Privacy Policy for CleanSlate

Last Updated: October 23, 2025

This Privacy Policy lays out, in exhaustive detail, how the CleanSlate mobile application ("App") and related services ("Service") collect, use, share, and safeguard your personal data when you use the Service. By downloading, installing, or using the App, you’re agreeing to this policy and confirming you’re either over 16 or have parental/guardian consent. If you’re not on board, kindly step away from the App. Got questions? Hit us up at support@clean-slate.app

1. Information We Collect

We collect a variety of data to keep the App running smoothly and to make it better. Here’s the breakdown:

• Device and Technical Data: We grab details about your device and how you use the App, including:
• IP addresses, device model, operating system version, and app version.
• Usage data like how often you open the App, which features you use (e.g., photo cleanup, video compression), and session duration.
• Crash reports and performance metrics to figure out what’s breaking and why.
• Identifiers & Advertising IDs: We collect device identifiers including IDFA (Identifier for Advertisers), IDFV (Identifier for Vendors), and an internally generated UUID (Universally Unique Identifier).
• User-Provided Content: Anything you voluntarily share, such as:
• Feedback, ratings, or reviews submitted through the App Store.
• Communications when you reach out to our support team, like emails or in-app messages.
• Content you generate within the App, like settings preferences or custom inputs.
• Content required for specific features: To ensure the Service functions properly, we may access:
• Photos or photo libraries (solely for photo management features).
• Email credentials (solely for mail management features).
• Email Service Data (If Enabled): If you grant us access to your email account (e.g., Gmail or iCloud Mail) to use mail management features, our use of your email data adheres to strict limitations:
• We only access email message metadata (e.g., sender, subject, date), headers, and content to provide specific functionality (e.g., deleting, moving, archiving, or unsubscribing from emails).
• This data is not shared with third parties unless required by law.
• We do not use your email data for advertising purposes.
• No human will read your email content unless:
• You give explicit consent for a specific purpose,
• It is necessary for security investigations (e.g., to investigate abuse), or
• We are required to do so by law.
• Analytics Data: We use third-party tools like Firebase to collect aggregated data, such as:
• How many users subscribe to premium features.
• Which features are most popular (e.g., photo cleanup).
• General trends in App usage to help us tweak performance.
• Face Data Processing: Our app processes user-provided photos locally to extract specific facial data points.
• Local Processing: All face data generation and processing occur entirely on-device in an offline environment. No face data is ever transmitted over any network.
• Data Types: The app generates numerical face embeddings (mathematical vectors), facial landmarks (key points describing facial geometry), and blendshape coefficients (values representing facial expressions such as smiles or open eyes) for comparison and analysis.
• Purpose: These data are used exclusively to power on-device photo organization and selection features.
• Storage & Retention: Face data is stored only within the app’s local on-device database and never uploaded to any server. It remains linked to the corresponding photos and is automatically deleted when those photos are removed, when app data is cleared, or when the app is uninstalled.
• No Sharing: We do not upload, sell, or share face data with any third parties.




We don’t collect data from anyone under 16 without verifiable parental consent. If you think a minor’s data slipped through, email us at support@clean-slate.app




2. How We Use Your Information




We don’t just collect data for kicks—here’s what we do with it:




• Run the Service: Deliver core App features like cleaning duplicate photos, compressing videos, or managing storage. Face data is used for features involving photo analysis (e.g., People albums or best-photo selection), see the "Special Note About Face Data" section below for details.
• Personalize Your Experience: Use your usage patterns and preferences to customize content or suggest features. Yes, we’re trying to make your life easier.
• Improve the App: Analyze usage data to fix bugs, optimize performance, and decide which features to prioritize. Tools like Firebase Crashlytics and Performance Monitoring help us spot issues before you rage-uninstall.
• Marketing & Analytics Purposes: We use the collected identifiers to track app installs, user engagement, attribution, and ad performance. These identifiers help us, and our partners, deliver relevant ads, measure campaign effectiveness, and understand user behavior across apps.
• Communicate with You: Send push notifications about updates, promotions, or tips (disable these in your device settings if they bug you). We also respond to your support queries with, hopefully, helpful answers.
• Legal Stuff: Comply with laws, prevent fraud, enforce our Terms of Service, or resolve disputes.
• Analytics: Use aggregated data to understand trends, like how many users love the photo cleanup feature or how often the App crashes on older devices.




3. Sharing Your Information




We don’t sell your data, but we do share it in specific cases:




• Third-Party Service Providers: We work with partners to keep the App running. Examples include:
• Analytics: Firebase for usage insights and crash reporting.
• Infrastructure: Cloud services like Google Cloud for hosting and data processing.
• Ad / Analytics Partners: We share the identifiers (IDFA, IDFV, UUID) with partners such as Google, Facebook, and Adjust. These partners use them to perform attribution, analytics, and ad management.
• These partners are contractually obligated to protect your data and only use it for the purposes we specify.
• Legal Requirements: We may share data if required by law, such as:
• Responding to court orders, subpoenas, or government investigations.
• Preventing fraud or protecting user safety.
• Enforcing our rights or defending against claims.
• Business Transfers: If CleanSlate Team is acquired, merges, or sells assets, your data may be transferred to the new entity. We’ll ensure they treat your data with the same care.
• Aggregated Data: We share anonymized, aggregated data (e.g., “80% of users prefer photo cleanup”) with partners for research or marketing purposes. This data can’t be tied back to you.




For users in the EEA, UK, or Switzerland, data transfers to countries with weaker privacy laws are protected by Standard Contractual Clauses or the EU-U.S. Data Privacy Framework. We’re not here to make GDPR lawyers’ lives harder.




4. Your Data Privacy Rights




You’ve got rights, and we’re legally obligated to respect them. Depending on where you live (e.g., GDPR for EEA, CCPA for California), you can:




• Access: Request a copy of all personal data we have on you.
• Rectification: Fix any incorrect data, like if we somehow got your email wrong.
• Deletion: Ask us to delete your data, though we may keep some for legal reasons (e.g., tax records).
• Restriction: Limit how we use your data.
• Objection: Say “no thanks” to certain processing, like direct marketing.
• Portability: Get your data in a machine-readable format to take elsewhere.
• Non-Discrimination: We won’t punish you for exercising your rights.
• Lodge a Complaint: Contact your local data protection authority (e.g., ICO in the UK) if you think we’re mishandling your data.




To exercise these rights, email support@clean-slate.app with your request, including enough details to identify you (e.g., email used in the App). California residents can request details about data shared for marketing by emailing “Request for California Privacy Information” with your state and email address. We’ll respond within the legally required timeframe (usually 30–45 days).




5. Data Retention and Deletion




We keep your data only as long as needed to:




• Provide the Service (e.g., until you uninstall the App or delete your account).
• Meet legal obligations, like retaining billing records for tax purposes.
• Resolve disputes or enforce agreements.




For example, we retain account-related data while you’re an active user and may keep some data (e.g., transaction records) for up to 7 years to comply with tax laws. If you request deletion, we’ll remove your personal data unless we’re legally required to keep it. Anonymized data (e.g., usage stats) may stick around indefinitely for analytics.




6. Data Security




We take security seriously, using measures like:




• Encryption for data in transit and at rest.
• Secure protocols for data transfers.
• Regular audits to spot vulnerabilities.




That said, no system is bulletproof. Hackers are crafty, and while we do our best, we can’t guarantee absolute protection. If we detect a breach, we’ll notify you as required by law (e.g., within 72 hours under GDPR).




7. International Data Transfers




Your data may cross borders to servers or partners in countries with different privacy laws. For EEA, UK, or Swiss users, we ensure compliance through:




• Standard Contractual Clauses approved by the European Commission.
• EU-U.S. Data Privacy Framework for transfers to the U.S.




We only transfer data to third parties who meet our privacy standards. If you’re curious about specific transfer mechanisms, email us at support@clean-slate.app




8. Third-Party Services




The App integrates third-party services, each with their own privacy policies. Key partners include:




Analytics & Performance Monitoring:

• Firebase (Analytics, Crashlytics, Performance Monitoring) by Google. See Google’s Privacy Policy: https://policies.google.com/privacy
• Adjust: For analytics and attribution. See Adjust’s Privacy Policy: https://www.adjust.com/terms/privacy-policy/




Authentication & API Integration:

• Google Sign-In: For user authentication. See Google’s Privacy Policy: https://policies.google.com/privacy
• Google API Client for REST: For integration with Google services (e.g., Gmail). See Google’s Privacy Policy: https://policies.google.com/privacy




Network & Data Handling:

• Alamofire: For network requests. See Alamofire’s GitHub for more information: https://github.com/Alamofire/Alamofire
• SwiftProtobuf: For data serialization/deserialization. See project details: https://github.com/apple/swift-protobuf




Development & Utility:

• CocoaLumberjack: For logging. See project details: https://github.com/CocoaLumberjack/CocoaLumberjack
• GRDBQuery: For database operations. See project details: https://github.com/groue/GRDBQuery
• Lottie: For animation rendering. See Lottie’s Privacy Policy: https://airbnb.io/lottie/#/README
• swift-async-algorithms: For handling asynchronous operations. See project details: https://github.com/apple/swift-async-algorithms
• swift-collections: For data structure utilities. See project details: https://github.com/apple/swift-collections




We’re not responsible for how these third parties handle your data, but we choose partners with solid privacy practices. We recommend checking their policies for details.




9. Cookies, Tracking, and Similar Technologies




We (and our partners) may use SDKs, tracking pixels, and mobile measurement tools to collect identifiers (IDFA, IDFV, UUID), measure ad performance, and facilitate analytics.




You can manage cookies via your device settings or opt-out links in Section 5. Disabling cookies may limit some App features, so proceed with caution.




10. Children’s Privacy




The App isn’t designed for kids under 16. We don’t knowingly collect their data without parental consent. If you’re a parent and think your kid’s data is in our system, email support@clean-slate.app, and we’ll delete it promptly.




11. Special Note About Face Data




CleanSlate uses on-device technology to analyze faces that appear in the user-selected photos. We take user privacy extremely seriously.




Data Collection:

• All face data generation and processing occur entirely on-device in an offline environment. No face data is ever transmitted over any network.
• The app generates numerical facial landmarks, blendshape coefficients, and face embeddings for comparison and expression analysis. These data types are used only to evaluate photo quality and subject expressions. None of them are biometric identifiers, and they cannot reconstruct or identify a person’s face. We do not retain any original facial data once processing is complete.
• Facial Landmarks: 2D coordinates of key facial feature points within the photo.
• Blendshape Coefficients: Numerical values representing specific facial expressions.
• Face Embeddings: Mathematical vectors used to identify and group similar faces. It is important to note that these embeddings are not biometric identifiers; they are abstract representations that cannot be used to reconstruct a face or identify a specific, real-world individual.




Data Use:

• Face data is processed solely to provide the app’s core on-device functionality. It is used only to identify the best photo among similar images based on expression and quality.
• The data is never used for advertising, tracking, or any purpose other than this feature, and it never leaves the user’s device.
• The specific uses are:
• Facial Landmarks and Blendshape Coefficients: These are used to analyze facial pose and expression. This analysis is a crucial component of our “best photo” scoring algorithm, ensuring that photos featuring better expressions (e.g., smiling, eyes open) receive higher scores when recommending which duplicate to keep.
• Face Embeddings: These are used to cluster similar faces into a “People Album,” facilitating features that allow users to quickly find duplicate photos containing specific individuals.
• Favorites Ranking: Users can designate specific individuals as “favorites.” The app uses embeddings to recognize these individuals and applies a higher weight to their facial expressions during the “best photo” calculation, ensuring their best looks are prioritized.




Data Sharing and Disclosure

• All face data (landmarks, blendshapes, and embeddings) is generated and processed strictly on-device using built-in local models. No data is ever sent to or processed by external servers.
• We do not share any of this face data with third parties.
• All data is stored securely within a local database inside the App Sandbox.




Data Storage and Retention

• Face data requires persistent local storage to allow for immediate re-calculation of “best photo” recommendations if a user updates their “favorite” people settings.
• Retention is strictly tied to the source media: if a user deletes a photo, the associated face data is immediately removed from the local database.
• All face data is permanently erased if the user uninstalls the app or clears the app's data.




12. Changes to This Privacy Policy




We may update this policy to reflect new features, or legal requirements. We’ll notify you of significant changes via:




• In-App notifications.
• Email (if applicable).




Continued use of the App after changes means you accept the new policy. If you don’t like it, uninstall the App and let us know why at support@clean-slate.app




13. Contact Us




Got complaints, questions, or just want to chat about data privacy? Reach out:

• Email: support@clean-slate.app