Privacy Policy

Last updated: February 2025

1. Who we are and scope

This Privacy Policy describes how we collect, use, and protect your personal data when you use Temmely (“Service”). The Service is operated from Denmark. For the purpose of the EU General Data Protection Regulation (GDPR) and Danish data protection law, we are the data controller for the personal data we process in connection with the Service.

We use third-party services (including for AI, authentication, and payments) that may process your data as our processors or as separate controllers. Their policies are linked where relevant below.

2. Data we collect and why

Account and authentication

When you create an account, we (via our authentication provider, Firebase/Google) collect information such as email address and any profile data you provide. We use this to create and manage your account, enforce our Terms, and communicate with you about the Service. Legal basis: performance of our contract with you; where applicable, consent or legitimate interest (e.g. account security).

Usage and portrait generation

When you use the Service to generate portraits, we process the images and prompts you submit. This data is sent to our AI provider Fal (fal – Features & Labels, Inc.) so they can run the models that produce your portraits. We may also store usage-related data (e.g. number of portraits generated, token or credit usage) to operate the Service and prevent abuse. Legal basis: performance of our contract; legitimate interest (improving and securing the Service).

Fal’s processing is governed by their Privacy Policy and Terms of Service. We use only a limited set of Fal models; we do not control Fal’s infrastructure or their handling of data beyond what is necessary for the Service.

Payments

Payment processing is handled by Stripe (or another payment provider we use). We may receive and store information such as transaction status, amount, and (where provided) billing-related details. We do not store full card numbers. Card data is collected and processed by the payment provider in accordance with their privacy policy. Legal basis: performance of our contract; legal obligation (e.g. accounting).

Technical and logs

We may collect technical data (e.g. IP address, browser type, device information) and logs for security, troubleshooting, and to ensure the Service works correctly. Legal basis: legitimate interest (security and operation of the Service); where required, legal obligation.

3. Sharing and international transfers

We share personal data only as needed to run the Service:

  • Fal (USA): Images and prompts for AI processing. Fal may process data in the United States. We rely on appropriate safeguards (e.g. standard contractual clauses or other mechanisms approved under GDPR) where required for transfers outside the EEA.
  • Firebase/Google: Account and authentication data, in accordance with Google’s privacy policy and our configuration.
  • Payment providers (e.g. Stripe): Data necessary to process payments.
  • Hosting and infrastructure: As needed to operate the Service.

We do not sell your personal data. We may disclose data if required by law or to protect our rights, safety, or property.

4. Retention

We keep your data only as long as necessary for the purposes in this policy: to provide the Service, comply with legal obligations (e.g. tax and accounting), and resolve disputes. Account data is typically retained while your account is active and for a reasonable period after closure; we may retain some data longer where the law requires it.

5. Your rights (GDPR and Danish law)

If you are in the EU/EEA or Denmark, you have the right to:

  • Access your personal data and receive a copy.
  • Rectification of inaccurate or incomplete data.
  • Erasure (“right to be forgotten”) in certain circumstances.
  • Restriction of processing in certain circumstances.
  • Data portability – receive your data in a structured, machine-readable format where applicable.
  • Object to processing based on legitimate interest, including profiling.
  • Withdraw consent where we rely on consent, without affecting lawfulness of processing before withdrawal.
  • Lodge a complaint with a supervisory authority – in Denmark: Datatilsynet (www.datatilsynet.dk); in other EEA countries, your local data protection authority.

To exercise these rights, contact us using the details in Section 7. We will respond within the time limits set by applicable law (generally one month under GDPR).

6. Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or alteration. Because the Service relies on third-party providers (e.g. Fal, Firebase, payment processors), we cannot guarantee the security of their systems; we choose providers that implement appropriate safeguards.

7. Contact

For questions about this Privacy Policy, your personal data, or to exercise your rights, please contact us at the email or address you use to operate Temmely (e.g. the contact details shown on the Temmely website or in the app). If you are in the EEA, you may also contact our data protection contact if we have designated one and made it available on the Service.