Privacy Policy

1. Introduction

Welcome to Otter Ridge Software, LLC. This Privacy Policy describes how Otter Ridge Software, LLC ("we," "us," or "our") collects, uses, and discloses information when you use our mobile applications ("Apps") and websites ("Websites") (collectively, "Services"). By using our Services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

We collect various types of information in connection with the Services, including:

• Email Addresses: We collect your email address when you register for an account, subscribe to our newsletters, or contact us for support.
• Payment Information: When you make purchases through our Services, payment information (such as credit card details) is collected and processed by secure third-party payment processors. We do not directly store sensitive payment information on our servers.
• App-Specific Data: Certain apps may collect additional data necessary for their core features, such as photos, demographic information, or other user-provided content. The specific data collection practices for these apps are detailed in Section 5.

3. How We Use Your Information

We use the information we collect for various purposes, including:

• To provide, operate, and maintain our Services.
• To process your transactions and manage your orders.
• To send you transactional emails (e.g., purchase confirmations, password resets).
• To send you marketing communications (with your consent, where required).
• To provide customer support and respond to your inquiries.
• To monitor and analyze usage and trends to improve our Services.
• To evaluate the inclusivity and diversity of our user base through aggregate, anonymized analytics in order to improve our products.
• To detect, prevent, and address technical issues or fraudulent activities.

We want to be clear: We will NEVER sell your personal data to third parties.

4. How We Share Your Information

We may share your information with third parties in the following circumstances:

• Payment Processors: We use third-party payment processors to handle transactions. These include, but may not be limited to, Apple App Store Payments, Google Play Store Payments, RevenueCat, and Stripe. These processors collect and process your payment information directly.
• Analytics Providers: We use analytics services to understand how our Services are used and to improve them. This includes Firebase Analytics and Plausible Analytics (a privacy-focused web analytics solution).
• AI Service Providers: Certain apps share user-provided data with third-party AI processing providers to deliver core app features, such as AI-generated images. The specific providers, data shared, and data handling practices for each app are described in Section 5.
• Cloud Storage Providers: We use Firebase Storage (provided by Google) to securely store user-generated content such as images. Access to stored data is protected by authentication and access controls.
• Email Marketing Services: We may use third-party email marketing services to send marketing and transactional emails.
• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Third-Party Artificial Intelligence (AI) Services & Face Data

Certain apps in our portfolio use third-party artificial intelligence (AI) services to provide core functionality, such as AI-generated images or AI-assisted features. This section describes how each app collects, uses, and handles data transmitted to third-party AI providers. We will never sell your personal data to third parties. Any data shared with third-party AI services is used solely for the purpose of delivering the requested feature and is not used for advertising, profiling, or any unrelated purpose unless otherwise specified below. We ensure that any third-party AI service we work with provides data protection standards equal to or exceeding our own.

The following subsections describe the specific AI data practices for each applicable app.

5.1 Prim — AI Headshot Generation

What Data We Collect:

Prim collects photos containing your face ("face data") that you voluntarily submit for the purpose of generating AI headshots. In addition, Prim collects your self-reported gender and ethnicity. No face data or demographic information is collected automatically — all data is provided by you through explicit action within the app.

How We Use Your Data:

Your face data, along with your self-reported gender and ethnicity, is used to generate AI headshots that accurately reflect your appearance. Gender and ethnicity information is also used in aggregate, anonymized analytics to help us evaluate the inclusivity and diversity of our user base and improve our product accordingly. Face data is not used for advertising, user profiling, or any purpose unrelated to headshot generation and product improvement.

Third-Party Sharing:

To generate AI headshots, your face data is transmitted securely to our third-party AI processing provider, Replicate, Inc. A personalized AI model is created on Replicate's platform using your submitted photos. Your self-reported gender and ethnicity are used in the generation prompt but are not stored by Replicate as personal data. We do not sell, trade, or share your face data with any other third parties.

Data Storage & Retention:

Generated headshots are stored securely in our cloud storage infrastructure (Firebase Storage), protected by authentication and access controls that ensure only you can access your data.

On Replicate's platform, prediction data — including input photos submitted for generation and generated output files — is automatically deleted within one hour of processing. This brief retention window exists solely to complete the image generation request. Replicate does not retain prediction data beyond this one-hour window and does not use your face data for any other purpose, including model training, analytics, or advertising.

Your personalized AI model is stored on Replicate's platform for a maximum of 90 days of inactivity. This model is retained so that you can generate additional headshots over time without incurring the cost and processing time of retraining a new model. If you do not use your model within 90 days, it will be automatically deleted from Replicate's platform. Any use of your model (such as generating a new headshot) resets this 90-day period. You may also delete your face model data at any time from within the app; when you do, we immediately delete the corresponding model from Replicate's platform. Replicate does not independently retain your AI model after we have deleted it.

Generated headshots stored in Firebase Storage are retained for a maximum of 90 days of inactivity. If you do not access or download your headshots within 90 days, they will be automatically deleted. Any interaction with your headshots (such as viewing or downloading them) resets this 90-day period. You may also delete your generated headshots at any time from within the app.

Your Choices:

You may decline to submit face data at any time by simply not using the headshot generation feature. All face data collection requires your explicit action and consent. You may delete your face model data and generated headshots at any time from within the app. If you do not actively use your personalized AI model, it will be automatically deleted after 90 days of inactivity. Similarly, generated headshots will be automatically deleted after 90 days of inactivity.

6. Data Retention

We retain personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies. Retention periods for specific data types may vary and are described in the relevant sections of this policy (see Section 5 for app-specific retention details). For general account information such as email addresses, we retain this data for the duration of your account's existence or until you request its deletion.

7. Cookies and Tracking Technologies

Our websites use Plausible Analytics, a privacy-focused analytics solution that does not use cookies or collect personal data. Our mobile apps use Firebase Analytics, which may collect device-level identifiers and usage data to help us understand how our apps are used and to improve them. Firebase Analytics does not use traditional tracking cookies in our mobile apps, but may associate usage data with a device or app instance identifier. We do not use tracking technologies for advertising or personalization purposes. For more information on how Firebase handles data, please refer to Google's privacy documentation. If our practices change in the future, we will update this Privacy Policy accordingly.

8. Children's Privacy

Our Services are not intended for individuals under the age of 18 or the legal age of majority in their jurisdiction. We do not knowingly collect personally identifiable information from children under these ages. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

9. International Data Transfers

As our target audience is global, your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

10. Your Choices and Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data, including:

• The right to access, update, or delete the information we have on you.
• The right to object to our processing of your personal data.
• The right to request that we restrict the processing of your personal data.
• The right to data portability.
• The right to withdraw consent at any time where we rely on your consent to process your personal information.

To exercise any of these rights, please contact us using the details provided below.

11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.