Image / Video / Audio Generation · faceapp.comFaceApp
Graded against 804 verified platforms, from its own policy text. Automated assessment against a published rubric — not legal advice.
“Our Services may allow you and other users to transform and share content, including photos, images, graphics, videos and other materials (collectively, “User Content”). FaceApp does not claim ownership of any 1) User Content that you share on or through the Services, or 2) User Content transformed through the Services that you save or share on or through…”
Watch: Commercial use
Start here. These are the highest-risk verified clauses AIRIN found in the platform's own policy text.
This clause defines the scope of the license for Apple-Enabled Software as limited and non-transferable, restricting use to devices owned or controlled by the user in accordance with Apple's Usage Rules.
Exclusive jurisdiction clauses in a foreign country impose substantial cost and logistical burdens on users, effectively denying access to justice for users who cannot afford international litigation. The 'irrevocably submit' language removes any flexibility.
Exclusive jurisdiction for appeals and enforcement in a foreign court imposes significant travel and legal cost burdens on non-Cyprus users, effectively discouraging challenges to arbitration awards.
Scores derived from 58 enriched findings — same verbatim citations as below. AI-generated, not legal advice.
- Your outputs and prompts are explicitly yours — FaceApp's terms include affirmatively protective IP language.
- Data handling is conditional — 8 privacy or retention clauses warrant review before using FaceApp at scale.
Derived from AI-enriched analysis of the verified findings below — informational only, not legal advice.
How to read this page: Overall risk rates what FaceApp's own policy terms mean for your prompts, outputs, and data. The benchmark bands below grade those same verified terms relative to peers — a platform in a risky-by-default category can rate HIGH risk and still grade STRONG against its peer set. Both trace to the cited findings.
Policy benchmark
rubric v1.0 — how this is scoredBased on 162 verified, verbatim-cited findings below — read the citations.
Based on 217 verified, verbatim-cited findings below — read the citations.
Automated assessment against a published rubric — not legal advice.
Fully verified — complete core corpus captured and read in full.
- Privacy PolicyVerified - read in full - 76 citationsstaticLast captured 2026-06-07
- Terms of ServiceVerified - read in full - 104 citationsstaticLast captured 2026-06-07
Only citation-backed plan differences are shown here; absent cells mean AIRIN has not verified a tier-specific claim.
Clarifies that FaceApp does not claim ownership of User Content or Transformed Content, confirms that users retain all rights in their content, and grants FaceApp a nonexclusive, sublicensable, royalty-free, worldwide, fully paid license to use and process User Content; defines the scope of the content license granted to FaceApp and the user's retained ownership.
" Our Services may allow you and other users to transform and share content, including photos, images, graphics, videos and other materials (collectively, “User Content”). FaceApp does not claim ownership of any 1) User Content that you shar..."
This clause clarifies that FaceApp does not receive payment card or billing data for subscribers; only subscription status is received. This is a favorable data-minimization approach for paid users, though it shifts billing data liability to Apple/Google.
"App-related purchase history , if you choose to purchase an Apps subscription, we will not receive such information as billing address, credit card etc. (as we don’t distribute subscriptions directly), we will only receive confirmation from..."
Establishes the procedure for submitting data subject requests, including identity verification requirements, authorized agent provisions for California residents, and the non-discrimination principle when exercising rights.
" To make a request, please email us at privacy@faceapp.com . We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will r..."
Establishes a legitimate-interest basis permitting FaceApp to use personal data to improve, monitor, and protect the Apps and Site, invoking the company's business interest in maintaining safe and secure services.
" To improve, monitor, and protect our Apps and the Site . It is in our legitimate business interests to improve and keep our services safe and secure for our users. We do this by:"
This clause imposes a representation and warranty obligation on the user to confirm they are not located in a sanctioned country and are not on any U.S. Government prohibited or restricted parties list, creating a compliance obligation as a condition of use.
" Legal Compliance. You represent and warrant that (a) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a “terrorist supporting” country, and (b) you are not..."
This clause obligates users to comply with Cyprus, EU, UK, and other international export control and economic sanctions laws, prohibiting provision, export, reexport, or transfer of the Services to sanctioned regions or restricted entities.
" The Services are subject to Cyprus, EU, UK and other international and foreign export control and economic sanctions laws and regulations. You agree to comply strictly with all such laws and regulations as they relate to the Services. With..."
This compliance clause imposes affirmative user obligations under U.S. export control and sanctions law. Breach could constitute both a contractual violation and a regulatory offense with significant penalties.
"The Services may be subject to U.S. economic sanctions regulations administered by the Office of Foreign Assets Control (“OFAC”), U.S. Department of the Treasury. You agree to comply strictly with all such laws and regulations as they relat..."
Conditions free-tier use on acceptance of FaceApp watermarking Transformed Content for self-advertising purposes and acknowledges that sponsored/commercial content may not always be identified (with a carve-out for UK/EU users); establishes tier-based commercial-use obligations and disclosure differences.
" You acknowledge that if you use the free version of the App, you hereby agree that FaceApp may place its watermark on Transformed Content, which in some jurisdictions may be deemed as self-advertising and self-promotion. The manner, mode a..."
Clause A states that photos/videos are temporarily cached on cloud servers, while Clause B states that only the local device can view the photo/video, strongly implying the data's accessibility and residency are strictly confined to the local device, which contradicts its presence on cloud servers.
" Photographs or videos are temporarily cached on the cloud servers during the editing process and encrypted using a key stored locally on your mobile device."
" Photographs or videos you select when you use the Apps , via your camera or camera roll (if you have granted the Apps the permission to access your camera or camera roll), or via the in-App internet search functionality. We process only specific photos and videos you choose to modify using the Apps; and we do not collect your photo or video albums even if you grant us access to them. We safeguard each photograph or video that you select using an encryption key stored locally on your device. This means that the only device that can view the photo or video is the device from which the photograph or video was submitted using the Apps - the user’s device. Please note that while we do not require or request any metadata attached to the photographs or videos you select for editing, metadata (including, for example, geotags) may be associated with your photographs or videos by default. We take steps to delete any metadata that may be associated with a photograph or video you provide when you use the Apps. Photographs or videos may remain cached in the cloud for a limited period between 24 to 48 hours after your last edit, so that you can return to it and make additional changes if you so choose."
Within one document
Evidence appendix
Showing priority citations first. The full appendix is available for audit trails; not every citation is a severe risk.
" Scope of License. The license granted to you is limited to a non-transferable license to use the Apps on any Apple-Enabled Software that you own or control as permitted by the Usage Rules set forth in the Apple Media Services Terms and Conditions."
This clause defines the scope of the license for Apple-Enabled Software as limited and non-transferable, restricting use to devices owned or controlled by the user in accordance with Apple's Usage Rules.
AI-generated interpretation, not legal advice.
"To market and to promote our Services . We may use your personal information to understand where our App and Site traffic comes from to improve our marketing strategies and our promotional companies. It helps us to personalize our promotion offers and understand broader our Service audience behavior, offering a tailored experience. Where required under applicable law, we process your personal information based on your consent for these purposes, which you may withdraw at any time. Otherwise, we process your personal information for marketing and promotional purposes where it is in our legitimate interests to do so."
Reliance on 'legitimate interests' for marketing without requiring affirmative consent may be problematic under GDPR in some contexts. The policy provides a withdrawal mechanism only where required by law, leaving users in other jurisdictions without a clear opt-out right.
AI-generated interpretation, not legal advice.
" Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. Please note that we may require additional information in order to verify your identity and process your request."
Limits the scope of user data choices by identifying circumstances where requests cannot be fulfilled, such as when compliance would impair others' rights, service delivery, or legal obligations, and directs users to the complaint process if unsatisfied.
AI-generated interpretation, not legal advice.
"Any use of our Services or FaceApp Content other than as specifically authorized herein, without our prior written permission, is strictly prohibited and will result in automatic termination of the licenses granted under this Agreement. You will not remove, alter or conceal any copyright, trademark, watermark, service mark or other proprietary rights notices incorporated in or accompanying the FaceApp Content and/or Transformed Content."
Restricts any use of Services or FaceApp Content beyond specifically authorized uses to require prior written permission, provides that unauthorized use automatically terminates granted licenses, and prohibits removal or alteration of proprietary rights notices.
AI-generated interpretation, not legal advice.
"To create anonymous, aggregated, or de-identified data. We may create anonymous, aggregated, or de-identified data where it is in our legitimate business interests, and use and share it with third parties."
Aggregation/de-identification carve-outs are common but can pose risks when datasets include facial transformation data. The policy imposes no restrictions on how third parties may use this de-identified data, and no mention is made of de-identification standards applied.
AI-generated interpretation, not legal advice.
" 2.4. We use cookies that are essential for FaceApp to function. We would also like to use cookies and similar technologies to store, access and process your information for analytics, troubleshooting, and marketing. With your consent, we and our third-party partners may use additional tracking technologies to enhance your user experience."
Discloses that FaceApp uses essential cookies required for functionality and, with user consent, additional cookies and tracking technologies for analytics, troubleshooting, and marketing by FaceApp and third-party partners, establishing the consent-based permission structure for non-essential data processing.
AI-generated interpretation, not legal advice.
" We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Apps and Site. We may, and if required by law will, provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the Apps."
Reserves the platform's right to modify the Privacy Policy at any time and establishes the procedure for notifying users of material changes, including updating the date and posting on the apps and site.
AI-generated interpretation, not legal advice.
" You acknowledge that if you use the free version of the App, you hereby agree that FaceApp may place its watermark on Transformed Content, which in some jurisdictions may be deemed as self-advertising and self-promotion. The manner, mode and extent of such advertising and promotions are subject to change without specific notice to you. Unless you are located in the UK or the EU, you acknowledge that we may not always identify sponsored content, or commercial communications as such. If you are located in the UK or the EU you acknowledge and agree that all advertisements and promotions are recognized as sponsored content or commercial communications by default."
Conditions free-tier use on acceptance of FaceApp watermarking Transformed Content for self-advertising purposes and acknowledges that sponsored/commercial content may not always be identified (with a carve-out for UK/EU users); establishes tier-based commercial-use obligations and disclosure differences.
AI-generated interpretation, not legal advice.
" Any modifications to this Privacy Policy will be effective upon our posting the new terms to the Site and/or upon implementation of the new changes on the Apps and Site (or as otherwise indicated at the time of posting). In all cases, your continued use of our services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy."
Defines when modifications become effective (upon posting) and establishes that continued use of services constitutes acceptance of the modified Privacy Policy terms.
AI-generated interpretation, not legal advice.
" For compliance, fraud prevention, and safety. We may use and disclose the information we collect (such as device data and Apps usage information) where it is in our legitimate business interests to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Apps and Site; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity. We may disclose this information to government authorities and other third parties as required by applicable law. We cannot disclose the photos and videos that have been cached for processing as we do not store the encryption keys."
Permits FaceApp to use and disclose collected data (device data and usage information) for compliance, fraud prevention, safety, and enforcement of terms and conditions, including disclosure to government authorities and third parties, on a legitimate-interest basis.
AI-generated interpretation, not legal advice.
" 2.3. We will only process personal information on the basis of our legitimate interests where such interests are not overridden by your interests or your fundamental rights and freedoms."
Limits FaceApp's reliance on legitimate interests as a legal basis for processing personal information by requiring that such interests not override users' interests, fundamental rights, or freedoms, qualifying the scope of legitimate-interest permissions granted elsewhere.
AI-generated interpretation, not legal advice.
" Photographs or videos you select when you use the Apps , via your camera or camera roll (if you have granted the Apps the permission to access your camera or camera roll), or via the in-App internet search functionality. We process only specific photos and videos you choose to modify using the Apps; and we do not collect your photo or video albums even if you grant us access to them. We safeguard each photograph or video that you select using an encryption key stored locally on your device. This means that the only device that can view the photo or video is the device from which the photograph or video was submitted using the Apps - the user’s device. Please note that while we do not require or request any metadata attached to the photographs or videos you select for editing, metadata (including, for example, geotags) may be associated with your photographs or videos by default. We take steps to delete any metadata that may be associated with a photograph or video you provide when you use the Apps. Photographs or videos may remain cached in the cloud for a limited period between 24 to 48 hours after your last edit, so that you can return to it and make additional changes if you so choose."
Restricts FaceApp's data collection to only specific photos/videos selected by the user for modification, explicitly excluding collection of entire photo/video albums, and describes an encryption obligation to protect each selected file using a device-local key.
AI-generated interpretation, not legal advice.
"FaceApp reserves the right to modify, discontinue, replace or remove any Services (including but not limited to beta Services) temporarily or permanently at any time in FaceApp’s sole discretion, with or without notice. You agree that FaceApp will not be liable to you or to a third party for any modification, discontinuance, replacement or removal of any Services."
The provision gives FaceApp unilateral power to modify or discontinue services without notice or compensation. Combined with the liability exclusion, users bear all risk associated with service changes or termination.
AI-generated interpretation, not legal advice.
"is, in our sole judgment, objectionable, restricts or inhibits any other person from using or enjoying our Services or may expose FaceApp or others to any harm or liability of any type."
The 'sole judgment' standard for objectionable content gives FaceApp unchecked enforcement discretion. Users have no contractual right to contest takedowns or enforcement actions based on this provision.
AI-generated interpretation, not legal advice.
" TO THE FULLEST EXTENT PERMITTED BY LAW, FACEAPP AND THE OTHER FACEAPP PARTIES WILL NOT BE LIABLE TO YOU UNDER ANY THEORY OF LIABILITY-WHETHER BASED IN CONTRACT, TORT, NEGLIGENCE, BREACH OF STATUTORY DUTY, STRICT LIABILITY, WARRANTY, OR OTHERWISE- FOR ANY: (A) INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, PUNITIVE OR SPECIAL DAMAGES; OR (B) LOST PROFITS, LOSS OF BUSINESS OR REVENUE, LOSS OF CONTRACTS, USE, OPPORTUNITY OR ANTICIPATED SAVINGS, OR LOSS OF OR DAMAGE TO GOODWILL, DATA OR SOFTWARE (IN EACH CASE WHETHER DIRECT OR INDIRECT), EVEN IF FACEAPP OR THE OTHER FACEAPP PARTIES HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES."
This clause limits FaceApp's liability by excluding indirect, consequential, exemplary, incidental, punitive, and special damages as well as lost profits and data losses under any theory of liability to the fullest extent permitted by law.
AI-generated interpretation, not legal advice.
" TO THE FULLEST EXTENT PERMITTED BY LAW, THE TOTAL LIABILITY OF FACEAPP AND THE OTHER FACEAPP PARTIES, FOR ANY CLAIM ARISING OUT OF OR RELATING TO THIS AGREEMENT OR OUR SERVICES, REGARDLESS OF THE FORM OF THE ACTION, IS LIMITED TO THE AMOUNT PAID, IF ANY, BY YOU TO ACCESS OR USE OUR SERVICES, OR IF GREATER, ONE HUNDRED EURO (€ 100)."
This clause caps FaceApp's total aggregate liability for any claim to the amount paid by the user or €100, whichever is greater, to the fullest extent permitted by law.
AI-generated interpretation, not legal advice.
" FURTHER, FACEAPP AND THE OTHER FACEAPP PARTIES WILL NOT BE LIABLE FOR ANY FAILURE OR DELAY RESULTING FROM ANY CONDITION BEYOND OUR REASONABLE CONTROL, INCLUDING BUT NOT LIMITED TO GOVERNMENTAL ACTION OR ACTS OF TERRORISM, PANDEMICS, EPIDEMICS, EARTHQUAKE, FIRE, FLOOD OR OTHER ACTS OF GOD, LABOR CONDITIONS, POWER FAILURES, AND INTERNET DISTURBANCES."
This clause excludes FaceApp's liability for failures or delays caused by force majeure events beyond its reasonable control, including acts of God, governmental action, pandemics, and infrastructure failures.
AI-generated interpretation, not legal advice.
"Subscriptions to the Services can only be purchased via third-party marketplaces (e.g., through the Apple App Store or Google Play Store). FACEAPP DOES NOT SELL ANY PAID SUBSCRIPTIONS DIRECTLY, DISTRIBUTE ANY PAID CONTENT AND/OR PROCESS PAYMENT FOR ANY SERVICES OR PURCHASES DIRECTLY. BY AGREEING TO THIS AGREEMENT, USERS THAT PURCHASE SUBSCRIPTIONS TO, OR OTHERWISE PAY FOR, THE SERVICES AGREE TO BE BOUND BY THE TERMS AND CONDITIONS AND/OR END USER LICENSE AGREEMENTS (OTHER LEGAL AGREEMENTS) WITH THE RELEVANT THIRD-PARTY MARKETPLACES (APPLE APP STORE, GOOGLE PLAY STORE, ETC.) WITH RESPECT TO SUCH SUBSCRIPTIONS OR OTHER PAYMENTS."
By accepting FaceApp's terms, paid users are automatically bound by Apple/Google marketplace terms for payment data handling. FaceApp disclaims all payment liability, meaning users must resolve payment and data disputes with third-party processors under those processors' own terms.
AI-generated interpretation, not legal advice.
Common questions about FaceApp's policies
- Can you use FaceApp's output commercially?
- Commercial use allowed — with conditions — based on 2 verified findings from FaceApp's published policy. Informational only, not legal advice.
Clause detail — protections, your obligations, and coverage
Every clause below is a verbatim quote from FaceApp's own published policy, read in full and linked to its exact location. Protections and user obligations are reported separately from risk because they are different kinds of clause — an obligation on you is not a risk to your data. Informational only, not legal advice.
✅ Protections found
33 verified clausesClauses in FaceApp's policies that work in your favour — commitments the platform made to you.
- Governing law & disputesarbitration & class-action waiver
“30-Day Right to Opt-Out. You have the right to opt out of the provisions of this Arbitration Agreement by sending written notice of your decision to opt-out to: arbitration@faceapp.com , within thirty (30) days after first becoming subject to this Arbitration…”
This clause grants users the right to opt out of the arbitration agreement within 30 days by written notice, specifying the formal requirements for such notice and confirming that all other agreement terms remain in effe…
📍 Terms of Service › “12A. BINDING ARBITRATION AGREEMENT - UNITED STATES USERS”Jump to exact text → - Governing law & disputesarbitration & class-action waiver
“Modification. Notwithstanding any provision in this Agreement to the contrary, we agree that if FaceApp makes any future material change to this Arbitration Agreement you may reject that change within fourteen (14) days of such change becoming effective by sen…”
This clause grants users the right to reject future material changes to the arbitration agreement within 14 days by written notice, specifying the formal requirements for such rejection notice.
📍 Terms of Service › “12A. BINDING ARBITRATION AGREEMENT - UNITED STATES USERS”Jump to exact text → - Indemnity & liabilitydamages/liability cap
“The limitations set forth in this section will not limit or exclude liability for fraud or fraudulent misrepresentation, death or personal injury caused by the gross negligence of FaceApp or the other FaceApp Parties, or for any other matters as to which liabi…”
This clause carves out exceptions to the liability limitations, preserving liability for fraud, fraudulent misrepresentation, death or personal injury caused by gross negligence, and other matters where liability cannot…
📍 § 10 (LIMITATION OF LIABILITY)Jump to exact text → - Privacy & data use
“To make a request, please email us at privacy@faceapp.com . We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized age…”
Establishes the procedure for submitting data subject requests, including identity verification requirements, authorized agent provisions for California residents, and the non-discrimination principle when exercising rig…
- Designated security contact: privacy@faceapp.com
📍 § 4 (Your Choices)Jump to exact text → - Privacy & data use
“If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. If you are…”
Provides users with a remedy to file complaints with the company or with applicable data protection regulators, identifying the Information Commissioner's Office for UK residents and referencing EU regulatory authorities…
📍 § 4 (Your Choices)Jump to exact text → - Indemnity & liabilityindemnity direction
“Intellectual Property Rights. The parties acknowledge that, in the event of any third-party claim that the Apps or your possession and use of the Apps infringe that third party’s intellectual property rights, FaceApp, and not Apple, will be solely responsible…”
This clause obligates FaceApp to be solely responsible for the investigation, defense, settlement, and discharge of any third-party intellectual property infringement claims arising from the Apps, excluding Apple from an…
📍 § 17 (ADDITIONAL TERMS APPLICABLE TO MOBILE SERVICES)Jump to exact text →
+ 27 more verified clauses of this kind on this platform, cited in full in the report.
📋 Rules you must follow
40 verified clausesWhat FaceApp requires of YOU. These are your obligations, not risks to your data or IP, so they are cited here and excluded from this platform's risk rating.
- Moderation & enforcementconduct restrictions
“The Services may be subject to U.S. economic sanctions regulations administered by the Office of Foreign Assets Control (“OFAC”), U.S. Department of the Treasury. You agree to comply strictly with all such laws and regulations as they relate to the Services. W…”
This compliance clause imposes affirmative user obligations under U.S. export control and sanctions law. Breach could constitute both a contractual violation and a regulatory offense with significant penalties.
📍 § 18 (REGULATORY)Jump to exact text → - Moderation & enforcementconduct restrictions
“The Services are subject to Cyprus, EU, UK and other international and foreign export control and economic sanctions laws and regulations. You agree to comply strictly with all such laws and regulations as they relate to the Services. Without limiting the fore…”
This clause obligates users to comply with Cyprus, EU, UK, and other international export control and economic sanctions laws, prohibiting provision, export, reexport, or transfer of the Services to sanctioned regions or…
📍 § 18 (REGULATORY)Jump to exact text → - Moderation & enforcement
“FaceApp’s name and logos are trademarks and service marks of FaceApp (collectively, the “FaceApp Trademarks”). Other companies, products, and service names and logos used and displayed via the Services may be trademarks or service marks of their respective own…”
Defines FaceApp Trademarks, reserves all trademark and service mark rights, and restricts any use of FaceApp Trademarks without prior written permission, including prohibiting implied licenses by estoppel.
📍 § 5 (LIMITED LICENSE; COPYRIGHT AND TRADEMARK)Jump to exact text → - Moderation & enforcement
“We offer Software that may be made available through the Apple App Store, the Google Play Store, or other distribution channels (“Distribution Channels”). If you obtain such Software through a Distribution Channel, you may be subject to additional terms of the…”
This clause incorporates the terms of Distribution Channels (Apple App Store, Google Play Store, etc.) as potentially binding on the user, and acknowledges that the Agreement is solely between the user and FaceApp, not t…
📍 § 17 (ADDITIONAL TERMS APPLICABLE TO MOBILE SERVICES)Jump to exact text → - Moderation & enforcementconduct restrictions
“The technology and software underlying the Services or distributed in connection therewith are the property of FaceApp, its affiliates, and its licensors (including the Apps, collectively, the “Software”). You agree not to copy, modify, create a derivative wor…”
This clause asserts FaceApp's ownership over the underlying software and technology, and restricts users from copying, modifying, reverse-engineering, sublicensing, or otherwise transferring any rights in the Software, w…
📍 § 17 (ADDITIONAL TERMS APPLICABLE TO MOBILE SERVICES)Jump to exact text →
+ 35 more verified clauses of this kind on this platform, cited in full in the report.
What the policies actually cover
13 topics- Product telemetry & usage tracking2 protective11 clauses
- Advertising & tracking1 protective4 clauses
- Sale or sharing of personal data1 protective2 clauses
- Sensitive data (biometric, location, health)1 protective2 clauses
- Children's data1 protective5 clauses
- Government & law-enforcement disclosure2 clauses
- Arbitration & class-action waiver2 protective10 clauses
- Damages & liability cap1 protective9 clauses
- Indemnity direction1 protective2 clauses
- Terms can change at any time1 protective5 clauses
- Deletion rights & post-termination survival5 protective7 clauses
- Breach-notification promises1 protective1 clause
- Conduct restrictions21 obligations21 clauses
99 further verified clauses are cited on this page but not yet assigned a topic.
Cross-clause notes
The Terms of Service, § 3 (USER CONTENT) describes rights the platform takes in user content, and the Privacy Policy, § 2.2 describes disclosure of data to third parties or subprocessors. Both clauses are in force at the same time — read them together.
Automated cross-reference against the published rubric — not legal advice.
Clause intelligence
Canonical clauses and stance patterns extracted from the same gate-verified citations shown on this page.
The clause allows indefinite, perpetual, or necessity-based retention.
“With respect to non-photograph and non-video information that we may collect, we will retain such information only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy unless a different retention period is permitted or required by applicable law. You may also ask that we delete your information using the “Request cloud data removal” option in the “Support” section of the Apps se...”Open source citation
The clause allows indefinite, perpetual, or necessity-based retention.
“With respect to non-photograph and non-video information that we may collect, we will retain such information only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy unless a different retention period is permitted or required by applicable law. You may also ask that we delete your information using the “Request cloud data removal” option in the “Support” section of the Apps se...”Open source citation
The clause imposes arbitration, class-action waiver, or jury-trial waiver terms.
“Survival of Agreement. This Arbitration Agreement shall survive the termination of your relationship with FaceApp and/or the expiration, termination or rescission of the Agreement.”Open source citation
The clause imposes arbitration, class-action waiver, or jury-trial waiver terms.
“Arbitration Rules and Forum. If you and FaceApp do not resolve the dispute within the tolling period and you choose to make a demand for arbitration, then the arbitration will be resolved through confidential binding arbitration by Judicial Arbitration and Mediation Services (“JAMS”), an established alternative dispute resolution provider. Disputes involving claims, counterclaims or requests for relief equal to or...”Open source citation
The clause imposes arbitration, class-action waiver, or jury-trial waiver terms.
“Arbitration Fees. Payment of all filing, administration and arbitrator fees and costs will be governed by JAMS’s rules. If you bring an arbitration proceeding with claims substantially similar to those that failed and/or were rejected in a previous arbitration proceeding, you (including your attorney(s)) knew or reasonably should have known that the claims were previously unsuccessful, and you did not raise unique...”Open source citation
Tier matrix
Plan-level conditions detected from citation-backed clauses. Empty tiers mean AIRIN has not captured decisive tier language yet.
| Tier | Surface | Verdict | Risk | Citations |
|---|---|---|---|---|
| All applicable tiers | commercial use | worsens | HIGH | 5 |
| All applicable tiers | data retention | conditional | MEDIUM | 2 |
| All applicable tiers | governing law disputes | conditional | MEDIUM | 19 |
| All applicable tiers | indemnity liability | conditional | MEDIUM | 3 |
| All applicable tiers | moderation enforcement | worsens | HIGH | 4 |
| All applicable tiers | output ownership | worsens | HIGH | 5 |
| All applicable tiers | privacy data use | worsens | HIGH | 2 |
| All applicable tiers | prompt ownership | improves | LOW | 1 |
| Free | indemnity liability | conditional | MEDIUM | 1 |
| Free | output ownership | worsens | HIGH | 3 |
| Pro / Paid | indemnity liability | conditional | MEDIUM | 1 |
| Pro / Paid | prompt ownership | worsens | HIGH | 2 |
Policy evolution
Open full timelineBefore/after stance changes across captured policy versions. When no material delta exists yet, AIRIN shows the latest citation-backed stance events instead.
Latest stance: sale or sell on subprocessors data sharing
“3.2. We do not sell personal information. We may share your non-photograph and non-video information in the following circumstances:”Open timeline citation
Latest stance: platform claims or reserves rights on privacy data use
“We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Apps and Site. We may, and if required by law will, provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the Apps. Any modifications to this Privacy Policy will be effective upon our posting the new terms to the Site and/or upon implementation of the new changes on the Apps and Site (or as otherwise indicated at the time of posting). In all cases, your continued use of our services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.”Open timeline citation
Latest stance: third party or vendor sharing on audit rights dpa residency
“Standard Contractual Clauses (or an alternative legal tool, such as the UK Government-approved International Data Transfer Agreement or Addendum) to require the third party to protect your data and to provide you with EU- and UK-level rights and protections;”Open timeline citation
Latest stance: third party or vendor sharing on privacy data use
“For compliance, fraud prevention, and safety. We may use and disclose the information we collect (such as device data and Apps usage information) where it is in our legitimate business interests to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Apps and Site; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity. We may disclose this information to government authorities and other third parties as required by applicable law. We cannot disclose the photos and videos that have been cached for processing as we do not store the encryption keys.”Open timeline citation
Latest stance: third party or vendor sharing on subprocessors data sharing
“Affiliates. We may share information we collect from you with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.”Open timeline citation
Latest stance: third party or vendor sharing on subprocessors data sharing
“Affiliates. We may share information we collect from you with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy. Service providers. We may share your information with service providers that perform services on our behalf or help us operate the Apps (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose. Third-party platforms and social media networks. You may select to post the edited photograph or edited video to your social media account. We do not control any third-party platform’s use of your information, which is governed by that third party’s privacy policy and terms and conditions. Professional advisors. We may disclose your information to professional advisors, such as lawyers and auditors, where necessary in the course of the professional services that they render to us. Business transfers. We may also transfer or assign your personal data in the course of corporate divestitures, consolidations, mergers, acquisition, reorganization or other transfers of assets, or in the event of bankruptcy or dissolution. Compliance with law . We may be required to disclose your information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities, or for the compliance, fraud prevention, and safety reasons described above.”Open timeline citation
Latest stance: third party or vendor sharing on subprocessors data sharing
“Service providers. We may share your information with service providers that perform services on our behalf or help us operate the Apps (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.”Open timeline citation
Latest stance: third party or vendor sharing on privacy data use
“To create anonymous, aggregated, or de-identified data. We may create anonymous, aggregated, or de-identified data where it is in our legitimate business interests, and use and share it with third parties.”Open timeline citation
Capture recency
- Privacy Policy:Last captured 2026-06-07· verified 2026-06-07verified once — no re-scan in 96 days
- Terms of Service:Last captured 2026-06-07· verified 2026-06-07verified once — no re-scan in 96 days
Dates state when our pipeline captured and verified each document — not when the vendor last changed it. Documents are re-scanned on a recurring cadence; a document verified once says so until a re-scan confirms it again.
↓ 255 fewer findings this quarter vs last (0 vs 255). First scan: June 2026.
Compare and stack are saved in your browser. Open compare · View your stack. A correction triggers an automated re-read of FaceApp's policies — no human edits the data.
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Every finding above is a verbatim quote from FaceApp's own published policy, captured to an immutable snapshot and read in full through a two-gate verification pipeline. Confidence labels and any analysis are AI-generated and informational only — not legal advice.
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