Last Updated: March 27, 2026
These Terms and Conditions (the "Terms") govern your use of the mobile applications (the "App"), provided by APPCAPITAL AG, a company registered at Baarerstrasse 78, 6300, Zug, Switzerland, together with companies in the same corporate group (hereinafter "AppCapital Group") ("we", "us", "our").
Our contact details:
Address: Baarerstrasse 78, 6300, Zug, Switzerland
E-mail: kb@appcapital.vc
Please read this Privacy Policy carefully as it contains important information about how we collect, process, and share your Personal and Face Data. We may update this Privacy Policy from time-to-time to keep it in conformity with the relevant legislation, including the Regulation of the European Parliament and of the Council (EU) 2016/679 (the "GDPR") and California Consumer Privacy Act 2018 (the "CCPA"). If we make any major changes and need your explicit consent, we will request your consent or renewed consent.
How Do We Collect Your Face Data?
Our Apps do not directly collect or store face data. It functions by requesting access to the user's camera, enabling the processing of facial photos to technically be able to use our Apps. With the user's explicit consent, Apps then transfer the processed data for storage in a designated section separate from the Apps, typically the user's photo gallery on its device. This approach ensures that the App's role is strictly limited to processing face data and that we do not collect it to any of our storage or server.
How Do We Process and Use Your Face Data?
We affirm that we do not utilize the collected face data for any purposes. Since the data remains securely stored on the user's device, we do not have access to it and, consequently, do not have any intentions to use this data in any form. We prioritize user privacy and, therefore, do not share any face data with third parties or external services. The data processed by our Apps is exclusively stored on the user's device. This ensures that the user retains full control and ownership of their personal information at all times.
How Long Do We Retain Your Face Data?
The duration for which face data is retained is entirely controlled by the user. Given that the data is stored locally on the user's device, they have the authority to manage and delete the data as per their preference. We do not impose any restrictions or guidelines on the retention period of the face data.
How Do We Collect Your Personal Data?
We collect Personal Data if you provide it to us or automatically by electronic means. In order to provide certain functionalities of the App, some features may use artificial intelligence technologies (the "AI Features") to process your inputs and generate results.
Use of AI-Powered Features
When you choose to use AI Features, the App may process the content that you actively submit (such as text, images, or other inputs) in order to:
- generate responses or outputs requested by you;
- enable specific AI-powered tools and functionalities within the App.
AI Features are used only in connection with specific actions initiated by you and are not active in the background without your interaction.
User control and consent: We do not process your Personal Data through AI Features without your knowledge. Before using any AI Feature, you will be clearly informed that your input may be processed using artificial intelligence technologies. By choosing to proceed, you provide your consent to such processing. You may choose not to use AI Features at any time. Core functionality of the App remains available without using AI Features, except where a feature inherently requires AI to function. You also have the right to withdraw your consent at any time by discontinuing the use of AI Features.
Data processed through AI Features: Depending on how you use the App, the following categories of data may be processed through AI Features:
- content of your requests, queries, or inputs (including text, images, or other data you actively submit);
- limited Technical Data necessary to ensure proper delivery of the feature.
We process only the minimum amount of data necessary to provide the requested functionality. We do not access, collect, or transmit Face Data through AI Features. Any processing of Face Data remains local to your device.
Third-party AI service providers: AI Features may be provided either by us or by third-party service providers acting on our behalf. Where third-party providers are involved:
- they process your Personal Data solely for the purpose of providing the requested functionality;
- they are contractually bound by data protection and confidentiality obligations;
- they are not permitted to use your Personal Data for their own independent purposes;
- they are not permitted to retain your Personal Data longer than necessary to provide the service.
No use of data for AI training: We do not use your Personal Data submitted through AI Features to train artificial intelligence models, unless we explicitly inform you in advance and you provide separate, explicit consent for such use.
International data transfers: Some AI service providers may be located outside the European Union or your country of residence. Where this occurs, we ensure that appropriate safeguards are implemented in accordance with applicable data protection laws, including the use of Standard Contractual Clauses (SCC) or other lawful mechanisms.
No automated decision-making: AI Features do not constitute automated decision-making that produces legal effects concerning you or similarly significantly affects you. Any outputs generated by AI Features are provided for informational or functional purposes only.
How Do We Process Your Personal Data?
We respect your privacy and aim to limit the Personal Data that we collect from you to the amount which is strictly necessary to fulfil the purposes of processing.
When Can We Share Your Personal Data?
We can share your Personal Data with third parties only in the cases listed below:
When we are required by law: We may disclose your Personal Data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies), in connection with any legal proceedings or prospective legal proceedings and in order to establish, exercise or defend our legal rights.
With our partners who help us support the App: We may have partners that help us to make the App better, including analytics and advertising partners which may process your Technical Data and some User Data for analytical and advertising purposes respectively.
The list of our analytics and advertising partners:
- Google Analytics — a web analytics service provided by Google, Inc. Address: 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA.
- Facebook Ads — a Facebook tool provided by Meta Platforms, Inc. Address: 1601 Willow Road, Menlo Park, CA 94025, USA.
- Google Ads — a contextual advertising service from Google, Inc. Address: 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA.
Please note that some of these companies may be located outside the EU. Where this is the case, we meet the strict conditions of Personal Data transfers from the EU to other countries by using the Standard Contractual Clauses (SCC) adopted by the European Commission.
How Long Do We Retain Your Personal Data?
We retain your Personal Data for no longer than it is necessary to fulfill the purposes specified in this policy. Except for any legal obligation that sets a longer data retention period, at the end of these periods, the Personal Data processed will be deleted or anonymized.
Do We Use Automated Decision-Making?
We neither use automated decision-making nor refer to the automated profiling.
What Rights Do You Have?
Rights of EU residents:
- Right of access — you can receive a copy of the Personal Data that we hold about you, as well as other supplementary information.
- Right to rectification — of your Personal Data which is incomplete or inaccurate.
- Right to erasure — you can ask us to delete or remove your Personal Data in certain circumstances.
- Right to restrict processing — if the accuracy of the Personal Data is contested, the processing is unlawful, or we no longer need the data but you require it for legal claims.
- Right to data portability — applies only to information we have processed based on your consent or Terms and Conditions.
- Right to object — to the processing where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object.
- Right to withdraw consent — at any time where we are relying on consent to process your Personal Data.
We will address your request within 1 month. This period may be extended by 2 further months where necessary.
Rights of California residents:
- Right to opt out — under the CCPA each California resident can request business stops selling Personal Data to third parties. We do not, and will not, provide your Personal Data in direct exchange for money.
- Other rights — you have a right to be informed about what categories of Personal Data we are collecting, request a free copy of your Personal Data in a readable format, and request deletion of Personal Data collected in the past 12 months.
As required by CCPA we endeavor to respond to a verifiable request within 45 days of its receipt (up to 90 days if more time is needed).
How to exercise any of your rights? You may exercise your rights by sending a relevant request to the e-mail indicated in the contact details above.
If you have any comments about how we process your Personal Data, please let us know and we will consider your claim. If you are not satisfied with our response, you have the right to file a complaint with the competent authority.