Privacy Policy
Last updated: 27 October 2026
1. Controller
The controller responsible for processing your personal data is:
Ovix Solutions, c/o JL Consulting Group GmbH#1076, Zürcherstrasse 84, 8852 Altendorf, Switzerland
Email: contact@rutila.app
Use this address for any privacy question and to exercise your rights.
2. Applicable law
We are based in Switzerland. Our processing of personal data is governed by the Swiss Federal Act on Data Protection (FADP). For users in the EU/EEA, the General Data Protection Regulation (GDPR) applies in addition; for users in the United Kingdom, the UK GDPR. Residents of the United States also have the rights described in section 13.
3. What data we process
You need an account to use the app. You sign in with your email address, your Google account or your Apple ID. Without signing in, you can only see the introduction screens.
Data you provide:
- Account data: email address and sign-in data. If you sign in with Google or Apple, we receive the email address and account identifier shared by that provider (with Apple, possibly a private relay address).
- Photos: the images you upload (e.g. selfies) and the images created or edited from them.
- Purchase and credit data: purchased packs and subscriptions, store transaction identifiers, your credit balance, credit bookings and the country of your store account (to calculate VAT and partner commissions). We do not receive payment details such as card or account numbers – payments are handled entirely by Google Play or the Apple App Store.
- Job data: chosen style or template, time, status and an optional rating of the result.
- Partner codes you redeem and, if you apply for the partner program, the details entered in the form (name, email address, platform, profile link, follower count, preferred code, topic, your confirmation that you are 18 or older).
- Partner area (partners only): name or company name, address, country, tax status and VAT number, payout method and account details (IBAN, Wise or PayPal email address, US bank or SWIFT details, or local account details), sign-in links and sessions, a log of changes to these details (time and area changed, not the old values) and your payouts and payout statements. We store account details encrypted and show them only with the last four digits. Partners see only monthly totals of purchases made with their code, never who bought.
- Messages you send us, e.g. support requests.
- Your acceptance of our Terms of Service and the version of this privacy policy shown to you, each with the time.
- Reports you submit about a generated image: the reason, an optional note and the job concerned. The image itself is not sent.
Data collected automatically:
- IP address of your device when it connects to our servers (to deliver the service and to limit requests).
- Device identifier, only when you redeem a partner code; in that case we store the IP address only as a hash.
- Push token of your device (Firebase Cloud Messaging), if you allow notifications.
- Technical editor events in minimised form (e.g. tool used, export format, number of variants). Prompts, image content and local file paths are not stored in them.
- Safety blocks: when our AI provider refuses an image for content reasons, we store the category and the time for your account, but neither the prompt nor the image.
- Account status: a warning or suspension after a breach of our Terms of Service, with the reason.
We do not collect the location of your device. The app uses no advertising or analytics trackers, no cookies and no pixels.
4. Purposes of processing
- Sign-in and account management
- The core feature: creating and editing images from your photos
- Processing purchases and subscriptions, managing your credit balance
- Push notifications, e.g. when your images are ready
- Service emails, e.g. sign-in links and partner program confirmations
- Preventing fraud and abuse, e.g. limiting requests and preventing multiple code redemptions
- Enforcing our Terms of Service and handling reports about generated images
- Error analysis and app stability
- Running the partner program and paying commissions
- Answering your requests
We do not send marketing emails and do not use your data for advertising. There is no automated decision-making or profiling with legal or similarly significant effects.
5. Legal bases (EU/EEA)
- Contract performance (Art. 6(1)(b) GDPR): sign-in, account management, image creation, purchases and credits, push notifications and service emails, partner program, the record of your acceptance of our Terms of Service.
- Legitimate interests (Art. 6(1)(f) GDPR): fraud and abuse prevention, IT security, error analysis and stability, enforcing our Terms of Service (reports about images, safety blocks, account status).
- Legal obligation (Art. 6(1)(c) GDPR): compliance with legal requirements, e.g. keeping partner payout statements.
- Consent (Art. 6(1)(a) GDPR): for processing your photos (before your first upload) and wherever else the app asks for your permission, e.g. for push notifications. You can withdraw consent at any time; processing carried out before withdrawal remains lawful.
6. AI processing and photos
- Image creation and editing: for this we send the photos you upload to Google's Gemini API. Processing may take place in the United States. In the paid service we use, Google does not use the content to train its models.
- Subject selection in the editor: uses Google ML Kit and runs entirely on your device. Your photos do not leave your device for this.
We do not use AI to profile you, to personalise content based on your usage behaviour or to show advertising.
Photos and biometric data: We use your photos solely to create the images you request. We do not create face templates or any other biometric identifiers from them, do not identify you by your face, and do not sell, lease, trade or otherwise profit from your photos; they are shared only with the service providers listed in section 7 to create images. Before your first upload, the app asks for your explicit consent and we store it with a timestamp. We delete uploaded photos after generation, within 24 hours at the latest. You can withdraw your consent at any time in the app (Profile → Privacy & data → Withdraw photo consent); your account and credits are kept.
7. Recipients and service providers
We use the following service providers to operate the app. They receive personal data only as far as their task requires and process it on our behalf under data processing agreements (Art. 28 GDPR). We do not sell your data.
- Supabase Inc. (USA; data stored in the EU, Ireland): sign-in, database and temporary image storage – privacy policy
- Railway Corp. (USA; server region EU West, Amsterdam, Netherlands): hosting of the application server and job queue; your photos pass through it during processing – privacy policy
- Google LLC (USA) / Google Ireland Ltd.: AI image creation (Gemini API), sign-in with Google, purchase processing (Google Play Billing), push notifications (Firebase Cloud Messaging), on-device subject selection (ML Kit) – privacy policy
- Apple Inc. (USA) / Apple Distribution International Ltd.: sign-in with Apple and purchase processing (App Store); if you ask Apple for a refund, we tell Apple on request whether the purchase has already been used – privacy policy
- Amazon Web Services EMEA SARL (Luxembourg; region Frankfurt, EU): sending service emails (Amazon SES) – privacy notice
- Wise (Wise Payments Limited, United Kingdom, and its group companies) and, if a partner chooses it, PayPal (Europe) S.à r.l. et Cie, S.C.A. (Luxembourg): commission payouts to partners. They receive the account details and the amount needed for the transfer and process them as independent controllers under their own privacy policies – Wise privacy notice · PayPal privacy statement
These services are required to operate the app. You can object to the associated data transfers by not using the app or the relevant feature (e.g. choosing a different sign-in method, not uploading photos, or disabling push notifications in your device settings) or by deleting your account.
Beyond that, we only disclose data where we are legally required to, or where it is necessary to protect our rights, your safety or the safety of others, or to investigate fraud.
8. International transfers
Some service providers are located in, or process data in, countries outside Switzerland and the EEA, in particular the United States. We base such transfers on adequacy decisions of the European Commission or the Swiss Federal Council (including the EU-U.S. and Swiss-U.S. Data Privacy Framework) or on Standard Contractual Clauses of the European Commission recognised by the Swiss FDPIC.
9. Retention and deletion
- Uploaded photos: processed only temporarily and deleted automatically as soon as generation is complete.
- Generated images: deleted from our servers as soon as your app has downloaded them. An additional automated process removes any leftover temporary files after 24 hours at the latest. Your finished images are stored only locally on your device; there is no cloud gallery.
- Account data, purchase and credit data, push token, redeemed partner codes and editor events: until you delete your account. Records of your store purchases are kept by Google Play or the Apple App Store under their own rules.
- Partner program data: for the duration of your participation. Sign-in links expire after 15 minutes, sessions after 7 days. When the partnership ends, we delete payment details, sign-in data and application details after the last payout. We keep your name, email address, payouts and payout statements (name, address, VAT number, amount) for 10 years, as Swiss law requires.
- Safety blocks: 90 days.
- Reports about images, account status and the record of your acceptance of our Terms of Service: until you delete your account.
- Data subject to statutory retention: as long as the law requires.
10. Your choices and rights
Directly in the app (Profile → Privacy & data) you can at any time:
- view the data stored about you and export it as a file (Export data, View data export),
- withdraw your consent to the processing of your photos (Withdraw photo consent),
- permanently delete your account and all associated server-side data (Delete account),
- delete the images stored locally on your device (Delete local images).
You can turn off push notifications at any time in your device settings. Uninstalling the app stops further data collection but does not delete your account.
Under the FADP and the GDPR you also have the right of access, rectification, erasure, restriction of processing, data portability (in a structured, commonly used and machine-readable format), to object to processing based on legitimate interests, and to withdraw consent. To exercise these rights, write to contact@rutila.app. We respond within one month; for complex requests this may be extended by up to two months.
You can lodge a complaint with a data protection authority:
- Switzerland: Federal Data Protection and Information Commissioner (FDPIC), https://www.edoeb.admin.ch
- EU/EEA: the authority in your country, listed at https://edpb.ec.europa.eu/about-edpb/members_en
- United Kingdom: Information Commissioner's Office, https://ico.org.uk
11. Children
The app is intended only for people aged 18 or over. If we learn that someone under 18 has provided us with data, we delete it promptly. Parents and guardians can reach us at contact@rutila.app.
12. Security and data breaches
We protect your data with technical and organisational measures; access is limited to people who need it to operate and develop the app. If a data breach nevertheless puts your rights at risk, we report it to the competent authority (under the GDPR within 72 hours, under the FADP as soon as possible) and inform you without undue delay if it poses a high risk to you.
13. United States residents
Depending on your state (e.g. California under the CCPA/CPRA, Virginia, Colorado, Connecticut, Texas), you have the right to know which personal information we have collected about you, to have it corrected or deleted, and to limit the use of sensitive information to what is necessary. We do not sell your data or share it for cross-context behavioural advertising. We will not discriminate against you for exercising these rights. Send requests to contact@rutila.app; you may also designate an authorised agent.
14. This website
The website rutila.app is static and sets no cookies. There is no analytics or advertising tracking.
- Vercel Inc. (USA): website hosting; your IP address is processed in server logs – privacy policy
- Google Fonts (Google LLC, USA): fonts are loaded from Google, which transmits your IP address to Google – privacy policy
Partner program: If you apply via the partner form, we store your name, email address, platform, profile link, follower count, preferred code, topic and your confirmation that you are 18 or older in order to run the partner program and pay commissions (Art. 6(1)(b) GDPR). We send you a confirmation email with your code via Amazon SES. While you type, the form checks whether your preferred code is still available. Partners sign in to the partner area with a link we email to them; the session is kept in the browser's local storage, not in a cookie.
15. Changes
We update this privacy policy when our processing changes. We mark material changes with a new date and, where the law requires it, ask for your consent first. Earlier versions are available on request at contact@rutila.app.
16. Language
This privacy policy is available in English and German. The English version is authoritative.