Privacy Policy
Effective October 17, 2026 · Last updated October 17, 2026
This Privacy Policy explains how BuroBrain LLC ("BuroBrain", "we", "us") handles personal data when you use the BrainDV apps for iPhone and Android (the "App"), the braindv.com website (the "Website"), and when you email us. It is written to be read in full; the summary below is not a substitute for the details.
1. Who we are
BrainDV is made by BuroBrain LLC, a limited liability company organized in the United States. BuroBrain is the controller of the personal data described in this policy. You can reach us at founder@burobrain.com.
This policy does not cover Apple's App Store, Google Play, Sign in with Apple or Google accounts. Those services are provided by Apple and Google under their own privacy policies.
2. Summary
- You can use camera guidance, run the photo checks and preview a crop without an account. Your photos stay on your device.
- The App detects your face on your device only to guide framing and position the crop. It does not identify anyone, does not create a face template and does not send face data to us or anyone else.
- A BrainDV account is created only when you buy, restore a purchase or finalize an export. It is anonymous (a random ID) unless you choose to sign in with Apple or Google.
- Our server keeps your account, your purchase and export records (the "ledger") and your settings. It does not receive your photos, except through the optional features described in sections 3 and 6.
- The optional AI advice feature, which would send a photo to OpenAI, is off by default and needs your explicit permission first. In the current version of the App it sends nothing (section 6).
- Payments are handled by Apple or Google. We never see your card details.
- We do not sell personal data, do not share it for advertising, do not track you across other companies' apps or websites, and the App contains no advertising or analytics software.
- You can delete your account in the App or by email. See Account and data deletion.
3. What we collect and how
| Data | What it includes | How and when |
|---|---|---|
| Photos | Photos you take with the camera or import from your photo library, the working copy used for checks, and the files you export | Stored in the App's private storage on your device. They are not uploaded to us. The App saves a file to your photo library or opens the share sheet only when you tap the button to do so. |
| Face detection results | Position and size of faces, landmarks such as eyes, nose and chin, head angles, and an estimate of whether the eyes are open | Computed on your device for the current photo and held in the App's memory only. Never stored and never sent to us. See section 4. |
| Photo measurements and check results | Pixel dimensions, file size, brightness, sharpness, framing values and each check result (pass, warning, unknown or fail) | Computed and kept on your device. Not sent to us. |
| Account data | A random account ID; creation and last-activity times; hashed sign-in tokens. If you sign in with Apple, or with Google where the App offers it: the provider's user identifier for BrainDV and, if the provider shares one, a verified email address (Apple may give a private relay address) | Created by our server when you first buy, restore or finalize an export, and when you choose to sign in. We do not ask for or store passwords or your name. |
| Purchase records | Platform (iOS or Android), product, store transaction ID or purchase token, original transaction ID, Google order number, purchase date, date we verified it, store environment, storefront country or region code, and refund or revocation notices | From Apple or Google when you buy or restore a purchase and when a store reports a refund or revocation. |
| Export records | An export code, platform, photo type (for example "U.S. visa digital"), status, whether an included export or a credit was used, and times | Created when you finalize an export. They never contain the image. |
| Settings and consent | Your choice for AI advice and the time you gave consent; your choice for cloud history | Stored on your device; also stored on our server if you have an account. |
| AI advice usage records | Time, outcome, image size in bytes, number of tokens, estimated cost and response time of each request | Only if you use the optional AI advice feature. They never contain the image or the advice text. |
| Cloud history files (optional) | Copies of your exported photo files | Only if the App offers cloud history and you turn it on. It is off by default and is not offered in the current version of the App. |
| Emails | Your email address, the content of your message and our replies, including waitlist requests | When you email us or join the waitlist. |
| Technical request data | IP address, time, requested address, response status and browser or app user agent | Recorded by the servers that run our API and Website when your device connects to them. |
The App asks for access to the camera (to take a photo) and to your photo library (to import a photo, and to save a finished photo when you ask). It does not use the microphone, your location, your contacts or any advertising identifier. We do not ask for your name, date of birth, nationality, passport number or visa case number.
4. Face detection and biometric information
To guide framing and crop a photo to the proportions a published requirement describes, the App needs to know where the face is. It uses an on-device face detection library (Google ML Kit) that returns the position of the face, landmarks such as the eyes and chin, head angles and an estimate of whether the eyes are open. The library can also return other estimates, such as whether a person is smiling; the App does not use them and discards them.
- This processing happens entirely on your device. Face detection results are kept in memory for the photo you are working on and are discarded afterwards. They are not written to storage and are not sent to us or to anyone else.
- Face detection is used only to guide framing, position the crop and run photo-quality checks. It is not used to identify or recognize anyone, to verify identity, or to compare one face with another.
- We do not create or store face templates, faceprints, face embeddings or any other representation that could identify a person.
- We do not use your face or photos to infer age, gender, ethnicity, emotion, health or any other personal characteristic, and we do not use them for advertising or to train machine learning models.
Because nothing derived from your face leaves your device or is retained, BuroBrain does not collect, capture, receive, store, possess, sell or disclose biometric identifiers or biometric information, including as those terms are used in the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act, Washington's biometric identifier law (RCW 19.375) and similar laws. If this ever changes, we will update this policy before the change, publish a retention and destruction schedule where the law requires one, and ask for your written consent before any collection.
ML Kit runs on your device and does not send your photos or face data to Google. Google states that ML Kit may send Google technical information about the library's performance and use (such as device and app information) to maintain and improve it.
5. What stays on your device and what reaches us
| Activity | Where it happens |
|---|---|
| Camera guidance, face detection, photo checks, crop and preview | Only on your device |
| Creating the exported file | On your device |
| Counting an export against your included exports or credits | Our server records the export code, photo type and platform (no image) |
| Purchases and restore | Apple or Google, then our server, which checks the purchase with Apple or Google and records it |
| Optional AI advice (off by default) | Our server forwards a copy of the photo you choose to OpenAI and keeps the image only in memory while the request runs |
| Optional cloud history (off; not offered in the current version) | Our server stores the exported file, reachable only through links that expire after a few minutes |
On Android, the App excludes its stored photos and files from Android's app data backup. On iPhone, files in the App's storage may be included in your own device backups (for example iCloud Backup) according to your device settings; those backups are controlled by you and Apple, not by us.
6. Optional AI advice
The App includes an optional feature that can send a copy of a photo you choose to OpenAI, L.L.C. to receive short written tips about lighting, shadows, glare, head position, expression or focus. This feature:
- is off by default and is never needed to use the App;
- is turned on only through a screen that explains what is sent, to whom and how long it is kept, and asks for your explicit permission. Nothing is sent before you agree;
- sends only the photo you choose to check, with fixed instructions from us. It does not send your account ID, email address, other photos or purchase data to OpenAI;
- gives advice only. It is never part of the checks and never changes your photo;
- can be turned off at any time in Settings, which withdraws your consent. We can also switch it off for everyone.
Current status: in the current version of the App, AI advice is not active. If you turn it on, your choice is saved (on your device, and on our server if you have an account), but no photo is sent. If a later version activates it, the same rules apply.
When it is active, our server holds the image in memory only for the duration of the request and never writes it to our database, file storage or logs. We send the request with OpenAI's option to store responses turned off. OpenAI processes the request under its API terms and policies, which govern any retention on its side. Details are in the AI Processing Disclosure.
7. Why we use data and our legal bases
We use personal data only for the purposes below. If you are in the European Economic Area (EEA), the United Kingdom or Switzerland, the legal basis for each purpose is shown in the second column.
| Purpose | Legal basis (EEA, UK, Switzerland) |
|---|---|
| Creating and securing your account, signing you in, keeping your purchases across reinstalls when you sign in | Performance of our contract with you |
| Verifying purchases with Apple or Google, granting included exports and credits, counting exports, restoring purchases | Performance of our contract with you |
| Processing refunds and revocations reported by the stores; preventing one purchase being used twice or by several accounts | Performance of our contract; our legitimate interest in preventing fraud and abuse |
| Optional AI advice and optional cloud history | Your consent, which you can withdraw at any time |
| Answering your emails and support requests | Performance of our contract; our legitimate interest in helping people who contact us |
| Waitlist emails about the BrainDV launch | Your consent |
| Keeping our servers secure and working (request records, rate limits, troubleshooting) | Our legitimate interest in running a secure service |
| Keeping purchase records for tax and accounting, and responding to lawful requests | Compliance with legal obligations |
Where we rely on legitimate interests, we have balanced them against your rights, and you can object (section 14). We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. The photo checks assess a photo, not a person, and you decide what to do with the result.
8. Who receives data
We share personal data only with the following recipients and only as needed for the purposes above:
- Hetzner Online GmbH hosts the server that runs our API and database. It processes data on our behalf.
- Cloudflare, Inc. hosts and delivers the Website and provides network security and DNS for our domains. It processes technical request data on our behalf.
- Apple and Google distribute the App, process payments and refunds, and provide Sign in with Apple and Google sign-in. When you buy, the App passes your random BrainDV account ID to the store as a purchase reference so we can match the purchase to your account, and our server asks Apple or Google to confirm the purchase. Apple and Google act as independent controllers for their own services.
- Google ML Kit (on-device face detection) may send Google technical usage metrics as described in section 4. It does not receive your photos.
- OpenAI, L.L.C. receives a photo only if you turn on AI advice and the feature is active (section 6).
- Our email service provider stores the emails you send to us and our replies.
- Authorities and others where required: when the law requires it, or where needed to protect the rights, safety or security of users, the public or BuroBrain.
- A successor business: if BuroBrain is involved in a merger, acquisition or sale of assets, personal data may transfer to the new owner, who must continue to protect it as this policy describes. We will tell you before that happens.
We never submit photos or any other data to a government website or agency on your behalf.
9. No advertising, no tracking, no analytics
- We do not sell personal data, and we do not share it for cross-context behavioral advertising or targeted advertising.
- The App does not track you as defined by Apple's App Tracking Transparency framework: we do not link data from the App with data from other companies' apps or websites for advertising, and we do not share it with data brokers. The App does not access your device's advertising identifier.
- The App contains no advertising, analytics or crash reporting software.
- The Website does not use analytics or advertising and does not set cookies itself. Cloudflare, which delivers the Website, may use strictly necessary security cookies to protect it from attacks.
- Because we do not sell or share personal data, there is nothing to opt out of. We treat a Global Privacy Control signal as a valid opt-out request where the law requires it.
10. How long we keep data
| Data | How long |
|---|---|
| Face detection results | Only in memory while you work on the current photo; never stored |
| Photos and exports on your device | Until you delete them (Settings, "Delete local data") or uninstall the App |
| Account data, settings and consent records, export records, AI advice usage records, cloud history files | Until you delete your account |
| Purchase and export ledger records | Kept after account deletion, without your email address or sign-in identifiers, for up to 7 years after the end of the year of the purchase, for tax, accounting, refund handling and fraud prevention; then deleted |
| Images sent for AI advice | Held in our server's memory only while the request runs; never stored by us |
| Technical request data in server logs | Up to 30 days |
| Database backups | Replaced on a rolling basis; each backup is kept for 14 days |
| Waitlist requests | Until you ask us to remove you, or 24 months after the public launch of BrainDV, whichever comes first |
| Support emails | Up to 24 months after the conversation ends, unless we need them longer to handle a legal claim |
11. Deleting your data and your account
- In the App: Settings, "Delete account". This deletes your account and the data listed on the Account and data deletion page from our server immediately.
- On your device: Settings, "Delete local data" removes every photo, export and setting the App stored on the device. Uninstalling the App also removes them.
- By email: write to founder@burobrain.com. We complete verified requests within 30 days.
Deleting your account does not cancel or refund a store purchase, and purchases recorded on a deleted account cannot be moved to a new account. Purchase ledger records are kept as described in section 10.
12. Security
We protect personal data with measures appropriate to the risk, including:
- encrypted connections (HTTPS) between the App, the Website and our servers;
- sign-in tokens kept in the secure storage of your device (iOS Keychain or Android Keystore); on our server, refresh tokens are stored only as one-way hashes;
- a database that is not reachable from the internet, with every request limited to the account of a verified sign-in token;
- server keys and secrets kept only on our server, never in the App or Website;
- short-lived signed links for any stored file, rate limits, and access limited to the people who run BrainDV.
No system is perfectly secure. If a personal data breach affects you, we will notify you and the competent authorities as and when the law requires.
13. International transfers
BuroBrain is based in the United States. Our service providers process data in the United States, the European Union and other countries where they operate. When we transfer personal data from the EEA, the UK or Switzerland to a country without an adequacy decision, we use the European Commission's Standard Contractual Clauses (with the UK Addendum where relevant) in our agreements with service providers, or rely on another lawful transfer mechanism such as the EU-U.S. Data Privacy Framework where the recipient participates in it. Transfers that are necessary to provide the service you ask for, such as verifying your purchase with Apple or Google, are made on that basis. You can ask us for more information about these safeguards.
14. Your rights and choices
You control most processing directly in the App:
- turn AI advice on or off in Settings;
- delete local data, or your account, in Settings;
- allow or refuse camera and photo library access in your device settings.
Depending on where you live, you also have the right to:
- access the personal data we hold about you and receive a copy;
- correct inaccurate data;
- delete your data;
- receive your data in a structured, machine-readable format and have it sent to another company (portability);
- object to processing based on our legitimate interests, and restrict processing in certain cases;
- withdraw consent at any time, without affecting processing that took place before;
- opt out of the sale or sharing of personal data and of targeted advertising (we do none of these);
- appeal our decision on your request, where your state law provides that right;
- lodge a complaint with a data protection authority, for example the authority in the EEA country where you live or work, the UK Information Commissioner's Office, or the Swiss Federal Data Protection and Information Commissioner.
To make a request, email founder@burobrain.com with the subject "Privacy request". To protect your data, we verify requests before acting on them: write from the email address linked to your account, or give us details that let us find your account (for example your platform and a store order number). Accounts that were never linked to Apple or Google contain no email address or name, so we may not be able to match a request to them; in that case the deletion button in the App is the most reliable option. An authorized agent may make a request for you where the law allows, with your signed permission. We respond within one month (45 days where U.S. state law applies), and tell you if we need more time as the law allows. Requests are free of charge. We will not treat you differently for using your rights.
15. Notice for U.S. state residents
This section applies to residents of California and other U.S. states with consumer privacy laws, in addition to the rest of this policy. In the past 12 months we collected the following categories of personal information, from the sources and for the purposes described in sections 3 and 7:
- Identifiers: random account ID, Apple or Google user identifier, email address, IP address.
- Commercial information: purchase, refund and export records.
- Internet or other electronic network activity: technical request data.
- Photographs: only if you use the optional AI advice or cloud history features; otherwise photos stay on your device.
We do not sell or share your personal information, as "sell" and "share" are defined by the California Consumer Privacy Act as amended by the California Privacy Rights Act, and we have not done so in the past 12 months. We do not knowingly sell or share the personal information of consumers under 16. We do not use or disclose sensitive personal information for purposes that would give you a right to limit it, and we do not process biometric information (section 4). We do not collect consumer health data as defined by the Washington My Health My Data Act. Retention periods are in section 10, and your rights and how to use them are in section 14.
16. Children
BrainDV is not directed to children. We do not knowingly collect personal data from children under 13, or under 16 in the EEA and the UK. BrainDV does not yet support photos of children: please do not use it to prepare a photo of anyone under 16 until we announce that support. If you believe a child has given us personal data, email founder@burobrain.com and we will delete it.
17. Changes to this policy
We will post any change on this page and update the "Last updated" date. If a change is material, for example a new use of photos or a new recipient, we will tell you in the App or on the Website before it takes effect and, where the law requires, ask for your consent again.
18. Contact
BuroBrain LLC, email founder@burobrain.com. We answer privacy questions in English; you may write to us in any of the languages of the Website and we will do our best to help.