Privacy Policy

This Privacy Policy explains how MLC ("we", "us", "our") collects, uses, and protects your information when you use our AI virtual try-on mobile application (the "App"). The App lets you try on clothing, mix and match outfits, change hairstyles and hair color, swap faces, retouch and enhance photos, remove backgrounds, and use other AI photo tools.

Please read this Privacy Policy carefully. By installing or using the App you agree to the practices described here. If you do not agree, please do not use the App.

Summary of key points

• Your photos are uploaded over an encrypted connection to our own AI servers to generate your result.
• We run our own AI models. Your photos are not sent to any third-party AI provider.
• Uploaded photos and generated results are deleted from our servers immediately after the result is returned to your device.
• We do not create facial recognition templates, biometric identifiers, or face geometry maps, and we never use your photos to identify you.
• Your photos are never used to train AI models and are never sold or shared for advertising.
• The App is free and supported by ads. Ad and analytics partners may receive device identifiers, but never your photos.

1. Information We Collect

1.1 Photos and content you provide

When you use an AI feature you choose a photo from your gallery or take one with the camera. Depending on the feature this may include a photo of yourself or another person, photos of clothing items you add to your wardrobe, a reference photo for face swap, and any text or style options you select. These photos may show a person's face and body.

1.2 Generated images

The App creates new images based on your photo and the feature you selected. Generated images are returned to your device and stored only on your device (in the App's history, wardrobe, or your photo library if you choose to save them).

1.3 Device and technical data

We and our service providers automatically collect limited technical information: device model, operating system version, app version, language and region, an app-generated installation identifier, the advertising identifier (IDFA on iOS, GAID on Android) when permitted, IP address, crash reports, and basic usage events such as which features are used and how often.

1.4 Support messages

If you contact us by email we keep your message and email address so that we can reply.

2. Information We Do Not Collect

• We do not collect precise location (GPS) data.
• We do not access your contacts, call logs, messages, or microphone.
• We do not use Face ID, TrueDepth, or any facial recognition technology.
• We do not create or store biometric templates, facial geometry, or identifiers that could be used to recognize you.
• We do not require an account. You can use the App without providing your name or email address.
• We do not sell your personal information.

3. Facial Data and Biometric Information

Photos you upload may contain a face. Our AI models analyze the visual content of the image, including the position of the face and body, only to render the effect you requested (for example to place a garment on your body, change a hairstyle, or swap a face). This processing is automated and temporary.

We do not extract, store, or compare facial features to identify any individual, do not build a biometric profile, and do not use facial data for authentication, verification, surveillance, or marketing. Any intermediate data created during processing is discarded together with the photo as described in Section 4.

Where applicable law treats facial images as sensitive or biometric data (for example the GDPR, the UK GDPR, or certain U.S. state laws), we process it only with your explicit consent, which you give when you select a photo and start an AI feature. You can withdraw consent at any time by not using the AI features or by uninstalling the App.

Face Swap and photos of other people

You may only upload photos of yourself, or of other people who have given you their permission. You must not use the App to create images of a person without their consent, to impersonate anyone, or to create misleading, sexual, or harmful content. We may refuse to process content that violates these rules.

4. How Your Photos Are Processed and Deleted

1. You select a photo and an AI feature in the App.
2. The photo is sent over an encrypted HTTPS/TLS connection to AI servers operated by us.
3. Our own AI models process the image in memory to generate the result. No third-party AI service receives your photo.
4. The generated image is returned to your device.
5. Immediately after the result is delivered, the uploaded photo, the generated image, and all temporary processing files are deleted from our servers. We keep no copy.

Processing is fully automated. No person views your photos, unless we are required to do so by law or to investigate a report of abuse. We do not use your photos or generated images to train, improve, or evaluate AI models.

Because results are stored only on your device, you control them: delete them from the App's history or wardrobe, from your photo library, or by uninstalling the App.

5. How We Use Information and Legal Bases

• To provide the App — generate AI results, and maintain your wardrobe and history on your device. (Performance of a contract; consent for photo processing.)
• To operate and improve the App — measure feature usage, diagnose crashes, and fix bugs. (Legitimate interests.)
• To show advertising — display ads in the free version and, where you consent, personalized ads. (Consent; legitimate interests for non-personalized ads.)
• To respond to you — answer support requests and privacy requests. (Legitimate interests; legal obligation.)
• To comply with law and enforce our terms. (Legal obligation; legitimate interests.)

6. Third-Party Services

We use a small number of service providers. They may receive technical data and identifiers described in Section 1.3, but none of them receive your photos or generated images.

• Apple App Store / Google Play — app distribution.
• Google AdMob and its mediation partners — advertising in the free version. See Google's Privacy Policy and AdMob partner list.
• Google Analytics for Firebase and Firebase Crashlytics — usage statistics and crash reporting. See Firebase Privacy.
• Attribution partner (Adjust) — measures which campaign led to an install so we can evaluate marketing. See Adjust Privacy Policy.

These providers process data under their own privacy policies and are contractually bound to use it only to provide their services to us. We may also disclose information when required by law, to protect our rights or users' safety, or as part of a business transfer.

7. Advertising and Tracking Choices

The App is free and supported by ads. Ad partners may use your advertising identifier and technical data to show and measure ads. You can limit this at any time:

• iOS: when the App asks for permission to track (App Tracking Transparency), you can choose "Ask App Not to Track". You can change this later in Settings › Privacy & Security › Tracking. Declining does not limit any feature of the App.
• Android: Settings › Google › Ads › "Delete advertising ID" or "Opt out of Ads Personalization".
• EEA, UK and Switzerland: the App shows a consent dialog before any personalized ads are served. You can change your choice in the App's settings.

8. AI-Generated Content

Results produced by the App are AI-generated simulations. They may be inaccurate, unrealistic, or unexpected, and they do not guarantee how a real garment, hairstyle, or cosmetic treatment will fit, look, or feel. Do not rely on them for purchasing, medical, or other decisions.

You are responsible for how you use generated images. You must not present them as genuine photographs where this could mislead or harm anyone, and you must comply with the rules in Section 3 and in our End-User License Agreement.

9. Data Retention and Deletion

Because the App does not require an account, there is no account to delete. Uninstalling the App removes all locally stored data. To request deletion of any data we may hold about you (for example support correspondence), contact us at the address in Section 14.

10. Data Security

All data in transit between the App and our servers is encrypted using TLS. Our AI servers are access-controlled, and uploaded content is never written to long-term storage. We use administrative, technical, and physical safeguards appropriate to the sensitivity of the data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

11. International Data Transfers

We are based in Vietnam and our AI servers may be located in Vietnam or other countries. Our service providers may process technical data in the United States and elsewhere. Where required, we rely on appropriate safeguards such as standard contractual clauses for transfers out of the EEA, UK, or Switzerland.

12. Your Privacy Rights

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

• access the personal information we hold about you and receive a copy;
• correct inaccurate information;
• delete your information;
• restrict or object to certain processing, including direct marketing;
• withdraw consent at any time, without affecting processing that already took place;
• data portability;
• not be discriminated against for exercising your rights;
• lodge a complaint with your local data protection authority.

EEA / UK / Switzerland (GDPR): we respond within one month. California (CCPA/CPRA): we do not sell or share personal information as defined by the CCPA, and we respond within 45 days. Vietnam (Decree 13/2023/ND-CP): you may exercise the rights set out in the Decree by contacting us.

To exercise any right, email us at the address below. We may ask you to verify your identity before responding.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top shows the current version. If we make a material change to how photos or facial data are processed, we will notify you in the App and, where required, ask for your consent again. Continued use of the App after an update means you accept the revised policy.

14. Contact Us

If you have any questions about this Privacy Policy or want to exercise your rights, contact us:

MLC Construction Trading Import Export Co., Ltd.
26, Street 3, Hiep Binh Area, Quarter 4, Hiep Binh Phuoc Ward, Thu Duc City, Ho Chi Minh City, Vietnam