1) Summary (Key Points)
- What we do: We help you transform photos by changing hairstyles and hair colors.
- What you control: You choose whether to create an account, grant location access, and upload content for generation.
- AI/photo processing: If you upload content for generation, we process it on Twila Team servers to generate your result. We do not share that uploaded content with any third party (including service providers and third-party AI model providers), and we delete it immediately after processing completes.
- No sale of personal information: We do not sell personal information.
2) Information We Collect
We collect information you provide, information collected automatically, and information collected with permissions you choose to grant.
- Account: name, username, email.
- User-provided: customer support content; optional photos/text submitted for generation.
- Automatically collected: device information, usage statistics, crash logs/diagnostics.
- Location (optional): precise or approximate location if you allow it.
3) How We Use Information
- Provide and maintain the Services.
- Personalize your experience and remember preferences.
- Improve performance, reliability, and features.
- Security and fraud prevention.
- Customer support.
- Legal compliance.
4) AI / Photo Transformation Processing
Twila offers photo transformation features that may involve automated processing ("AI features"). When you choose to use these features:
- Processing location: your uploaded photo and any text you provide are processed on servers controlled by Twila Team to generate the requested result.
- No third-party sharing for generation: we do not share uploads or prompts used for generation with any third party (including service providers and third-party AI model providers), except where required by law.
- No face recognition / biometrics: we do not perform facial recognition and do not create biometric templates.
- No training or marketing: we do not use your uploads for model training or marketing.
- Deletion after processing: we delete uploaded content immediately after processing completes, subject to limited temporary caching needed for reliability and security.
- Local storage by default: generated images may be stored locally on your device by default.
5) Cookies, Similar Technologies, and Web Beacons
If parts of the Services are provided through web-based components (e.g., in-app web views), we may use cookies or similar technologies to keep you signed in, remember preferences, and measure performance. These technologies may include web beacons.
6) How We Share Information
- With your consent.
- With service providers/processors who help us operate, support, secure, or improve the App, under contractual confidentiality and use restrictions.
- For legal reasons and to protect rights and safety.
We share only what is necessary for the specific purpose, and we do not sell personal information.
7) Data Retention
8) Security & 9) International Data Transfers
- Security: encryption in transit and, where appropriate, at rest; access controls; periodic reviews/audits; backups and recovery procedures.
- Cross-border transfers: where required, we use safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms.
10) Your Rights and Choices
Depending on your location and applicable law, you may have rights to access, correct, delete, restrict, object, or withdraw consent. To submit a request, email:
tristanposts33@outlook.com
We aim to respond within 5 business days.
11) Children & 12) Changes
The App is not directed to children under 17 and we do not knowingly collect personal information from children under 17. We may update this policy from time to time and will update the Effective Date above when changes become effective.