Privacy Policy

Last updated: September 25, 2026

Introduction

Tweaky ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your information when you use our mobile application ("Tweaky" or the "App").

By using Tweaky, you agree to the collection and use of information in accordance with this policy.

Information We Collect

1. Photos and Images

• What we collect: Photos you choose to enhance using Tweaky
• How we use it: Photos are sent to our secure servers for AI enhancement processing
• Storage: Photos are held only as long as needed to process and deliver your result, and are automatically deleted from our servers within 30 days
• We do NOT: Store your photos permanently, share your photos with third parties, or use your photos for any purpose other than enhancement

2. Device Information

• What we collect: A randomly generated device identifier (UUID)
• How we use it: To track usage limits per device and manage subscriptions
• Storage: Stored locally on your device in secure iOS Keychain storage
• We do NOT: Collect your device's hardware identifiers, phone number, or IMEI

2.1 Device Region, Language, and Time Zone

• What we collect: Your device's region setting (e.g. "GB", "US"), preferred language code (e.g. "en", "es"), and time zone (e.g. "Europe/London") - sent as request headers from the app to our servers
• How we use it: To understand the geographic distribution of our users so we can decide where to deploy regional infrastructure. Stored alongside each enhancement job for aggregate analysis only.
• Source: Read from your device's Settings (region, language, time) - NOT derived from your IP address or any location services
• We do NOT: Use GPS, request location permissions, geolocate your IP address, or attempt to identify your city or address

2.2 Device Model and iOS Version

• What we collect: Your iPhone/iPad model identifier (e.g. "iPhone15,3") and iOS version (e.g. "18.2") - sent as request headers
• How we use it: To prioritise performance work for the most-used devices and to plan when older iOS versions can be dropped
• Source: Read from the device's model and system version - does NOT contain a serial number, IMEI, MAC address, or any unique device fingerprint
• We do NOT: Combine this with other identifiers to fingerprint or track individual users; the same model and iOS version are shared by millions of devices

2.3 App Version and Subscription Tier

• What we collect: The version of Tweaky you are running and your current subscription tier label (free, basic, or annual) - sent as request headers
• How we use it: To monitor adoption of new app versions, size our servers for paid and free traffic, and debug version-specific issues
• We do NOT: Send any payment, billing, or App Store transaction details - those stay entirely with Apple

3. Usage Data

• What we collect: Number of images enhanced, timestamps of usage
• How we use it: To enforce subscription tier limits and improve our service
• Storage: Associated with your random device identifier, not your name or contact details

4. Subscription Information

• What we collect: Subscription status (free/premium), subscription type
• How we use it: To unlock premium features and manage your subscription
• Storage: Managed by Apple through App Store subscriptions
• We do NOT: Store your payment information - all payments are handled by Apple

5. Crash Diagnostics

• What we collect: Crash reports from the app - stack traces, iOS version, app version, and the app's state at the moment of the crash (free memory, current screen, etc.). Collected via Google's Firebase Crashlytics.
• How we use it: To find and fix bugs that make the app crash on real devices
• What's included: A Firebase-generated installation identifier that groups crashes from the same installation. It is NOT linked to your device identifier, your subscription, or any personal identifier.
• What's NOT included: No photos, no image contents, nothing you have typed, no advertising identifier, no location, no contacts
• Storage: Retained by Firebase Crashlytics for 90 days, then automatically deleted
• Opt-out: Crash reporting is required for us to ship a reliable app. If you do not consent to it, please uninstall the app.

Information We Do NOT Collect

How We Protect Your Information

Security Measures

• Encryption in Transit: All data is transmitted using HTTPS/TLS encryption
• Secure Storage: Device identifiers stored in iOS Keychain (hardware-encrypted)
• Certificate Pinning: Our app verifies server authenticity to prevent interception
• Auto-Deletion: Uploaded photos are automatically deleted from servers within 30 days
• No Third-Party Sharing: We never share or sell your data

Data Processing

• Photos are processed on secure Google Cloud Platform servers in the Netherlands (EU)
• Processing typically completes within seconds
• Processed images are transmitted back to your device
• Original and processed images are deleted from servers within 30 days

Data Retention

Data Type	Retention Period
Uploaded photos	Retained for up to 30 days, then automatically deleted
Processed images	Retained for up to 30 days, then automatically deleted
Device identifier	Until you delete the app and clear Keychain
Usage statistics	12 months rolling
Subscription status	Managed by Apple
Crash reports	90 days in Firebase Crashlytics, then automatically deleted
Region, language, device and app details (2.1 - 2.3)	Stored with the job record, deleted within 30 days

Your Rights

You have the right to:

• Access: Request information about what data we hold
• Deletion: Request deletion of your usage data
• Opt-out: Uninstall the app to stop all data collection

To exercise these rights, use the details on our Contact page.

Children's Privacy

Tweaky is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

Third-Party Services

Apple App Store

• Handles all payment processing
• Manages subscriptions
• Subject to Apple's Privacy Policy

Google Cloud Platform

• Provides our image processing servers, located in the Netherlands (EU)
• Stores job and usage records in the United States (see International Data Transfers below)
• Subject to Google Cloud's security certifications (SOC 2, ISO 27001)

Firebase Crashlytics (crash diagnostics only)

• Used only to collect crash reports - see section 5 above
• We do not use Firebase Analytics, Performance Monitoring, Messaging, or any other Firebase product

International Data Transfers

Tweaky is operated from the United Kingdom. Our servers run on Google Cloud in fixed locations, wherever you are in the world:

Data	Where it is processed and stored
Your photos and enhanced images	Netherlands (European Union). Photos are uploaded, enhanced and stored only in the EU, and are deleted within 30 days. They are never sent to the United States.
Job hand-off messages: your random device identifier, the settings you chose, and where your photo is stored (not the photo itself)	Belgium (European Union). Held briefly to pass each job to our processing servers, then removed.
Job and usage records: your random device identifier, dates and times, the settings you chose, a fingerprint of each photo (so the same photo is not uploaded twice), your device's region, language and time zone settings, and your subscription status	United States. These records contain no photos, names or contact details. Job records are deleted after 30 days.
Technical server logs	Google Cloud, in locations chosen by Google. Deleted after 30 days.
Crash reports (section 5)	Google Firebase, in locations chosen by Google. No photos or contact details are ever sent.

The UK recognises the EU as providing adequate protection for personal data, so sending your photos to the Netherlands for processing needs no further safeguards. Records held in the United States are protected by Google's Cloud Data Processing Addendum, which includes the Standard Contractual Clauses and the UK Addendum to them, and Google LLC is certified under the EU-US Data Privacy Framework and its UK Extension.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by updating the "Last Updated" date at the top and posting a notice in the app for material changes.

Who we are

Tweaky is operated by LILYA LABS LTD, registered in England and Wales, company no. 17439824.

Registered office:

124 City Road
London
EC1V 2NX
United Kingdom

For privacy questions, data-rights requests and other contact details, see our Contact page.

© 2026 LILYA LABS LTD.