Privacy Policy

Last updated: 2026-11-07.2

This document is provided in English. The English version is binding.

Draft for v0.1 — must be reviewed by qualified counsel before launch.

1. Who we are

Game Avatar Studio (operator to be confirmed) (“Game Avatar Studio”, “we”) operates this website. Contact: support@example.com.

2. What we collect

• Account data: name, email and profile picture from the sign-in provider you choose (Google, Discord, X, Facebook or Apple).
• Selfies you upload, and the images we generate from them.
• Biometric identifiers / information: the AI model analyses the geometry of your face in your selfie in order to reproduce your likeness. We treat this as biometric data under laws such as the Illinois Biometric Information Privacy Act (BIPA), Texas CUBI, GDPR Art. 9, Korea PIPA and Japan APPI.
• Consent records: what you agreed to, when, the document version, your country and a salted hash of your IP address.
• Payment data: purchases are sold through Link (Stripe Managed Payments), which acts as merchant of record and is an independent controller of your payment and billing data (name, billing address, email, payment method) under its own privacy policy (link.com/privacy). We receive the purchase amount, status and country, never your card number. You can ask Link to delete your payment data.
• Technical data: IP address (for security and rate limiting), approximate location (country and state/region, derived from your IP by our host, used to apply regional restrictions), browser type, and error logs.
• Product analytics: anonymous funnel events (e.g. “upload”, “purchase”) without cookies, without your selfie or images, and without your name or email. Server-side events use a salted one-way hash instead of your account id.

3. Why we use it (and legal bases)

• To create the images you ask for — your explicit consent (GDPR Art. 6(1)(a) and 9(2)(a); BIPA written release).
• To run your account, credits and purchases — performance of our contract with you.
• To keep the service safe: moderation, abuse prevention, fraud and rate limiting — our legitimate interests and legal obligations.

We never use your selfies, faces or generated images to train AI models, and we never sell or share biometric data.

4. Biometric data retention and destruction policy

This is our written, publicly available retention schedule and destruction guideline (BIPA 740 ILCS 14/15(a)).

• Purpose: the only purpose for which we collect or process facial geometry is to generate the stylised images you request.
• No templates kept: we do not create or store a reusable face template, embedding or faceprint. Facial analysis happens transiently inside the image model while your image is generated.
• Selfie retention: your uploaded selfie is permanently deleted at the latest 24 hours after upload — earlier if you use your free re-roll. An automated job runs every hour to enforce this.
• Generated images are kept for 30 days so you can download them, then deleted automatically. You can ask us to delete them earlier.
• Hard limit: in all cases biometric data is destroyed when the initial purpose has been satisfied or within 3 years of your last interaction with us, whichever comes first.
• Processors: our image-generation provider (fal.ai), moderation provider (OpenAI) and face-count check (which only returns the number and size of faces, with no template stored) process the selfie only to return a result to us, under contracts that forbid training on it.
• Consent records (not biometric data) are retained for 3 years as proof of consent.

5. Age limit and regions

The service is not offered in Illinois, USA, and uploads from Illinois are blocked.

You must be 18 or older to use Game Avatar Studio. We do not knowingly process photos of anyone under 18. If you believe a minor’s photo has been uploaded, report it to abuse@example.com and we will delete it.

6. Sharing

We share data only with processors that run the service: hosting (Vercel), database and storage (Supabase), payments (Stripe / Link as merchant of record), image generation (fal.ai), moderation (OpenAI), rate limiting (Upstash) and your chosen sign-in provider. Some are located outside your country; we rely on standard contractual clauses where required.

7. AI transparency

Every generated image carries a visible “AI-generated” mark and a machine-readable label in its metadata. Do not remove these marks when sharing images.

8. Your rights

Depending on where you live you can access, correct, export or delete your data, withdraw consent at any time (this stops future processing), object, and complain to your data-protection authority. Email support@example.com. We answer within 30 days.

9. Security

Selfies and images are stored in private storage, transferred over TLS and only reachable through short-lived signed links. Location and device metadata (EXIF) are removed from uploads.

10. Changes

We will tell you about material changes before they take effect and ask for consent again where required.