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Privacy Policy

Effective date: 26 October 2026

This Privacy Policy explains how ART APP LTD (“we”, “us”) processes data when you use Temfy: AI Comic & Manga Maker (formerly Temfy: AI Comic & Manga Maker), an app that turns your story into a comic with artificial intelligence (the “App”). We are the controller of this data for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Premium and credit packs bought on the website temfy.app/comics/ are also sold by ART APP LTD, as described in section 5.

1. In short

2. Legal bases

We process data to perform our contract with you (generating comics, subscriptions and credits), on the basis of our legitimate interest in running, protecting and improving the App, and on the basis of your consent where we ask for it (processing photos and text for generation, notifications, support requests).

3. Data on your device

3.1. Characters (a name and a photo you picked from your library), finished comics (cover and pages), story history, the chosen style, number of pages and interface language are stored on your device. Photos are chosen in the system photo picker: the App receives only the photos you select and has no access to the rest of your library.

3.2. The “comic is ready” notification is local: it is created on the device without a server. You can turn notifications off in the device settings.

3.3. When you save or share a comic, the App opens the system share sheet; you decide what to send and to whom, and we do not receive that data.

4. Comic generation

4.1. When you tap “Create”, the App sends the story text, the chosen style and your characters’ names and photos (scaled down to 1024 pixels on the longer side) to our server function (Google Cloud Functions for Firebase, USA). The function passes them to the Google Gemini API (Google LLC), which draws the cover and pages, and returns the images to the App.

4.2. We do not store the story text, photos or generated images on our servers: they exist on the server only while the comic is being generated. Google processes them as a service provider under the Gemini API terms.

4.3. Do not upload photos of people without their consent. Before the first generation the App explains what is sent and asks you to confirm.

4.4. To make sure the server accepts requests only from the genuine App, we use Firebase App Check (Apple App Attest / DeviceCheck), which verifies the App and device without sending your personal data.

5. Subscriptions and credits

5.1. Subscriptions and credit packs are sold and charged by the App Store; we have no access to your payment details. Purchases are processed by RevenueCat (USA), which receives a random App user identifier created at installation and not linked to your name, email or phone number, your purchase history and subscription status. RevenueCat Privacy Policy.

5.2. Your credit balance is kept on our server (Google Cloud Firestore): the App user identifier, the credit balance, purchases already counted (RevenueCat transaction identifiers) and records of charges for generation (number of pages, time, outcome). Stories, photos and comics are not stored there.

5.3. If you came from an Apple Search Ads campaign, RevenueCat receives an attribution token from Apple (AdServices) to identify the campaign. The advertising identifier (IDFA) is not used.

5.4. Buying Premium or credits on the Website. Premium and credit packs bought on temfy.app/comics/premium/ are sold and billed by ART APP LTD (a private company limited by shares, registered in England and Wales, company number 16291637, registered office 86–90 Paul Street, London EC2A 4NE), which is the controller of the payment and purchase data described in this paragraph; the terms of purchase are in the Website Purchase Terms.

The Website purchase records (the email hash and its link to the App’s user ID) are kept for as long as they are needed to provide and restore access and credits and are deleted at your request; payment records are kept for as long as the law requires. A Website subscription is cancelled on the Manage subscription page.

6. Technical services

The App does not collect contacts, precise location, health data, browsing or search history. It only receives the photos you pick yourself.

7. Purposes

Story text and photos are used to generate the comic you asked for. Purchase and credit data are used to provide subscriptions, add and charge credits and refund them when a generation fails. Usage statistics and crash reports are used to fix bugs and improve the App. App Check is used to protect the server from abuse. Support requests are used to answer them and fix problems.

8. Sharing

8.1. We do not sell data and do not share it with third parties other than the processors listed in this Policy — Apple (App Store, App Attest, Apple Search Ads, Sign in with Apple), Google (Firebase, Cloud Functions, Cloud Firestore, Gemini API, Google Analytics, Crashlytics; Google Analytics on the Website), RevenueCat, Stripe (Website payments), Yandex (Yandex.Metrica on the Website), Netlify (hosting of the Website and its server functions, including the one that receives support requests and stores their details) and Telegram FZ-LLC (delivery of support requests) — or where disclosure is required by law.

8.2. International transfers. These processors may process data in the United States, the European Union and other countries. Where data is transferred outside the UK, it is protected by the safeguards these providers offer, such as the UK International Data Transfer Addendum to the EU Standard Contractual Clauses.

9. Retention

Data on your device is kept until you delete it or delete the App; your credit balance is also kept in the device’s secure storage (Keychain) so purchased credits are not lost when you reinstall the App. Story text and photos are not kept on our servers after generation. The credit balance and records of purchases and charges are kept for as long as needed to provide the service and for accounting, and deleted on request. RevenueCat keeps purchase history for as long as needed to provide subscriptions and for accounting. Usage statistics and crash reports are kept according to the Google Analytics and Crashlytics retention settings. Technical details of support requests are deleted after 12 months; Telegram messages are kept for as long as we need them to reply.

10. Your rights

10.1. You have the right to access, rectify or erase your personal data, to restrict or object to processing, to data portability and to withdraw consent by writing to the address in section 12. To help us find your data, include your support request number if you have one. You can complain to the Information Commissioner’s Office (ico.org.uk) or to the data protection authority in your country.

10.2. You can turn notifications off in the device settings. Without consent to AI processing comics are not generated; the rest of the App remains available.

11. Security and children

11.1. Data between the App and servers is sent over an encrypted connection (HTTPS).

11.2. The App is not intended for children under 13, and we do not knowingly collect their personal data.

12. Company details and contact

ART APP LTD — a private company limited by shares, registered in England and Wales, company number 16291637
Registered office: 86–90 Paul Street, London EC2A 4NE, United Kingdom
Email for personal data requests: artappltd@gmail.com

13. Changes

We may update this Policy. The current version is always available at temfy.app/comics/privacy.html.