Privacy Policy
Effective date: October 6, 2026 · Version 1.1
1. Who we are
Evemi (the "Service") — the iOS app, our website and the web app — is published and operated by Mobilio Jivisata UAB, a private limited company registered in the Republic of Lithuania (company code [company code], registered office [registered address]) ("we", "us", "our").
We are the controller of the personal data described in this policy within the meaning of the EU General Data Protection Regulation (GDPR). You can contact us about privacy at [privacy email].
2. Scope
This policy applies to everyone who uses the Service on any device. It doesn't apply to third-party services you reach from the Service (for example Apple's App Store or Stripe's checkout pages), which have their own policies.
3. Data we collect
Data you provide
- Photos you upload to create an image, and any text you enter in the Create feature (your "idea").
- Email address, if you sign in with an email link or with Google. With Google sign-in we also receive your name and profile picture from Google; we use only the email to identify your account.
- Messages you send us when you contact support.
Data created when you use the Service
- Account identifier. On first use an anonymous account with a random identifier is created, so the Service can keep your gallery and limits.
- Generated images and their details: the style, format, creation time and, for Create, the text you entered.
- Usage counters: how many photos you have created, free trial photos used, photos remaining in your plan, extra photos purchased.
- Purchase records: which plan or photo pack you bought, its status, renewal and expiry dates, and identifiers of the transaction. Payments are processed by Apple or Stripe; we never receive your full card number.
- Trial counter: on iPhone, a random device identifier stored in the device's Keychain; on the web, your verified email. It is used only to count free trial photos so that they aren't granted again after reinstalling the app or creating a new account. It contains no other information about you.
- Usage and diagnostics (iOS app): which screens and styles you open, when you create, save or share a photo, view the purchase screen or buy something, crash reports and app performance, together with a random app-instance identifier. This never includes your photos or the text you enter.
- Advertising attribution (iOS app): when you installed the app and whether you came from an ad, plus, only if you allow it in the iOS "Allow Tracking" prompt, your device's advertising identifier (IDFA).
- Technical and security data: app integrity attestations (Apple App Attest on iPhone, Google reCAPTCHA Enterprise on the web), IP address, device and browser type, app version and server logs needed to run, secure and debug the Service.
We don't collect your precise location, contacts or other photos from your library. When you choose photos, iOS gives the app only the photos you select. Saving a result to your library needs only permission to add photos.
4. Purposes and legal bases
| Purpose | Data | Legal basis (GDPR Art. 6) |
|---|---|---|
| Creating the images you request and showing them in your gallery | Uploaded photos, text, generated images, account id | Performance of our contract with you (6(1)(b)) |
| Providing your plan, free trial, limits and purchases | Account id, email, usage counters, purchase records, trial counter | Contract (6(1)(b)) |
| Signing you in and syncing across devices | Email, account id | Contract (6(1)(b)) |
| Preventing fraud and abuse (e.g. repeated free trials, automated access) and keeping the Service secure | Trial counter, integrity attestations, technical data | Legitimate interests (6(1)(f)) in protecting the Service and paying customers |
| Understanding how the Service is used, fixing crashes and improving features | Usage and diagnostics | Legitimate interests (6(1)(f)) in a reliable, useful Service |
| Measuring which of our ad campaigns bring new users | Advertising attribution; the advertising identifier only with your permission | Legitimate interests (6(1)(f)); consent (6(1)(a)) for the advertising identifier, which you can withdraw in iOS Settings → Privacy & Security → Tracking |
| Support and service messages | Email, messages | Contract (6(1)(b)); legitimate interests (6(1)(f)) |
| Accounting, tax and legal obligations | Purchase records | Legal obligation (6(1)(c)) |
| Establishing or defending legal claims | Relevant records | Legitimate interests (6(1)(f)) |
We don't show ads in the Service, don't sell your data and don't use your photos or texts for advertising. With your permission we measure the performance of our own ads as described above. We don't make decisions about you based solely on automated processing that have legal or similarly significant effects.
5. Your photos and AI processing
- Your uploaded photos are sent over an encrypted connection to our servers and, from there, to our AI provider to generate the image you asked for. We don't store uploaded photos on our servers; they exist only while your request is processed.
- On iPhone a copy of the photos you chose stays on your device so you can compare before and after and reuse them. On the web they're kept only in your browser for the current session.
- We don't use your photos or results to train AI models, and we don't use facial recognition to identify you or anyone else. Images of faces are processed only to produce the picture you requested.
- Generated images are stored in your private gallery and are visible only to you. Images are AI-generated and may be marked as such where required by law.
- Upload photos of other people only with their permission.
6. Service providers
We share personal data only with providers who process it on our behalf under data processing agreements, or who act as independent controllers for their own services:
- Google Ireland Limited / Google LLC — Firebase (authentication, database, file storage, hosting, Remote Config), Google Cloud (servers, logs), Gemini API (image generation) and reCAPTCHA Enterprise (bot protection on the web). Under Google's terms for the paid Gemini API, your prompts and photos are not used to improve Google's products.
- Google also provides Google Analytics for Firebase and Firebase Crashlytics (usage statistics and crash reports from the iOS app).
- AppsFlyer Ltd. (Israel; EU adequacy decision) — install and advertising attribution for the iOS app.
- Apple Inc. / Apple Distribution International Ltd. — App Store purchases and subscriptions, and App Attest. Apple acts as an independent controller for App Store payments.
- Stripe Payments Europe, Ltd. — payments on the web. Stripe acts as an independent controller for payment data.
We may also disclose data where required by law, to protect rights and safety, or to a successor if our business is reorganised or sold, in which case this policy continues to apply.
7. International transfers
Our database is hosted in the European Union. Generated images, server processing and AI generation take place in the United States. Transfers outside the European Economic Area rely on the EU–US Data Privacy Framework where the recipient is certified, and on the European Commission's Standard Contractual Clauses with additional safeguards otherwise. You can request a copy of the relevant safeguards by contacting us.
8. Retention
- Uploaded photos: not retained on our servers after processing.
- Generated images: until you delete them or your account, and at most 365 days after creation.
- Account, usage and purchase data: while your account exists; purchase records are kept for as long as accounting and tax law requires (in Lithuania generally up to 10 years).
- Trial counter: kept after account deletion only as a counter, so a new account on the same device or email doesn't receive a new free trial. It contains no other information.
- Usage statistics and attribution data: up to 14 months; crash reports up to 90 days.
- Server logs: up to 30 days, longer only when needed to investigate a security incident.
9. Your rights
Under the GDPR you have the right to access your data, have it corrected, have it erased, restrict or object to its processing, receive it in a portable format, and withdraw consent where processing is based on consent. Most of this you can do in the app:
- delete individual photos in My Photos;
- delete your account and its data in Profile → Delete account (this doesn't cancel a subscription — manage it in your Apple ID settings or from your Stripe receipt);
- for anything else, write to [privacy email]. We'll answer within one month.
You also have the right to lodge a complaint with a supervisory authority, in particular in the EU country where you live. In Lithuania this is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, vdai.lrv.lt).
10. Cookies and device storage
The website and web app don't use advertising or analytics cookies; they use only storage that is strictly necessary for the Service: keeping you signed in, remembering your trial counter and preferences, caching the app for faster loading, and Google reCAPTCHA, which helps protect the Service from abuse. The iOS app stores similar data on your device and uses the analytics, crash reporting and attribution tools described above. It asks for your permission before accessing the advertising identifier; you can change your choice at any time in iOS Settings.
11. Security
Data is encrypted in transit and at rest. Access to the database and files is restricted to your own account by security rules, only our servers can change your limits and purchases, and requests are verified with app integrity checks. No system is perfectly secure; if a breach affects you, we'll notify you and the authorities as required by law.
12. Children
The Service is not directed to children. You must be at least 16 years old (or the age of digital consent in your country, if higher) to use it, and at least 18 or have a parent's permission to make purchases. If you believe a child has given us personal data, contact us and we'll delete it.
13. US state privacy notice
If you live in California or another US state with a consumer privacy law: we collect the categories of data in section 3 for the purposes in section 4; we don't sell or "share" personal information as those laws define it, and we don't use sensitive personal information for purposes other than providing the Service. You may request to know, correct or delete your data and won't be discriminated against for doing so. Contact us using the details below.
14. Changes
We may update this policy. We'll post the new version here with a new effective date and, for material changes, tell you in the app or by email before they take effect.
15. Contact
Mobilio Jivisata UAB
[registered address], Lithuania
Company code: [company code]
Email: [privacy email]