PiFl Labs Co., Ltd. ("Company", "we", "us") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and disclose information when you use the mobile application PiPi Draw ("App"). For matters not covered here, our general Privacy Policy applies.
PiPi Draw lets you turn a photo you take or select into an AI line-art sketch and then color or draw on it. Unlike our diary or journaling apps, PiPi Draw transmits your photo to our server (Cloud Functions) to perform the AI conversion. Please review the following carefully.
1. Purpose of Processing
- AI sketch conversion: Converting a photo you take or pick from your device gallery into a line-art sketch
- App functionality: Coloring and drawing on converted sketches, on-device saving of work sessions, and usage management
- User identification: Distinguishing users via an anonymous identifier created automatically on first launch (Firebase anonymous authentication) and managing usage and points — no sign-up or login is required
- Advertising: Ad serving and personalization via Google AdMob
- In-app purchases: Point pack purchases, premium subscription processing, and receipt validation
- Analytics and stability: Usage analytics and crash reporting via Firebase Analytics / Crashlytics (optional)
- Customer support: Receiving and responding to email inquiries
2. Information We Collect
| Category | Items | Collection / Processing Method |
|---|---|---|
| Photos & Images | Photo you take or select from the gallery (downscaled to a 1024px JPEG for conversion); resulting AI sketch (PNG) | Transmitted to Cloud Functions (server) for AI conversion, then temporarily stored in Cloud Storage |
| User Identifier | Firebase anonymous auth UID (a random identifier generated automatically by the App — no name, email, or other identity data is collected) | Generated automatically by Firebase Authentication on first launch |
| Sketch Metadata | Sketch style/options, creation time, image dimensions, hash of the original photo, daily/monthly usage counters, point balance and history | Written to Firestore by Cloud Functions |
| Advertising Identifier | Ad ID (IDFA/AAID), coarse location (country level), device info (OS, model, language) | Automatic via Google AdMob SDK (with consent) |
| In-App Purchases | Purchase receipt, transaction ID | Apple App Store / Google Play billing |
| App Usage Data (local) | Drawing sessions, strokes, sketches you save, brush settings, preferences | Stored locally on device (Drift/SQLite); saved sketches are cached on the device |
| Analytics & Stability (optional) | Usage events, device/app version info, non-identifying error logs | Firebase Analytics / Crashlytics (optional) |
| Email Inquiries | Email address, name (optional), inquiry content | Direct email submission |
3. AI Sketch Conversion
The App's core feature, AI sketch conversion, works as follows:
- Transmission: Your selected photo is downscaled to a JPEG of up to 1024px and sent, via our Cloud Functions (server), to Google's generative AI (Gemini / Vertex AI).
- AI processing: The AI converts the photo into a line-art sketch. We do not use your photos to retrain models.
- Storage: The original used for conversion (originals/) and the resulting sketch (sketches/) are stored in Firebase Cloud Storage. See Section 4 for retention.
- Local caching: Sketches you choose to keep are cached in on-device storage (Drift), so you can continue to use them even after the cloud copy is automatically deleted.
4. Retention Period
- Original photo for conversion (originals/): Automatically deleted 7 days after upload, per the Cloud Storage lifecycle policy
- AI sketch (sketches/): Automatically deleted 90 days after creation, per the Cloud Storage lifecycle policy (sketches you keep remain in on-device storage)
- Account info and sketch metadata: Retained while the account exists; fully deleted when the account is deleted
- Anonymous accounts: Automatically cleaned up — together with related data (sketches, stored images) — after 30 days of inactivity
- Advertising identifier and ad data: As per Google AdMob policy
- In-app purchase receipts: 5 years (Korean Act on Consumer Protection in Electronic Commerce)
- Local app data: Until the user deletes the App or resets the data
- Email inquiry records: 3 years after resolution
5. Disclosure to Third Parties
We do not sell, trade, or transfer your personal information to third parties except as required by law or with your explicit consent.
6. Processing Entrustment
| Processor | Purpose | Retention |
|---|---|---|
| Google LLC (Firebase) | Authentication, Cloud Functions (AI conversion), Cloud Storage (photo/sketch storage), Firestore (metadata), analytics/crash reporting | Until contract termination |
| Google LLC (Gemini / Vertex AI) | AI line-art sketch conversion | Processed in real time (not separately retained) |
| Google LLC (AdMob) | Mobile ad serving and ad identifier processing | Until contract termination |
| Apple Inc. | iOS in-app purchase processing | Until contract termination |
| Google LLC (Google Play) | Android in-app purchase processing | Until contract termination |
7. Gallery Sharing Feature
PiPi Draw plans to offer a gallery feature for sharing sketches between users in the future. This feature is disabled in v1.0 and does not currently operate. If the gallery is enabled, sharing will be limited to sketches you explicitly choose to upload (results created by AI-converting a photo taken with the in-app camera), and we will update this Policy and notify you at that time. This Policy may include provisions anticipating future functionality; however, no personal data is actually collected or shared through disabled features.
8. Advertising Identifier and Tracking Consent
The App displays advertisements via Google AdMob and may collect advertising identifiers (IDFA/AAID) for this purpose. No ads are shown while you are drawing or coloring, so as not to disrupt your focus.
- iOS users: On first launch, you will see Apple's App Tracking Transparency (ATT) prompt to choose whether to allow tracking. If denied, only non-personalized ads will be shown.
- Android users: You can opt out via Settings → Google → Ads → "Delete advertising ID" or "Opt out of ad personalization".
For details on Google AdMob's data processing, see the Google Privacy Policy.
9. App Permissions
The App may request the following permissions. Each can be denied, though doing so may limit related functionality.
- Camera: Taking a photo for AI sketch conversion
- Photos / Media: Selecting a photo to convert from your device gallery and saving the resulting sketch
- App Tracking Transparency (iOS): Tracking consent for ad relevance
10. Data Destruction
- Procedure: Unnecessary personal data is destroyed after approval by the Data Protection Officer. Originals and sketches in Cloud Storage are deleted automatically per the lifecycle policy in Section 4.
- Method: Electronic files are permanently deleted using non-recoverable methods. When an account is deleted, that account's sketches, stored images, and metadata are deleted as well. Local app data is removed when the user uninstalls the App.
11. Your Rights
- Right to be informed about the processing of your personal data
- Right to consent to and determine the scope of processing
- Right to access and request information about your personal data
- Right to request correction, deletion, suspension, or destruction
- Right to seek redress for damages caused by processing
You may exercise these rights (access, correction, deletion, restriction) by contacting us at privacy (at) pifl-labs.com. Upon a deletion request, we will delete all sketches, stored images, and metadata linked to your user identifier without undue delay.
12. Security Measures
- Access control and permission management (Firebase Security Rules restrict access to your own data)
- SSL/TLS encryption for data in transit
- Sensitive data stored in secure storage (Keychain/Keystore)
- Apple Privacy Manifest (PrivacyInfo.xcprivacy) compliance
13. Children's Privacy
The App is rated for general audiences and is not directed at children under 14. We do not knowingly collect personal data from children under 14. If we become aware of such collection, we will delete it immediately. Parents may request deletion at privacy (at) pifl-labs.com.
14. International Data Transfers
| Recipient | Country | Purpose | Items |
|---|---|---|---|
| Google LLC (Firebase) | United States | Auth, AI conversion, storage, metadata, analytics | Photos, sketches, user identifier, metadata |
| Google LLC (Gemini / Vertex AI) | United States | AI sketch conversion | Photo for conversion |
| Google LLC (AdMob) | United States | Mobile ad serving | Ad identifier, device info |
| Apple Inc. | United States | iOS in-app purchases | Purchase receipt, transaction ID |
| Google LLC (Google Play) | United States | Android in-app purchases | Purchase receipt, transaction ID |
15. Data Protection Officer
- Company: PiFl Labs Co., Ltd.
- Email: privacy (at) pifl-labs.com
16. GDPR (European Economic Area)
If you are located in the EEA, you have additional rights under the General Data Protection Regulation, including the right to access, rectify, erase, restrict processing, data portability, and object to processing. Contact us at privacy (at) pifl-labs.com.
17. Changes to this Policy
This Privacy Policy is effective as of June 4, 2026. Any changes will be announced on this page.