Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

2. Minimum Age

CartoonMe carries an App Store age rating of 9+ and is suitable for users aged 9 years or older. Younger users should use the app under the supervision of a parent or legal guardian.

Account creation (which requires an email address) is intended for users aged 13 or older. Users under 13 may still explore the app's AI features in guest mode without creating an account. If you are under 16 and located in the European Economic Area (EEA) or Switzerland, you may only create an account with the consent of a parent or legal guardian.

We do not knowingly collect personal data from children under 13. If we learn that we have collected data from a child under 13, we will promptly delete it. If you believe a child under 13 has provided us with personal data, please contact us at info@dreamr.ch.

3. Data We Collect

Account Information

• Email address (for account creation and authentication)
• Name or display name (optional, for personalization)

Photos and Facial Images

• Photos you upload for cartoon generation or face swap features
• These photos are sent to third-party AI services for processing (see Section 5)
• We do not use facial recognition or biometric identification technology
• Photos are processed solely to generate the requested image and are not used to identify individuals

User-Generated Content

• Comics you create and save within the app
• Custom text, images, and templates you upload
• Folders and organization preferences

Usage Data

• App interaction data (features used, time spent)
• Device information (device type, operating system)
• Approximate location (country, region and city) derived from your IP address by our analytics provider — an estimate at city level, not precise or GPS location
• Technical logs for error diagnosis and app improvement

Purchase Data

• Subscription status and entitlements (managed by RevenueCat)
• We do not have access to your payment details (credit card, bank account) — these are handled exclusively by Apple App Store or Google Play

4. Legal Basis for Processing (GDPR Art. 6)

We process your personal data based on the following legal grounds:

• Contract performance (Art. 6(1)(b)): To provide the app, your account, and its features — including AI comic generation and saving
• Consent (Art. 6(1)(a)): When you upload photos for AI processing, and when you allow advertising measurement through Apple's App Tracking Transparency prompt
• Legitimate interest (Art. 6(1)(f)): To run privacy-focused product analytics, improve app performance, fix bugs, prevent fraud, and ensure security

We do not sell your data to third parties. You may withdraw consent at any time by contacting us or deleting your account.

5. Third-Party Services and AI Processing

CartoonMe uses third-party services to provide its features. When you use certain features, your data may be shared with these providers:

AI Image Generation

Authentication & Email

Payments & Subscriptions

Advertising & Attribution

The following applies only after you agree to Apple's App Tracking Transparency prompt. If you decline, nothing below is sent, and iOS blocks these connections at system level.

We never send your photos, your generated comics, your story texts, your name or your email address to these advertising partners.

These third-party providers process your data according to their own privacy policies. We only share the minimum data necessary for each service to function. Photos sent for AI processing are used solely to generate the requested image and are not stored permanently by these providers for training purposes (subject to each provider's current policies).

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

• Account data: Retained while your account is active and for 30 days after deletion request
• User-generated content: Retained until you delete it or close your account
• Usage data: Anonymized or deleted after 12 months
• Technical logs: Automatically deleted after 90 days

After the retention period, data is securely deleted or anonymized so it can no longer identify you.

7. Your Rights

Under GDPR and Swiss FADP, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your account and data
• Export your data in a portable format
• Withdraw consent at any time

Contact us via email to exercise any of these rights. We respond within 30 days.

8. International Data Transfers

Your data may be processed on servers located in different countries. When we transfer data outside the European Economic Area (EEA) or Switzerland, we ensure adequate protection through:

• EU Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Swiss-recognized safeguards under FADP

We only work with service providers who comply with GDPR and provide appropriate data protection guarantees.

9. Cookies and Tracking

CartoonMe is a mobile application and does not use traditional browser cookies. However, we may use similar technologies:

Essential Data

• Authentication tokens to keep you logged in
• Local storage for app preferences and cached content

Product Analytics

We use a privacy-focused product analytics service, hosted on servers in the European Union, to understand how the app is used so we can improve features and fix problems. This data is pseudonymised and is never sold.

• Events we record: app opens, which template you select, when a generation starts, completes or fails, when the paywall is shown or dismissed, when a subscription starts or is restored, share taps, and when a photo is picked or taken
• What we do NOT record: your photos, your generated comics, the text of your stories, your email, or your name
• Identifier: a random per-install ID, linked to your account ID after sign-in — no personal data is attached
• Approximate location: our analytics provider derives a coarse location (country, region and city) from your IP address. This is an estimate at city level — we do not collect precise or GPS location
• International transfers are covered by EU Standard Contractual Clauses

Crash Reporting

We use a crash-reporting service to capture technical errors and crashes. Sensitive information (your email, IP address, authorization headers and query strings) is removed before any crash report is sent.

• What is sent: stack traces, device model, operating-system version and app version
• What is NOT sent: your email, your photos, or your comic content

Advertising Measurement

CartoonMe shows no advertising inside the app. We do use advertising measurement: if you agree to Apple's App Tracking Transparency prompt, your device advertising identifier and a small number of app events are shared with Meta and TikTok so we can tell which advertisement brought you here. Section 5 lists exactly what is sent.

If you decline, no advertising identifier is transmitted and iOS blocks these connections. You can change your choice at any time under iOS Settings → Privacy & Security → Tracking → CartoonMe. We still use no offer walls, we do not collect precise or GPS location, and we never sell your data.

You can request deletion of your analytics events at any time, or ask us to disable analytics for you, by contacting us at info@dreamr.ch.

10. Swiss FADP Compliance

For users in Switzerland, we comply with the Swiss Federal Act on Data Protection (FADP/nDSG) and its revisions (effective September 1, 2023):

• We process data in good faith and proportionately
• Data is collected only for specified, explicit purposes
• We implement appropriate technical and organizational security measures
• You have the right to information about your data processing (Art. 25 nDSG)
• You have the right to data portability (Art. 28 nDSG)

Swiss residents may lodge complaints with the Federal Data Protection and Information Commissioner (FDPIC).

11. Right to Lodge Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority:

EU Residents

You may contact your local Data Protection Authority in any EU member state where you reside, work, or where the alleged infringement occurred.

Swiss Residents

We encourage you to contact us first so we can address your concerns directly.

12. Contact Information

For any questions about this Privacy Policy or to exercise your data protection rights, please contact:

We aim to respond to all data protection requests within 30 days. For complex requests, we may extend this period by an additional 60 days, in which case we will inform you of the extension and reasons.

Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any material changes through the app or via email. Your continued use of CartoonMe after such changes constitutes acceptance of the updated policy.