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 or into the art style or photo look you selected
- 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: Processing and verifying purchases of AI conversion packs
- Analytics and stability: Usage analytics and crash reporting via Firebase Analytics / Crashlytics (collected automatically while you use the App)
- 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 (the App downscales it to at most 1280px before sending, and our server downscales it again to a JPEG of up to 1024px for conversion); resulting AI image (line art as PNG; art styles and photo looks as JPEG) | 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 |
| Conversion Job Records | Conversion request ID; status (in progress, completed, failed); conversion type (line art, or an art style or photo look and which one); what was used (a free conversion or a conversion pack); on completion, result details (location and size of the result image, conversions left, etc.); on failure, an error code and whether it was refunded; timestamps; user identifier | Written to Firestore by Cloud Functions when you request a conversion, so that you can get the result again if the connection drops and are not charged twice |
| AI Result Reports | ID of the reported result; the reason you chose (offensive or inappropriate, people or animals look distorted, too different from the photo, other); details of the reported result (conversion type, style, AI model, location of the result image); app version, build and platform (iOS/Android); number and time of reports; user identifier. No free-text note is collected | Written to Firestore by Cloud Functions when you report a result on the result screen; used only to review that result and improve AI conversion |
| Advertising Identifier | Ad ID (IDFA/AAID), coarse location (country level), device info (OS, model, language) | Collected automatically by the Google AdMob SDK when ads load (the iOS advertising ID only if you allow tracking; in regions where ad consent is requested, after the consent screen) |
| In-App Purchases | Purchase receipt, transaction ID, product and platform, conversion pack balance | Apple App Store / Google Play billing (after checking the purchase, our server records it and the conversion pack balance in Firestore) |
| 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 | Usage events, device/app version info, non-identifying error logs | Collected automatically by Firebase Analytics / Crashlytics while you use the App |
| 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: The App downscales your selected photo to at most 1280px and sends it to our Cloud Functions (server), which downscales it again to a JPEG of up to 1024px and passes it to a generative AI provider: Google's generative AI (Gemini API) or OpenAI's image generation AI, depending on the type of conversion. A photo is sent to OpenAI only if you have agreed to the in-app AI photo transfer notice that names OpenAI.
- AI processing: The AI converts the photo into a line-art sketch or into the art style or photo look you selected. 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
- Conversion job records: Automatically deleted 7 days after creation (Firestore TTL), or earlier together with the account if it is deleted
- AI result reports: Retained while the account exists; deleted together with the account
- 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 API) | AI image conversion (line art, art styles, photo looks) | Up to 55 days for abuse monitoring, then deleted (provider policy) |
| OpenAI OpCo, LLC | AI image conversion (line art, art styles, photo looks) | Up to 30 days for abuse monitoring, then deleted, unless longer retention is required by law or reasonably necessary to protect the provider's services or third parties (provider policy) |
| 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 API) | United States | AI image conversion | Photo for conversion |
| OpenAI OpCo, LLC | United States | AI image conversion | Photo for conversion |
| Google LLC (AdMob) | United States | Mobile ad serving | Ad identifier, device info, anonymous user identifier (rewarded ads) |
| Apple Inc. | United States | iOS in-app purchases | Product being purchased, buyer-check token |
| Google LLC (Google Play) | United States | Android in-app purchases | Product ID, purchase token |
Contact details and further information for each recipient are set out below.
Transfer details: Google LLC (Firebase)
United States · 1600 Amphitheatre Parkway, Mountain View, CA 94043 · privacy contact: Google privacy inquiry form
- Items: the anonymous user identifier; the photo for conversion (the photo the App sends at up to 1280px, which our server downscales to a JPEG of up to 1024px and stores) and the resulting AI image; sketch metadata (style and options, creation time, hash of the original photo) and usage and point records; conversion pack purchase records (transaction ID, product, platform) and the conversion pack balance; conversion job records and AI result reports; app usage events, device and app version info, and error logs; connection IP addresses.
- When and how: on first launch (anonymous sign-in), while you use the App (usage analytics and error reports), and each time you request an AI conversion, have a purchase checked, or report a result, over an encrypted connection (HTTPS/TLS). Photos, results, and Firestore records are stored in Google Cloud's Seoul region; anonymous sign-in is processed only in Google's US data centers.
- Purpose: anonymous sign-in, running the AI conversion server (Cloud Functions), storing photos and results (Cloud Storage), managing metadata, usage, conversion packs, and reports (Firestore), and usage analytics and crash reporting (Analytics, Crashlytics).
- Retention: as in Section 4 (originals for conversion and conversion job records are deleted automatically after 7 days and AI results after 90 days; account data, metadata, and reports are kept until the account is deleted, and so on). Under the provider's policy, IP addresses logged by the sign-in service are kept for a few weeks, and crash reports (Crashlytics) are kept for 90 days before their deletion begins.
- How to refuse and its effect: if you do not use AI conversion, buy conversion packs, or report results, the related photos and records are not sent. The anonymous user identifier and usage and error information are sent automatically while you use the App and cannot be turned off separately in the App; if you do not want this, stop using (delete) the App and request deletion of your data as described in Section 11. You will then not be able to use the App.
Transfer details: Google LLC (Gemini API)
United States · 1600 Amphitheatre Parkway, Mountain View, CA 94043 · privacy contact: Google privacy inquiry form
- Items: the photo for conversion (a JPEG of up to 1024px, with location and other photo metadata removed) and the conversion instructions. No user identifier is sent.
- When and how: each time you request a conversion processed by Gemini, sent through our server (Cloud Functions) to the Gemini API over an encrypted connection (HTTPS/TLS).
- Purpose: AI image conversion (line art, art styles, photo looks).
- Retention: up to 55 days for abuse monitoring, then deleted (provider policy). This data may be stored transiently or cached in any country where Google or its agents maintain facilities, and Google does not use photos and results received through the paid API to improve its products (provider terms).
- How to refuse and its effect: if you do not agree to the in-app notice about sending photos to AI, or withdraw it at any time in Settings ("Send photos to AI"), your photos are not sent to any AI provider (Google or OpenAI). AI conversion is then unavailable; features that do not send photos, such as coloring and photo filters, remain available.
Transfer details: OpenAI OpCo, LLC
United States · 1455 3rd Street, San Francisco, CA 94158 · privacy contact: privacy (at) openai.com
- Items: the photo for conversion (a JPEG of up to 1024px, with location and other photo metadata removed) and the conversion instructions. No user identifier is sent.
- When and how: each time you request a conversion processed by OpenAI, sent through our server (Cloud Functions) over an encrypted connection (HTTPS/TLS).
- Purpose: AI image conversion (line art, art styles, photo looks).
- Retention: up to 30 days for abuse monitoring, then deleted, unless longer retention is required by law or reasonably necessary to protect the provider's services or third parties (provider policy).
- How to refuse and its effect: if you do not agree to the in-app notice about sending photos to AI, or withdraw it at any time in Settings ("Send photos to AI"), your photos are not sent to any AI provider (Google or OpenAI). AI conversion is then unavailable; features that do not send photos, such as coloring and photo filters, remain available.
Transfer details: Google LLC (AdMob)
United States · 1600 Amphitheatre Parkway, Mountain View, CA 94043 · privacy contact: Google privacy inquiry form
- Items: device identifiers such as the advertising ID (IDFA/AAID); IP address (which may be used to estimate approximate location); app and ad interaction information (app launches, taps, video views, ads seen); performance and diagnostic information. When you watch a rewarded ad to get a free conversion, the anonymous user identifier is also passed on so that the reward can be confirmed.
- When and how: each time the App loads or shows an ad, the Google Mobile Ads SDK in the App sends it directly to Google's servers (not through our server). On iOS we first ask whether you allow tracking (ATT), and in regions where ad consent is required, ads are requested only after the consent screen.
- Purpose: serving and measuring ads; confirming that a rewarded ad was watched (one free conversion).
- Retention: under Google's Privacy Policy. Google states that it anonymizes advertising data in server logs by removing part of the IP address after 9 months and cookie information after 18 months (provider policy).
- How to refuse and its effect: if you deny tracking on iOS or delete your advertising ID on Android, the advertising ID is not passed on (see Section 8). In regions where ad consent is requested, you can change your choice at any time in Settings ("Ad privacy choices"). In regions where ad consent is not requested (such as Korea), IP addresses, usage information, and the like are sent when ads load, and this cannot be turned off separately in the App. If you do not watch rewarded ads, the anonymous user identifier is not passed on. The App's features remain available; if ads cannot be loaded because you have not consented, only the free conversion earned by watching a rewarded ad is unavailable.
Transfer details: Apple Inc.
United States · One Apple Park Way, Cupertino, CA 95014 · privacy contact: Apple privacy contact form
- Items: the product being purchased and, when you buy conversion packs, a buyer-check token (a UUID derived from the anonymous user identifier).
- When and how: when you buy conversion packs on iOS, the App passes them to Apple's payment system (StoreKit). Our server checks the transaction signed by Apple against Apple's certificates and does not send transaction information back to Apple.
- Purpose: processing in-app purchases and confirming the buyer so that conversion packs go only to the user who bought them.
- Retention: under the privacy policy of Apple as the payment processor (kept only as long as necessary for the purposes for which it was collected, or as required by law; provider policy).
- How to refuse and its effect: nothing is sent if you do not buy conversion packs. Paid conversion packs are then unavailable; other features remain available.
Transfer details: Google LLC (Google Play)
United States · 1600 Amphitheatre Parkway, Mountain View, CA 94043 · privacy contact: Google privacy inquiry form
- Items: what is needed to check a conversion pack purchase — the product ID and the purchase token.
- When and how: when you buy conversion packs on Android and the App asks for them to be credited (a purchase not yet credited is sent again when the App restarts), our server (Cloud Functions) sends it to the Google Play Developer API over an encrypted connection (HTTPS/TLS).
- Purpose: confirming that the purchase is valid and completing its delivery.
- Retention: under the privacy policy of Google as the payment processor.
- How to refuse and its effect: nothing is sent if you do not buy conversion packs. Paid conversion packs are then unavailable; other features remain available.
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 October 1, 2026 (changes: OpenAI added as an AI photo conversion provider; Google Gemini retention and connection method (Gemini API) corrected; overseas transfer details — contact, items, timing and method, purpose, retention, and how to refuse — added for every recipient; conversion job records and AI result reports added with their retention; automatic collection of analytics, error, and ad data stated and photo upload sizes corrected; point pack and premium subscription purchases, which the App does not offer, removed; previous version effective June 4, 2026). Any changes will be announced on this page.