Your Privacy
The short version: Your photos are yours. We collect only what we need to run the App, we never sell your personal data to third parties, and you can delete your account and all associated data at any time.
Contents
Cloud Portrait ("we", "us", "our") is the data controller responsible for your personal data collected through the Cloud Portrait mobile application and website at cloud-portrait.web.app.
For any privacy-related enquiries or to exercise your rights, please contact us through the App's support section. We aim to respond to all requests within 30 days, or within the timeframe required by applicable law.
| Category | Examples | Purpose |
|---|---|---|
| Account data | Name, email address, profile photo, username, bio | Creating and managing your account |
| User content | Photos, album titles, captions, comments, reactions | Providing the core social features of the App |
| Communications | Support messages, feedback, bug reports | Responding to your requests and improving the App |
| Category | Examples | Purpose |
|---|---|---|
| Device & technical data | Device model, OS version, app version, IP address, language settings | Operating and securing the App; fraud prevention |
| Usage data | Features used, screens visited, session duration, crash reports | Improving App performance and user experience |
| Advertising data | Ad interactions, ad identifiers (e.g. Google Advertising ID), approximate location (country/region) | Showing relevant advertisements; measuring ad performance |
Google Sign-In: If you choose to sign in with Google, we receive your name, email address, and profile picture via Google's OAuth 2.0 service. We do not receive your Google password. Your use of Google Sign-In is also governed by Google's Privacy Policy.
Where applicable law requires us to identify a legal basis for processing your personal data, we rely on the following:
| Legal Basis | When We Rely on It |
|---|---|
| Contract | Processing necessary to provide the App and fulfil our Terms of Service (account creation, content hosting, social features) |
| Legitimate interests | Improving the App, preventing fraud and abuse, securing our systems, crash analytics. We balance these interests against your rights and interests. |
| Consent | Personalised advertising (where required by law); optional communications such as newsletters. You may withdraw consent at any time. |
| Legal obligation | Complying with applicable laws, responding to lawful requests from authorities, and retaining records as required by law |
We use the information we collect strictly for the following purposes:
We do not use your personal data for automated individual decision-making or profiling that produces legal or similarly significant effects on you.
You own your photos. We do not claim ownership over any photographs or content you upload. We will never sell, license or use your images for advertising without your explicit consent.
When you upload a photo, we store it securely on our servers in order to display it within the App. We do not perform facial recognition or biometric analysis on your photos.
We access your device's photo library only when you explicitly choose to upload a photo. We do not scan, index or analyse your photo library in the background.
When you delete a photo or album, it is removed from public view immediately. Residual copies may remain in encrypted backup storage for up to 90 days before permanent deletion.
When you delete your entire account, all your content and personal data will be permanently deleted within 90 days, except where retention is required by law.
Cloud Portrait is free to use and is supported by advertising revenue. We display ads served by third-party networks including Google AdMob and other partners listed in our app-ads.txt.
By default, our advertising partners may use your advertising identifier (e.g. Google Advertising ID / GAID) and usage data to serve you ads tailored to your interests. Where required by law (e.g. for EU/EEA users, or users who opt out), we request non-personalised ads only.
We do not share your photos, album content, or personal messages with advertisers.
Cloud Portrait uses Google Firebase (Google LLC, USA) for infrastructure, authentication and storage. Your data may therefore be processed in the United States and other countries outside your country of residence.
For transfers of personal data from the European Economic Area (EEA), United Kingdom or Switzerland, we rely on the EU Standard Contractual Clauses (SCCs) adopted by the European Commission, and/or adequacy decisions where applicable, to ensure your data receives an equivalent level of protection.
For transfers from Brazil, we rely on contractual guarantees equivalent to those required by the LGPD. For information about the safeguards in place, please contact us.
We retain your personal data only for as long as necessary for the purposes described in this Policy, or as required by law.
| Data Type | Retention Period |
|---|---|
| Account data and user content | For the duration your account is active, plus up to 90 days after deletion |
| Photos (deleted individually) | Removed from public view immediately; purged from backups within 90 days |
| Crash and analytics data | Up to 14 months in aggregate, anonymised form |
| Support communications | Up to 3 years from last contact |
| Legal compliance records | As required by applicable law (typically 5–7 years) |
Depending on where you live, you have some or all of the following rights regarding your personal data. We honour these rights for all users regardless of location, to the extent technically feasible.
Access
Request a copy of the personal data we hold about you, including categories and specific pieces of information.
Correction / Rectification
Request that we correct inaccurate or incomplete data. You can update most account data directly in the App settings.
Deletion ("Right to be Forgotten")
Request deletion of your personal data. You can delete your account in App settings; we will complete deletion within 90 days.
Data Portability
Receive a structured, machine-readable copy of your data (photos, account info) to transfer to another service.
Restriction of Processing
Ask us to restrict how we process your data in certain circumstances (e.g. while a dispute is being resolved).
Objection
Object to processing based on our legitimate interests, including the use of your data for direct marketing or analytics.
Withdraw Consent
Where processing is based on consent (e.g. personalised ads), you can withdraw consent at any time without affecting prior processing.
Lodge a Complaint
You have the right to lodge a complaint with your local data protection authority (e.g. supervisory authority in the EU, ANPD in Brazil, ICO in the UK).
To exercise any right, use the account settings in the App or contact us through the support section. We will respond within 30 days (or within the shorter period required by your local law). We will not discriminate against you for exercising your privacy rights.
If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with additional rights.
In the past 12 months we have collected: identifiers (name, email, device ID), internet or network activity (usage data, crash logs), photos and other visual content, and inferences drawn from usage for app improvement. We do not collect sensitive personal information as defined by the CPRA beyond what is required to operate the App.
We do not sell your personal information for money. However, sharing advertising identifiers with ad networks may constitute "sharing" under the CPRA. You have the right to opt out of this sharing. To opt out, adjust your device's advertising settings (Android: Settings → Privacy → Ads → Delete Advertising ID).
To submit a verifiable consumer request, contact us through the App's support section. We will respond within 45 days. You may designate an authorised agent to make a request on your behalf.
If you are located in Brazil, the Lei Geral de Proteção de Dados (LGPD — Law No. 13,709/2018) applies to our processing of your personal data.
In addition to the rights described in Section 10, you have the right to:
Our legal bases for processing under the LGPD include: execution of a contract (Art. 7, V), legitimate interest (Art. 7, IX), compliance with a legal obligation (Art. 7, II), and, where required, your consent (Art. 7, I).
Cloud Portrait is not directed to children under the age of 13 (or the applicable minimum age in your jurisdiction — 16 in certain EU/EEA member states). We do not knowingly collect personal information from children below this age threshold.
If we discover that we have inadvertently collected personal data from a child without verifiable parental consent, we will delete that data promptly.
If you are a parent or guardian and believe your child has created an account or provided personal information to us, please contact us immediately through the App's support section and we will take appropriate action within 5 business days.
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:
No method of transmission over the internet or electronic storage is completely secure. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority within the timeframes required by applicable law (72 hours under GDPR; without undue delay under LGPD).
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. When we make material changes, we will:
Your continued use of the App after the effective date of any changes constitutes your acceptance of the updated Policy, to the extent permitted by law.
For any privacy-related questions, requests to exercise your rights, or concerns about our data practices, please contact us through the support section within the Cloud Portrait App, or visit cloud-portrait.web.app.
We take all privacy concerns seriously and aim to respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority: