Privacy Policy

Flashbuy Trade Limited ("we," "us," or "our") operates AvatarAI. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our AI Headshot Generation Service.

1. Information We Collect

Personal Information: Name, email address, phone number, billing address, payment details (processed securely through Stripe), account credentials, and correspondence.

Photos and Biometric Data: When you upload photos for AI headshot generation, we process facial images to generate AI-enhanced portraits. This constitutes biometric data processing under applicable laws.

Automated Information: IP address, browser/device type, pages viewed, cookies data, and interaction patterns with our AI service.

2. How We Use Your Information

  • To process AI headshot generation requests
  • To manage your account and credits
  • To process payments securely through Stripe
  • To communicate service updates and support
  • To improve our AI models and service quality
  • To prevent fraud and unauthorized access
  • To comply with legal obligations

3. AI-Generated Content & Your Photos

Photo Processing: Your uploaded photos are processed by our AI service to generate headshots. Photos are temporarily stored during processing and deleted from our active servers within 30 days after generation is complete.

No Training on Your Data: We do NOT use your uploaded photos or generated images to train, improve, or fine-tune our AI models. Your data is used solely for generating your requested headshots.

Generated Images Ownership: You retain ownership and all rights to the AI-generated headshots produced from your photos. You may use them for personal and commercial purposes according to your purchased plan.

4. Biometric Data Protection

We recognize that facial images constitute biometric data under certain jurisdictions (including Illinois BIPA, EU GDPR, and others). We commit to:

  • Obtaining your explicit consent before processing facial images
  • Using biometric data only for the stated purpose (headshot generation)
  • Not selling or sharing biometric data with third parties
  • Deleting biometric data within 30 days of processing completion
  • Providing you the right to request immediate deletion of your photos

5. Sharing of Your Information

We do not sell your personal information or photos. We may share with:

  • AI Service Providers: Trusted AI processing partners who generate headshots on our behalf (under strict data processing agreements)
  • Payment Processors: Stripe for secure payment processing
  • Cloud Storage: Secure cloud providers for temporary photo storage
  • Legal Requirements: If required by law or to protect our rights

6. International Data Transfers

Your data may be transferred to and processed in the United Kingdom, the United States, and other locations where our service providers operate. We ensure appropriate safeguards are in place for such transfers.

7. Data Security

We implement industry-standard security measures including encryption in transit (TLS) and at rest, access controls, and regular security audits. However, no method of electronic transmission or storage is 100% secure.

8. Your Data Protection Rights

Depending on your location, you may have the following rights:

  • Access: Request a copy of your personal data
  • Rectification: Request correction of inaccurate data
  • Deletion: Request deletion of your photos and personal data
  • Objection: Object to processing of your data
  • Portability: Request your data in a portable format
  • Withdraw Consent: Withdraw consent for biometric data processing at any time

To exercise any of these rights, contact us at flashbuy@forallpay.asia

9. Cookies

We use essential cookies for authentication and service functionality. You can disable cookies in your browser settings, but some features may not work properly.

10. Children's Privacy

Our Service is not intended for individuals under 18. We do not knowingly collect or process photos of children. If we become aware that a child's photo has been uploaded, we will delete it immediately.

11. Changes to This Policy

We may update this policy periodically. Changes will be posted here with an updated "Last Updated" date. Continued use of the Service after changes constitutes acceptance of the updated policy.

12. Contact Us

  • Company: Flashbuy Trade Limited
  • Email: flashbuy@forallpay.asia
  • Address: Room A133, Unit 01, 15/F, Block A, Wah Sang Industrial Building, 14-18 Wong Chuk Yeung Street, Fo Tan, Hong Kong

Last Updated: June 2026