Privacy Policy

Privacy Policy

Last Updated: March 20, 2026

Xleum Software Limited (“Company”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, process, store, disclose, and protect information when you use our mobile application and related services (the “App” or “Service”).

By accessing or using the App, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the App.

1. Scope of This Policy

This Privacy Policy applies only to information collected through the App and related communications with us.

It does not apply to information collected offline or through third-party websites, applications, or services that are not operated by us.

2. Third-Party Processing and Data Use

This section explains how user-selected media is processed when using AI generation and editing features.

(a) The App uses artificial intelligence technologies, including machine learning and neural network-based systems, to generate videos, animate portraits, transform visual styles, and provide other AI-powered media creation and editing features.

(b) We may use third-party cloud providers and service providers, including providers such as Amazon Web Services, Google Cloud Platform, or similar infrastructure and processing vendors, to process and transform the media you choose to upload or capture through the App.

(c) Only the photos, videos, or other media that you specifically choose to upload, capture, or submit for AI generation or editing are transmitted for processing. The App does not automatically upload your entire camera roll, photo library, or media collection.

(d) Your uploaded or captured media is used solely to provide the AI generation, editing, rendering, and related Service features that you request.

(e) We do not use your uploaded media, face-related content, or generated outputs for advertising, profiling, identity recognition, or unrelated secondary purposes. We do not use such content to train separate AI models for unrelated purposes unless we separately obtain your consent where required by applicable law.

(f) Media submitted for processing may be temporarily stored on secure servers or cloud infrastructure operated by us or our service providers solely for the purpose of completing the requested processing, delivering the output, maintaining service integrity, preventing abuse, and complying with legal obligations.

3. Information We Collect

We may collect the following categories of information:

3.1 Information Collected Automatically

When you use the App, certain technical information may be collected automatically, including:

(a) device type, operating system, app version, language settings, and time zone;

(b) device identifiers and app instance identifiers, including anonymized or pseudonymized identifiers where applicable;

(c) usage information, such as feature interactions, session events, crash logs, diagnostics, and performance data;

(d) general location information, such as country or region inferred from your device, IP address, or settings.

We use this information to operate, maintain, secure, troubleshoot, analyze, and improve the App.

3.2 Information You Provide Voluntarily

You may choose to provide information when using the App, including:

(a) contact information, such as your email address when contacting customer support;

(b) optional account or profile information, if account features are made available;

(c) content, prompts, photos, videos, audio, or other materials that you upload, capture, create, or submit through the App;

(d) any communications, feedback, or support requests you send to us.

4. Face Data Policy

This section describes our practices regarding face-related content contained in user-selected media and any temporary facial-region analysis used to provide certain features.

4.1 Face-Related Content We Process

If you choose to upload or capture a photo or video containing a person’s face, the App may temporarily process the facial content visible in that user-selected media solely to provide the feature you request.

We do not collect or store biometric identifiers such as facial recognition templates, biometric face embeddings used for identification, facial geometry used for identity matching, or Face ID data.

To the extent facial landmarks, contours, or similar facial-region information are technically processed during generation or editing, such processing is temporary, used only to provide the requested output, and not used to identify any individual.

4.2 How We Use Face-Related Content

Face-related content is used only to provide user-requested features within the App, such as AI video generation, portrait animation, visual transformation, media enhancement, and similar editing or generation features initiated by you.

We do not use face-related content for facial recognition, identity verification, authentication, profiling, advertising, personalized marketing, tracking, or any unrelated secondary purpose.

4.3 Sharing and Storage of Face-Related Content

If off-device processing is necessary to provide the requested feature, user-selected media containing facial content may be securely transmitted to our servers and to trusted cloud or processing service providers acting solely on our behalf.

Such providers may process this information only for the limited purpose of providing the requested Service to us and may not use it for their own independent purposes.

Face-related content may be temporarily stored in secure cloud infrastructure or processing environments operated by us or our service providers solely as needed to complete processing, deliver requested results, protect the security and integrity of the Service, prevent abuse, and comply with legal obligations.

We do not sell face data or share face-related content with advertisers, data brokers, or unrelated third parties.

4.4 Retention of Face-Related Content

Face-related content is retained only for as long as necessary to complete the requested processing and deliver the generated result.

Unless a longer retention period is required by law or is temporarily necessary for security, fraud prevention, abuse prevention, dispute resolution, or technical delivery, face-related content is automatically deleted after processing is completed or within a limited retention period consistent with the purpose for which it was processed.

5. How We Use Information

We may use collected information to:

(a) provide, operate, process, maintain, and improve the App and its features;

(b) create, render, deliver, and store user-requested outputs and content;

(c) respond to inquiries, feedback, and customer support requests;

(d) analyze usage, troubleshoot problems, and improve functionality and user experience;

(e) maintain safety, integrity, and security, detect abuse or fraud, and enforce our terms and policies;

(f) comply with legal obligations and protect our rights, users, and the public.

We do not use personal information for unrelated purposes without your consent, except as permitted or required by law.

6. Sharing of Information

We do not sell your personal information.

We may share information only in limited circumstances, including:

(a) with vendors, cloud providers, infrastructure providers, analytics providers, payment processors, customer support providers, or other service providers who perform services on our behalf and are bound by contractual or legal restrictions;

(b) to comply with applicable law, regulation, legal process, or lawful governmental request;

(c) to protect the rights, safety, security, and integrity of users, the App, our company, or the public;

(d) in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction;

(e) with your direction or consent.

Where face-related content is involved, sharing is limited to what is necessary to provide the requested functionality and is subject to appropriate safeguards.

7. Data Retention

We retain personal information only for as long as reasonably necessary to:

(a) provide, maintain, and support the Service;

(b) complete requested transactions and deliver requested outputs;

(c) maintain security, prevent abuse, and investigate violations;

(d) comply with legal obligations;

(e) resolve disputes and enforce agreements.

Uploaded media, generated content, and related processing data may be retained for different periods depending on the purpose for which they were processed, the technical requirements of the Service, and legal obligations.

Where feasible, we delete or de-identify information when it is no longer needed for the purposes described in this Privacy Policy.

8. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect your information from unauthorized access, use, alteration, disclosure, or destruction.

However, no method of electronic transmission, storage, or processing is completely secure, and we cannot guarantee absolute security.

9. Your Rights and Choices

Depending on your jurisdiction, you may have rights regarding your personal information, including the right to:

(a) access the personal information we hold about you;

(b) request correction of inaccurate information;

(c) request deletion of your personal information;

(d) withdraw consent, where processing is based on consent;

(e) object to or request restriction of certain processing, where permitted by law.

You may exercise these rights by contacting us using the contact details below. We may request information necessary to verify your identity before responding.

10. Children’s Privacy

The App is not directed to children under 13 years of age, or under the minimum age required by applicable law in the relevant jurisdiction.

We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete such information promptly.

11. International Data Transfers

Your information may be processed and stored in countries other than the country in which you live. These countries may have data protection laws that differ from those in your jurisdiction.

Where required by applicable law, we take appropriate steps to provide adequate safeguards for cross-border transfers of personal information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we will provide notice through the App, on our website, or by other appropriate means, as required by law. Your continued use of the App after the updated Privacy Policy becomes effective means that you acknowledge and accept the updated Policy.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: feedback@xleumsoftware.com

Website: www.xleumsoftware.com