LensUp AI

Privacy Policy

Last updated: 14 April 2026 — Version 1.1

1. Data Controller

Giuseppe Mosca
65015 Montesilvano (PE), Italy
privacy@lensupai.com

2. Data processed, purposes and retention

Details about processed data, their purposes, and retention periods are available upon request by writing to privacy@lensupai.com.

3. Face Data

LensUp AI does not retain face data. The selfie containing the user's face is transmitted in memory to the AI model (Google Vertex AI) and discarded immediately upon completion of processing. No facial image is ever written to disk, database, or any storage system.

The duration of processing is limited to the in-memory transit required to generate the headshot, typically a few seconds. Once processing is complete, all face data ceases to exist on LensUp AI systems.

LensUp AI does not use face data for any purpose other than generating the headshot requested by the user. Face data is not used for AI model training, profiling, facial recognition, or any other purpose.

4. Legal basis

5. Sub-processors: Google LLC — Vertex AI and Firebase Authentication

LensUp AI uses two Google LLC services as data processors (sub-processors) under Art. 28 GDPR, both covered by the Google Cloud Data Processing Addendum (DPA) signed in the GCP Console.

5a. Google Vertex AI (Gemini) — photo processing

5b. Google Firebase Authentication — user authentication

6. Your rights

Rights under Arts. 15–22 GDPR may be exercised at any time from the Profile section of the app or by writing to privacy@lensupai.com. The controller responds within 30 days (Art. 12.3 GDPR).

7. Security

8. Minors

The service is restricted to persons aged 16 or over (Art. 8 GDPR). An age verification step is implemented at registration. LensUp AI does not knowingly collect data from minors under 16.

9. Contact

For any data protection enquiry: privacy@lensupai.com