Privacy Policy
PixPunch
Last updated: July 4, 2026
Effective date: July 4, 2026
1. Introduction
PixPunch ("we", "us", "our", or the "Data Fiduciary") is committed to protecting your personal data. This Privacy Policy explains what data we collect, how we use it, with whom we share it, and what rights you have in relation to it.
This policy applies to all users ("you", "Data Principal") of the PixPunch application and website at https://app.pixpunch.com/ (the "Service"), operated by:
PixPunch
A company registered in India
Email: support@pixpunch.com
We process personal data in accordance with India's Digital Personal Data Protection (DPDP) Act, 2023 and its rules, the Information Technology Act, 2000, and, where applicable, the General Data Protection Regulation (GDPR) for users located in the European Economic Area (EEA) and the United Kingdom.
Under the DPDP Act, PixPunch acts as the Data Fiduciary in relation to your personal data, and you, as our user, are the Data Principal.
2. Data We Collect
2.1 Information You Provide Directly
- Account information: name, email address, username, and password when you register
- Profile information: profile photo, biography, photography skill level, and preferences you choose to provide
- Payment information: billing details (processed by our payment provider — we do not store full card numbers)
- Communications: messages, support requests, and feedback you send to us
- User Content: photographs and images you upload or capture through the Service for AI coaching and analysis
2.2 Information Collected Automatically
- Device information: device model, operating system, browser type, language settings, and unique device identifiers
- Usage data: features accessed, time spent, actions taken within the Service, session frequency, and error logs
- Log data: IP address, access timestamps, referring URLs, and pages viewed
- Camera access: only when you actively grant permission; we do not access your camera in the background
2.3 Information from Third Parties
- Authentication providers: if you sign in via Google, Apple, or another third-party provider, we receive your name, email address, and profile photo from that provider, subject to your privacy settings with them
- Analytics providers: we use analytics services to collect aggregated and anonymised usage data to help us understand how the Service is used. Details of these providers and how they operate are set out in our Cookie Policy
3. Purposes of Processing
We process your personal data for the following purposes:
| Purpose | Legal Basis |
|---|---|
| Providing and operating the Service | Performance of a contract |
| Processing payments and managing subscriptions | Performance of a contract |
| Analysing your photos to deliver AI coaching feedback | Performance of a contract / Consent |
| Communicating with you about your account, updates, and support | Performance of a contract |
| Sending marketing communications | Consent (given separately, and withdrawable at any time) |
| Improving our AI models and the Service using your photos | Consent (given separately from the core Service; see Section 4) |
| General product/service improvement (non-photo usage data) | Legitimate interests |
| Detecting and preventing fraud, abuse, and security incidents | Legitimate interests / Legal obligation |
| Complying with legal obligations | Legal obligation |
| Resolving disputes | Legitimate interests / Legal obligation |
Consent withdrawal: Where our processing relies on your consent, you may withdraw that consent at any time. Withdrawing consent is as simple as giving it — you can do this through your account settings or by contacting us at support@pixpunch.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and may limit your ability to use certain features of the Service (for example, AI coaching requires processing your photos).
4. Photographs and AI Processing
When you upload or capture photos through the Service, we process these images to provide AI coaching feedback. Photographs may contain sensitive information, including images of people.
- Photos are processed by our AI systems to generate coaching output, as necessary to provide the Service to you
- We only use your photos to train or improve our AI models where you have given separate, explicit consent for this purpose — this is never a condition of using the core coaching Service, and you can decline without losing access to AI coaching
- We do not use your photos for advertising or share them with third parties for their own purposes
- The scores and feedback generated by our AI are intended to support your own creative decisions. They do not produce any legal effect or similarly significant decision about you, and are not used for automated decision-making that affects your rights
- You may request deletion of your photos at any time (see Section 8)
5. Cookies and Tracking
We use cookies and similar tracking technologies on our website and app. Please see our Cookie Policy for full details, including the specific analytics and tracking providers we use.
6. Data Sharing
We do not sell your personal data. We may share your data with:
- Service providers: third-party vendors who assist with hosting, payment processing, analytics, customer support, and cloud storage — bound by data processing agreements and permitted to use your data only to perform services on our behalf
- AI infrastructure providers: cloud-based AI services used to process your photos and generate feedback, subject to appropriate data protection safeguards
- Legal and regulatory authorities: where required to comply with a court order, legal obligation, or request from a government authority
- Business transfers: in connection with a merger, acquisition, or sale of assets, provided the acquiring entity agrees to honour this Privacy Policy
We require all third parties to implement appropriate technical and organisational measures to protect your data.
7. International Data Transfers
PixPunch is based in India. If you access the Service from outside India, your data may be transferred to and processed in India or other countries where our service providers operate, including countries whose data protection laws may differ from those in your country.
We transfer personal data outside India in accordance with the DPDP Act, 2023. As of the date of this policy, the DPDP Act permits transfers to countries not restricted by the Central Government. If the Government of India notifies restrictions on transfers to specific countries in the future, we will comply with those restrictions and update this policy accordingly.
Where we transfer data to the EEA/UK or process data of EEA/UK residents, we implement appropriate safeguards in accordance with GDPR, including standard contractual clauses or other legally recognised transfer mechanisms.
8. Data Retention
We retain your personal data for as long as necessary to provide the Service and comply with our legal obligations:
- Account data: retained for the duration of your account and deleted within 90 days of account closure
- Photos and User Content: retained as long as you maintain your account; you may delete individual photos at any time through the Service
- Payment records: retained for a minimum of 7 years to comply with applicable financial and tax laws
- Support communications: retained for up to 3 years from the date of resolution
- Anonymised analytics data: may be retained indefinitely, as it can no longer be linked back to you
9. Your Rights
Depending on your location, you may have the following rights regarding your personal data:
Under India's DPDP Act, 2023
- Right to access information: obtain a summary of the personal data we process about you and the processing activities undertaken
- Right to correction and erasure: request correction of inaccurate or incomplete personal data, and request deletion of your personal data, subject to legal retention obligations
- Right to grievance redressal: raise a grievance with our designated Grievance Officer (see Section 14), and receive a response within the timelines set out below
- Right to escalate to the Data Protection Board: if you are not satisfied with how we resolve your grievance, you have the right to file a complaint with the Data Protection Board of India
- Right to nominate: nominate another individual to exercise your rights on your behalf in the event of your death or incapacity
- Right to withdraw consent: withdraw consent at any time for any processing based on consent, as easily as it was given (see Section 3)
Additional Rights for EEA/UK Users (GDPR)
- Right to restrict processing: request that we limit processing of your data in certain circumstances
- Right to data portability: receive your data in a structured, machine-readable format
- Right to object: object to processing based on legitimate interests
- Right to lodge a complaint: with your national data protection supervisory authority
To exercise any of these rights, please contact us at support@pixpunch.com. We will respond within 30 days of receiving your request. We may need to verify your identity before processing your request.
10. Security and Breach Notification
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction, including:
- Encryption of data in transit (TLS/HTTPS) and at rest
- Access controls and authentication measures
- Regular security assessments
No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
In the event of a personal data breach, we will, in accordance with the DPDP Act and applicable law:
- Notify the Data Protection Board of India of the breach, in the form and manner prescribed by law
- Notify affected Data Principals of the breach without delay, describing the nature of the breach, its likely consequences, and the measures we have taken or propose to take to mitigate the risk
- Where the GDPR applies, notify the relevant supervisory authority and affected individuals in accordance with GDPR breach-notification timelines and requirements
11. Children's Privacy
Under the DPDP Act, 2023, a "child" means anyone under the age of 18.
We do not knowingly collect or process the personal data of a child without verifiable parental or lawful guardian consent. Where we become aware that a user is a child, we will:
- Not undertake tracking or behavioural monitoring of that child
- Not display targeted advertising directed at that child
- Only process the child's personal data where such processing is clearly in the child's best interest, and obtain verifiable consent from a parent or lawful guardian before doing so
If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us immediately at support@pixpunch.com and we will take steps to verify this and delete such data where appropriate.
12. Third-Party Links
The Service may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you visit.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Service and updating the "Last updated" date. For significant changes, we may also send you a direct notification by email. Your continued use of the Service after the effective date of any changes constitutes acceptance of the updated policy.
14. Grievance Officer / Contact
For privacy-related queries, concerns, or to exercise your rights, please contact our designated Grievance Officer:
PixPunch — Grievance Officer
Email: support@pixpunch.com
Website: https://app.pixpunch.com/
We aim to acknowledge your query within 48 hours and resolve it within 30 days. If you are not satisfied with our resolution, you may escalate your complaint to the Data Protection Board of India.