Privacy Policy

1) Eligibility & Accounts

Data Controller: Payless Images Co., Ltd.
Address: Northwest Building 2F, 3-7-1 Sendagaya, Shibuya-ku, Tokyo 151-0051, Japan
Email (all privacy inquiries, support, DPO): support@paylessimages.com
(If required by law, we will appoint and publish our EU/UK representative details in this section.)

2) What this Policy covers

This Policy describes what we collect, why we collect it, how we use it, who we share it with, how long we keep it, your rights, and how to contact us about privacy.

3) Personal data we collect

• Account & profile. Email, username, encrypted password, country/region, and any profile details or preferences you add.
• Content you provide. Images, videos, audio, and text you upload; prompts; captions you generate; file metadata; project names.
• Usage & device data. IP address, device identifiers, OS/browser type, language, in-app actions (feature usage, buttons tapped), timestamps, crash logs, diagnostics.
• Payments & subscriptions. Plan type, transaction amount, timestamps, and limited payment metadata from our payment partners. We do not store full card numbers.
• Communications. Support requests, feedback, surveys, and your marketing preferences.
• Sign-in services (optional). If you choose Apple/Google sign-in, we receive the account identifier and email they provide. You can revoke access in your platform account settings.
  Biometric data. AI Captions processes images/video to generate captions but is not designed to extract or store biometric identifiers (e.g., facial geometry templates). If we add face-specific features later, we will request explicit consent and limit use to that purpose.

4) Purposes and legal bases for processing

• Provide and operate the Services (account creation/login; generate, edit, export captions; cloud sync). Legal basis: contract necessity.
• Payments, billing, and fraud prevention. Legal basis: contract necessity; legal obligations; legitimate interests.
• Support & service communications (responding to requests, service notices, incident updates). Legal basis: legitimate interests/contract necessity.
• Improve safety and performance (analytics, diagnostics, testing, security monitoring, abuse prevention). Legal basis: legitimate interests.
• Marketing & promotions (emails, in-app messages) where permitted. Legal basis: consent (you can withdraw at any time).
• Compliance (tax, accounting, regulatory, and lawful requests). Legal basis: legal obligations/legitimate interests.

5) How we use your content

We process your uploaded content only to provide the Services (e.g., to generate captions and deliver outputs you request). We do not use your content to train third-party “general” AI models. If we integrate with Google Workspace/Drive, we will not use Google data to develop or train generalized AI/ML models. You can delete your projects at any time inside the app (subject to residual backups per Section 7).

6) Sharing your data

We share personal data only as needed to provide and secure the Services:

• Service providers (processors): cloud hosting/CDN, analytics, customer support tools, email/SMS, payment processors, anti-fraud, error monitoring?bound by contract and limited to our instructions.
• Affiliates (intra-group): for internal admin where applicable.
• Legal & safety: to comply with laws, enforce our terms, or protect rights, property, and safety.
• Business changes: if we undergo a merger, acquisition, or asset sale, your data may be transferred in accordance with this Policy.

We do not sell personal information. We do not share personal information for cross-context behavioral advertising without providing any legally required opt-outs.

7) International transfers

Your data may be processed in countries outside your own. Where required, we use appropriate safeguards (e.g., EU Standard Contractual Clauses and UK equivalents) to protect your data during transfers. Copies of key safeguards are available on request (subject to redactions).

8) Retention

We retain personal data only as long as needed for the purposes above, including legal, accounting, and security requirements. If you close your account, we aim to delete or de-identify account-level personal data within 30 days, subject to data we must retain (e.g., transaction records, fraud prevention, backups with limited retention).

9) Security

We use administrative, technical, and physical safeguards designed to help protect personal data (e.g., encryption in transit, access controls, network protections, vulnerability testing). No method is 100% secure; please use a strong password and keep your credentials confidential.

10) Your choices

• Access, correction, deletion, portability, and objection/restriction (where applicable).
• Marketing controls: you can unsubscribe in emails or change in-app settings at any time.
• Permissions: you can revoke camera/microphone/photos permissions in your device settings.
  To exercise rights, email support@paylessimages.com. We may request information to verify your identity.

11) Ads, analytics & tracking

We may use analytics to understand feature performance and improve the app. If we show personalized communications or promotions, we will obtain consent where required and provide in-app controls. You can also adjust device-level ad preferences (e.g., “Limit Ad Tracking” on iOS or “Opt out of Ads Personalization” on Android).

12) Third-party links and integrations

Third-party websites or integrations you access from our Services are governed by their own privacy policies. Please review their policies before providing personal data.

13) Children’s privacy

Our Services are not directed to children under 13 (or the age of digital consent in your jurisdiction, e.g., 16 in parts of the EEA/UK). We do not knowingly collect personal data from such children. If you believe a child has provided data, please contact us so we can delete it.

14) Region-specific disclosures

California (CCPA/CPRA). California residents can request access to and deletion of personal information, and information about our collection/disclosure practices. We do not “sell” personal information as defined by CPRA and do not “share” it for cross-context behavioral advertising without providing opt-out rights. Contact support@paylessimages.com to exercise your rights.
EEA/UK (GDPR). See Sections 4 and 10 for lawful bases and rights. For transfers outside the EEA/UK, see Section 7. You may lodge a complaint with your local supervisory authority; we encourage you to contact us first.
Japan (APPI). We specify purposes of use in Section 4 and limit processing accordingly. You may request disclosure, correction, addition/deletion, suspension of use, or suspension of third-party provision, and we will respond per APPI. Contact support@paylessimages.com to exercise these rights.

15) Changes to this Policy

We may update this Policy from time to time. The updated version applies after the “Last updated” date. For material changes, we will provide notice as required by law (e.g., in-app notice or email).

16) Contact

Payless Images Co., Ltd.
Northwest Building 2F, 3-7-1 Sendagaya, Shibuya-ku, Tokyo 151-0051, Japan
Email: support@paylessimages.com