Privacy Policy
The short version
- Your face data never leaves your Mac. We never receive it and have no access to it.
- Camera images are processed in memory and never saved.
- The app connects to the internet only to activate or deactivate your license. It sends the key and a hash of your Mac's hardware identifier.
- Paddle handles payment. We keep your name, email, license key and a few purchase records to deliver and support your license.
- We do not sell your data.
1. Who is responsible
The controller of the personal data described here is [[PREENCHER: razão social ou nome completo do responsável]], [[PREENCHER: CNPJ]], [[PREENCHER: endereço completo]].
Data protection officer (in Brazil, encarregado): [[PREENCHER: nome do encarregado (DPO) ou confirmação de que é o próprio responsável]]. Contact for any privacy matter: [[PREENCHER: e-mail de suporte e privacidade]].
This policy covers the Face In app, this website and the sale of licenses. Paddle, as the reseller, processes payment data as a separate controller under its own privacy policy.
2. What stays on your Mac
Face In works on your Mac, using Apple's on device frameworks (Vision and Core ML). The following data is created and stored only on your Mac. We have no access to any of it:
- The mathematical model of each face you enroll: lists of numbers, not photos.
- The name you give each face, its permissions and the apps allowed for it.
- A profile photo, only if you choose one.
- Your Mac password, used to unlock the lock screen for you.
All of the above is encrypted with AES-GCM 256. The encryption key is kept in your Mac's Keychain, protected by Touch ID or your Mac password, and is not synced with iCloud.
Also on your Mac, in plain text: a log of unlock attempts (date, result, name of the face, similarity level; no images) and your app preferences. A diagnostic file is created only when you ask for it.
Camera images are processed only in memory and are never saved.
Biometric data. Face data never leaves your Mac. We do not collect, receive, store or process it: all processing is done by the software on your device, under your control. If you send us a diagnostic file or a screenshot for support, we receive only what you choose to send.
If you use Time Machine, your backups may contain copies of these files. The encrypted files stay encrypted in the backup. To delete this data, remove the faces in the app, or delete the folder ~/Library/Application Support/FaceIn after quitting the app. Copies in your own backups follow your backup settings.
3. What the app sends
The app connects to our server only when you activate or deactivate your license. It sends:
- your license key;
- a SHA-256 hash of your Mac's hardware identifier. We never receive the identifier itself, and the hash cannot be turned back into it.
There is no periodic check and no analytics inside the app. As with any internet connection, our server and Cloudflare (which sits in front of it) also see the IP address of the request. We use it for security and to limit abuse. [[PREENCHER: prazo de retenção dos logs de acesso (IP) do servidor e do nginx]]
4. Purchase data and Paddle
Paddle.com is the Merchant of Record for our orders. At checkout, Paddle collects your name, email, country and payment details. We never see your full card details. Paddle shares with us what we need to deliver your license: your name, email, and the transaction and customer identifiers. See the Paddle privacy policy.
5. What we keep, why, and on what basis
Our server (in Brazil) keeps, for each license: the key, the buyer's name and email, the Paddle transaction and customer identifiers, the hash of the activated Mac, dates (purchase, activation, deactivation) and the status (active or revoked).
| Purpose | Data | Legal basis (LGPD / GDPR) |
|---|---|---|
| Deliver the license key and the download by email | Name, email, key, Paddle identifiers | Performance of a contract (LGPD art. 7, V / GDPR art. 6(1)(b)) |
| Activate the app and enforce one Mac per key | Key, Mac hash, dates, status | Performance of a contract (LGPD art. 7, V / GDPR art. 6(1)(b)) and legitimate interest in preventing misuse (LGPD art. 7, IX / GDPR art. 6(1)(f)) |
| Revoke keys after refund or chargeback | Key, Paddle identifiers, status | Performance of a contract and legitimate interest in preventing fraud (same articles) |
| Answer support requests | What you write to us, name, email, key | Performance of a contract (LGPD art. 7, V / GDPR art. 6(1)(b)) |
| Keep tax and accounting records | Purchase records | Legal obligation (LGPD art. 7, II / GDPR art. 6(1)(c)) |
| Protect the site and the server | IP address, request data | Legitimate interest in security (LGPD art. 7, IX / GDPR art. 6(1)(f)) |
| Site analytics | See the Cookie Policy | Consent (LGPD art. 7, I / GDPR art. 6(1)(a)), only after you accept |
We do not use your data for automated decisions that significantly affect you, and we do not build advertising profiles.
6. How long we keep it
License data is kept while the license exists, plus the period required by tax and legal rules. [[PREENCHER: prazo legal/fiscal de guarda em anos]] You can ask us to delete your data at any time. After deletion, we can no longer reactivate your key, move it to another Mac or confirm your purchase.
7. Service providers
We share data only with providers that help us run the service, and only what each one needs:
| Provider | Role | Location |
|---|---|---|
| Paddle | Reseller and payment (separate controller) | United Kingdom and United States |
| Hostinger | Server hosting | Brazil |
| Cloudflare | Network, security and delivery of the site and the server | United States (global network) |
| Resend | Sending transactional emails (your key) | United States |
| [[PREENCHER: ferramenta de analytics]] | Site analytics, only with consent | [[PREENCHER: país da ferramenta de analytics]] |
We do not sell your personal data. We may disclose data when required by law or by a court order.
8. International transfers
Some providers process data outside your country, including in the United States and the United Kingdom. If you are in the European Economic Area or the UK, your data is also processed in Brazil. We use the safeguards allowed by law for these transfers, such as standard contractual clauses (LGPD art. 33 and GDPR art. 46) or adequacy decisions where they exist. [[PREENCHER: confirmar o mecanismo de transferência adotado com cada fornecedor]] You can ask us for a copy of the safeguards.
9. Your rights
Under the LGPD (Brazil, art. 18)
You can ask us for: confirmation that we process your data; access; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary or excessive data; portability; deletion of data processed with your consent; information about who we share data with; information about the possibility of not giving consent and its consequences; and withdrawal of consent. You can also object to processing that does not comply with the law, and file a complaint with the ANPD (Autoridade Nacional de Proteção de Dados).
Under the GDPR (EEA and UK)
You have the right of access, rectification, erasure, restriction of processing, data portability and objection, including to processing based on legitimate interest. Where processing is based on consent, you can withdraw it at any time, without affecting what was done before. You can lodge a complaint with the data protection authority of the country where you live or work.
How to exercise them
Write to [[PREENCHER: e-mail de suporte e privacidade]] from the email used in the purchase, or tell us your license key. We may ask for confirmation of your identity. We answer within the deadlines of the applicable law (for example, 15 days for a full access report under the LGPD, and one month under the GDPR).
Data on your Mac is under your control: you can view, edit and delete it in the app at any time. We cannot do it for you, because we have no access to it.
10. California residents
Under the CCPA, as amended by the CPRA, you have the right to know what personal information we collect, to delete it, to correct it, and not to be discriminated against for exercising these rights. We do not sell personal information and do not share it for cross context behavioral advertising. [[PREENCHER: rever esta frase se o site passar a usar cookies de marketing]] To make a request, write to [[PREENCHER: e-mail de suporte e privacidade]].
11. Security
Communication between the app and our server uses HTTPS. The license the server returns is signed, and the app verifies the signature. Access to the server is restricted. No system is completely secure; if a security incident affects your data, we will notify you and the authorities as the law requires.
12. Children
Face In is not directed at children. Buying a license requires legal capacity to contract, or the involvement of a parent or guardian. We do not knowingly collect data from children.
13. Changes
We will publish any change on this page, with a new date. If a change is significant, we will announce it on the site and, where appropriate, by email.
Language
This page exists in English and in Brazilian Portuguese. If the two versions differ, the version in your own language prevails when the law of your country requires it. In every other case the Portuguese version prevails. [[PREENCHER: confirmar: em conflito, prevalece a versão em português]]