This Privacy Policy explains how Halloween Filter collects and uses information when you use the Halloween Filter iPhone app. Halloween Filter is the data controller for the information described below. Questions and privacy requests can be sent to admin@singmehappybirthday.com.
Who we are
Halloween Filter is an independent entertainment app operated from the United Kingdom. For privacy enquiries, requests or complaints, email admin@singmehappybirthday.com. If you need a postal contact address for a formal data-protection request, ask by email and we will provide it.
Information we collect
Depending on how you use the app, we collect:
- Your source photo and the AI-generated Halloween portrait created from it.
- A device identifier generated by the app and stored in the iPhone Keychain, which allows the app to create an anonymous account and keep track of render availability.
- Sign in with Apple information, including your stable Apple account identifier and, when Apple supplies them, your name and email address. The email may be an Apple private-relay address. Apple supplies a name only on the first sign-in.
- Purchase records, including Apple transaction ID, product, credits granted, the signed transaction record and credit-ledger entries.
- Refund information, including your prior Apple refund count and how much of a purchase was used when Apple asks us about a refund request.
We do not include analytics or tracking SDKs, collect advertising identifiers, show advertising, or use your information for cross-app tracking. The Halloween app does not record your IP address in its account or render records and does not use push notifications.
How we process your photo
When you create a portrait, the app converts your selected image to JPEG and securely uploads it to our service. The original is stored privately in Amazon S3 in the EU (Stockholm) region. All Halloween Filter image generation uses Google Gemini. We send the image, together with the effect instructions you chose, from our server to a Google Gemini image model. This means your photo leaves our own systems and is processed by Google as our AI service provider.
Google’s current Gemini API terms say that content handled under its paid-service data terms is not used to improve Google’s products, although prompts and responses may be logged for a limited period for safety, abuse prevention and legal obligations. Google’s terms apply those paid-service data protections to services made available in the United Kingdom, European Economic Area and Switzerland. See the Gemini API Additional Terms and Google Privacy Policy.
We do not use your photo or portrait to train our own AI models. The finished portrait is AI-generated. It is an illustration or stylised image, not a photograph or a factual record.
Storage, links and deletion
We store your original photo and generated portrait until you delete that render. Generated portraits are delivered to the app through private links that expire after seven days; expiry of a link does not itself delete the stored files.
To delete a render, open Gallery in the app and delete it. This requests deletion of both the source photo and generated result from storage. Signing out does not delete your server-side account, purchase history or renders.
The current app does not yet provide complete in-app account deletion. To request deletion of your account and associated personal data, email admin@singmehappybirthday.com from the address associated with Sign in with Apple, or include enough information for us to identify the account. Some purchase records may need to be retained where required for accounting, fraud prevention or legal obligations.
Purchases, fraud prevention and Apple refunds
We use purchase and credit-ledger records to deliver render packs, prevent duplicate credit grants and investigate fraud or refund abuse. Our legal basis is performance of our contract for purchases and our legitimate interests in protecting the service from misuse.
Consent for this reporting is given when you accept the Terms of Use and Privacy Policy during Sign in with Apple. We record the version and time accepted. You can object to future refund-consumption reporting by emailing admin@singmehappybirthday.com. We will apply your choice to your account.
Our legal bases
- Consent for processing the photo you choose to submit for an AI transformation. You can withdraw this by deleting the render and not submitting further photos.
- Contract to provide the app, authenticate your account, deliver purchased renders and maintain your balance.
- Legitimate interests to secure the service, maintain transaction records and prevent or respond to fraud and refund abuse.
- Legal obligation where records must be retained or disclosed under applicable law.
Your data-protection rights
Depending on where you live and the circumstances, you may have rights to be informed, access your personal data, correct it, have it erased, restrict processing, receive portable data, and object to processing. Read the ICO guide to individual rights.
Email admin@singmehappybirthday.com to exercise a right. We may need to verify your identity. You can also complain to the UK Information Commissioner’s Office through ico.org.uk.
Children
Halloween Filter is not directed to anyone under 18. Do not use the app if you are under 18, and do not upload a photo of a minor. If you believe a minor’s information has been submitted, contact us so we can delete it.
Changes to this policy
We may update this policy as the app changes. Material changes to how information is shared will use a new policy version and may require renewed acceptance in the app.
Policy version: 2026-08-21