Privacy Policy

Effective Date: February 17, 2026 Last Updated: February 17, 2026

1. Introduction

Toon Tech Ltd (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your information when you use our mobile applications, including Umax AI, Jawmax, and related services. By using our services, you consent to the practices described in this policy.

2. Data Controller Information

Company Name: Toon Tech Ltd

Registered Address: 128 City Road, London, United Kingdom, EC1V 2NX

Email: support@toontech.uk

3. Information We Collect

We collect only the minimum data necessary to provide our AI-based facial analysis:

Biometric Data: When you upload a selfie, our software analyzes your "face geometry" to provide aesthetic ratings. Under the GDPR, this is Special Category Data. Under US state laws (like BIPA), this is Biometric Information.

Images: We process the photos you upload.

Technical Data: IP address, device type, and operating system for security and fraud prevention.

4. Legal Basis for Processing (GDPR)

Explicit Consent (Art. 9(2)(a) GDPR): For the processing of biometric data/facial geometry.

Contractual Necessity (Art. 6(1)(b) GDPR): To deliver the analysis and results you request.

5. Third-Party AI Processors & International Transfers

To provide high-quality analysis, your encrypted image is transmitted to our AI partners: Google LLC (Gemini AI) and OpenAI, LLC. Safeguards: Your data is transferred to the United States under Standard Contractual Clauses (SCCs). Our partners are contractually prohibited from using your data to train their models.

6. Data Retention & Destruction

Selfies: Your uploaded photo is processed in memory and deleted immediately after the result is generated.

Biometric Identifiers: We do not store permanent "faceprints." In all cases, any transient data is destroyed within 24 hours.

7. Regional Disclosures

UK & EU: You have the right to lodge a complaint with the ICO (UK) or the CNIL (France).

USA (BIPA / CCPA): This serves as your Written Release and Retention Schedule. We do not sell or trade biometric information.

8. Your Rights and Data Deletion

You have the right to access, rectify, or erase your personal data at any time.

How to Delete Your Data:

In-App Deletion: You can exercise your right to be forgotten instantly by navigating to the Profile Page within the app and clicking the "Delete User" button. This action will notify our systems to purge your records.

Manual Request: Alternatively, you may email us at support@toontech.uk. Please include your User ID in the email so we can manually process your deletion request.

9. Children’s Privacy

Our services are intended for users aged 18+. We do not knowingly collect data from children under 13.