Last updated: September 3, 2025

This Privacy Policy explains how EliWaxman.com and our mobile and web applications (collectively, the “Services”) handle information. We design our AI features with privacy-by-default: we do not store personally identifiable information (PII) on our servers, and our AI apps are built to process sensitive inputs (like face images and face landmarks) locally on your device.

Plain English TL;DR
• We don’t store PII on our servers.
• Face data (images, landmarks, face-shape analysis) is processed on-device and is not shared outside your device.
• We don’t sell data, we don’t build advertising profiles, and we don’t use face data to identify you.
• If you choose to save an image or result, it’s saved on your device (e.g., Photos/Files) and remains under your control.

Controller: EliWaxman.com
Contact: privacy@eliwaxman.com
If you have questions or requests about this policy, please contact us.

This policy covers the EliWaxman.com website and our AI-powered applications, including apps that analyze face shape or other visual attributes. It explains what we (do not) collect, how on‑device processing works, and your choices.

We do not store personally identifiable information (PII) on our servers. We do not maintain server-side databases of user profiles, images, faceprints, or any biometric identifiers tied to you. We also do not sell data, and we do not share face data with advertisers.

• Aggregated app metrics provided by platform vendors (e.g., Apple App Analytics) may include non-identifiable statistics such as install counts or crash summaries. These reports do not include face data or images.
• Support communications you initiate (e.g., emailing us) will include whatever you send. We recommend not sharing sensitive information in support requests.

Our AI apps may capture face images from your device camera and compute non-identifying geometric descriptors(e.g., facial landmarks or meshes) using on-device frameworks (e.g., Apple’s Vision). We do not create or store a persistent biometric template. We do not use face data for identity or authentication.

Policy Text: “We don’t collect face data on our servers. Face images and landmark/mesh data are processed locally on your device and are not transmitted outside the device.”

We use local (on-device) processing to:

• Analyze facial geometry to estimate face shape or similar high-level attributes;
• Render previews, overlays, or recommendations;
• Generate outputs you explicitly request (e.g., saving an image to Photos).

Policy Text: “All face-shape analysis and Apple SDK (Vision/AR) face landmark data are processed on-device and are not shared outside the app.”

We do not share face images or face landmarks with third parties. We do not upload face data to our servers. We do not sell face data. If you choose to share an output (e.g., by exporting an image), that sharing is under your control and occurs via your chosen channel.

Policy Text: “We do not transmit or disclose face data to any third party; no face data is uploaded to our servers or stored in the cloud.”

• On-device only: Face data is processed in memory on your device and not retained by us.
• Your saves: If you save an image or result, it is stored locally on your device (e.g., in Photos/Files) under your control.
• No server retention: We do not retain face data on servers because we do not collect it server-side.

Policy Text: “We retain no face data on our servers. On-device face data is ephemeral and exists only as needed to provide the feature; any saved outputs reside on your device.”

Face data is not shared with third parties and is not stored in any cloud. Processing happens on the device. If you explicitly export content to another app or service, that export is under your control and subject to that app’s policy.

Policy Text: “Face data is not shared with third parties and is not stored in any cloud location; processing occurs solely on your device.”

Our apps may request device permissions (e.g., Camera, Photos) solely to perform requested features. Denying permissions may reduce app functionality. No permission grants us ongoing server access to your content because we don’t upload your content to our servers.

• GDPR/EU: To the extent any processing occurs, it is necessary to provide the Service you request (Art. 6(1)(b) GDPR). We do not profile you and do not process special categories of personal data on our servers.
• CCPA/CPRA (California): We do not “sell” or “share” personal information as defined by these laws.

• You can deny or revoke camera or photo library permissions at any time in system settings.
• You control what you save/export from the app.
• You can delete any saved images from your device storage at any time.

We implement a local-first design to minimize risk: face data is processed on-device and not transmitted to us. For any non-identifiable telemetry we may receive (e.g., crash summaries), we use industry-standard safeguards from platform providers.

Our Services are not directed at children under 13 (or the age required by your jurisdiction). We do not knowingly collect personal data from children.

Because we do not store PII on our servers and do not upload face data to the cloud, we do not perform cross-border transfers of your personal data in connection with face data features.

We may update this policy from time to time. We will update the “Last updated” date above and, where legally required, provide additional notice.

Questions or requests: privacy@eliwaxman.com

Q1. What face data does the app collect?
Answer: We do not collect face data on our servers. The app processes face images and facial landmarks locally on the device.
Where in policy: §5.1 (What face data the app uses).
Quoted policy text:

“We don’t collect face data on our servers. Face images and landmark/mesh data are processed locally on your device and are not transmitted outside the device.”

Q2. Provide a complete and clear explanation of all planned uses of the collected face data.
Answer: Face data is used only to analyze facial geometry to estimate face shape and to render previews/recommendations—all processed on-device. No Apple SDK (Vision/AR) face landmark data is shared outside the app.
Where in policy: §5.2 (How and why we use face data).
Quoted policy text:

“All face-shape analysis and Apple SDK (Vision/AR) face landmark data are processed on-device and are not shared outside the app.”

Q3. Will the face data be shared with any third parties? Where will this information be stored?
Answer: No. We do not share face data with third parties, and we do not upload or store it in any cloud. Processing occurs solely on the device.
Where in policy: §5.3 (Sharing and disclosure), §5.5 (Third parties and storage location).
Quoted policy text:

“We do not transmit or disclose face data to any third party; no face data is uploaded to our servers or stored in the cloud.”
“Face data is not shared with third parties and is not stored in any cloud location; processing occurs solely on your device.”

Q4. How long will face data be retained?
Answer: We retain no face data on our servers. On-device face data is ephemeral—kept only as needed to provide the feature. If you save an image or result, it is stored locally on your device under your control.
Where in policy: §5.4 (Retention of face data).
Quoted policy text:

“We retain no face data on our servers. On-device face data is ephemeral and exists only as needed to provide the feature; any saved outputs reside on your device.”

Q5. Where in the privacy policy is the app’s collection, use, disclosure, sharing, and retention of face data explained?
Answer: See §5 Face Data — specifically §§5.1 (what), 5.2 (uses), 5.3 (sharing), 5.4 (retention), and 5.5 (third parties & storage location).

Q6. Quote the specific text from the privacy policy concerning face data.
Answer (selected excerpts):

“We don’t collect face data on our servers. Face images and landmark/mesh data are processed locally on your device and are not transmitted outside the device.”
“All face-shape analysis and Apple SDK (Vision/AR) face landmark data are processed on-device and are not shared outside the app.”
“We do not transmit or disclose face data to any third party; no face data is uploaded to our servers or stored in the cloud.”
“We retain no face data on our servers. On-device face data is ephemeral and exists only as needed to provide the feature; any saved outputs reside on your device.”

Note: This document is provided for general informational purposes and does not constitute legal advice. You should consult with counsel to confirm compliance with applicable laws in your markets (e.g., GDPR, CCPA/CPRA) and app store policies.