Privacy Policy

Effective Date: November 1, 2024

Welcome to InkFusion, an AI-driven application that allows you to generate and virtually try on tattoo designs by either using in-app suggestions or creating custom designs based on your own textual input (collectively, “InkFusion”, “App”).

We are committed to safeguarding your privacy and will collect and process your personal information only with your consent, as specified in this Privacy Notice and in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and any other relevant regulations.

This Privacy Notice outlines how Oleg Barabash, the developer of InkFusion, collects, uses, and shares your personal data, and provides information about your privacy rights.

1. Scope

This Privacy Policy applies to personal data handled through our InkFusion app, our website at [insert your website URL] (the “Site”), and any other associated online or offline services. For ease, we refer to these collectively as our “Services.”

2. Updates to Our Privacy Policy

We reserve the right to amend this Privacy Policy as we see fit. Should any significant changes occur, we will notify you in line with relevant legal requirements, with updates taking effect as of the date mentioned in the notice. By using our Services following these updates, you acknowledge and accept the revised Privacy Policy. We recommend that you review this Privacy Policy periodically to stay informed of any changes.

3. Personal Information We Collect

The categories of personal data we gather depend on your interactions with InkFusion, our Services, and relevant legal requirements. We collect information that you provide directly, data automatically gathered when you engage with our Services, and data from other sources, such as third-party platforms and services, as detailed below.

3.1 Information You Provide to Us Directly

  1. Photos. We may process photos that you upload from your device to try on tattoo sketches. To upload content, we need access to your device’s camera. Importantly, we do not collect or store biometric data (e.g., facial geometry, physiological, or behavioral characteristics) from these photos, nor do we use face recognition or similar biometric identification technologies.

  2. Biometric Data. With your explicit consent, we may process certain biometric data, including facial features and other markers, to enable precise placement of tattoos on uploaded images. This may involve analyzing facial structure to ensure the design fits the contours of your face or body. You can revoke this consent at any time via the in-app support options or by contacting us directly.

  3. Generated Content. We process the images you create within the app, including overlays of tattoo sketches on your photos.

  4. Usage Data. We collect information about your usage of our Services, such as the tattoo designs you view, pages you visit, links you click, and overall interaction details. Additionally, we collect IP addresses, device data, browser information, network connectivity, and geolocation data to enhance user experience and service efficiency.

  5. Interactive Features. Any personal information submitted through public interactive features (such as content shared on social media or forums) is considered “public” and is not subject to the same privacy protections.

  6. Purchases. For any paid features, we may collect information related to your purchases, including payment details, through third-party payment processors. We do not store payment information directly but may receive billing details to complete transactions.

  7. Communications with Us. We may collect contact details such as email and phone number when you inquire about our Services, request support, or subscribe to our newsletter.

  8. Surveys. Should you participate in our surveys, you may be asked to provide certain personal information.

3.2 Information Collected Automatically

  1. Automatic Data Collection. We automatically collect details such as IP address, device identifiers, location data, and metadata associated with your activities on the Services. We also gather information on your interactions, including links clicked and pages visited before, during, and after using our Services.

  2. Analytics. To better understand user behavior, we use third-party analytics tools, including Amplitude, to gather anonymized and aggregated data. This data helps us improve user experience while safeguarding individual identities.

3.3 Information Collected from Other Sources

We may obtain data about you from other sources, such as third-party platforms, app stores, login services, or social networking sites, based on your privacy settings within these platforms.

4. How We Use Your Information

We use your personal data for various business-related purposes, which include delivering our Services, managing administrative tasks, and promoting our offerings, as described below.

If InkFusion intends to change the purposes of processing as specified, we will inform you of such changes and seek separate consent if required by applicable law.


4.1 Provide Our Services

We use your information to fulfill our contract with you and deliver our Services, which includes:

  • Enabling you to try on tattoo sketches;

  • Managing your personal data;

  • Granting access to certain areas, functionalities, and features of our Services;

  • Addressing customer support and technical inquiries;

  • Communicating with you regarding your activities on our platform and any updates to our policies; and

  • Processing your payment information and handling transactions for purchased products or Services.


4.2 Administrative Purposes

We may also use your data for various administrative purposes, including:

  • Pursuing our legitimate interests, such as direct marketing, research and development (including marketing research), information security, and fraud prevention;

  • Detecting and addressing security incidents, protecting against malicious or fraudulent activity, and prosecuting offenders;

  • Measuring interest and engagement levels in our Services;

  • Providing short-term, transient uses, such as ad customization;

  • Enhancing and developing new products and features;

  • Maintaining quality control and ensuring internal security;

  • Authenticating and verifying individual identities;

  • Debugging to identify and resolve errors;

  • Auditing to ensure compliance with interactions and transactions; and

  • Enforcing our agreements and policies, as well as fulfilling legal obligations.


4.3 Marketing and Advertising Our Products and Services

We may use personal information to personalize content and advertisements, providing these materials as permitted by law.

We may market to you through email campaigns, targeted advertising, and “interest-based” or “personalized” advertising, including through cross-device tracking.

If you have questions regarding our marketing practices or wish to opt out of your data being used for marketing, you can contact us with “Do Not Share My Personal Information for Cross-Context Behavioral Advertising” as the subject line.


4.4 Other Purposes

We may also use your data for other purposes, as permitted by law or requested by you:

  • Consent-Based Use. With your consent, we may use your personal information for other purposes explicitly disclosed at the time of collection or as otherwise permitted by law.

  • De-identified and Aggregated Data. We may use your personal information to create de-identified or aggregated data, such as anonymous demographic information, location data, and device information, for analytical purposes.

  • Sharing with Friends or Colleagues. Our Services may include functionalities that allow you to share content with others. For example, you may share certain content with a friend or colleague through our referral services, such as sending an invitation to try our Services.

5. How We Disclose Your Information

We share your personal information with third parties for various purposes, including to deliver our Services, safeguard rights and safety, and facilitate significant business events, like mergers, sales, or asset transfers. Here’s a breakdown of these disclosures:

We do not share your biometric data, including photos and face embeddings, except through Google services for secure data storage. You may review Google’s data handling policies through the provided link.

Only authorized affiliates and a select group of employees may access biometric data strictly to operate the app, improve user experience, and provide customer support.


5.1 Disclosures to Deliver Our Services

We may share your information with the following types of third parties:

  • Third Parties. When using the Services, you may choose to share your personal information or content with third parties through in-app features.

  • Service Providers. We may share personal information with third-party providers who assist in delivering our Services. This includes providers for IT support, hosting, payment processing, analytics, customer support, and similar services.

  • Business Partners. We may share personal information with business partners when providing products or services you’ve requested, or with whom we jointly offer products and services.

  • Advertising Partners. We may share certain personal information, excluding biometric data, with third-party advertising partners. These partners may set cookies or tracking tools to collect data (e.g., IP address, pages visited, location, etc.) and deliver personalized ads. This practice is known as “interest-based advertising” or “personalized advertising.”

  • APIs/SDKs. Our Services may integrate third-party APIs (Application Program Interfaces) and SDKs (Software Development Kits) to enable certain features. For more information about these integrations, please contact us as outlined in Section 17 (“Contact Us”).


5.2 Disclosures to Safeguard Rights and Compliance

In cases where we, in good faith, believe it necessary, we may disclose your information to:

  • Comply with legal and national security requests, including court orders and subpoenas;

  • Protect the rights, property, or safety of you, others, or ourselves;

  • Enforce our policies or agreements;

  • Collect amounts owed to us; or

  • Assist with investigations or legal actions involving suspected or actual unlawful activities.

6. Your Privacy Choices

Your options regarding the management of your personal information are shaped by applicable laws, as outlined below.

Device Settings. We may send push notifications through the App. You can opt out of receiving these notifications by adjusting your device settings. With your permission, we may also collect precise, location-based information via the App, which you can disable through your device’s location settings.

“Do Not Track” (DNT). DNT is a privacy setting available on some web browsers. Please note that our Services do not respond to or honor DNT signals or similar browser-based privacy mechanisms.

Cookies and Interest-Based Advertising. You may control the use of cookies and other tracking technologies by changing your device or browser settings. Adjusting these settings may impact your experience with our Services, and some features may not function correctly if these Technologies are disabled.

  • Mobile Applications. To opt out of personalized ads on mobile applications, follow the instructions provided by your device’s operating system, such as Android or iOS. Please note that cookie-based opt-outs are not effective on mobile applications.

  • Industry Websites. The online advertising industry provides additional tools to help you manage preferences for targeted ads. You can opt out of receiving personalized ads from participating organizations by visiting sites such as the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA), the European Digital Advertising Alliance (EDAA), and the Digital Advertising Alliance of Canada (DAAC).

Note: You must adjust these privacy settings separately for each browser and device to ensure that your choices are consistently applied across all platforms.

7. Your Privacy Rights

As required by law, you may have the following rights regarding your personal information:

  • Access Your Data: You may request access to personal data we hold about you, allowing you to review this data and confirm it is being processed lawfully.

  • Correct Your Data: You may request the correction of any incomplete or inaccurate personal data that we hold about you. We may need to verify the new information you provide to ensure its accuracy.

  • Request Data Deletion: You may ask us to delete or remove your personal data where there is no valid reason for us to retain it. You may also request deletion if you object to processing (see below), if your data was processed unlawfully, or if we are required to comply with local laws. In certain cases, we may be unable to fulfill your deletion request, but if so, we will notify you at the time.

  • Object to Processing: You may object to our processing of your personal data if it impacts your fundamental rights and freedoms, particularly if we are using it for our legitimate interests or for direct marketing purposes. In specific cases, we may demonstrate that we have compelling grounds for processing that override your rights and freedoms.

  • Limit Automated Decisions: You have the right not to be subject to decisions based solely on automated processing, including profiling, where such decisions have legal or similarly significant effects. We currently do not use automated decision-making and profiling.

  • Restrict Processing: You may ask us to suspend processing your personal data in certain situations, such as:

    • If you want us to confirm the data’s accuracy.

    • If our data use is unlawful but you don’t want us to delete it.

    • If you need us to retain the data to establish, exercise, or defend legal claims.

    • If you’ve objected to our data use but we need to verify overriding legitimate grounds.

  • Data Portability: You may request to transfer your personal data to you or a third party. We will provide your data in a structured, commonly used, machine-readable format. This right applies only to data provided with your consent or used to perform a contract.

  • File a Complaint: If you believe our processing of your data violates applicable laws, you may lodge a complaint with a relevant supervisory authority.

  • Compensation for Damages: If you’ve suffered material or non-material harm due to any violation of data protection laws by entities or individuals processing your data, you may be entitled to compensation.

  • Withdraw Consent: Where processing relies on your consent, you can withdraw it at any time. This will not impact the legality of any processing conducted before your withdrawal. However, if you withdraw consent, we may no longer be able to provide certain services or features. We will inform you if this is the case.

How to Exercise Your Privacy Rights

To exercise these rights, please contact us as outlined in Section 17 (Contact Us). We will handle requests in line with legal requirements and provide an update within one month. If needed, we may extend this response time by up to two additional months, especially if requests are numerous or complex. We will inform you of any delay within one month of receiving your request and provide clear reasons for the extension.

8. Security of Your Information

We prioritize the security of your information and apply organizational and technical safeguards to protect it from unauthorized access, disclosure, use, and alteration. These security measures are regularly reviewed and updated to help keep your data secure. However, despite our best efforts, no system can be entirely secure, and we cannot guarantee the absolute security of the information you share with us. To the maximum extent allowed by law, we accept no liability for unauthorized access or disclosure.

By using our Services or sharing your information with us, you agree to receive electronic communications from us regarding security, privacy, and administrative matters. In the event of a security breach, we may attempt to notify you via electronic means, such as posting on our Services, or through other communication channels, such as mail or email, as appropriate.

9. International Data Transfers

Your data may be stored and processed outside of the European Economic Area (EEA), such as by our affiliated companies or third-party service providers located in regions including but not limited to Ukraine and the USA, where data protection laws may differ from those within the EEA.

For users within the EEA, we ensure that data transfers to third countries outside the EEA are carried out with appropriate safeguards. These measures include using standard contractual clauses as required by the European Commission and conducting transfer impact assessments to evaluate the receiving country’s data protection laws. Alternatively, such transfers may rely on your explicit consent or other legal frameworks that comply with EEA data protection regulations. By using our Services, you consent to these transfers and processing activities as outlined in this Privacy Notice.

Whenever we share your information with third parties, we take steps to ensure that it is protected and used solely for the purposes described in this Privacy Notice. This protection is ensured by selecting certified service providers, implementing data processing agreements, and establishing technical safeguards to secure your information in storage, use, and transit.

Additionally, InkFusion may disclose personal information as required to comply with legal obligations. For example, we may share information necessary for investigations or legal proceedings in response to official requests by authorized bodies.

10. Retention of Personal Information

We store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Please note that your generated images are not stored on our servers. Instead, they remain on your device and can be deleted manually through the app or by uninstalling the app. If you choose to remove the app, all associated data, including generated images, will be deleted from your device.

Additionally, you may request us to delete any other personal data by contacting us at support@inkfusion.app.

11. Supplemental Privacy Notice for California Residents

This notice applies to California residents and addresses our handling of personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). California residents have rights to understand what types of personal information we collect and whether we have disclosed this information for business purposes within the last twelve (12) months. Below are the general categories of personal information we collect and disclose to third parties:

  1. Identifiers – Shared with service providers, advertising partners, and other users or third parties with whom you interact through the App.

  2. Biometric Data – Shared exclusively with service providers.

  3. Personal information as defined under California Civil Code § 1798.80(e) – Shared with service providers and other users or third parties you engage with.

  4. Commercial Information – Shared with service providers and other users or relevant third parties.

  5. Internet or Other Electronic Network Activity – Shared with service providers, advertising partners, and other users or third parties you interact with.

  6. Geolocation Data – Shared with service providers, advertising partners, and other users or related third parties.

  7. Inferences to Create Consumer Profiles – Shared with service providers, advertising partners, and other users or related third parties.

The sources of personal information and the purposes for which we collect and use it are described in earlier sections of this notice.

Additional Privacy Rights for California Residents

  • “Sales” of Personal Information
    InkFusion does not "sell" personal information as defined by the CCPA and CPRA, nor do we have actual knowledge of any “sales” of personal information for individuals under 16 years of age.

  • Non-Discrimination
    You are entitled to receive non-discriminatory treatment for exercising your privacy rights under the CCPA and CPRA. We will not deny you our services, charge different prices, or alter the quality of services based on your choice to exercise these rights.

  • Authorized Agent
    You, or a person authorized to act on your behalf, may make a verifiable consumer request regarding your personal information. To designate an authorized agent, please reach out to us using the “Contact Us” section below.

  • Verification
    For verification purposes, we may request specific information to confirm your identity when responding to a request related to your data. This could include verifying the email associated with the data we hold about you.

  • Limiting Use of Sensitive Personal Information
    You have the option to request that we limit our use of your sensitive personal information (e.g., financial data, precise geolocation, genetic data) strictly to essential service provisions.

If you are a California resident and wish to exercise any of these rights under the CCPA or CPRA, please contact us as described in Section 17 (Contact Us) below. We will handle your requests in line with all applicable legal requirements.

12. Supplemental Policy for Nevada Residents

Nevada residents have the right to opt out of the sale of certain personal information to third parties for licensing or sale purposes. To exercise this right, please reach out to us as described in Section 17 (Contact Us) below, with the subject line “Nevada Do Not Sell Request.” Be sure to include your name and the email address linked to your account. Currently, we do not engage in the sale of personal information as defined by Nevada Revised Statutes Chapter 603A.

13. Supplemental Policy for Virginia Residents

Under the Virginia Consumer Data Protection Act, residents have specific rights concerning their personal data. You may request to:

  1. Access your personal data.

  2. Correct any inaccuracies in your personal data.

  3. Obtain a copy of your personal data.

  4. Opt out of the processing of your personal data for purposes of:

    • Targeted advertising,

    • The sale of personal data, or

    • Profiling in support of decisions with legal or similarly significant impacts on you.

We would like to note that we do not sell your personal information as defined by the applicable provisions in the Code of Virginia. If you wish to exercise these rights, please contact us using the methods described in Section 17 (Contact Us).

14. Children’s Information

We comply with the requirements of both the GDPR and the U.S. Children’s Online Privacy Protection Act (COPPA) concerning the processing of minors’ personal data. Our Services are not intended for children under sixteen (16) (or a different minimum age as stipulated by local law), and we do not knowingly process children’s personal data. If you discover that your child has provided us with personal information without your consent, please contact us as outlined in Section 14 (Contact Us). If we find that we have unintentionally collected a child’s personal information in violation of applicable regulations, we will take immediate action to delete that information.

15. Third-Party Websites/Applications

Our Services may contain links to third-party websites or applications, and other sites or applications may link to our Services. We do not control or endorse these third-party services. We encourage users to review the privacy policies of each website and application they engage with. We do not take responsibility for the privacy practices or content of any linked websites or applications, and providing personal information to third-party websites or applications is at the user’s own discretion and risk.

16. Supervisory Authority

If you are located within the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data violates applicable law. Each EU member state has its own supervisory authority responsible for data protection matters.

17. Contact Us

We hope this Privacy Notice has clarified how your personal information is managed at InkFusion. InkFusion is committed to safeguarding your personal data. If you have any questions regarding our privacy practices or this Privacy Notice, or if you would like to exercise any of your privacy rights as outlined, please feel free to reach out to us at: email: support@inkfusion.app