Effigy — Privacy Policy
Effective Date: May 22, 2026
This Privacy Policy explains how we collect, use, disclose, and protect your information when you use the Effigy mobile application ("App"). Effigy is an AI-powered image and video generation app available on the Apple App Store. We are committed to protecting your privacy and handling your data responsibly.
By downloading or using Effigy, you agree to the practices described in this policy.
Effigy does not require account registration or login. We do not collect names, email addresses, passwords, or other account credentials. Images you voluntarily submit to generate AI media are processed via our AI pipeline and are not persistently stored with your identity.
When you use the App, we may automatically collect limited technical data, including:
• Device information (device model, operating system version, unique device identifiers such as IDFV)
• App usage statistics (feature interactions, session duration, crash reports)
• General coarse location inferred from IP address (country/region level only)
• IP address for network communication and fraud prevention
This data is collected in aggregated or pseudonymous form and is used solely to maintain and improve the App.
Reference images you submit to generate content are transmitted to our proprietary AI processing servers. We do not associate this content with any personally identifiable information. Generated outputs are delivered to your device and are not stored on our servers beyond the time required for processing, unless you explicitly save or share content through in-app features.
All AI processing is performed by our own in-house trained models on our own cloud infrastructure. Your photos and generated content are NOT sent to any third-party AI service provider.
When you submit a photo containing a human face, our AI model may process facial features (such as facial structure, skin tone, expression, and general appearance) solely for the purpose of generating AI-transformed images and videos. The following applies to all face data processing:
• Collection: The App processes facial features contained in user-submitted photos. No biometric identifiers, facial recognition templates, or faceprint data are created, extracted, or stored at any time.
• Purpose: Face data is used exclusively for AI image and video generation — to transform your submitted photo into stylized artwork or animated video. Face data is never used for facial recognition, identity verification, user profiling, advertising, or any other purpose.
• Third-Party Sharing: Face data is NOT shared with any third parties. All processing is performed by our proprietary AI models on our own servers.
• Storage and Retention: Face data is temporarily held in server memory only during the active AI processing session, typically lasting a few seconds to under one minute. Once the generated result is delivered to your device, the original submitted photo and all intermediate processing data (including any facial feature data) are automatically and permanently deleted from our servers. No face data is persistently stored.
• User Consent: Before your first use of AI generation features, the App will display a clear disclosure explaining that your selected photo (which may contain face data) will be sent to our servers for processing. You must provide explicit consent before any data is transmitted. You may withdraw consent at any time by discontinuing use of the App.
We may use third-party analytics providers (such as Firebase Analytics or similar services) to collect aggregated usage data and crash diagnostics. These providers may collect device identifiers in accordance with their own privacy policies. We encourage you to review the privacy policies of any third-party analytics services used in the App.
We do not collect or access the Apple Advertising Identifier (IDFA). We do not track you across apps or websites owned by other companies. If we ever need to access the IDFA in the future, we will request your explicit permission through Apple’s App Tracking Transparency (ATT) framework before doing so.
We use the information described above for the following purposes:
• Operating, maintaining, and improving the App and its AI features
• Processing user-submitted photos (including those containing faces) through our AI models to generate images and videos
• Diagnosing technical problems and preventing fraud or abuse
• Analyzing aggregate usage trends to guide product development
• Complying with legal obligations and enforcing our Terms of Service
• Sending optional push notifications if you have granted permission (you may opt out at any time in device settings)
We do not use your data for targeted advertising, and we do not sell your personal information to third parties.
We do not sell, rent, or trade your personal information. We do not share user-submitted photos, face data, or AI-generated content with any third parties. All AI processing is performed on our own infrastructure.
We may share limited non-personal data only in the following circumstances:
• Service Providers: Trusted third-party vendors who assist in operating the App (e.g., cloud hosting, analytics), subject to confidentiality agreements. These providers do NOT have access to your submitted photos or face data. These providers will protect your data in a manner consistent with this Privacy Policy.
• Legal Compliance: When required by law, court order, or governmental authority, or to protect the rights, property, or safety of our company, our users, or the public.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, provided the successor entity continues to honor this Privacy Policy.
We retain automatically collected technical data only for as long as necessary to fulfill the purposes described in this policy, or as required by applicable law.
User-submitted photos (including those containing face data) and AI-generated outputs are processed in real time and are NOT persistently stored on our servers. All image data and intermediate processing data are automatically deleted immediately upon delivery of the generated result to your device.
You may request deletion of any personal data we hold about you by contacting us at Spark_Connect@outlook.com. Upon receiving a verified deletion request, we will delete your data within 30 days, except where retention is required by law. You may also delete the App from your device at any time, which will remove all locally stored data.
Before your first use of AI generation features, the App displays a clear disclosure screen informing you:
• What data is sent: Your selected photo (which may contain facial features) will be transmitted to our servers for AI processing.
• Who processes the data: All processing is performed by our own proprietary AI models on our own secure cloud servers. No data is sent to any third-party AI service.
• Your choice: You must tap "I Agree" to proceed. If you decline, no data is transmitted and no AI processing occurs.
You may withdraw consent at any time by discontinuing use of the App's AI generation features.
Effigy is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information promptly. If you are a parent or guardian and believe your child has submitted personal information through the App, please contact us at Spark_Connect@outlook.com.
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to Delete: Request deletion of personal information we have collected about you.
• Right to Opt-Out: Opt out of the sale or sharing of your personal information. Note: we do not sell or share your personal information.
• Right to Non-Discrimination: Exercise your rights without receiving discriminatory treatment.
To exercise any of these rights, please contact us at Spark_Connect@outlook.com. We will respond within 45 days as required by law.
The App does not collect, capture, or otherwise obtain biometric identifiers or biometric information as defined under the Illinois Biometric Information Privacy Act (BIPA). No facial recognition templates, faceprints, or other biometric data are created or stored. The facial features processed during AI generation are used solely for content transformation and are immediately deleted after processing.
Regardless of your location, you may request access to, correction of, or deletion of any personal information we hold about you by contacting us at Spark_Connect@outlook.com. We will honor such requests to the extent required by applicable law.
Effigy respects your privacy choices. We do not track you across apps and websites owned by other companies. In accordance with Apple’s App Tracking Transparency (ATT) policy, we will always request your explicit consent before engaging in any form of tracking. You can change your tracking preferences at any time in your device’s Settings > Privacy & Security > Tracking.
We implement industry-standard technical and organizational measures to protect information against unauthorized access, alteration, disclosure, or destruction. All data transmissions between your device and our servers are encrypted using TLS/SSL. However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.
The App may integrate third-party SDKs (such as Firebase Analytics) or link to external websites. These third-party services do NOT receive your submitted photos or face data. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party services you access through the App.
If you use the App from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries. By using the App, you consent to such transfers in accordance with this Privacy Policy.
We may update this Privacy Policy from time to time. When we make material changes, we will update the Effective Date at the top of this policy and, where appropriate, provide notice within the App. Your continued use of the App after any changes constitutes acceptance of the updated policy.
If you have questions, concerns, or requests regarding this Privacy Policy, please contact us at:
Email: Spark_Connect@outlook.com
We will respond to your inquiry within a reasonable time.