bahmeteva.

Privacy Policy

Last updated: December 17, 2025

1. Who we are

This Privacy Policy explains how Ksenia Bakhmeteva, a sole proprietor, processes personal data when you use our website and mobile applications.

Contact: hello@bahmeteva.com

2. What data we collect

2.1 Website (bahmeteva.com)

We do not run behavioral analytics and we do not sell personal data. This website processes only support messages that you send us (name, email, message content, attachments).

2.2 Mobile Applications

When you use our mobile applications available on the Apple App Store:

Photos/Images:

  • You may upload photos for AI portrait generation (core app functionality).
  • We do NOT store your photos.
  • ALL photos and generated portraits are stored exclusively on your device.

Anonymous User Identifier:

  • An anonymous ID is created to manage subscriptions and app features.
  • This ID cannot identify you personally (no name, email, or phone number required).

Purchase Information:

  • Subscription status and token balance to provide app functionality.
  • Purchase history for managing in-app purchases.

Usage Data:

  • Basic app interaction data (e.g., number of generations, feature usage) to enable core functionality like token-based systems.
  • We do not use behavioral analytics for advertising purposes and we do not sell your data.

Analytics Data:

  • We collect anonymous usage data (e.g., app interactions, feature usage, approximate location based on IP address) to improve app performance and user experience.
  • This data is not linked to your identity.
  • Analytics data is used solely for understanding how users interact with the app and improving our services.

3. Legal bases (GDPR/UK GDPR)

• Contract / pre-contract steps — to read and respond to your support requests; to provide app functionality and process purchases.

• Legitimate interests — to operate the website and apps efficiently; to prevent fraud; to analyze app usage and improve our services.

4. How we use data (purposes)

Website:

• Respond to support requests and communicate with you as needed.

Mobile Applications:

  • Process uploaded content (e.g., photos) to provide core app functionality.
  • Manage subscriptions and in-app purchases.
  • Enable app features (e.g., token deduction, feature access).
  • Analyze anonymous usage patterns to improve app performance and user experience.

We do not use your data for targeted advertising or marketing purposes.

5. Retention

Website:

• Support emails: typically up to 24 months, unless law requires longer.

Mobile Applications:

  • Photos/uploaded content: NOT retained - we do not store any photos or generated portraits.
  • User data (subscriptions, token balance): Retained while you actively use the app, or until you request deletion.
  • Analytics data: Retained in anonymized form for up to 24 months for analysis purposes.

6. Payments

Website:

• We do not process payment data on this website.

Mobile Applications:

  • Purchases occur through Apple's App Store.
  • We do not process or have access to your payment information (credit card, billing address, etc.).

7. Cookies

We do not use marketing cookies on this website or in our mobile applications. Our mobile applications use analytics tools to collect anonymous usage data as described in Section 2.2.

8. Sharing & processors

Website:

• We share personal data only as needed with our email/support provider (data processor acting under our instructions).

Mobile Applications:

  • We do NOT share photos or face data with any third parties.
  • Photos are processed to generate AI portraits and are NOT stored.
  • Subscription management is handled through Apple App Store and a subscription service (anonymous IDs only, no photo data shared).
  • Analytics provider (processes anonymous usage data to help us improve the app; data is not linked to user identity).

All service providers are contractually obligated to protect your data.

9. International transfers

Your data may be processed outside Georgia by our service providers (e.g., USA, EU). Where required, we rely on appropriate safeguards (e.g., standard contractual clauses).

10. Your rights

You may have rights to access, rectify, delete, restrict/object, port data, and withdraw consent (where applicable).

To exercise your rights:

11. Security

We use reasonable technical and organizational measures to protect personal data, including encrypted data transmission and secure storage.

12. Children

Our website and mobile applications are not directed to children under 16. We do not knowingly collect personal information from children under 16. If we discover we have inadvertently collected such information, we will delete it promptly.

13. Changes

We may update this Policy from time to time. Continued use after changes means you accept the updated Policy.

14. Contact

Email: hello@bahmeteva.com