Privacy Policy

Effective Date: 8 May 2026 · Last Updated: 8 May 2026

1. Introduction

This Privacy Policy explains how AffSiwen S.À R.L. (“AffSiwen”, “we”, “us”, “our”) collects, uses, shares, and protects information in connection with the PanelAI mobile application for iOS (“PanelAI”, the “App”, or the “Service”).

By installing or using PanelAI, you confirm that you have read this Privacy Policy and understand how your information is handled. If you do not agree with any part of it, please do not use the App.

2. Data Controller

The data controller responsible for personal data processed in connection with PanelAI is:

For purposes of the EU General Data Protection Regulation (“GDPR”), AffSiwen is the data controller. If you ever have a question or concern about how we handle your personal data, please contact us first at support.panelai@affsiwen.com — we want to hear from you and we will work to resolve any issue directly.

3. About PanelAI

PanelAI is a private feedback tool that helps adult users improve their dating-app photos. Photos you choose to analyse are processed entirely on your device using Apple Intelligence; we do not receive copies of your photos and do not store them on our servers. PanelAI returns structured feedback covering composition, lighting, expression, and styling, plus written suggestions for improvement.

4. What We Collect and Why

We try to collect only what is necessary to make the App work and improve over time. Below is a complete list of personal-data categories we may process, the purpose of each, and the legal basis under GDPR.

4.1 Information You Provide During Onboarding

• Age range, name (or nickname), the dating apps you use, your reason for trying PanelAI, and similar self-reported answers.
• Purpose: to tailor the feedback you receive and the experience to your context.
• Legal basis: performance of our agreement with you (Article 6(1)(b) GDPR).

4.2 Photos You Choose to Analyse

• We do not collect, transmit, store, or have access to your photos. Photos are analysed on your device by Apple Intelligence; only the resulting numerical scores and textual feedback exist after analysis, on your device.
• You can delete photos directly from your device at any time using the iOS Photos app or the App’s controls.
• Purpose: to deliver feedback you can use.
• Legal basis: performance of our agreement with you (Article 6(1)(b) GDPR).

4.3 Device Identifiers

• An anonymous installation identifier (“install UUID”) that we generate the first time you launch PanelAI.
• The Identifier for Advertisers (“IDFA”) — only if you grant App Tracking Transparency permission (see Section 5).
• Purpose: to remember your subscription status, attribute installs to marketing campaigns, and prevent fraud.
• Legal basis: legitimate interests (Article 6(1)(f) GDPR) for the install UUID; consent (Article 6(1)(a) GDPR) for the IDFA.

4.4 Subscription and Transaction Information

• The subscription plan you have, its renewal status, and the amount and currency of your purchase. Apple processes payment; we do not see or store your payment-card details.
• Purpose: to grant the access you have paid for, manage renewals, support refunds processed by Apple, and meet our accounting and tax obligations.
• Legal basis: performance of our agreement (Article 6(1)(b) GDPR) and legal obligation (Article 6(1)(c) GDPR).

4.5 In-App Activity and Diagnostics

• Anonymised event data such as which screens you view, which paywall you see, whether you start a subscription, and any errors or crashes.
• Purpose: to understand how PanelAI is used in aggregate, fix bugs, and improve the product.
• Legal basis: legitimate interests (Article 6(1)(f) GDPR), with respect for any tracking-permission choice you have made.

4.6 Marketing-Attribution Data

• Limited information about how you arrived at PanelAI — for example, the marketing campaign that brought you, install timestamps, and event signals required to measure ad performance.
• Purpose: to measure the effectiveness of our marketing and to allocate budget responsibly.
• Legal basis: consent (Article 6(1)(a) GDPR) where you have allowed tracking; otherwise legitimate interests (Article 6(1)(f) GDPR) on the basis of fully anonymised or privacy-preserving signals (such as Apple’s SKAdNetwork / AdAttributionKit).

What we do not collect

We do not knowingly collect special categories of personal data (“sensitive data”) under Article 9 GDPR, financial-account data, contacts, calendar entries, precise location, microphone or camera streams, or browsing history outside the App.

5. App Tracking Transparency

On first use, iOS will show you the App Tracking Transparency (“ATT”) prompt. Choosing “Ask App Not to Track” prevents PanelAI and the providers we work with from accessing your device’s IDFA or linking your activity in PanelAI with your activity in unrelated apps for advertising purposes. We respect that choice fully. You can change your decision at any time in iOS Settings → Privacy & Security → Tracking.

6. How We Share Data With Service Providers

We do not sell your personal data. To run PanelAI we share specific, limited categories of data with categories of service providers who act on our instructions under written data-processing agreements that require them to apply equivalent protection to that described in this Policy. We do not name individual vendors here so that this Policy stays accurate as our supplier list evolves; the categories we use are:

• Subscription-management providers — verify Apple receipts, track entitlements, and manage trial and renewal events.
• Mobile-attribution providers — measure which marketing channel brought a user, using either privacy-preserving Apple frameworks or, with your consent, IDFA-based attribution.
• Product-analytics providers — aggregate in-app event data so we can understand and improve the user experience.
• Advertising-measurement networks — receive limited conversion signals so our ad campaigns can be optimised; where IDFA is used, only after your ATT consent.
• Cloud-infrastructure and email providers — host our backend services and let us send you the support replies you ask for.
• Customer-support tooling — enables us to respond to your emails and data-rights requests.

We may also share data:

• With professional advisers (lawyers, auditors, accountants) under confidentiality obligations.
• With public authorities, where we are legally required to do so.
• In connection with a corporate transaction (for example, a merger or acquisition), in which case we will notify you of any change in controllership.

7. International Transfers

AffSiwen is established in Luxembourg (EEA). Some of the service-provider categories above operate from countries outside the EEA, including the United States. Where this happens, we rely on appropriate safeguards under Chapter V of the GDPR — typically the European Commission’s Standard Contractual Clauses, or an applicable adequacy decision (such as the EU-US Data Privacy Framework, where the recipient is certified). You can request a copy of the relevant safeguards by writing to support.panelai@affsiwen.com.

8. How Long We Keep Data

We keep personal data only as long as we need it for the purposes described above and any legal obligations.

When you delete data through the App or by emailing us, we honour the request within 30 days.

9. Your Rights

If you are in the European Economic Area, the United Kingdom, Switzerland, or another jurisdiction whose laws extend equivalent rights, you have the following rights regarding your personal data:

• Access — ask for a copy of the personal data we hold about you.
• Rectification — ask us to correct data that is inaccurate or incomplete.
• Erasure — ask us to delete your personal data (“right to be forgotten”).
• Restriction — ask us to pause processing in certain circumstances.
• Portability — ask for a structured, commonly used, machine-readable copy of data you provided.
• Object — object to processing based on legitimate interests.
• Withdraw consent — at any time, where processing is based on consent (including ATT permission and marketing-attribution consent).

To exercise any of these rights — or simply to ask us a question or share a concern — use the in-app deletion controls or write to support.panelai@affsiwen.com from the email address you would like us to associate with your request. We may need to verify your identity before fulfilling certain requests. We aim to respond within 30 days. We treat every message as a priority and we want the chance to make things right with you directly, so please reach out to us before considering any other route.

10. Security

We use technical and organisational measures designed to protect your data — including TLS encryption in transit, access controls, secret rotation, and reviews of the providers we work with. The App also relies on Apple’s platform-level protections (sandboxing, on-device enclave for Apple Intelligence). No system is perfectly secure; if you become aware of unauthorised access related to PanelAI, please contact us immediately at support.panelai@affsiwen.com.

11. Children

PanelAI is intended for adults who are 18 or older. We do not direct the App to children and do not knowingly collect personal data from anyone under 18. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at support.panelai@affsiwen.com so that we can take prompt action to delete it.

12. Cookies and Similar Technologies

The PanelAI iOS app does not use web cookies. If you visit our marketing website, we may use:

• Strictly necessary cookies — to operate the site;
• Analytics cookies — to understand traffic in aggregate;
• Advertising cookies — to measure campaign effectiveness.

You can manage non-essential cookies through the consent banner displayed on the website on first visit, and you can withdraw consent at any time through that banner.

13. California Privacy Notice (CCPA / CPRA)

This section supplements the rest of this Privacy Policy and applies if you are a California resident.

Categories of personal information collected. In the past twelve months we may have collected the categories described in Section 4: identifiers (install UUID, IDFA where consented), commercial information (subscription transactions), internet or other electronic activity (in-app analytics), and inferences drawn from these (for example, engagement segments). We do not collect biometric information, precise geolocation, sensitive personal information, or data from minors under 16.

Sources. Directly from you, automatically from your use of the App, and from our service providers and Apple.

Purposes. To deliver and improve the Service, secure it, market it, and meet legal obligations — as detailed above.

Disclosure for business purposes. We share categories of information with the categories of service providers listed in Section 6, under contracts that limit their use of the data to the purposes for which we engaged them.

Sale or sharing of personal information. We do not sell personal information for money. We may “share” personal information for cross-context behavioural advertising (as defined under California law) where you have granted ATT consent. You can opt out of this sharing at any time by withdrawing ATT consent (iOS Settings → Privacy & Security → Tracking) or by emailing support.panelai@affsiwen.com with the subject line “Do Not Sell or Share My Personal Information”.

Your California rights. Right to know, right to access, right to correct, right to delete, right to opt out of sale/sharing, and right to non-discrimination. We will not deny you services, charge a different price, or provide a different quality of service because you exercised your privacy rights.

Authorised agents. You may use an authorised agent to submit a request. We may require proof of authorisation and verification of identity.

To submit a California request, email support.panelai@affsiwen.com.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top will reflect the most recent change. If a change is material, we will notify you in-app or by other reasonable means before it takes effect. Your continued use of PanelAI after the new effective date means you accept the updated policy.

15. Contact Us

Questions, requests, or concerns about this Privacy Policy or your personal data: