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Photold Privacy Policy

Effective date: October 8, 2026 · Last updated: October 8, 2026

This Privacy Policy ("Policy") describes how Pace Tech ("Pace Tech", "we", "us" or "our") collects, uses and shares information in connection with the Photold mobile application (the "App") and the Photold pages and purchase flow on pacetech.co (the "Website"). It applies to all users, regardless of country.

By downloading, installing or using the App or the Website you confirm that you have read this Policy. If you do not accept it, please stop using the App and the Website.

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 information described below. The service providers listed in Section 7 process information on our behalf or, where stated, as independent controllers under their own privacy policies.

2. Summary (Non-Binding)

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

  • The App creates an account for you automatically, without a name or password. You may sign in with your e-mail address (or, on Android, your Google account) to use the same account on another device.
  • Photos you save to your Photold library are kept on your device and backed up to our cloud storage, linked to your account.
  • When you use an AI feature, the selected image is sent through our servers to our AI providers (Google and eachlabs) to create the result.
  • We use analytics, crash reporting and advertising measurement tools. Where the law requires it, we ask for your consent first; on iOS, tracking only happens if you allow it.
  • If you do not have a subscription, you can choose to watch rewarded ads, served by Google AdMob and its partners Liftoff Monetize and Unity Ads, to earn credits.
  • Payments are handled by Apple, Google or, on the Website, FastSpring (our reseller and merchant of record). We never receive your payment card details.
  • We do not sell your personal data for money, and we do not use your photos to train AI models.
  • You can delete your data at any time in the App under Settings → Delete my data.

3. Information We Process

3.1 Account Information

On first launch the App creates an anonymous account with a random identifier. If you sign in with an e-mail link, we process your e-mail address; if you sign in with Google on Android, we receive your e-mail address and Google account identifier. If you buy on the Website, we receive your e-mail address, name and country from the checkout and use them to create or link your account and to send you sign-in and order e-mails.

3.2 Photos and Your Library

When you scan a printed photograph or import an image, the App processes it to crop, correct and edit it. Photos you save to your Photold library, together with their thumbnails, albums and scan details, are stored on your device and in our cloud storage (Google Firebase), linked to your account, so that your library is kept if you reinstall the App or sign in on another device. Embedded location metadata (EXIF) is removed from library photos before they are stored. Photos you save to your device's photo library are controlled by you.

3.3 AI Features

When you start an AI feature (for example, colorize, restore or animate), the App sends the selected image(s) and the options you chose through our servers to our AI providers: Google (Gemini API) and eachlabs, which may run the request on AI models of other providers. The result is returned to the App. Images uploaded to eachlabs are deleted once the result is ready, and in any case within about two hours. Google processes requests under the Gemini API terms. We also keep a record of each AI operation (type, status and credits used) to charge and refund credits, enforce usage limits and prevent abuse.

Only submit images you have the right to use. If you do not want an image processed by these providers, do not start an AI feature for it.

3.4 Credits, Subscriptions and Purchases

We keep your credit balance, credit usage and rewarded-ad credits on our servers. Subscriptions and in-App purchases are processed by Apple or Google; we receive the purchase details (product, dates, status and a transaction identifier) through RevenueCat. Purchases on the Website are sold by FastSpring, our reseller and merchant of record, which collects your payment and billing details and processes them as an independent controller under its own privacy policy; we receive only the order details (order number, product, price, country, your name and e-mail address). Payment card details are handled only by Apple, Google or FastSpring.

3.5 Rewarded Ads

If you do not have a subscription, you can choose to watch a rewarded video ad to earn credits. Ads are served by Google AdMob, which may fill a request through its mediation partners Liftoff Monetize (Liftoff / Vungle) and Unity Ads. When an ad is loaded or shown, these providers may collect your IP address (from which an approximate location can be derived), your device's advertising identifier (on iOS only if you allow tracking), device and app information, information about the ads you see and how you interact with them, and diagnostics. Each provider processes this data under its own privacy policy: Google, Liftoff, Unity. To credit a watched ad, Google sends our server a signed confirmation containing your account identifier and a transaction identifier.

3.6 Analytics, Crash Reports and Attribution

We use Google Firebase (Analytics, Crashlytics, Remote Config) to understand how the App is used, to fix crashes and to configure features, and Meta App Events and Apple's attribution service to measure which ads led to an install or purchase. These tools process app events, device and app information, an app-instance identifier and, where permitted, your device's advertising identifier. In the EEA, the UK and Switzerland, analytics and marketing tools run only after you consent; on iOS, your advertising identifier is used only if you allow tracking.

3.7 Information Stored on Your Device

The App stores settings on your device, such as onboarding progress, your consent choices and cached values (for example your credit balance). They are deleted when you uninstall the App or use Delete my data.

3.8 The Website

The Photold pages on pacetech.co use Google Analytics and PostHog to measure visits and the steps of the purchase flow, and the Meta Pixel to measure which of our ads lead to visits and purchases (for example that a checkout was started or a plan or credit pack was bought, with its price). These tools set cookies or similar identifiers in your browser and receive your IP address, browser information and the pages you visit. When you buy, we also report the purchase to Meta from our server (Meta's Conversions API) with its amount, your country and your e-mail address in hashed (SHA-256) form, so Meta can link it to the ad you came from; this happens only when the Meta Pixel is allowed to run for you. Checkout is provided by FastSpring as described in Section 3.4.

Visitors from Europe (including the EEA, the UK, Switzerland and Türkiye) are asked first: none of these tools load until you accept, and the site works the same if you reject them. You can change your choice at any time: .

3.9 Information We Do Not Collect

We do not access your contacts or calendar, and we do not collect your precise (GPS) location.

4. How We Use Information

  • to provide the App, your account and your library, including sync across devices;
  • to run the AI features you request and manage credits, subscriptions and purchases;
  • to show the rewarded ads you choose to watch and credit them;
  • to send sign-in, purchase and service e-mails;
  • to measure and improve the App and our marketing, and to fix errors;
  • to prevent fraud and abuse, enforce usage limits and keep the service secure; and
  • to comply with legal obligations.

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

  • Performance of a contract (Article 6(1)(b) GDPR / Art. 5(2)(c) KVKK): your account and library, AI features you start, credits, purchases and rewarded ads you choose to watch.
  • Your consent (Article 6(1)(a) GDPR / Art. 5(1) KVKK): analytics, marketing measurement and personalised ads where consent is required, and tracking on iOS. You may withdraw consent at any time (see Section 12); this does not affect processing already carried out.
  • Our legitimate interests (Article 6(1)(f) GDPR): security, fraud prevention, crash diagnostics and non-personalised ads, where these are not overridden by your rights.
  • Legal obligation (Article 6(1)(c) GDPR): keeping purchase and tax records.

6. Permissions

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

  • Camera — to scan printed photos;
  • Photo Library — to import images and to save your results;
  • Tracking (iOS) — to use your advertising identifier for ad measurement and relevant ads.

You may revoke any permission at any time in your device settings; doing so may disable the related feature.

7. Who We Share Information With

Provider Purpose
Google (Firebase, Google Cloud) Account, cloud storage of your library, servers, analytics, crash reports, configuration
Google (Gemini API), eachlabs AI features
Google AdMob, Liftoff Monetize, Unity Ads Rewarded ads
Meta Platforms Advertising measurement (App Events in the App, Meta Pixel on the Website)
Apple, Google Play, RevenueCat In-App purchases and subscription management
FastSpring Website checkout, payment and tax (as merchant of record and independent controller)
Resend Sending sign-in and order e-mails
PostHog Website analytics

We may also disclose information where required by law, to protect our rights or the safety of others, or in connection with a merger, acquisition or sale of assets.

8. Data Retention

Category Retention
Account, library, credits, AI operation and ad-reward records Until you delete your data or account
Images sent to eachlabs Deleted when the result is ready, at the latest within about two hours
Images sent to Google's Gemini API Per Google's Gemini API terms
Purchase and tax records As long as required by law
Analytics, crash and advertising data For the retention periods set in the respective provider's service
Settings on your device Until you uninstall the App or delete your data

9. International Transfers

Our servers are located in the United States, and our service providers may process information in other countries whose data protection laws may differ from those of your country. Where required by law, these transfers rely on appropriate safeguards offered by the providers, such as the European Commission's Standard Contractual Clauses.

10. Security

Pace Tech uses commercially reasonable technical and organizational measures to protect your information, including encrypted (HTTPS) connections, authenticated access to our servers and access rules that limit each account to its own data. No system is perfectly secure, and we cannot guarantee that information will never be accessed, disclosed or lost.

11. Your Rights

Depending on where you live, you may have the right to:

  • access, correct or delete your personal data;
  • restrict or object to processing;
  • receive your data in a portable format;
  • withdraw any consent you have given;
  • opt out of the "sale" or "sharing" of personal data and of targeted advertising (US state laws); and
  • 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).

Settings → Delete my data in the App permanently deletes your account and the data linked to it. Records we must keep by law (such as purchase and tax records) are kept only as long as required. For other requests, write to info@pacetech.co; we will respond within 30 days.

12. Advertising and Tracking Choices

  • iOS: you can allow or deny tracking when the App asks, and change it later in Settings → Privacy & Security → Tracking.
  • Android: you can reset or delete your advertising ID in your device settings.
  • EEA, UK and Switzerland: the App asks for your consent before analytics, marketing measurement and personalised ads are used, and you can change your ad choices in the App under Settings → Ad privacy choices.
  • Website: in Europe, analytics and the Meta Pixel run only after you accept them in the cookie banner; use Cookie settings in Section 3.8 to change your choice. Everywhere, you can block or delete cookies in your browser.
  • US state laws: we do not sell personal data for money, but using advertising identifiers for ads may count as "sharing" or targeted advertising. You can opt out by denying tracking (iOS), deleting your advertising ID (Android) or e-mailing us.

The App and the Website do not respond to browser Do Not Track signals.

13. 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.

14. 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.

15. Contact

Privacy questions, requests or complaints:

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

Pace Tech

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