Shots Alive — Privacy policy
Draft — needs review by a lawyer. Version 2026-10-23.
Shots Alive turns a photo of a child's clay figure or drawing into a short cartoon. The app is used by the parent: a parent signs in, adds children, takes the photo and decides what is shared. This policy explains what we collect, why, who processes it and how long we keep it.
Who we are. [Operator legal name, registration number, address] ("we"). Contact: [support email] — the same address is in the app under For parents → Help & contact.
The short version
- Only the creation leaves your phone. The photo is cut out on the device; we receive a picture of the figure or drawing on a transparent background, never the background, a person or a face. If our first check sees a person, the cartoon stops and nothing else is sent anywhere.
- A child profile holds a first name and a birth month — nothing else. No child photo, no child face anywhere in the product.
- We send the cutout and generated text to the AI services listed below to make the cartoon. None of it is used to train AI models.
- Cutouts and intermediate files are deleted after 30 days; finished cartoons stay while your account exists; deleting the account wipes everything within 7 days.
- No advertising, no ad SDKs, no tracking or analytics SDKs, no selling of data.
What we collect
| Data | Why | Where it comes from |
|---|---|---|
| Parent email address (email or Google sign-in; Apple may give a private relay address) | sign-in codes, account, support replies | you |
| Apple / Google account identifier | sign-in | Apple / Google |
| Language, PIN for the parent area (stored only as a one-way hash) | app settings, parental gate | you |
| Child's first name, birth month, a colour | age timeline ("Masha, 5 years 3 months"), narration | you |
| Cutout image of the creation (PNG) | making the cartoon | your phone |
| Generated content: story text, drawn scenes, clips, narration, music, the finished video and poster | the cartoon itself | our AI pipeline |
| Consent records (which version, when, which vendors) | proof of your consent | you |
| Push token and platform (iOS / Android) | the "your cartoon is ready" notification | your phone |
| Reports you send about a cartoon | safety and moderation | you |
| Purchase records (plan, store, amount, date) — from the paid plans onwards | entitlements, accounting | App Store / Google Play / RuStore / payment provider |
| Crash reports with personal data removed (only when crash reporting is switched on) | fixing bugs | the app |
What we never collect: photos of people or faces, the original photo, location, contacts, the advertising identifier, browsing history, voice recordings.
If your phone cannot cut the creation out (older iOS or no Google Play services), the app asks you first and, only if you agree, uploads the whole photo. It is then handled exactly like a cutout (same AI services, same 30-day deletion). Please make sure nobody is in such a photo.
Who processes the data (AI services and other processors)
To make a cartoon our server sends data to these AI services. You see the same list, in your language, on the consent screen before the first cartoon and any time under For parents → Privacy & AI vendors. We ask again whenever the list changes.
| Service | Country | What it does | What it receives |
|---|---|---|---|
| Google (Gemini, Nano Banana, Lyria) | USA | looks at the creation, writes the story, draws the character and scenes, composes music, checks the finished poster | the cutout image; the story text, which may include the child's first name |
| fal.ai (Seedance, Kling, MiniMax models) | USA | turns the drawn scenes into video clips | the drawn scene images (made from the cutout); the motion text |
| BytePlus (ByteDance, Seedance) — only if we switch clips to it; you would be asked again | Singapore | same as fal.ai | same as fal.ai |
| OpenAI (text-to-speech) | USA | reads the narration (English, and Russian as a fallback) | the narration text, which may include the child's first name |
| Yandex SpeechKit | Russia | reads the Russian narration | the narration text, which may include the child's first name |
Other processors that help run the service: [hosting provider and country] (servers, database, file storage), [email provider] (sign-in codes), Google Firebase Cloud Messaging / Apple Push Notification service / RuStore push (notifications), Sentry (crash reports, only if enabled, personal data removed), and from the paid plans onwards Apple, Google, RuStore and [YooKassa] for payments. We do not sell or rent data and share it with nobody else, except where the law requires it.
No training. We only use AI services whose terms, or our contract with them, say that data sent through their API is not used to train their models. [Lawyer: confirm the exact clause per vendor.]
Legal bases
- Your consent (GDPR Art. 6(1)(a) and 8; 152-FZ Art. 9; COPPA verifiable parental consent) — for sending the cutout and story text to the AI services, given on the consent screen by the parent. You can withdraw it at any time by deleting the account; cartoons already made stay until then.
- Contract (Art. 6(1)(b)) — the account, the cartoons you asked for, notifications, purchases.
- Legitimate interests (Art. 6(1)(f)) — security, preventing abuse, crash reports without personal data.
- Legal obligation (Art. 6(1)(c)) — keeping payment records for accounting.
How long we keep it
| Data | Kept for |
|---|---|
| Uploaded cutouts and intermediate files (drawn scenes, clips, narration, music) | deleted 30 days after they were made |
| Finished cartoons and posters, child profiles, consent records | while the account exists |
| Push tokens | until you sign out, delete the account, or the token stops working |
| Everything above, after you delete the account | deleted within 7 days (files and database rows) |
| Payment records | kept for the period accounting law requires, against an anonymised account |
| Server logs | [14] days |
The 30-day and 7-day deletions run automatically every day.
Children
The app is meant to be operated by parents and guardians. Children watch the cartoons and take part in the creative steps; everything that involves accounts, sharing, purchases, settings and links sits behind a press-and-hold entry and a 4-digit PIN that the parent sets. We do not knowingly collect personal data from children beyond the child's first name and birth month that the parent enters, and the creation pictures described above. If you believe a child gave us data without a parent, write to us and we will delete it.
Sharing a cartoon
Nothing is public unless you share it. A private family link opens a simple page with the video, its title and "Made with Shots Alive"; it is hidden from search engines, does not show your child's name, and stops working as soon as you tap Stop sharing. Save to phone and Share to apps hand the video file to your phone; what happens next is up to the apps you choose. Before the first share the app reminds you that the video shows only the creation, never faces.
Your rights
You can, at any time, in the app under For parents:
- see the consent and the vendor list (Privacy & AI vendors);
- download everything we store about you as a JSON file with 24-hour links to every stored file (Download my data);
- correct children's names and birth months (Children);
- delete everything (Delete everything) — the account is closed immediately and wiped within 7 days.
You can also write to [support email] to exercise your rights of access, rectification, erasure, restriction, portability and objection, and you may complain to your data-protection authority (in the EU/UK your local DPA or the ICO; in Russia Roskomnadzor).
Security
Traffic is encrypted (HTTPS). Files are stored in private storage and reachable only through short-lived signed links. The PIN and sign-in codes are stored only as one-way hashes. Access to production systems is limited to [named staff]. [Lawyer: reference the written information-security programme required by the 2025 COPPA rule.]
International transfers
Our servers are in [country]. The AI services above are in the USA, Singapore and Russia. Transfers rely on your consent and, where available, on the vendors' standard contractual clauses. [Lawyer: 152-FZ cross-border transfer notification to Roskomnadzor; EU SCCs / UK IDTA per vendor.]
Changes
When this policy or the vendor list changes, the app shows the new version before the next cartoon and asks for your consent again.