Privacy Policy

This privacy policy applies to the Barbear app (hereby referred to as "Application") for mobile devices that was created by Tortuga Labs, LLC (hereby referred to as "Service Provider"). This Application is a consumer-facing service that uses AI to apply fun haircuts to your photos. Users are permitted to use the app for personal purposes but may not redistribute.

Face Data and Photo Processing

What Face Data We Collect

When you use Barbear to apply a hairstyle transformation, the Application accesses photos that contain your face. The Application does not extract, analyze, or store facial geometry, biometric identifiers, or facial feature maps. We process only the image pixels necessary to apply the AI hairstyle effect.

How Face Data Is Used

Your photos are used exclusively to generate AI hairstyle transformations. When you select a photo, it is sent to our third-party processing provider, Replicate, Inc., solely for the purpose of applying the hairstyle effect. The processed image is then returned to the Application and displayed to you. Your photos are not used to train AI models, build facial recognition databases, or for any purpose other than delivering the hairstyle transformation you requested.

Third-Party Processing

To provide the AI hairstyle transformation feature, your photos are transmitted to Replicate, Inc., a third-party cloud processing service. Replicate processes the image to apply the hairstyle effect and returns the result to the Application. Replicate does not store your photos after processing is complete. Replicate does not use your photos to train AI models or for any purpose other than providing the requested transformation.

Data Retention

Your photos may be stored on our servers to provide the hairstyle transformation service and allow you to access your transformed images. We do not extract, store, or retain any facial geometry, biometric identifiers, or face data from your photos. Replicate does not retain your photos after processing is complete.

Face Data Sharing

Your face data is shared only with Replicate, Inc. for the sole purpose of processing hairstyle transformations. Your photos are not sold, shared with advertisers, used for facial recognition, or disclosed to any other third parties except as required by law.

Information We Collect

Photos and Camera Access

Barbear requires access to your device's photo library or camera to function. You may either select existing photos from your library or take new photos within the app. These photos are used solely to generate AI-powered hairstyle transformations as described in the Face Data and Photo Processing section above.

How We Use Your Information

The Application collects information when you download and use it. This information may include your device's Internet Protocol address (e.g. IP address), the pages of the Application that you visit, the time and date of your visit, the time spent on those pages, the time spent on the Application, and the operating system you use on your mobile device.

The Service Provider may use the information you provide to contact you from time to time to provide you with important information, required notices, and marketing promotions.

For a better experience while using the Application, the Service Provider may require you to provide certain personally identifiable information. The information that the Service Provider requests will be retained by them and used as described in this privacy policy.

Data Disclosure

The Service Provider may disclose User Provided and Automatically Collected Information: as required by law, such as to comply with a subpoena or similar legal process; when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; and with their trusted service providers who work on their behalf, do not have an independent use of the information disclosed to them, and have agreed to adhere to the rules set forth in this privacy statement.

Opt-Out Rights

You can stop all collection of information by the Application easily by uninstalling it. You may use the standard uninstall processes available on your mobile device or via the mobile application marketplace or network. If you have granted access to your photo library or camera, you may revoke these permissions at any time through your device's settings.

Data Retention Policy

The Service Provider will retain User Provided data, including photos, for as long as you use the Application and for a reasonable time thereafter to provide the service. We do not retain any face data or biometric information. If you'd like the Service Provider to delete User Provided Data that you have provided via the Application, please contact them at barbearapp@bytortuga.com, and they will respond in a reasonable time.

Children

The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13. The Application does not address anyone under the age of 13, and the Service Provider does not knowingly collect personally identifiable information from children under 13 years of age. If the Service Provider discovers that a child under 13 has provided personal information, they will immediately delete it from their servers. If you are a parent or guardian and are aware that your child has provided personal information, please contact the Service Provider at barbearapp@bytortuga.com so they can take the necessary actions.

Security

The Service Provider is concerned about safeguarding the confidentiality of your information. They provide physical, electronic, and procedural safeguards to protect the information they process and maintain. Your personal information is stored securely and is protected using industry-standard security measures. Transmission of photos to Replicate for processing occurs over encrypted connections.

Changes

This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes by updating this page with the new Privacy Policy. You are advised to review this Privacy Policy regularly for any updates, as continued use of the Application is deemed approval of all changes. This Privacy Policy is effective as of 2025-12-31.

Your Consent

By using the Application, you consent to the processing of your information as set forth in this Privacy Policy, now and as amended in the future.

Contact Us

If you have any questions regarding privacy while using the Application or have concerns about data practices, please contact the Service Provider via email at barbearapp@bytortuga.com.

For more information about Tortuga Labs, LLC, please visit www.bytortuga.com.