Photold Privacy Policy

This Privacy Policy ("Policy") describes how Pace Tech ("Pace Tech", "we", "us" or "our") handles information in connection with the Photold mobile application (the "App"). It applies to all users of the App, regardless of country.

By downloading, installing or using the App you confirm that you have read this Policy in full and that you accept it. If you do not accept it, you must stop using the App and uninstall it.

1. Who We Are and How to Reach Us

• Data controller / publisher: Pace Tech
• Application: Photold (co.pacetech.photold)
• Privacy contact: info@pacetech.co

For the purposes of the EU/UK General Data Protection Regulation, the United Kingdom Data Protection Act 2018, the California Consumer Privacy Act / CPRA and the Turkish Personal Data Protection Law (KVKK), Pace Tech acts as the data controller for the limited categories of information described below.

2. Summary (Non-Binding)

This summary is provided for convenience. The remainder of the Policy is what binds the parties.

• We do not require an account, sign-in, name, email, phone number, address or location.
• We do not maintain a server-side database of users or photos.
• We do not embed advertising, analytics or tracking SDKs.
• We do not sell, share or rent personal data.
• We process your photos only on your device, except for the opt-in AI Colorize and AI Restore features, which each send a single image to Google's Gemini API at your request and at your risk.
• The number of AI Colorize / AI Restore operations you can perform is subject to allowances that may differ by subscription tier, by country or region, and that may change over time — no specific number is promised.

3. Information We Process

3.1 Photos and Camera Input

When you scan a printed photograph or pick an image from your photo library, the image is captured by the operating system's standard camera or photo library APIs. Photold receives the image solely for the purpose of:

• displaying it in the editor;
• performing local cropping, perspective correction and filter previews;
• writing the final result to your device's Photos library when you tap Save; and
• (only if you tap Colorize or Restore) transmitting a single copy to Google's Gemini API as described in Section 3.2.

Images are stored in your device's standard application cache only for as long as you are working on them, and are deleted by the operating system or by you when you discard or close the editor. Pace Tech does not transmit your images to any infrastructure that Pace Tech owns or controls.

3.2 AI Colorize & AI Restore Features (Third-Party Processing)

The Colorize with AI and Restore with AI buttons are opt-in features. Each time and only each time you tap one of them, the App transmits a copy of the selected image to Google LLC's Gemini API (model gemini-2.5-flash-image) for the purpose of generating, respectively, a colorized or a restored version of that image. The result is returned to your device.

The number of AI Colorize and AI Restore operations you are allowed to perform is limited by an allowance that depends on your current subscription tier (free, weekly, monthly, yearly, etc.) and that may also differ by country, region or storefront. No specific number is promised in this Policy; the only figure that applies to you is the one shown inside the App or in the App Store / Google Play listing for your current package in your country. These allowances — and the reset cadence, carry-over rules, pricing and any overage or credit-pack options — may be introduced, changed or removed by Pace Tech at any time, as further described in the Terms of Use.

You acknowledge and agree that:

• the image leaves your device and is processed by Google on infrastructure that Pace Tech does not own, control, audit or supervise;
• Google's processing is governed by Google's own Terms of Service, Privacy Policy and Generative AI Prohibited Use Policy, available at ai.google.dev/gemini-api/terms and policies.google.com/privacy;
• Google may temporarily retain the request and the response for safety, abuse prevention, debugging and product improvement, and may transfer the data internationally;
• Pace Tech is not a controller, processor or guarantor of Google's processing and disclaims all liability for it; and
• you are solely responsible for ensuring that you have all rights necessary to submit the image to a third-party AI service.

If you do not consent to this third-party processing, do not tap the Colorize or Restore buttons. Every other feature of the App functions entirely on-device.

3.3 Local Settings and Counters

The App stores small, non-personal values on your device using the operating system's standard preferences storage:

• a flag indicating whether onboarding has been completed;
• the current AI Colorize and AI Restore usage counters, the date each was last reset and the subscription tier associated with your device, used solely to enforce per-package usage allowances.

These values never leave your device and contain no personal information. They are deleted when you uninstall the App or clear its data via your device settings.

3.4 Diagnostic and Aggregate Data Collected by the Platforms

Apple Inc. and Google LLC, as the operators of the App Store and Google Play, may collect aggregate, de-identified analytics and crash reports relating to your use of the App. This collection is performed by the platform itself and is governed by the platform's own privacy policy. Pace Tech does not receive personally identifying data from these reports.

4. Information We Do Not Collect

For clarity, Pace Tech does not collect, request or process the following information through the App:

• name, email address, postal address, telephone number;
• precise or approximate geolocation;
• contacts, calendars, microphone audio, sensor data;
• advertising identifiers (IDFA, GAID), device serial numbers or IMEI;
• payment information (purchases are processed by Apple or Google directly);
• behavioral or interest-based profiles.

5. Legal Bases for Processing (EU/UK/Türkiye Users)

Where data protection laws require a legal basis, Pace Tech relies on:

• Performance of a contract (Article 6(1)(b) GDPR / Art. 5(2)(c) KVKK) to deliver the on-device features you request.
• Your consent (Article 6(1)(a) GDPR / Art. 5(1) KVKK), given by your explicit tap on the Colorize with AI or Restore with AI button, to transmit the relevant image to Google's Gemini API. You may withdraw this consent at any time by simply not tapping the button. Withdrawal does not affect the lawfulness of processing already carried out.
• Our legitimate interests (Article 6(1)(f) GDPR) in operating, securing and improving the App, where these are not overridden by your rights.

6. Permissions

The App will, through the operating system, request permission to access:

• Camera — to capture printed photos;
• Photo Library (read access) — to import an existing image for cropping;
• Photo Library (add access) — to save your scanned and edited photos.

Permissions are granted by you to the operating system, not to Pace Tech. You may revoke any permission at any time in your device settings; doing so may disable the related feature.

7. Data Retention

8. International Transfers

The App itself does not transfer personal data internationally on Pace Tech's behalf. However, any image you submit through the AI Colorize or AI Restore features is transmitted to Google's Gemini API, which processes data in Google's global infrastructure. By tapping Colorize or Restore, you provide your explicit consent to that international transfer (Article 49(1)(a) GDPR / Art. 9(1) KVKK), with full awareness that the destination jurisdiction may not provide a level of data protection equivalent to your country of residence.

9. Security

Pace Tech implements commercially reasonable technical and organizational measures designed to protect the limited information processed by the App, including HTTPS-only network communication for the AI Colorize and AI Restore features. No system, including the operating system on your device and the public internet, is perfectly secure. Pace Tech does not warrant that the App or any related transmission is invulnerable to interception, unauthorized access or compromise. You assume the residual risk of using a connected mobile application.

10. Your Rights

Depending on the jurisdiction in which you reside, you may have the right to:

• request access to, correction or deletion of personal data we hold about you;
• request restriction of, or object to, processing;
• request data portability;
• withdraw any consent you have given;
• not be subject to a decision based solely on automated processing that produces legal effects on you (none such occur in the App);
• lodge a complaint with your local data protection authority — for example, the Information Commissioner's Office (UK), the European Data Protection Board or the Turkish Personal Data Protection Authority (KVKK).

Because Pace Tech does not maintain a server-side database of identifiable users, in most cases there is no personal data on our infrastructure to retrieve, rectify or delete. Where you have submitted an image to Google through the AI Colorize or AI Restore features, requests relating to that image must be directed to Google. We will respond to legitimate, sufficiently identified requests sent to info@pacetech.co within 30 days.

11. Children's Privacy

The App is not directed to children under the age of 13 (or under 16 in the European Economic Area, the United Kingdom and any other jurisdiction whose law applies a higher minimum age for the processing of children's personal data). Pace Tech does not knowingly collect personal information from children below the applicable age threshold. If you believe a child has used the App or that we have inadvertently received information from a child, please contact us at info@pacetech.co and we will take appropriate action, including deletion of any such information from our records.

If you are below the applicable minimum age in your jurisdiction, you may use the App only with the verifiable consent and supervision of a parent or legal guardian.

12. Do Not Track / Global Privacy Control

The App does not engage in cross-context behavioral advertising, tracks no activity across third-party apps or websites, and does not respond to Do Not Track or Global Privacy Control browser signals because no browser-based interface is offered.

13. Changes to This Policy

Pace Tech may update this Policy from time to time, including in response to changes in the App, applicable law or third-party services. The "Effective date" and "Last updated" lines at the top of this Policy reflect the current revision. Material changes will be communicated through the App's release notes or through an in-App notice. Your continued use of the App after a revised Policy becomes effective constitutes your acceptance of the revised Policy. If you do not accept a revision, you must stop using the App.

14. Contact

Privacy questions, requests or complaints:

Email: info@pacetech.co
Subject line: Photold — Privacy

Pace Tech