal Data Protection Service; the transfer is based on your consent and on the providers' contractual commitments to process data only to provide the service.

5. HOW LONG WE KEEP DATA

The video, face frames and finished clip at the AI provider — for a limited time under the provider's policy, only to deliver the result. We do not store videos or clips.
The history of finished clips — on your device until you delete it.
Diagnostics and IP address records — no more than 7 days, then deleted automatically.
The "this installation has already had its free generation" marker — up to 400 days.
Anonymised usage statistics — up to 40 days.
Reports and suggestions — up to 180 days.
The notification token — for as long as the App is installed.

6. FACE FRAMES (BIOMETRIC DATA)

Face frames and their processing by the provider may qualify as biometric data under the laws of some jurisdictions (Georgia, the EU, certain US states). Therefore: we ask for your explicit consent before your first generation; the frames are used only for the current generation; we do not create or store face templates, do not use them for identification and do not sell them; the provider deletes them within the periods set out in section 5. Do not send videos of other people without their explicit consent.

7. YOUR RIGHTS

You may request access to your data, its rectification, erasure, restriction of processing and portability, withdraw consent and object to processing. Since there are no accounts, we can locate your data only by the installation identifier: it is shown in the App under "About" — include it in your email to ahoneyhunters@gmail.com. We reply within 30 days. You may also lodge a complaint with the Personal Data Protection Service of Georgia (pdps.ge) or with the supervisory authority of your own country (for the EU/EEA, the data protection authority where you live).

8. CHILDREN

The App is intended for persons aged 13 and over; under 18 — with the consent of a parent or guardian. If we learn that data of a child under 13 has been processed without such consent, we will delete it.

9. SECURITY

All connections are encrypted (HTTPS). We keep no accounts and collect no contact details, so even in the event of an incident the data cannot be matched to your identity. We notify the supervisory authority and, where required, you of incidents affecting your rights within the periods set by law.

10. CHANGES

We may update this Policy; the current version is available in the App and at promptogram.app/legal/privacy.