This policy explains what personal data [Legal business name] ("ShineSnap", "we") collects, why, who we share it with, and the rights you have. We are the Data Fiduciary for your personal data under India's Digital Personal Data Protection Act, 2023 (the "DPDP Act"). In short: we collect what we need to run ShineSnap, we don't sell your data, and we don't use your photos to train AI.
1. What we collect
- Account details: your mobile number, which every account verifies, your email address and name if you sign in with or link a Google account, and an account ID.
- Photos and Results: the photos you upload, the images and animations we generate, and the styles you chose.
- Payments: the pack you bought, the amount, currency, status and Razorpay order and payment IDs. Razorpay handles your card, UPI or bank details. We never see or store them.
- Usage: pages you visit and actions you take in the app (for example "generated an image"), device and browser type, and approximate location from your IP address. Account details and other sensitive fields are masked in our analytics.
- Technical data: IP address, server logs and error reports, kept to run and secure the service.
- Messages: what you send us when you contact support.
2. Why we use it
We process your personal data on the basis of your consent, which you give when you sign up and accept these terms, and for the legitimate uses the DPDP Act allows, to:
- sign you in and run your account;
- generate and store your images and animations;
- process payments, keep your credit balance and send receipts and important service emails;
- prevent fraud and abuse (for example, free credits are given once per verified mobile number), and enforce our Terms;
- understand how ShineSnap is used and fix problems;
- meet legal obligations, such as tax and accounting records.
We do not sell your personal data, show you third-party ads, or use your photos or Results to train AI models.
3. How AI processing works
To create a Result, we send your photo and the style you chose to an AI provider (listed below), which returns the generated image. Before generation, photos may pass automated safety checks. We only use the providers' paid business services, whose terms do not allow them to use the data we send to train their models. [Confirm this for each provider before launch.] Providers may keep data briefly for abuse monitoring, as their terms describe.
4. Who processes it for us
These companies process personal data on our behalf, only to provide their service to us:
| Provider | What for | Data |
|---|---|---|
| Google Firebase | Sign-in and verifying your mobile number | Phone number, and Google account email and name if you use Google |
| Razorpay | Payments | Payment details, contact details you give at checkout |
| Cloudflare (R2) | Storing photos and Results | Photos and Results |
| Railway | Running our servers and database | All account and service data |
| Google Gemini, directly or through OpenRouter | Generating images | Photos and chosen style |
| Photoroom | Background removal and studio images | Photos |
| Replicate | Creating video animations | Results you choose to animate |
| Resend | Sending emails | Email address and email content |
| PostHog | Product analytics | Usage data, with account details masked |
| Sentry | Error reports | Technical data from errors |
Some of these providers process data outside India, including in Singapore (where our servers and database run), the United States and the European Union. We only transfer data to countries the Government of India has not restricted under the DPDP Act. We may also share data when the law requires it, or with a buyer if ShineSnap's business is sold, under this policy.
5. How long we keep it
- Original photos and Results: until you delete them or your account. Photos you upload but never create anything from are deleted after 24 hours.
- Account details: until you delete your account. We may delete an account, with its photos and Results, after [3 years] without any sign-in, once we've emailed or texted you a warning at least 30 days before.
- Payment and credit records: as long as tax and accounting law requires (currently up to 8 years). They are anonymised once your account is deleted.
- Server logs, error reports and backups: up to [30] days.
- Analytics data: up to [12] months.
6. Your rights
Under the DPDP Act you can:
- ask for a summary of the personal data we hold about you and who we've shared it with;
- ask us to correct, complete or update your data;
- ask us to erase your data, or delete your account yourself (see below);
- withdraw your consent at any time. This doesn't affect processing already done, but we won't be able to provide the service without it;
- nominate another person to exercise these rights if you die or become unable to;
- complain to our Grievance Officer, and if you're not satisfied, to the Data Protection Board of India.
To use these rights, email [email protected] from your account's email or mention your account's phone number. We'll reply within 30 days. We may ask you to confirm your identity first.
7. Deleting your account
To delete a single photo, open the Result in the Studio and choose Delete. It disappears at once, and we erase the file within a few minutes.
To delete everything, go to Account and choose Delete account. We sign you out at once and then erase your photos, Results and personal details from our systems and providers, normally within a few minutes and always within 30 days, including backups. Payment records are kept in anonymised form, as the law requires.
9. Security
We use reasonable security safeguards: encryption in transit (HTTPS), private storage that can only be reached through short-lived links, access controls on our systems, and monitoring. No system is perfectly secure. If a personal data breach affects you, we'll tell you and the Data Protection Board as the DPDP Act requires.
10. Children
ShineSnap is for people aged 18 and over. We don't knowingly collect personal data from children. If you believe a child has given us personal data, email [email protected] and we'll delete it.
11. Changes to this policy
We'll update the date at the top when this policy changes. If a change is significant, we'll tell you in the app or by email before it takes effect.
12. Grievance Officer and contact
[Name of Grievance Officer], Grievance Officer, [Legal business name], [Registered address, India]. Email: [email protected]. We acknowledge complaints within 48 hours and aim to resolve them within 30 days.