Privacy Policy
Data categories, lawful bases, retention, transfers, and your rights.
Introduction
AIFACECRAFT (“we,” “our,” or “us”) is operated by XUSLABS LTD and is committed to protecting your privacy. This Privacy Policy is a legally binding agreement that explains how we collect, use, disclose, retain, and safeguard your information when you use our AI-powered image generation platform and related services (the "Service").
By accessing or using the Service, you confirm that you have read, understood, and agree to be bound by this Privacy Policy and our Terms of Service. If you do not agree, you must not access or use the Service. We may update this policy from time to time; your continued use after changes constitutes acceptance of the revised policy where permitted by law.
Who We Are and Scope
Controller: XUSLABS LTD (Company No. 16706799), England and Wales. Registered with the UK Information Commissioner's Office (ICO); registration reference ZB986561. This policy covers account, authentication, uploads, generation, billing, support, safety, and abuse-handling flows.
Privacy / legal: legal@aifacecraft.com
Support: support@aifacecraft.com
Abuse: abuse-report@aifacecraft.com
Information We Collect
Account and Identity
- Name, email address, username, and password (stored in hashed form)
- Profile information and preferences you provide
- Communication records and support correspondence
Payment Information
Payment processing is handled by third-party providers (e.g. Stripe). We do not store full payment card numbers on our servers. We may retain billing identifiers, subscription status, and transaction history necessary to provide the Service and comply with legal obligations.
Content You Provide and We Generate
- Text prompts, descriptions, and reference images you upload
- AI-generated images and other outputs created through the Service
- Style preferences, settings, and generation history
Technical and Usage Data
- Device type, browser, and operating system
- IP address, approximate location, and log data
- Usage analytics (e.g. feature use, session duration) to operate and improve the Service
- Campaign tags on the link you used to reach our website (utm_source, utm_medium, utm_campaign and utm_content, for example the name of the ad you clicked), recorded with your account when you sign up. We carry them in the page address only; nothing is stored on your device for this.
- Cookies and similar technologies as described in the Cookies section below
Job Applications
If you apply for a role, we receive the name, email address, portfolio and social links and message you send us, together with the IP address and browser details of the submission. We use them only to assess your application and delete them 6 months after you apply.
What You Have to Give Us, and What Happens If You Do Not
Some data is a contractual requirement: without it the Service cannot do the thing you are asking it to do. The rest is optional, and saying no costs you nothing.
- Your email address and password (or Google sign-in). Required to create an account. Without an account you cannot use the Service.
- A photograph, when the feature needs one. Required for any feature that works from your likeness. We cannot generate a portrait from a photograph you have not given us; if you do not upload one, those features will not run. Text-only features do not need a photograph.
- Payment details, if you buy. Required to take payment; handled by our payment processor, not stored by us. Without them you stay on the free allowance.
- Everything else is optional — display name, profile picture, social links, marketing email, non-essential cookies. Declining them does not limit generation.
How We Use Your Information
Service Provision
- Generate the images and videos you ask for from your prompts and photographs
- Where our video provider requires it, check automatically whether a reference image shows a person before it is used in a video; the image is sent to that provider once for this check
- Process payments and manage subscriptions
- Provide customer support and technical assistance
- Maintain platform reliability, security, and performance
We do not use your uploaded images or generated outputs to train AI models.
Service Improvement and AI
- To deliver, maintain, and improve the Service and AI systems
- Quality assurance, safety, and content moderation (including to prevent illegal or harmful use)
- We may use aggregated, anonymized, or de-identified data that cannot reasonably identify you for analytics, research, and product improvement.
- No training by us: We do not use your uploaded images, prompts, or generated outputs to train any AI model. The AI providers that process them for us do so under their business terms: Google (Vertex AI and the Gemini API), OpenAI and BytePlus do not use this content to train their models; fal.ai's terms allow it to use anonymised or aggregated usage data, which may be derived from what is submitted, to develop its services and AI models. Higgsfield, which we use only as a backup for video generation when our primary video provider is at capacity or cannot accept a request, receives that content under its standard terms, which allow it to use the content and the resulting video to train and improve its models.
Communication and Marketing
- Send service updates and notifications
- Respond to inquiries and support requests
- Provide personalized recommendations
- Marketing communications (with your consent)
How We Collect and Lawful Bases
We collect data directly from you (signup, uploads, support), automatically (logs, telemetry, security), and from processors (payments/auth). Every processing activity below names the lawful basis it runs on, so you can see which one applies where.
- Contract (Art. 6(1)(b)). Creating and operating your account; receiving your uploaded photograph and prompt and producing the image or video you asked for; storing your outputs so you can return to them; taking payment and managing your subscription and credits; answering support requests about your account or a generation.
- Legitimate interests (Art. 6(1)(f)). Five, each with the interest stated:
- Keeping the Service secure and available — rate limiting, bot protection, error monitoring and operational logs. The interest is running a service that is not taken down or degraded by attack or fault.
- Preventing misuse of a face-generation product — reviewing reports, investigating abuse (non-consensual imagery, impersonation, child safety) and enforcing our rules. The interest is protecting people whose likeness could be misused, including people who are not our users.
- Defending legal claims — retaining the minimum record needed to answer a dispute, chargeback or regulatory question. The interest is being able to evidence what happened.
- Keeping promotions fair — comparing the IP address and browser details recorded when accounts are created to detect self-referral and duplicate accounts in Refer & Earn. The interest is making sure referral rewards go to genuine invitations. A match alone does not decide anything: a person reviews a held reward before it is cancelled.
- Knowing which campaigns bring sign-ups — recording, with your account, the campaign tags of the link you arrived from. The interest is spending our advertising budget on campaigns that actually bring people who sign up. We see these tags per campaign, not to profile you, and they are deleted with your account. You can object at any time and we will remove them from your account. Separately, to see how our website is used and improve it, our host Vercel counts page views without cookies; switching off analytics in Cookie settings turns this off (see the Cookie Policy).
- Legal obligation (Art. 6(1)(c)). Keeping billing and tax records for the statutory period, and responding to lawful requests from authorities.
- Consent (Art. 6(1)(a)). Non-essential cookies, marketing email, and any optional feature that asks you first. You can withdraw consent at any time, and withdrawing it does not affect processing that already happened.
AI-Generated Content and Intellectual Property
Your Responsibility
You are solely responsible for the prompts, reference images, and any other content you submit, and for how you use any AI-generated outputs. You must ensure that your inputs and your use of outputs do not infringe any third-party rights (including copyright, trademark, publicity, or privacy) and comply with all applicable laws. We do not guarantee that any output is non-infringing, accurate, or suitable for any particular use.
Legal Status of AI Outputs
The legal status of AI-generated content (including copyright and ownership) varies by jurisdiction and is evolving. We do not represent or warrant that outputs are protectable or that you will acquire any particular rights in them. You use outputs at your own risk.
- We do not claim ownership of content you create using the Service. You retain rights in your own inputs to the extent you have them.
- You grant us a limited, worldwide, non-exclusive license to use, store, process, and display your content only as necessary to provide, secure, and improve the Service and to comply with law.
- We may retain and use anonymized or aggregated data derived from usage as described in this policy.
Data Security
We implement reasonable technical and organizational measures designed to protect your personal data against unauthorized access, loss, or alteration, including encryption in transit, access controls, and secure infrastructure. No method of transmission or storage is 100% secure; we cannot guarantee absolute security and are not liable for unauthorized access that occurs despite our reasonable efforts.
- Encryption for sensitive data in transit and at rest where appropriate
- Access controls, authentication, and need-to-know access to personal data
- Incident response and, where required by law, breach notification procedures
- We may use subprocessors (e.g. cloud and AI providers); we require them to protect data consistent with this policy and applicable law
Data Sharing and Disclosure
We do not sell your personal information. We may share data only as follows:
- Service providers and subprocessors: Payment processors (e.g. Stripe), cloud hosting, AI/ML infrastructure, analytics, and support tools, under contracts that require appropriate protection of data
- Merchant of record: for purchases sold through Link (Sold through Link, LLC, a Stripe affiliate), Stripe and Link also use your payment, order and billing details for their own purposes, including order management, customer support, tax collection and fraud prevention, under their own privacy policies
- Advertising measurement (only with marketing consent): If you accept marketing cookies and arrived from one of our ads, we tell that ad platform (currently Google Ads) that its click led to a sign-up or purchase, using the click identifier from the ad link, the type of action, and for purchases the amount, currency and a hashed order reference. We do not send your name, email address, prompts, images or payment details, and ad personalisation is switched off. You can withdraw this consent at any time from Cookie settings.
- The person who invited you: If you join with an invite, the person who invited you sees your first name, the first letter of your last name, and whether your account has triggered a referral reward (for example, that you made your first creation, or subscribed and to which plan). They do not see your creations, uploads or payment details.
- Legal obligation and rights: When required by law, court order, or government request, or when we reasonably believe disclosure is necessary to protect our rights, your safety, or the safety of others, or to detect fraud or security issues
- Business transfers: In connection with a merger, sale of assets, or acquisition, subject to the same privacy commitments
- With your consent: Where you have given explicit consent for a specific disclosure
- Anonymized or aggregated data: Data that cannot reasonably identify you may be used or shared for analytics, research, and product improvement
Data Retention
We retain your data only as long as necessary to provide the Service, comply with legal obligations (e.g. tax, dispute resolution), resolve disputes, and enforce our agreements. Account and profile data are retained until you delete your account or request deletion, subject to lawful retention requirements. Generated content and logs may be retained for a limited period for service operation and security; after that they may be deleted or anonymized. You may request deletion of your personal data as described under Your Rights; we will honor such requests where required by law.
- Uploaded source photographs: 30 days after that photograph was last used. The clock is per photograph, not per account: a photograph you never use again is deleted 30 days after upload, and an account that goes quiet loses its photographs on the same schedule. A scheduled job performs the deletion daily. If you registered a photograph or an output with our video provider for a video, the provider's copy is deleted shortly after the photograph or output itself. Content sent to our backup video provider, Higgsfield, is kept and deleted under Higgsfield's own terms. Higgsfield stores the files it receives at unguessable links on its content delivery network that do not require a login, and its service gives us no way to delete them on your behalf.
- Generated outputs: until you delete them. They stay private to your account and you can delete any of them at any time.
- Operational logs are retained proportionally for fraud, security, and legal defence.
- Consent, request and case records. Cookie choices: 2 years. Your acceptance of our terms and your upload confirmations: while your account exists, and afterwards until 6 years from when they were recorded. Privacy requests: 2 years after they are closed. Abuse reports: 3 years after they are closed; reports passed to the authorities are kept for as long as the law or the investigation requires. The IP address and device details in these records are removed 90 days after a case is closed.
- Notifications: 180 days. Prompt text and file links attached to background generation jobs are cleared 30 days after the job ends, and video recovery records are deleted 30 days after they end. Your saved outputs are not affected.
- Job applications: 6 months after you apply.
- If you delete your account, it happens immediately. Your photographs, the images you generated and the account itself are deleted at once and cannot be restored. Copies held by our video provider are deleted shortly afterwards by an automatic job; content that was sent to our backup video provider, Higgsfield, is kept and deleted under Higgsfield's own terms. If you were on our waitlist, within a day your waitlist entry is reduced to your email address and invitation status; we keep that only so a founding-member credit cannot be paid twice, and it is deleted with the rest of the waitlist, at the latest on 22 March 2027. Copies inside encrypted backups are overwritten within 30 days. We keep a record that the deletion took place for 6 years; the IP address and device details in it are removed after 90 days.
- Payment records are the exception, and we have to keep them. If you have paid us, we keep the record of that payment — date, amount and what was bought. UK company and tax law requires accounting records to be kept for six years, so this record is processed under a legal obligation and is outside the scope of a deletion request (UK GDPR Article 17(3)(b)). It does not contain your photographs, your prompts or the images you generated.
- Deletion requests sent by email are actioned within one month, as described under Your Rights.
Deletion requests are processed within legal/operational timelines; immediate deletion from active backups, immutable logs, or legal-hold archives may not be technically possible.
Your Rights and Choices
Depending on your location, you may have the right to access, correct, delete, restrict, object to certain processing, or receive a portable copy of your personal data. We will respond to verifiable requests within the timeframes required by applicable law (e.g. within 30 days where required). We may retain certain data where retention is required or permitted by law (e.g. legal hold, fraud prevention, or enforcement of our Terms).
- Access and portability: Request a copy or export of your personal data
- Correction: Update or correct inaccurate data via account settings or by contacting us
- Deletion: Request deletion of your account and associated personal data, subject to lawful exceptions
- Restriction and objection: In certain jurisdictions you may restrict or object to specific processing; we will honor such rights where required
- Withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing
To exercise rights (access, deletion, correction, objection, portability), contact details below. You may also lodge a complaint with the UK ICO at ico.org.uk.
We may decline, limit, or charge a reasonable administrative fee for manifestly unfounded, excessive, or repetitive requests where permitted by law.
Deletion, DSAR, and Abuse Operations
You can request account and data deletion through support channels. Some records may be retained for legal, fraud, abuse, and dispute-defense requirements. Backups may take additional time to cycle out.
- DSAR requests are logged and may require identity verification before sensitive disclosure or portability actions are fulfilled
- Abuse evidence may be retained longer for trust and safety enforcement
- Payment/accounting records can be retained per statutory obligations
Cookies and Tracking
We use cookies and similar technologies for operation, security, and improvement of the Service:
- Strictly necessary: Required for authentication, security, and core functionality
- Performance: Analytics and usage to improve the Service
- Functional: To remember preferences and settings
- Marketing: Only where you have given consent, where required by law
You can control cookies via your browser settings. Disabling certain cookies may affect Service functionality.
Children's Privacy
The Service is not directed at and is not intended for use by anyone under the age of 18.
- We do not knowingly collect personal data from anyone under 18. There is no age band below 18 at which this Service may be used, with or without parental consent.
- When you create an account you confirm that you are 18 or over. We record that confirmation with a timestamp. This is a declaration, not an identity check.
- If we learn that we have collected personal data from anyone under 18, we will delete the account and the data promptly.
- If you believe a child has provided personal data to us, contact legal@aifacecraft.com immediately.
International Data Transfers
Some of our providers process your data outside the United Kingdom: in the United States (for example fal.ai, OpenAI, Higgsfield, Google Analytics, Google Ads, and Vercel, which operates its platform mainly from the United States), in Japan (Supabase, where our database is stored, and Vercel, a US company whose servers running our application are in Tokyo; your requests first reach the Vercel edge location nearest to you), in Southeast Asia (BytePlus), and, for some of Google's AI services, in locations Google selects. For each provider, our Sub-processor and Transfer Appendix names where the data is processed and the safeguard we rely on: UK adequacy regulations, including the UK Extension to the EU–US Data Privacy Framework for certified US companies such as Google (for Google Analytics and Google Ads); or standard contractual clauses with the UK International Data Transfer Addendum. Higgsfield, our backup video provider, receives content as an independent controller under its standard terms and applies the transfer safeguards described in its own privacy policy.
You can ask for a copy of the safeguard that covers any provider by writing to legal@aifacecraft.com.
See our public Sub-processor and Transfer Appendix for the current provider matrix and transfer safeguards.
Where legally valid requests are received from courts, regulators, or competent authorities, we may disclose relevant data and preserve records as required by law.
Regional Supplements and Conflict Rules
If mandatory local privacy law grants you stronger rights than this policy text, those mandatory rights prevail for that specific jurisdiction and scope. Otherwise, this policy and our Terms govern.
Enterprise customers may have separate signed DPA/contract controls. Where those signed controls conflict with this public policy for enterprise scope, the signed agreement prevails.
Marketing and B2B Contexts
Promotional messaging uses opt-in/consent rules where required. Enterprise/B2B arrangements may include separate privacy terms and data processing agreements.
Related legal policies: Terms, Acceptable Use, Refund, Cookie Policy, Data Retention Summary.
California Privacy Rights (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) provides you with specific rights regarding your personal information.
We Do Not Sell or Share Your Personal Information
We do not sell personal information. We do not share personal information for cross-context behavioral advertising purposes. With your marketing consent, we disclose limited information to Google solely to measure the performance of our own ads, with ad personalisation switched off; Google may not use it to target ads to you. We have not sold or shared personal information in the preceding twelve (12) months.
Your California Rights
- Right to know: You may request disclosure of the categories and specific pieces of personal information collected, the sources, business purposes, and categories of third parties with whom we share.
- Right to delete: You may request deletion of personal information we collected, subject to exceptions (legal obligations, security, completing transactions).
- Right to correct: You may request correction of inaccurate personal information.
- Right to opt-out of sale/sharing: Not applicable as we do not sell or share PI.
- Right to limit use of sensitive PI: We use sensitive PI only for service provision as permitted under CCPA.
- Non-discrimination: We will not discriminate against you for exercising your CCPA rights.
Authorized Agents
You may designate an authorized agent to make requests on your behalf. We may require verification of the agent's authority (e.g. a signed written authorization or power of attorney) before processing the request.
California Civil Code Section 1798.83 (“Shine the Light”): We do not disclose personal information to third parties for their direct marketing purposes.
Automated Decision-Making and Profiling
We may use automated systems for content moderation, safety scoring, fraud detection, and abuse prevention. These systems process technical signals and behavioral patterns to protect platform integrity.
- Automated moderation may flag, restrict, or remove content that appears to violate our policies.
- We do not make solely automated decisions that produce legal effects or similarly significant effects on individuals without appropriate safeguards (including human review where required by applicable law).
- Where EU/UK GDPR Article 22 applies, you have the right to request human intervention, express your point of view, and contest decisions.
Governing Law and Disputes
This Privacy Policy and any disputes arising out of or relating to it or the processing of your personal data shall be governed by the laws of England and Wales, without regard to conflict of law principles. The courts of England and Wales shall have exclusive jurisdiction, except where prohibited by mandatory consumer protection law in your country of residence. Nothing in this policy affects your statutory rights as a consumer.
Contact Us
For questions about this Privacy Policy, to exercise your privacy rights, or to report a concern, contact:
Privacy / Data requests: legal@aifacecraft.com
Support: support@aifacecraft.com
Abuse: abuse-report@aifacecraft.com
Operator: AIFACECRAFT
Company: XUSLABS LTD (No. 16706799)
Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
We will respond to verifiable requests in accordance with applicable law.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. For material changes we will provide notice by email (where we have it), a prominent notice on the Service, and/or an updated effective date below. Where required by law (e.g. GDPR), we may seek your consent to material changes. Your continued use of the Service after the effective date of changes constitutes acceptance of the updated policy to the extent permitted by law.
Version history
- 2026-10-v8 — 2026-10-18. Sign-up campaign measurement: a fifth legitimate interest, “Knowing which campaigns bring sign-ups”. When you sign up we record the campaign tags (utm_source, utm_medium, utm_campaign, utm_content) of the link you arrived from with your account. They travel in the page address only, nothing is stored on your device, and during Google or Apple sign-in they are held for up to 15 minutes in our short-lived sign-in record (Upstash, see the Sub-processor Appendix). Our host Vercel also counts page views, without cookies or storage on your device, to see how our website is used; switching off analytics in Cookie settings turns this off. Vercel's entry in the Sub-processor Appendix and the Cookie Policy describe what it receives.
- 2026-10-v7 — 16 October 2026. Refer & Earn: a fourth legitimate interest, “Keeping promotions fair” (comparing the IP address and browser details already recorded at sign-up to detect self-referral; no new data is collected), and what the person who invited you can see. The Terms of Service add a Refer & Earn section.
- 2026-10-v6 — 12 October 2026. Advertising measurement: with marketing consent, Google Ads learns that a click on one of our ads led to a sign-up or purchase (click identifier, action, amount, currency, hashed order reference), with ad personalisation switched off. Google Ads is added to the Sub-processor Appendix and to the international transfers section; purchases are also reported to Google Analytics from our server. The Cookie Policy lists the new cookies. This falls within the marketing cookie purpose you could already accept or refuse (campaign attribution and conversion tracking), now narrower: no retargeting.
- 2026-10-v5 — 11 October 2026. No change to this Privacy Policy. The Terms of Service add a section on included image benefits (Unlimited and Free Gen).
- 3 October 2026 — update without a new version. The servers that run our application (Vercel) moved from the United States to Japan, next to our database. What we collect, why, and the transfer safeguard are unchanged. The International Data Transfers section now also names the UK Extension to the EU–US Data Privacy Framework. Vercel's entry in the Sub-processor Appendix now names the safeguard set out in Vercel's data processing addendum.
- 2026-09-v4 — 26 September 2026. Higgsfield is added as a backup provider for video generation, used only when our primary video provider is at capacity or cannot accept a request. What its terms allow (use of what it receives to improve its models), where it stores files and why we cannot delete them are stated under training, international transfers and Data Retention.
- 2026-09-v3 — 24 September 2026. The Sub-processor Appendix now lists every provider that processes your data, including BytePlus (ByteDance group), Google's Gemini API and Google Analytics. International transfers are described provider by provider. The no-training commitment is stated for us and for each AI provider. Copies held by our video provider are covered in Data Retention.
- September 2026 — corrections published without a change of date. ICO registration number corrected; minimum age stated as 18; the no-training commitment made unconditional; the lawful basis stated for each processing activity; what you have to give us, and what happens if you do not, added; uploaded photographs deleted 30 days after they were last used; account deletion made immediate; OpenAI added to the Sub-processor Appendix.
- 2026-05-v2 — 25 May 2026. Previous version.
Applicable Law
We process personal data in accordance with applicable privacy and data protection laws, including where relevant:
- UK GDPR / Data Protection Act 2018 (United Kingdom)
- EU GDPR (European Economic Area)
- CCPA/CPRA (California, USA)
- Other federal, state, or regional laws that apply to our processing
Last updated: 2026-10-18
Effective date: 2026-10-18
This Privacy Policy is binding as of the effective date above. It applies to the AIFACECRAFT Service operated by XUSLABS LTD. For terms of use, refunds, and other legal terms, see our Terms of Service.