Privacy Policy

Last Updated: January 2025

This Privacy Policy describes how SimpuMind ("we", "our", or "us") collects, uses, and protects your information when you use the Photo & ID Maker mobile application ("App"). We are committed to protecting your privacy and ensuring transparency about our data practices.

1. Information We Collect

1.1 Photos and Images

The App allows you to capture or import photos for creating ID photos. All photo processing is performed locally on your device. We do not upload, store, or transmit your photos to our servers or any third-party services. Your photos remain on your device and are only saved to your device's photo library if you choose to export them.

1.2 Face Detection Data

When you use the App to analyze a photo for ID compliance, the App performs on-device face detection using Google ML Kit's face detection API. This processing occurs entirely on your device. The following data is computed from your photo during analysis:

• Face bounding box (position and size of the face within the image)
• Face pose angles (roll and yaw, to verify the face is forward-facing)
• Facial landmark positions (eyes, nose, mouth corners, and other features)
• Eye openness probabilities (left and right eye)
• Smiling probability
• Face contour points (outline of the face and hairline)

This face data is used solely to verify that your photo meets official ID photo requirements — for example, checking that the face is centered, the head-to-frame ratio is correct, the eyes are open, and the expression is neutral. It is not used for identification, authentication, or any other purpose.

Face data is never stored, uploaded, or transmitted. It is computed in memory during the analysis step and discarded immediately after. It is never written to disk, sent to our servers, or shared with any third party. Google ML Kit processes images entirely on your device and does not transmit face data to Google or any external service.

1.3 App Preferences and Settings

We store your app preferences locally on your device, including:

• Selected country and template preferences
• Language settings
• Default background color preferences
• Export size preferences

This information is stored locally on your device and is not transmitted to us or any third parties.

1.4 Subscription Information

If you purchase a subscription, payment processing is handled by Apple (for iOS) or Google (for Android) through their respective app stores. We use RevenueCat to manage subscription status. RevenueCat may collect:

• Purchase transaction information
• Subscription status
• Device identifiers (for subscription management)

For more information about RevenueCat's privacy practices, please visit: https://www.revenuecat.com/privacy

1.5 Advertising Data

The App uses Google AdMob to display advertisements. AdMob may collect:

• Device identifiers (such as advertising ID)
• IP address
• App usage data
• Location data (general, not precise)

This data is used to provide personalized advertisements. You can opt out of personalized ads in your device settings. For more information about AdMob's privacy practices, please visit: https://policies.google.com/privacy

1.6 Analytics Data

We do not currently use third-party analytics services. If we implement analytics in the future, we will update this Privacy Policy to reflect those practices.

2. How We Use Your Information

We use the information we collect to:

• Provide and improve the App's functionality
• Process subscription purchases and manage premium features
• Display relevant advertisements (through AdMob)
• Respond to your support requests
• Comply with legal obligations

3. Data Storage and Security

3.1 Local Storage

All photos and app preferences are stored locally on your device. We do not have access to this data, and it is protected by your device's security measures.

3.2 Data Retention

Since photos are stored locally on your device, you have full control over data retention. You can delete photos at any time through your device's photo library. App preferences are retained until you uninstall the App or clear the App's data.

3.3 Security Measures

We implement appropriate technical and organizational measures to protect your information. However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

4. Third-Party Services

The App uses the following third-party services:

4.1 Google AdMob

AdMob is used to display advertisements in the App. AdMob may collect device identifiers and usage data for advertising purposes. For more information, see: https://policies.google.com/privacy

4.2 RevenueCat

RevenueCat manages subscription purchases and premium feature access. RevenueCat processes payment information through Apple and Google's payment systems. For more information, see: https://www.revenuecat.com/privacy

4.3 Apple App Store / Google Play Store

Payment processing for subscriptions is handled by Apple (iOS) or Google (Android). These platforms collect payment information and transaction data. Please refer to their respective privacy policies for more information.

5. Your Rights and Choices

5.1 Access and Deletion

Since photos are stored locally on your device, you can access and delete them at any time through your device's photo library. To delete app preferences, you can uninstall the App or clear its data through your device settings.

5.2 Opt-Out of Personalized Ads

You can opt out of personalized advertisements by adjusting your device's advertising settings:

• iOS: Settings → Privacy & Security → Apple Advertising → Limit Ad Tracking
• Android: Settings → Google → Ads → Opt out of Ads Personalization

5.3 Subscription Management

You can manage or cancel your subscription at any time:

• iOS: Settings → [Your Name] → Subscriptions
• Android: Google Play Store → Subscriptions

5.4 GDPR Rights (European Users)

If you are located in the European Economic Area (EEA), you have certain rights under the General Data Protection Regulation (GDPR), including:

• Right to access your personal data
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object to processing

To exercise these rights, please contact us using the information provided in the "Contact Us" section below.

6. Children's Privacy

The App is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country. By using the App, you consent to the transfer of your information to these countries.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

9. California Privacy Rights

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA), including:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information
• Right to access your personal information
• Right to request deletion of your personal information

To exercise these rights, please contact us using the information provided in the "Contact Us" section below.

10. Contact Us

This Privacy Policy is effective as of the date listed above and applies to all users of the Photo & ID Maker app.