Privacy Policy — Photo-Animation Service
Effective Date: 2026-05-26
Last Updated: 2026-05-24
Service: Photo-Animation Telegram Bot (@photoanimate_bot)
Data Controller: Solved — an informal product team operated by independent contributors. Primary contact: Egor Yackovlev (founder), egor.yackovleff@gmail.com.
Contact: privacy@solved.group
1. Who We Are
We are Solved — an informal product team operated by independent contributors — the operator of the @photoanimate_bot Telegram bot ("Service"). Solved is in the process of incorporating a legal entity; until that incorporation completes, the team operates collectively under the founder's responsibility (Egor Yackovlev, egor.yackovleff@gmail.com). This Privacy Policy explains how we collect, use, store, and protect your personal data — including biometric data — when you use the Service.
2. Summary (TL;DR)
| What | How long | Why |
|---|---|---|
| Your Input Photo | ≤ 5 minutes | Deleted immediately after your video is generated |
| Your Output Video | 24h (free) / last 30–100 (paid) | So you can re-download it |
| Your Telegram user ID | Duration of account | To deliver the Service |
| Your consent record | Account lifetime + 3 years | Legal requirement for biometric data |
| Payment metadata | 90 days after account deletion | Fraud prevention, dispute resolution |
We do not sell your data. We do not retain facial/biometric data after video generation. We do not train AI models on your photos or videos.
3. What Data We Collect
3.1 Data You Provide Directly
| Category | Data Elements | Purpose |
|---|---|---|
| Input Photo | Image file (JPEG/PNG, ≤10MB) you upload | AI video generation |
| Biometric Data | Facial geometry transiently extracted from your Input Photo by the AI Provider | Required to generate an animated video |
| Age & Consent Record | Confirmation you are ≥18 years old; timestamp; consent version | Legal compliance; GDPR Art. 9 requirement |
3.2 Data Generated Automatically
| Category | Data Elements | Purpose |
|---|---|---|
| Telegram User ID | Numeric Telegram user identifier | Account identification; delivery of Output Videos |
| Generation Logs | Generation ID, timestamp, plan tier, AI provider used, processing duration | Service quality; cost tracking; fraud prevention |
| Payment Metadata | Transaction ID, plan type, payment amount, currency, timestamp | Billing; dispute resolution |
| Error Logs | Non-PII error codes and stack traces | Debugging and reliability |
3.3 Data We Do NOT Collect
- Name, email, phone number (unless you contact support)
- Location data
- Device identifiers or IP addresses (Telegram abstracts these)
- Persistent biometric templates or faceprints
- Browsing or usage data outside the bot
4. ⚠️ Biometric Data — Special Category Processing
This section is particularly important. Facial images are "special category" personal data under GDPR Art. 9. We process them only with your explicit, informed consent and under strict safeguards.
4.1 What Is Biometric Data in This Context
When you upload a photograph containing a human face, the AI Provider (currently Kling AI) transiently processes your facial image to generate motion. This process may involve extracting facial geometry, landmarks, or appearance representations. Under GDPR Art. 4(14) and Art. 9, this constitutes biometric data.
4.2 Lawful Basis
| Processing Activity | Lawful Basis | GDPR Reference |
|---|---|---|
| Processing Input Photo for video generation | Explicit consent | Art. 6(1)(a) + Art. 9(2)(a) |
| Retention of Output Video | Explicit consent | Art. 6(1)(a) |
| Generation logs (non-biometric) | Legitimate interest (service operation, fraud prevention) | Art. 6(1)(f) |
| Payment processing | Performance of contract | Art. 6(1)(b) |
4.3 How We Collect Consent
Before any image is processed, the bot requires you to affirmatively confirm: 1. "I am at least 18 years old." 2. "I have the right to process this photo (it is me, or I have the depicted person's explicit permission)."
You cannot proceed without both confirmations. This consent is:
- Freely given — you can use /cancel at any time
- Specific — given for this single processing activity
- Informed — this Privacy Policy is linked at /start
- Unambiguous — requires a tap on a confirmation button (no dark patterns)
4.4 Data Minimization
The Input Photo is transmitted only to the AI Provider for generation purposes. It is not: - Stored in our databases beyond the 5-minute processing window - Shared with any third party other than the AI Provider - Used for identification, model training, or any secondary purpose - Retained in backups beyond 24 hours
4.5 AI Provider Processing
Kling AI, operated by Kuaishou Technology, acts as a third-party processor for Input Photos. As of the effective date of this Policy, Kuaishou has not published a separate enterprise Data Processing Agreement for API customers; we therefore rely on Kuaishou's published Terms of Service and Privacy Policy as the governing instruments for their processing of your data. We are actively pursuing a formal DPA with Kuaishou and will update this section once executed. Our pipeline transmits each Input Photo to Kling AI solely to generate the requested Output Video and does not retain Input Photos after delivery (see §4.4). We do not have technical means to enforce Kuaishou's downstream retention practices beyond their published terms; if you object to processing by a China-based provider without a bilateral DPA, please do not use the Service.
4.6 Your Right to Withdraw Consent
You may withdraw consent at any time by:
- Using the /delete_data bot command (processes within 30 days)
- Emailing privacy@solved.group
Withdrawal does not affect the lawfulness of processing prior to withdrawal.
5. Data Retention
| Data | Retention | Deletion Trigger |
|---|---|---|
| Input Photo | ≤ 5 minutes | Automatic deletion after Output Video delivered |
| Output Video (Free tier) | 24 hours | Automatic deletion after 24h |
| Output Video (Paid tier) | Last 30 (Basic) / Last 100 (Pro) — no time TTL | Oldest deleted when limit exceeded |
| Output Video (post-cancellation) | 30-day grace period | Automatic deletion 30 days after subscription ends |
| Telegram User ID + profile | Duration of account | Account deletion request |
| Generation logs | 90 days after account deletion | Automated purge |
| Consent records | Account lifetime + 3 years | Retention required by Art. 9 lawfulness |
| Payment metadata | 90 days after account deletion | Automated purge |
5.1 Automated Deletion
Deletion of Input Photos and Output Videos is automated. We do not require manual action to trigger deletion — it occurs automatically based on the schedule above.
5.2 Backup Caveat
Due to automated backup scheduling, Input Photos may persist in encrypted backup snapshots for up to 24 hours before being overwritten. This residual window is minimized by excluding Input Photos from our primary backup scope where technically feasible.
6. How We Use Your Data
We use your data for the following purposes only:
- Delivering the Service — processing your photo and returning the animated video
- Account management — tracking your subscription, generation history, and billing
- Service reliability — logging errors and monitoring performance (no PII in logs)
- Fraud prevention — detecting abusive usage patterns
- Legal compliance — maintaining consent records as required by law
- Responding to support requests — only when you contact us
We do not use your data for: - Advertising or retargeting - Selling to data brokers - Training AI models on your likeness - Building profiles for purposes other than the Service
7. Data Sharing & Subprocessors
We share your data with the following categories of third parties only as necessary to operate the Service:
| Subprocessor | Role | Data Shared | Location | DPA |
|---|---|---|---|---|
| Kling AI (Kuaishou) | AI video generation | Input Photo (transient) | China / Global CDN | Reliance on Kuaishou ToS; formal DPA in negotiation (see §4.5) |
| AWS S3 | Video file storage | Output Video files | EU-West-1 (configurable) | Yes (EU DPA) |
| Telegram | Bot platform | User ID, bot interactions | Global | Telegram ToS |
| Langfuse | Observability (latency, cost tracking) | Generation metadata (no PII) | EU | Yes |
| Stripe | Payment processing | Payment data, email if provided | US/EU | Yes (EU DPA) |
We do not share your Input Photo, Output Video, or biometric data with any party other than the AI Provider listed above.
A current, maintained subprocessors list is available at [photoanimate.solved.group/subprocessors].
8. International Data Transfers
Your data may be transferred outside the European Economic Area (EEA) to:
- Kling AI (China): As noted in §4.5, Kuaishou has not published a separate enterprise Data Processing Agreement or executed SCCs with us as of the effective date of this Policy. The transfer relies on Kuaishou's published Terms of Service and Privacy Policy. Input Photo transfer is transient (processing only, no storage on Kuaishou's side per their published terms). We are actively pursuing a formal DPA incorporating EU SCCs Module 2 (controller → processor) and will update this section once executed.
- AWS S3: Operating within EU-West-1 (Ireland) region to minimize international transfers for Output Videos. AWS holds EU Standard Contractual Clauses.
- Stripe: US-based; covered by the EU-US Data Privacy Framework.
If you are an EEA resident and have questions about international transfers, contact privacy@solved.group.
9. Data Security
We implement the following technical and organizational measures:
- Encryption in transit: TLS 1.2+ for all data transmission
- Encryption at rest: AES-256 for stored Output Videos (AWS S3)
- Access controls: Principle of least privilege; no human access to Input Photos during processing pipeline
- Automated deletion: Input Photos deleted automatically after 5 minutes; no manual retention
- Audit logging: All data access events logged (metadata only)
- Subprocessor vetting: Formal DPA agreements with EU/US-based processors (AWS, Stripe, Langfuse); for non-EU/non-US processors without a published enterprise DPA (currently: Kuaishou/Kling AI), reliance on their published terms of service pending formal DPA execution — see §4.5 and §8.
10. Your Rights (GDPR / Applicable Law)
If you are in the EEA, UK, Switzerland, or a jurisdiction with comparable data protection law, you have the following rights:
| Right | Description | How to Exercise |
|---|---|---|
| Access | Receive a copy of your personal data | /my_data command or privacy@solved.group |
| Erasure | Request deletion of all your data | /delete_data command — fulfilled within 30 days |
| Correction | Correct inaccurate data | privacy@solved.group |
| Restriction | Restrict specific processing | privacy@solved.group |
| Portability | Receive your data in machine-readable format | privacy@solved.group — JSON export |
| Object | Object to legitimate-interest processing | privacy@solved.group |
| Withdraw consent | Withdraw biometric processing consent | /delete_data or privacy@solved.group |
| Complaint | Lodge a complaint with your supervisory authority | See §10.1 below |
Response time: 30 days for standard requests; 90 days for complex requests (with notice at day 30).
10.1 Supervisory Authorities
| Jurisdiction | Authority |
|---|---|
| Germany | BfDI (Der Bundesbeauftragte für den Datenschutz) |
| France | CNIL |
| UK | ICO (Information Commissioner's Office) |
| Netherlands | AP (Autoriteit Persoonsgegevens) |
| Other EU | Your national data protection authority |
10.2 US State Privacy Rights
If you are a California resident (CCPA/CPRA), Texas resident (CUBI), Illinois resident (BIPA), or resident of another US state with biometric privacy law, you have additional rights regarding biometric data. Please contact privacy@solved.group with the subject line "US Biometric Privacy Request."
11. Children's Privacy
The Service is not intended for persons under 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently received a minor's data, contact privacy@solved.group immediately and we will delete it within 72 hours.
12. Cookies and Tracking
The Photo-Animation bot is a pure Telegram bot with no web frontend in v1. We do not use cookies, web tracking pixels, or browser fingerprinting.
If a web payment page (Stripe Checkout) is later introduced, a separate cookie notice will be displayed on that page. Payment page tracking is limited to Stripe's own fraud detection (necessary cookies only).
13. Changes to This Policy
We will notify you of material changes by: 1. Sending a notification via the @photoanimate_bot bot 2. Posting the updated policy at [photoanimate.solved.group/privacy]
Changes take effect 14 days after notification. Continued use after the effective date constitutes acceptance of the updated policy. For changes to biometric data processing, we will re-request your explicit consent.
14. Contact & Data Controller
Data Controller: Solved — informal product team operated by independent contributors
Privacy Officer / Founder: Egor Yackovlev — egor.yackovleff@gmail.com
Email: privacy@solved.group
Bot support: /help command in @photoanimate_bot
Response time: within 5 business days
This Privacy Policy is published as v1.2 (2026-05-24) under the informal-team operating model. Solved is in the process of incorporating a legal entity; once registered, the entity will be substituted into the "Data Controller" and "Who We Are" sections and users will be notified per §13. The document has not yet been reviewed by a qualified lawyer. v1.2 addresses the Kling AI / Kuaishou DPA status disclosed in §4.5, §7, §8, and §9: there is no enterprise DPA in place as of the effective date; we rely on Kuaishou's published terms pending execution of a formal DPA. Formal DPA pursuit is tracked separately and will trigger v1.3 upon completion.