Last updated: October 22, 2026
Effective date: October 19, 2026
Contents
Bunlumi: AI Photo Organizer ("Bunlumi", "the App") is provided by Shenzhen Huanyang Technology Co., Ltd. ("we", "us"). We are the controller of personal data processed for the purposes described in this policy, except where a provider acts independently under its own privacy notice.
For privacy questions or requests, email [email protected]. The App is currently offered for the United States market. This policy explains how personal information is handled when you use the iOS App and its related application services. It does not replace Apple's privacy policy or the notices of services you independently choose to use.
With your permission, Bunlumi accesses photos and videos available through Apple's Photos framework. This may include file contents, thumbnails, local asset identifiers, filenames, creation dates, dimensions, duration, media type and file size. The App creates local image similarity values, category labels, scan indexes and sorting decisions to organize your library and identify potentially duplicate or similar items.
Library scanning, image classification, photo and video compression, and photo enhancement run on your device. These functions use Apple iOS system interfaces and local image processing and do not upload your photo or video files to our application servers or to an AI model provider. Image classification groups content; it does not identify named individuals or authenticate you using your face.
Photo enhancement uses the system photo picker to access the image you select. Saving an enhanced image creates a new copy. This enhancement export preserves selected camera and capture metadata and excludes GPS metadata. This statement applies to enhanced-image exports; it is not a promise that every file exported or shared by the App has all metadata removed.
Apple may download an original from iCloud Photos when it is not stored locally. Apple may also synchronize saved or deleted items according to your iCloud settings. Those transfers are handled through Apple services and may use mobile data. Files you expressly share through the iOS share sheet are delivered to the recipient or service you select.
Photos, screenshots and text you choose to provide can contain sensitive information. Limit access to the items needed for the feature, and avoid including other people's private information without authority.
The App also makes network requests. Local photo processing does not mean the App is entirely offline.
| Information | When and why it is processed | Recipients |
|---|---|---|
| Random app-specific identifier stored in Keychain; Apple's vendor identifier (IDFV); Adjust identifier; app identifier, version and build; device model; iOS version; language; first and previous opening timestamps | App operation, configuration, installation and subscription reporting, and attribution | Our application service providers and relevant measurement providers |
| IP address and ordinary connection/request metadata | When the App contacts an online service; to deliver requests, maintain service security and support diagnostics | The contacted service and its hosting/network providers |
| Chat message, recent user/assistant conversation history and dialogue context such as pending intent and suggested options | When you send a message to the AI assistant, to interpret the request and generate a reply or feature recommendation | Our chat backend in the United States and Google, which provides the paid Gemini API |
| Feedback text, app identifier and device locale country/region code | When you submit feedback, to investigate suggestions and problems; contact details are included only if you put them in your message | Our feedback service and support providers |
| App Store receipts, product identifiers, transaction/original transaction identifiers, expiration and entitlement status; device/vendor and attribution identifiers used in purchase reporting | When purchasing, checking or restoring subscriptions; to verify access, reconcile transactions and measure conversions | Apple; our subscription reporting service; Adjust for subscription conversion events |
| App interactions, installation/session identifiers, device/app characteristics, IP-derived location and crash or diagnostic information, depending on SDK configuration | Usage measurement, crash investigation and advertising attribution; the current App initializes the SDKs listed below at startup | Google/Firebase, Meta and Adjust |
| Public IP address, IP-derived country/region/city and coordinates, internet provider, connection type, transferred byte counts and measured transfer rates | When you use network testing or monitoring, to display network information and measure performance | Cloudflare, ipify, icanhazip, ipapi.co and ipwho.is as applicable |
Chat requests do not attach your photo library, thumbnails or library inventory. Text you enter is transmitted, including any personal information you include in it. Do not enter passwords, payment card details, identity documents or other sensitive information into chat.
Text chat is processed through our backend in the United States, which uses Google's paid Gemini API to generate replies. We send Google your message and the recent conversation context needed to generate a reply. Chat messages and generated replies are not used for model training.
To maintain context, our chat backend temporarily stores approximately the most recent 10 conversation turns, and session data is deleted after 24 hours. The client may also hold recent messages during the current session and transmit them with requests. The approximately 10-turn and 24-hour rules apply to our chat backend. Processing, retention and deletion by Google/Gemini are governed by the applicable terms and configuration of the paid API we use; see Sections 5 and 7.
Apple handles payment authorization and billing information. Receipt data is submitted to Apple for verification; our subscription reporting endpoint receives transaction/product and device/attribution fields. We do not receive your full payment card number or Apple Account password. An attribution identifier may be included in the App's StoreKit payment metadata.
Network speed tests upload generated test data and download test files, rather than uploading your photos. IP-derived coordinates are estimates; the App does not request GPS location permission for this feature. Tests can consume substantial data.
4. Permissions and your choices
| Permission or access | Purpose | How to manage it |
|---|---|---|
| Photos access, including limited access where offered by iOS | Browse, scan, classify, compress and request deletion of authorized media | iOS Settings → Apps → Bunlumi → Photos, or the Photos privacy settings on your iOS version |
| Add photos | Save enhanced images and other generated media | The App's Photos permission settings in iOS |
| System photo picker | Import only the photo you select for enhancement | Select or cancel in the picker; this does not itself authorize access to the entire library |
| App Tracking Transparency (ATT), when iOS allows a prompt | Apple's permission for tracking across other companies' apps and websites or accessing IDFA | iOS Settings → Privacy & Security → Tracking |
| Internet connection | Chat, feedback, subscriptions, SDK services, iCloud retrieval and network testing | Avoid the relevant online feature or restrict mobile data in iOS; some startup service requests occur independently of feature use |
The App requests ATT after the initial Photos permission flow, when the App is active and the system status is undetermined. A denial or restriction is respected without repeatedly requesting permission. When you return from Settings, the App refreshes the system status and Meta's advertising identifier settings. Adjust is configured to wait up to 120 seconds for an initial ATT decision and observes the system status; this waiting period does not disable every form of measurement.
The current App does not request camera, microphone, contacts or system location permissions. Network access and Keychain storage do not have separate iOS permission prompts. Denying Photos access limits library features; denying add access prevents saving new media. ATT refusal does not restrict core photo tools.
ATT permission is separate from consent required under privacy law. Refusing ATT restricts Apple's tracking permission and access to IDFA; it does not automatically disable every analytics event, diagnostic report or other identifier. You may contact us to withdraw applicable consent or request an advertising/analytics opt-out. There is currently no separate in-app privacy preference panel.
5. Third-party services
The App uses the following services:
| Service | Purpose | Privacy information |
|---|---|---|
| Apple Photos, iCloud and StoreKit/App Store | Media access, synchronization, purchases and receipt verification | https://www.apple.com/legal/privacy/ |
| Google Firebase Analytics | App usage and installation/session measurement | https://firebase.google.com/support/privacy |
| Google Firebase Crashlytics | Crash reports and diagnostic data | https://firebase.google.com/support/privacy |
| Google paid Gemini API | Receive chat text and necessary conversation context through our backend and generate AI replies; chat messages and replies are not used for model training | https://policies.google.com/privacy |
| Meta/Facebook SDK | App events and advertising measurement | https://www.facebook.com/privacy/policy/ |
| Adjust, including its Google on-device measurement integration | Installation attribution and conversion measurement | https://www.adjust.com/terms/privacy-policy/ |
| Cloudflare | Network speed test transfers; fallback public IP discovery through icanhazip | https://www.cloudflare.com/privacypolicy/ |
| ipify, ipapi.co and ipwho.is | Public IP discovery and IP-based network/location lookup | https://www.ipify.org/ ; https://ipapi.co/ ; https://ipwho.is/ |
| Chat backend operated by us | Process text requests and generate AI replies | This policy; privacy contact: [email protected] |
Providers can receive information directly from their SDKs or endpoints. Depending on the service and contract, they may act as processors or as independent controllers. The list does not imply that each provider receives every category of data. General interface, layout and image-processing libraries are not separate recipients merely because they are included in the App.
We ensure that third parties receiving user data from the App provide the same or equal protection of that data as described in this Privacy Policy and required by the applicable App Store Review Guidelines. Depending on the nature of the service, we implement these requirements through applicable service terms, data processing agreements, and necessary technical and organizational measures.
We may also disclose information to providers supporting hosting and support, when legally required, to protect legal rights and service security, or in a merger or business transfer subject to applicable privacy requirements. We do not publicly disclose your personal information by default.
We process necessary information for the following purposes, subject to applicable US federal and state privacy requirements:
Where applicable US state law defines advertising-related disclosure as a "sale", "sharing" or processing for targeted advertising, exchanges of identifiers, IP/network information and usage/conversion events with advertising measurement providers may fall within those definitions, even without a monetary payment. Do not interpret the local-processing statement in Section 2 as a statement that no data is shared for advertising purposes.
You can request "Do Not Sell or Share My Personal Information" or an opt-out of targeted advertising at [email protected]. State the request in the subject line. Authorized agents may submit requests where permitted by law. We do not knowingly sell or share the personal information of children under 16 for advertising purposes.
The App stores scan/classification caches, asset references, sorting decisions, feature counters, permission status and subscription state on your device. Some export and sharing operations create temporary files. The app-specific identifier is stored in Keychain and may remain after uninstalling or reinstalling the App.
Deleting the App normally removes its application container. Using iOS "Offload App" can preserve app data; uninstalling does not necessarily remove Keychain entries, Apple/iCloud copies, exported media or information already held by our servers or other providers. Revoking Photos permission prevents future unauthorized access but does not necessarily erase existing local indexes or server records.
Our chat and feedback servers are located in the United States. Our US chat backend receives your text and sends the message and recent conversation context needed for a reply to Google's paid Gemini API. Feedback is sent to our feedback service in the United States. This server-location statement applies only to our chat and feedback backends. Processing locations for other business endpoints and third-party services depend on their deployment, service terms and configuration; it does not establish that every recipient processes data only in the United States.
If a relevant service processes personal information outside the United States, we must comply with applicable data-transfer requirements and provide appropriate safeguards. Contact [email protected] for information about recipients, processing locations and applicable safeguards relevant to your data, and for copies of safeguards where applicable.
We retain personal information only for the purpose for which it was collected, applicable legal requirements and legitimate dispute/security needs. Specific periods or criteria are:
After the relevant period, we delete or irreversibly anonymize the information unless continued retention is legally required.
Information in backups is deleted according to the applicable backup rotation and cleanup arrangements. Until cleanup is complete, its use is limited to necessary security, disaster recovery or legally required retention. If data is restored from a backup, we take measures to ensure that information whose retention period has expired or that must legally be deleted remains subject to the corresponding deletion and use restrictions.
Contact us to ask about the period applicable to specific data or to request deletion. Section 8 explains how to submit a request and how requests are handled.
Depending on applicable US state law, you may have rights to know how we collect, use and disclose personal information; access, obtain a copy of, correct or delete personal information; withdraw applicable consent; and opt out of sale, sharing or targeted advertising. Withdrawal does not affect processing lawfully carried out before withdrawal. We do not use library classification to make decisions producing legal or similarly significant effects about you.
Subject to the conditions prescribed by applicable law, you have the right to receive the personal information you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, to request that it be transmitted directly to another data controller. You may submit a request using the email address listed in this policy.
You may email [email protected] to request deletion of personal information, withdraw applicable consent, or opt out of applicable sale, sharing or targeted advertising. You may also submit access, correction or data portability requests. State the right you wish to exercise and provide the information necessary to locate the relevant record, such as the approximate date of a feedback submission or an App Store transaction reference. Do not send passwords or full payment details. We may request proportionate identity or authority verification. You do not need to create an account to use the current App or make a privacy request.
Following necessary and proportionate verification, we handle requests within applicable statutory deadlines and, where applicable, communicate requests to relevant service providers. Access, correction, deletion and similar requests under applicable US state laws generally have a 45-day response period. Opt-out and other requests follow their applicable deadlines. We explain lawful extensions when necessary. If we cannot fully fulfill a request for a lawful reason, such as a legal obligation, we explain the reason, applicable retention arrangements and appeal options. You may appeal to the same email address and complain to the competent state attorney general, privacy regulator or other authority. We will not unlawfully discriminate against you for exercising privacy rights.
For information already deleted under our retention rules or held only on your device, we may be unable to provide a copy or perform deletion from our servers, and we will explain the circumstances to you.
Deleting personal data or uninstalling the App does not cancel an App Store subscription. Manage cancellation through your Apple Account subscription settings.
The App is not directed to children under 13 or a higher minimum age required by applicable law. If a minor is permitted to use the App, the parent or guardian should supervise use and provide authorization where required. We must comply with applicable children's privacy and parental authorization requirements. An App Store content rating does not replace these requirements.
If you believe a child has provided personal data without the required authorization, contact us so we can investigate and take appropriate action.
We use safeguards appropriate to the information and processing risks. The App uses HTTPS for its network endpoints. No device, network or storage system can be guaranteed completely secure. Where a personal data breach requires notice, we will provide notice under applicable law.
We may update this policy when the App or our practices change. We will update the date and give additional notice or obtain consent where legally required. A policy update does not retroactively authorize a new incompatible use of previously collected data.
Controller: Shenzhen Huanyang Technology Co., Ltd.
Developer address: Guangdong Shenzhen 2502, Aoxin Ya
Building, No.2030, Caitian S. Road, Fushan Community, Futian Sub-District, Futian District
Telephone:
86-17840959472
Privacy/support: [email protected]
Use
the contact above for questions about recipients, processing locations or retention arrangements relevant to your
data.
Shenzhen Huanyang Technology Co., Ltd. · [email protected]