Privacy Policy

1. Introduction

Muntean Holding AS ("Company", "we", "us", or "our") operates the Pencil Sketch mobile application ("App", previously offered as Sketchpage). We are the controller of the personal data described in this Privacy Policy. This Privacy Policy explains what information we and our service providers handle when you use the App, why, and what choices you have.

2. Information We Collect

2.1 Photos You Choose

The App reads only the photos you pick from your library, or a photo you take with your camera, and only when you ask it to create a sketch or coloring page. The photo is sent over an encrypted connection to our Firebase Cloud Function and from there to OpenAI's image API, which creates the result. The result is returned to your device. See Section 4 for details. Photos may show people or other personal information, so please only use photos you have the right to use.

2.2 Account and Usage Data

We use Firebase Authentication to create an anonymous account. It gives your installation a random user ID. There is no email address, name or password. For this account, our server keeps one record that contains:

• Your anonymous user ID and when the account was created
• Your credit balance
• Rewarded-ad counters (for example, how many ads you have watched toward your next credit, how many credits you earned today, and when the last ad was reported)
• Usage counters (for example, how many results you created in the current month, used for the fair use limit)
• Where reward verification is enabled, records of verified rewarded-ad completions (a transaction ID from Google, the ad unit and the reward)
• A ledger of request IDs and their status (for example, charged, completed or refunded), which prevents double charges and lets us return credits for failed requests
• The country code of your device's language and region setting, which we use only to decide how many ads are needed for a credit
• A short-lived copy of your Pro status, so that we do not have to look it up on every request

This record does not contain your photos or results.

2.3 Purchase Information

If you subscribe to Pencil Sketch Pro, the payment is handled by the Apple App Store or Google Play. We do not receive your payment card details. We use RevenueCat to manage subscription status; RevenueCat receives your anonymous user ID and purchase information (such as which subscription you have, its dates and renewal status) from the store. We receive from RevenueCat whether your Pro subscription is active.

2.4 Advertising Data

The App shows rewarded ads using Google AdMob. When an ad is requested, Google and its advertising partners may process your device's advertising identifier, IP address, device and ad-interaction information to deliver, measure and personalize ads, and to prevent fraud. We do not receive your advertising identifier or other ad profile data from Google. To confirm that you completed a rewarded ad, the App passes your anonymous user ID to AdMob, which can send a verification message containing that ID, a transaction ID and the reward to our server. See Section 6 for your choices. Pro subscribers do not see ads.

2.5 Technical Data and Logs

When the App contacts our servers, Google's infrastructure (Firebase and Google Cloud) automatically processes technical data such as your IP address and request details in order to deliver the service. Our server code writes operational logs for troubleshooting, abuse prevention and billing accuracy. These logs contain your anonymous user ID, request ID, the chosen style and type of result, image size, processing time and error information. They do not contain your photos, results or prompts.

2.6 Messages to Support

If you email us, we receive your email address and whatever you tell us. The "Contact support" option in the App adds your Support ID (your anonymous user ID) and the app version to the email so that we can find your account.

2.7 What We Do Not Collect

We do not collect your name, email address (unless you write to us), password, contacts, precise location or browsing history. The App does not include third-party analytics or crash-reporting SDKs. The App asks for access to your camera and photo library only for the features described above, and to save finished sketches to your photo library when you choose to.

3. How We Use Your Information and Our Legal Bases

We use the information described above for the following purposes:

• To create your sketches and coloring pages (performance of our contract with you)
• To run your anonymous account, credits, rewarded ads and Pro subscription (performance of a contract)
• To enforce fair use and ad limits, and to detect and prevent fraud and abuse (our legitimate interests)
• To keep the service secure, reliable and working, and to fix errors (our legitimate interests)
• To show rewarded ads that may be personalized, where you have given consent when this is required (consent)
• To answer your questions and requests (contract and legitimate interests)
• To comply with legal obligations

We do not use your photos for any purpose other than creating the result you requested. We do not use them to train AI models, and we do not make decisions about you by automated means that have legal or similarly significant effects. Safety systems, ours or OpenAI's, may refuse to process some images.

4. Photos and OpenAI

To create a result, the App sends your photo, together with the chosen style and settings, over an encrypted connection to our Firebase Cloud Function. The function sends the photo to OpenAI's image API and returns the result to your device. The function only holds the photo and the result while it is processing your request. We do not save your photo or the result to any database or file storage on our side, and we do not include them in our logs.

OpenAI processes the photo to generate the result under its API terms and policies. We do not control OpenAI's processing and, beyond what its terms state, we make no promises about how OpenAI handles data. For how OpenAI handles data sent through its API, please read OpenAI's Privacy Policy and OpenAI's data usage page.

Your finished sketches and coloring pages are then saved on your device only (see Section 7). They are not backed up by us.

5. Data Sharing and Service Providers

We do not sell your personal information for money. We share data only with the service providers that we need to run the App, and they process it for the purposes described in this Privacy Policy:

• Google Firebase (Google Cloud): anonymous authentication, Cloud Functions (our server code) and Firestore (our account database). Firebase privacy information
• OpenAI: creates the sketch or coloring page from your photo (see Section 4). OpenAI Privacy Policy
• RevenueCat: manages subscription status; receives your anonymous user ID and purchase information. RevenueCat Privacy Policy
• Google AdMob: shows rewarded ads and may process your advertising identifier (see Section 6). Google Privacy Policy
• Apple App Store and Google Play: distribute the App and process payments under their own privacy policies

5.1 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, government agencies).

5.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

6. Advertising, Consent and Your Choices

Rewarded ads are optional and are shown only to users who are not Pro subscribers. Before ads are loaded, the App asks for the consent that applies where you live:

• iOS: the App shows Apple's App Tracking Transparency prompt, which asks whether the App may track you across other companies' apps and websites. You can change your choice at any time in your device's Settings, under Privacy and Security, Tracking.
• EEA, UK and other regions where required: the App shows a consent form provided by Google (User Messaging Platform) that lets you choose how your data may be used for ads.
• Change your choice: where a consent form is required, you can reopen it at any time from the privacy options in the Profile screen of the App.
• Android: the App declares the Google advertising ID permission. You can reset or delete your advertising ID, or opt out of ads personalization, in your Android settings (Settings, Privacy or Google, Ads).

If you decline, you can still use the App. Depending on your choices and where you live, ads may be less relevant or may not be available, which means you may not be able to earn credits by watching ads. Pro subscribers do not see ads.

Some privacy laws, such as those in California, treat the sharing of advertising identifiers with advertising partners as a "sale" or "sharing" of personal information. You can opt out through the choices described above.

7. Data Retention and Where Your Data Lives

• Photos and results: not kept on our servers once your request is complete (see Section 4). OpenAI handles the data it receives according to its own terms.
• Sketches and coloring pages: stored on your device only. We cannot see, back up or recover them. Deleting the App removes them from your device.
• Account record: kept for as long as needed to provide the service, for example so that your credits and Pro status keep working, and deleted when you ask us to (see Section 8).
• Logs: kept for a limited period in Google Cloud logging, under its retention settings.
• Purchase records: Apple, Google and RevenueCat keep these under their own policies and legal obligations.
• Support emails: kept for as long as needed to deal with your request and any follow-up.

Deleting the App does not delete your account record on our servers. To have it deleted, contact us (Section 8). Deleting the App also does not cancel your subscription.

8. Your Rights and How to Use Them

Depending on where you live (for example, in the EEA, the UK or California), you may have the following rights:

• Access: Request access to the personal information we hold about you
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your personal information
• Objection and Restriction: Object to or ask us to restrict certain processing
• Portability: Request a copy of your information in a portable format
• Withdraw Consent: Withdraw consent where we rely on it, for example through the privacy options in the App
• Opt out of sale or sharing: see Section 6
• Non-discrimination: We will not treat you differently for exercising your rights

How to exercise your rights, including account deletion: email us at yolo@illebra.app, ideally using "Contact support" in the Profile screen of the App, which adds your Support ID so that we can find your account. Because your account is anonymous, we need this ID to identify your data. We may ask you for further information to verify the request. We aim to respond within one month. When you ask for deletion, we delete your account record and ledger from our systems and your anonymous account, and we will ask RevenueCat to delete its record linked to your user ID. Your credits will be lost and cannot be restored. We cannot delete data held by Apple, Google (including AdMob) or OpenAI; please contact them directly (see the links in Section 5).

You also have the right to complain to a data protection authority, for example the Norwegian Data Protection Authority (Datatilsynet) or the authority where you live.

9. Data Security

We use reasonable security measures to protect your information, including encrypted connections between the App, our servers and OpenAI, access limits for our database, and keeping our service keys on the server and never in the App. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

10. Children's Privacy

The App is not directed to children. You must be at least 13 years old (at least 16 years old in the European Economic Area) to use it. We do not knowingly collect personal information from children below that age. If you believe that a child has provided us with personal information, please contact us, and we will take steps to delete it.

11. Third-Party Links

The App and this page contain links to third-party websites and services, such as those of OpenAI, Google, RevenueCat, Apple and Google Play. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

12. International Data Transfers

We are based in Norway. Our server functions run in the United States (Google Cloud, region us-central1), and OpenAI, RevenueCat and Google process data in the United States and other countries. Your information may therefore be transferred to and processed in countries outside your own, including countries that may have different data protection laws. Where required, these transfers rely on safeguards recognised by applicable law, such as standard contractual clauses, as implemented by those providers.

13. Cookies and Our Website

The App itself does not use cookies. Ads in the App may use device identifiers as described in Section 6. Our website (sketch.page) uses Google Analytics (via Firebase) to measure visits, and Google Ads conversion measurement to measure the performance of our advertising for the App. These services set cookies only if you accept them in the cookie banner. If you decline, no analytics or advertising cookies are set, but Google still receives basic signals without cookies (for example that a page was viewed, with your IP address and browser information as part of the request), so that visits and ad results can be estimated in aggregate. You can change your choice at any time with "Cookie settings" at the bottom of every page of the website, and you can also control cookies in your browser settings.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example when we add or change features or service providers. We will post the new Privacy Policy on this page and update the "Last Updated" date, and we will inform you in the App about material changes. If we need your consent for a change, we will ask for it.

15. Contact Us

If you have any questions about this Privacy Policy, please contact us: