Privacy Policy

1. Introduction

This Privacy Policy describes how Tarfion Ltd ("we," "us," or "our") collects, uses, and protects your personal information when you use the Nevli application. Tarfion Ltd, Griva Digeni, 59, Kaimakliotis Building, 5th Floor, 6043 Larnaca, Cyprus, is the controller of personal data that we process. By using the App, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

We collect only the information necessary to provide you with the App's services.

• Account Information: Your account is created when you buy a subscription in the App, without an email address, or when you choose to sign in or sign up in Settings (with Sign in with Apple, Google sign-in, or an email address and a password); you do not need to sign in to subscribe. We keep your account identifier and authentication tokens, and your email address if you add one in Settings, sign up with email, or Sign in with Apple or Google sign-in shares it with us; your name if Google shares it. Sign in with Apple is available on iPhone and Google sign-in on Android. To link a purchase to your account, the App creates a random purchase key, keeps it in your device's secure storage (the iOS Keychain or Android Keystore) and adds it to your App Store or Google Play purchase; we store it with your account and use it only to sign you back into your account when you restore the purchase. If you forget your password, you can ask the App for a password-reset link: we send it to the email address of your account; the link works once, for one hour.
• Photos and Videos: The photos you choose for a template or for Animate Image. They may contain your face. We also keep the images and videos the App creates for you.
• Purchase Data: Your plan, its status, the credit packs you buy and their App Store or Google Play purchase identifiers (such as the transaction ID, or the Google Play purchase token and order ID), so we can unlock Pro features and add your credits. Payments are handled by Apple or Google Play; we never receive your card details.
• Usage Data: Your credit balance and its history (credits added and spent on each image or video), your time zone (so notifications reach you in the morning) and the ratings and reasons you send us about a result.
• Push Notification Token: If you allow notifications, a device token from Apple (on iPhone) or Google (on Android) and Firebase Cloud Messaging. We use it to tell you that your photo is ready, that your weekly credits have been added, and, while you do not have a subscription, to suggest one effect a day you can try. These suggestions stop once you subscribe.
• Server Logs: When the App connects to our servers, they record technical data such as your IP address, the time of the request and errors, for security and to fix problems.
• App Activity: How you use the App: the screens you open, the templates, plans, packs and buttons you tap, where a creation stopped (for example at the paywall or the consent prompt), the errors shown to you and the result of the on-device photo check (whether a photo passed, or which issue it had; never the photo or its measurements). With it come your device model, operating system, app version, language, time zone and screen size, a random install and session identifier, your account identifier if you have an account, and your IP address and the approximate location (country and city) derived from it. We use it to operate, maintain and improve the App, not for advertising.
• App Settings and Experiments: Some parts of the App (for example, the layout of the subscription screen) are set remotely, and we sometimes compare versions of them with different groups of users. To choose what you see, we use your random install identifier, your account identifier if you have one, your platform, app version, language, country and whether you have a subscription, and the advertising campaign that brought you to the App, if any; we record which version you were shown. This runs on our own servers.
• Install and Campaign Data: When you first open the App, we record the installation with a random device identifier. If you came to the App through one of our ads or web pages, we also record what that link carried: the campaign, ad set and ad (their names and identifiers, such as utm parameters), the ad network's click identifier (such as fbclid or gclid), the identifier of your visit to our web page, and what that page recorded: the Meta browser identifiers (fbp, fbc), your browser's user agent, your country and the page's address. When you create an account on that device, we link the installation to it. We use this to learn which of our campaigns bring people to the App and to measure our advertising, and we share part of it with Meta, as described in "Advertising Networks" below.
• Advertising Attribution (AppsFlyer): The App includes the AppsFlyer SDK, which tells us and the ad networks whether an install came from an ad. It collects your device's IP address, model, operating system, app version, language and the time of the install and first launch. On iPhone, the App asks for your permission to track (the system "Allow 'Nevli' to track your activity" prompt) on first launch; only if you allow it, AppsFlyer also collects your device's advertising identifier (IDFA) and may match your install to the ad you saw on other companies' apps or websites. If you do not allow it, AppsFlyer does not collect your IDFA and attributes your install through Apple's privacy-preserving SKAdNetwork / AdAttributionKit. This choice applies to AppsFlyer only: it does not stop the conversion events our server sends to Meta, described in "Advertising Networks" below. You can change your choice at any time in Settings > Privacy & Security > Tracking. On Android, the App does not collect the advertising ID; AppsFlyer may attribute an install to an ad by probabilistic matching of the IP address, device model and the time of the click and the install.
• Diagnostics: Crash logs and error reports from the App and our servers, for bug fixing, security and App stability. They contain no photos and no email address.

3. How We Process Your Photos with AI

The App uses cloud-based artificial intelligence to create the image or video you ask for.

• Your Consent: A photo leaves your device only after you tap "Allow and continue" in the consent prompt shown before your first generation. Withdraw consent at any time by deleting your account (Settings > Delete my account); no photo is sent without it.
• Purpose: Your photos are processed strictly to create the image or video you requested. This includes generating styled photos and videos from templates and creating animated videos from your images.
• Cloud Processing: We use cloud-based AI services through OpenRouter, which routes requests to model providers such as OpenAI and Meta. Images and videos are transmitted securely via encrypted connections.
• Storage and Retention: We do NOT use your photos to train AI models. Uploaded photos are kept on our servers only for the time of processing and deleted as soon as processing is complete, whether it succeeds or not. The photos you recently picked are remembered on your device only.
• On-Device Photo Check: On iPhone, before a photo can be sent, the App checks on your device using Apple's Vision framework that it shows one clearly visible face, and, where you have turned on Sensitive Content Warning or Communication Safety in your iPhone settings, uses Apple's Sensitive Content Analysis to check that it contains no nudity. This check runs only on your device; its results are not stored or sent anywhere, and a photo that fails it is not sent. On Android, this check is not currently available.
• No Biometric Templates: Apart from the on-device check above, whose results are discarded right away, we do not extract, store or share facial measurements or other biometric identifiers from your photos.
• Sharing: We do not sell or share your photos with third parties for marketing or advertising. When you tap Share or Instagram, the App hands the image or video to the app you pick on your device, such as Instagram, and you decide there whether to post it. The App does not sign in to Instagram, and we do not receive your Instagram account details or any data from Instagram or Meta.

4. Data Sharing

We do not sell your personal data. We share it with service providers who process it on our behalf under strict contract terms, and with the advertising networks described below:

• Cloud AI Providers: OpenRouter and the model providers it routes to (established in the USA, data transmitted under Standard Contractual Clauses).
• Infrastructure: Google Cloud and Google Firebase (hosting, storage, App activity analytics, authentication and push notifications through Firebase Cloud Messaging).
• Crash-Reporting Providers: for App diagnostics and stability.
• Email Delivery Provider: sends the password-reset emails you ask for; it receives your email address, your account identifier and the reset link.
• AppsFlyer Ltd.: mobile attribution, as described in "Advertising Attribution" above.
• Advertising Networks: the ad networks whose ads may have led you to the App (such as Meta, Google and TikTok) receive, through AppsFlyer, the fact of your install and first launch with its attribution data, so we can measure our campaigns. In addition, our server sends Meta conversion events through our marketing-measurement service: the installation of the App, the creation of your account and, if you came to the App through one of our ads or web pages, the subscriptions and credit packs you buy in the App (what you bought, its price and currency). With them go the campaign, ad set and ad your link carried, the ad network's click identifier (such as fbclid), the Meta browser identifiers (fbp, fbc), your country and your browser's user agent, and, if your account has an email address, a one-way hash (SHA-256) of that address, never the address itself. Meta uses them to tell which of our ads bring people to the App and to measure and improve our campaigns. These events are sent whatever you chose in the iPhone tracking prompt ("Allow 'Nevli' to track your activity"): that choice controls only whether AppsFlyer collects your advertising identifier (IDFA). Purchases of people who did not come through one of our ads, and test purchases (Sandbox, TestFlight), are not sent. Meta processes this data under its own terms and privacy policy.
• Apple: payments, Sign in with Apple and delivery of push notifications.
• Google LLC: Google sign-in, Google Play payments and delivery of push notifications on Android.

5. Data Retention

• Uploaded Photos: Only for the time of processing.
• Generated Results: Stored in your account until you delete them individually or delete your account.
• Account Data: Retained as long as your account is active. When you delete your account, your sign-in is removed and your push tokens are erased. Some records may remain where retention is necessary or permitted by law, including records maintained for regulatory or legal compliance, fraud prevention, security, billing and transaction purposes, disputes or legal claims, and technical backup or record-retention requirements. Your email address (if any), account identifier and purchase keys remain in our sign-in records, without any photos or content; write to [email protected] and we will erase them within 30 days.
• Push Notification Token: Until you sign out, delete your account or the token stops being valid.
• Server Logs and Error Reports: Up to 14 months from collection.
• App Activity, Experiments and Install and Campaign Data: For as long as needed for the purposes above, then deleted or anonymised. We may keep aggregated statistics without personal identifiers. AppsFlyer keeps attribution data, and Meta the conversion events we send it, under their own retention policies.
• Password-Reset Emails: A reset link stops working after one hour, once used, or when you ask for a newer one. Our email delivery provider keeps your email address, your account identifier and a record of the emails it sent under its own retention policy; write to [email protected] and we will ask it to erase them.
• Payment Notifications from Apple and Google Play: Kept as a record of payments. They contain no photos and no email address.

6. Your Rights and Deleting Your Nevli Account

You have the right to access, correct, or delete your personal data.

• Delete Your Account in the App: Open Nevli, go to Settings and tap Delete my account. This works the same on iPhone and on Android.
• Delete Your Account Without the App: Write to [email protected] from the email address of your account and ask us to delete it. If your account has no email address, include your account ID (shown at the bottom of Settings in the App) and the store receipt of your subscription. We will respond within 30 days.
• What Is Deleted and What Stays: When you delete your account, your sign-in is removed and your push tokens are erased. Some records may remain where retention is necessary or permitted by law, including records maintained for regulatory or legal compliance, fraud prevention, security, billing and transaction purposes, disputes or legal claims, and technical backup or record-retention requirements. Your email address (if any), account identifier and purchase keys remain in our sign-in records, without any photos or content; write to [email protected] and we will erase them within 30 days. Uploaded photos are kept only for the time of processing. Server logs and error reports are kept up to 14 months from collection, and payment notifications from Apple and Google Play are kept as a record of payments; they contain no photos and no email address. App activity and the install and campaign data are kept as described in Data Retention.
• Delete Some of Your Data and Keep the Account: To delete a single creation, open Creations in Nevli, press and hold the image and tap Delete; the image and its files are erased from our servers right away. To have any other data erased without deleting your account, write to [email protected] from the email address of your account; we will respond within 30 days.
• Your Subscription: Deleting the App or your Nevli account does not cancel a subscription. Cancel it in Settings › Apple ID › Subscriptions on iPhone, or in Google Play › Payments & subscriptions › Subscriptions on Android. See our Subscription Policy for more details.
• Tracking: On iPhone, turn tracking for Nevli on or off at any time in Settings > Privacy & Security > Tracking.
• Contact: To exercise your rights under GDPR or other applicable laws, email us at [email protected]. We will respond within 30 days.

7. Data Security

We implement commercially reasonable technical and organizational measures (including TLS encryption) to protect your personal data. However, no method of transmission over the internet is completely secure.

8. International Data Transfers

Your data may be processed outside your country of residence (e.g., in the USA for AI processing). We take appropriate measures to ensure protection, including the European Commission's Standard Contractual Clauses.

9. Children's Privacy

The App is intended only for adults aged 18 and over. We do not knowingly collect personal data from minors, and photos of children must not be uploaded. If you believe a minor has given us personal data, contact us and we will delete it.

10. Contact Us

Tarfion Ltd

Griva Digeni, 59, Kaimakliotis Building, 5th Floor, 6043 Larnaca, Cyprus

Email: [email protected]