Privacy Policy

Last updated: December 8, 2025

ATN Marketing ("we", "our", "us") operates the PiXmas and Picsmas AI Photo Editor services ("Service"). We are based in the European Union and are committed to protecting your privacy.

1. Overview

Your privacy matters. We designed PiXmas so that you can create AI Christmas photos safely, privately and without sharing personal information. We take privacy extremely seriously and designed the app so that:

By using the app, you consent to the practices described below.

2. What Data We Do NOT Collect

We do not collect or store:

Your images never stay on our servers. We do not have access to them.

3. Images You Upload (Face Data)

When you upload a photo, it may contain a person's face. We treat it as sensitive data, and:

The image is stored temporarily only to send it to Google's Gemini API and generate your result. It is then deleted automatically. Neither PiXmas nor Google Gemini stores uploaded photos after processing; images are automatically deleted once the AI output is returned. All images are sent in base64 encryption.

4. How Your Photos Are Processed

PiXmas is an AI image generator. When you upload a photo to create a Christmas scene:

We do not view, store, copy or have access to any photos.

5. How We Use Your Data

We use your data exclusively to:

We do not use your data to:

6. Face Data Processing

6.1 What Face Data Is Processed

Only the photo you upload. No additional analysis or identification is performed. We do not collect, derive, or process biometric identifiers or any facial geometry data.

Images you upload may contain faces. We treat these images as sensitive data. We do not extract biometric identifiers, facial measurements, or faceprints. Images are used solely to generate the requested AI transformation. Images are transmitted to Google's Gemini API for processing and are automatically deleted immediately after processing. We do not retain, store, sell, or share face data.

6.2 Purpose of Processing

Exclusively to generate the requested AI output (Christmas scene, portrait, style transformation).

6.3 Third-Party Processing

Photos are transmitted securely to Google Gemini API, which acts solely as a data processor. Google does not use your photos to train models when using Gemini for data processing.

Google processes uploaded photos only as a data processor acting on our behalf. Google does not store these images after processing, does not use them to train models, and does not use them for any advertising or tracking purposes. All images are sent in base64 encryption.

For more information about Google's AI privacy approach, visit:
Google Privacy Policy
Google Gemini Privacy Overview

6.4 Retention

6.5 No Sharing with Third Parties

Face data is never:

Only Google receives images purely for AI processing.

7. Tracking & ATT (App Tracking Transparency)

PiXmas does not track users for advertising purposes.

We do not:

ATT permission is not required, because we do not track.

8. Third-Party Providers

To generate your AI photos, PiXmas uses:

We do not share data with advertisers or data brokers.

9. Subscriptions & Payments

Subscriptions are managed securely through Apple. We do not receive or store any payment information. We only receive anonymous transaction confirmations (no payment card information). All billing is processed by Apple according to:

Apple Standard License Agreement

10. Data Security

We use:

All image transfers occur using encrypted HTTPS connections. No data is persisted or stored on our servers. Your creations exist only on your personal device.

11. Data Retention Summary

Data Type Retention
Uploaded photos Deleted immediately after processing
Generated images Saved only to user device if the user chooses
Crash logs Kept anonymized for stability
Purchases Apple manages; we store none

We do not retain any face images or associated data on our servers after processing is completed.

12. Children's Privacy

PiXmas is not designed for children under 13 without parental supervision. We do not knowingly collect personal data from children. We store no identifying data about any user.

13. Your Rights

Depending on your region, you may request:

14. Changes to This Policy

We may update this Privacy Policy when necessary. The updated version will always be available on this page. We will notify users accordingly.

15. Contact Us

If you have questions about this Privacy Policy, contact us at: hello@mindtastik.com