Last updated: 05.01.2026
1. Introduction
Welcome to SwappdAI.
Protecting your privacy and personal data is important to us. This Privacy Policy explains how we collect, use, process, and protect your personal data when you visit our website or use our AI-powered image transformation services.
SwappdAI complies with applicable data protection laws, including the General Data Protection Regulation (GDPR).
2. Data Controller
The controller responsible for data processing under applicable data protection laws is:
SwappdAI
WiIIi Braun (Sole Proprietor)
Germany
Email: hello@swappdai.com
3. Data We Process
Depending on how you interact with SwappdAI, we process the following categories of data:
a) Images & Facial Data
When you upload a photo to use Fun Cards, Art Lab, or Swap Me, our AI analyzes facial features to generate the requested image transformation.
This processing is strictly required to deliver the service.
SwappdAI does not perform biometric identification.
We do not create biometric profiles.
Uploaded images are not used to train AI models.
b) Account & Subscription Data
For users on Premium or Pro Creator plans, we process:
Email address
Subscription status and plan information
c) Usage Data
We track credit usage (e.g., free monthly credits or purchased credit bundles) to manage access to features and services.
d) Payment Data
Payments are handled exclusively by secure third-party payment processors.
SwappdAI does not store full credit card or payment details.
e) Website Usage Data
When visiting our website, technical data may be collected, such as:
Device and browser type
Pages visited
Approximate location (IP address anonymized)
4. Purposes of Processing
We process your data solely for the following purposes:
Image Generation: To create the AI-generated images you request
Service Management: To manage plans, credits, and feature access
Account Administration: To provide subscriptions and user support
Security: To ensure platform stability and prevent misuse
Website Optimization: To improve website performance and usability
5. Legal Basis for Processing (GDPR)
Our data processing is based on the following legal grounds:
Art. 6(1)(b) GDPR – Performance of a contract
(image generation, account services, subscriptions)Art. 6(1)(f) GDPR – Legitimate interest
(security, fraud prevention, service stability)Art. 6(1)(a) GDPR – Consent
(analytics cookies and non-essential tracking)
6. Data Retention & Facial Data Handling
Uploaded images and facial markers are processed temporarily and only for the duration necessary to generate your result.
Generated images are stored in your account gallery until you delete them.
You may delete generated images at any time.
Source photos are not retained longer than required for processing.
7. Third-Party Service Providers
To operate SwappdAI, we may use trusted third-party service providers (e.g. hosting, analytics, AI infrastructure).
These providers act as data processors under contractual agreements.
Data is processed only on our instructions and for the stated purposes.
No personal data is sold or shared for advertising purposes.
8. International Data Transfers
Some service providers (e.g. Google services) process data on servers outside the European Union, including the United States.
Where applicable, such transfers are safeguarded using:
EU Standard Contractual Clauses (SCCs) approved by the European Commission
9. Cookies
SwappdAI uses cookies to ensure proper website functionality and to analyze usage.
Types of Cookies Used
Essential Cookies
Required for security and core functionality.Preference Cookies
Remember user settings such as language or consent choices.Analytical Cookies
Help us understand how visitors use the website.
You can manage or withdraw your consent at any time via the cookie settings on our website. Blocking certain cookies may affect website functionality.
10. Google Services
Our website uses Site Kit by Google, which integrates the following services:
Google Analytics (GA4)
Used to analyze website usage and performance.
IP addresses are anonymized
Data such as device type and visited pages may be collected
Data may be processed on Google servers in the United States
Processing occurs only with your explicit consent via the cookie banner
(Art. 6(1)(a) GDPR).
Google Search Console
Used to monitor website visibility in search results.
No direct personal user data is processed.
Google acts as a data processor under applicable data protection agreements.
11. Children’s Privacy
SwappdAI is not intended for children under the age of 13 (or 16, where required by local law).
We do not knowingly collect personal data from children.
12. Your Rights
You have the right to:
Access your personal data
Rectification of inaccurate data
Deletion of your account and associated data
Data Portability (export of generated images)
Withdrawal of Consent at any time
To exercise your rights, contact us at:
hello@swappdai.com
13. Security Measures
We implement industry-standard technical and organizational measures, including SSL encryption, to protect your data against unauthorized access, loss, or misuse.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
The current version will always be available on this page.
15. Contact
If you have questions or concerns regarding data protection or this Privacy Policy, please contact us at: