Privacy Policy

Effective Date: November 2, 2026 · Version 1.0

Zhao Menglong ("we", "us", "operator") respects your privacy. This Privacy Policy explains what data SantaPhotoAI ("the Service", https://santaphotoai.com) collects, how it is used, and the rights you have. Please read it before using the Service.

1. Data Controller

Operator (data controller): Zhao Menglong — an individual merchant operating under the laws of the People’s Republic of China
Privacy contact: [email protected]
Data Protection Officer: not designated (not required at our scale and data sensitivity)

2. Data We Collect

2.1 Data you provide

Uploaded photos — processed to generate your stylized image; transmitted to our AI provider for processing and not permanently stored by us (see Sections 5–7);
Buyer email address — collected at checkout by our payment processor and passed to us solely to deliver your redeem code and order confirmation;
Correspondence — emails you send to us (support, refunds, privacy requests).

2.2 Data collected automatically

IP address — used for daily free-quota accounting and abuse prevention;
Device token — a random ID generated in your browser to keep your credit balance; it contains no personal identifiers;
Server logs — standard web-server logs (request time, errors) processed by our hosting provider.

The Service has no accounts, no passwords, no registration forms. We do not collect names, addresses, or payment card data.

3. How We Use Data

Providing and maintaining the Service (image generation) — performance of contract;
Billing and code delivery — performance of contract;
Abuse prevention, rate limiting, and security — legitimate interests;
Legal compliance — legal obligation.

We do not use your data for automated decision-making or profiling.

4. Cookies and Tracking

We use only strictly necessary browser storage: the device token (localStorage) and Cloudflare Turnstile (bot protection). We set no analytics or advertising cookiesand do not embed third-party trackers.

5. Sharing and Disclosure

We do not sell your personal information, as "sale" is defined under applicable law (e.g. CCPA). We share data only with:

Waffo Pancake — Merchant of Record and PCI-DSS payment processor. It handles checkout, taxes, and refunds; payment card data is processed exclusively by Waffo Pancake and never stored on our servers. Waffo's content-safety API also receives the final generation prompt (server-side template text) for a pre-generation safety check; the check is stateless and the prompt text is not retained;
Google (AI Studio) / Replicate — receive your uploaded photo transiently to run the image model (Google Gemini 2.5 Flash Image) for your generation request;
Cloudflare — hosting, CDN, bot protection, and server logs;
Legal and regulatory requirements — where required by law or competent authority.

6. Security Measures

All traffic encrypted via TLS/HTTPS;
Uploaded photos are processed in memory and not persisted; we keep only the minimal records needed to deliver credits;
Access follows least-privilege principles;
In the event of a security incident affecting your rights, we will notify you and the relevant regulators within 72 hours as required by law.

7. Retention

Uploaded photos: not stored after your generation request completes;
Order, credit, and redeem-code records: 30 days, then deleted;
Rate-limit and abuse counters: up to 90 days;
Support correspondence: kept as long as needed to resolve your request, then deleted.

8. Your Rights

Depending on your jurisdiction (e.g. GDPR/CCPA), you may have rights to access, correct, delete, restrict, or object to the processing of your data, to data portability, and to withdraw consent. To exercise any right, email[email protected]; we respond within 30 calendar days. If you believe we have not handled your request properly, you may complain to your local data protection authority.

9. Marketing Communications

We send only transactional email (your redeem code and order confirmation). We run no marketing lists and there is nothing to unsubscribe from.

10. Cross-Border Data Transfers

Our infrastructure and providers (Cloudflare, Google, Replicate, Waffo Pancake) may process data in the United States and other countries. Transfers rely on the providers' data processing agreements, including EU Standard Contractual Clauses where applicable.

11. Minors

The Service is not directed at children under 13, and we do not knowingly collect their data. Photos of minors may only be uploaded by a parent or legal guardian (family Christmas photos are a core, legitimate use when uploaded with consent). If you believe a child's data was provided to us, contact us and we will delete it promptly.

12. Third-Party Links

Checkout takes place on pages operated by Waffo Pancake. This Policy covers data we collect directly; third-party services are governed by their own policies.

13. Changes to This Policy

We may update this Policy. Material changes will be announced at least 15 days before taking effect via the Site, and the "Effective Date" above will be updated. Continued use after the effective date constitutes acceptance.

14. Contact

Privacy contact: [email protected] · Zhao Menglong (individual merchant), the People’s Republic of China. We answer privacy requests in English or Chinese.