Last updated May 21, 2026

Privacy Policy

This Privacy Policy explains how Mementum Lab & Victus Inc. handles information when you use TungMax AI: scan your face, including camera access, ARKit face scanning, AI photo analysis, scan history, analytics, referrals, subscriptions, and support.

1. Information We Collect

We collect information you provide or generate while using the app, including:

  • Selfies or photos you capture or select for face analysis.
  • Onboarding choices such as age range, gender selection or skip choice, goals, self-scan baseline, problem areas, sleep, water, and skincare routine inputs.
  • Scan results, including scan analysis, feature insights, AI commentary, scan dates, unlock status, and related progress history.
  • Routine and habit data, including daily tasks, completion history, streaks, and app settings.
  • Referral information, including device-linked user identifiers, referral codes, referred-by codes, referral counts, seal key usage, and related timestamps.
  • Product analytics events collected through Mixpanel, such as screen views, onboarding responses, scan flow actions, paywall interactions, referral actions, routine completions, settings changes, and share intents.
  • Support information you choose to send to us, such as your email address, screenshots, device model, iOS version, app version, and issue details.

2. Camera, Photo Library, and ARKit Face Scanning

TungMax AI requests camera access so you can take a selfie for analysis. On supported devices, the app uses Apple ARKit face tracking, which may use the TrueDepth camera, to detect face position and generate temporary face geometry, contour, eye-guide, and face-lock overlay data while you capture a photo.

This TrueDepth/ARKit data is processed on device only. We do not store, upload, sell, or share TrueDepth/ARKit face tracking data. We do not use it to identify you, authenticate you, create biometric templates, track you across sessions, or for advertising.

The app sends a photo for AI analysis only after you take or choose a photo and confirm it for analysis. If you choose a photo from your library, iOS photo permissions are used only for that selection flow.

3. Face Data

For this policy, "face data" means selfies or photos you submit for analysis, temporary ARKit/TrueDepth face tracking data used during camera capture, and scan results generated from a submitted photo.

Confirmed scan photos and scan results may be stored locally on your device so you can view scan history and progress. TrueDepth/ARKit tracking data is not retained and is discarded when the camera session ends.

Face data is used only to provide the app's private analysis experience, including camera guidance, AI analysis, feature insights, commentary, scan history, and self-improvement planning. Face data is not used for biometric identification, account login, identity verification, advertising, third-party tracking, or sale to third parties.

4. AI Photo Analysis

To generate your scan analysis, TungMax AI resizes and compresses the confirmed image, then sends it through the TungMax AI backend to an AI model provider through OpenRouter. The request may include the image and limited profile context needed to generate results, such as selected goals, self-scan baseline, and selected problem areas. We do not include your name or email address in the AI photo-analysis request.

Our backend does not intentionally persist submitted images or log image contents. Operational logs may include technical request metadata such as request IDs, endpoint names, timing, model names, HTTP status, and error messages.

The AI service returns scan analysis, feature insights, short commentary, and a Tung Tung reaction. AI results are automated, subjective, and for entertainment and self-improvement planning only.

5. Local Storage on Your Device

TungMax AI stores app data on your device so the app can preserve your profile, onboarding progress, scan history, pending scan results, selected or captured scan photos, routines, streaks, notification preference, sound preference, AI consent state, purchase/unlock state, referral state, and a stable anonymous app identifier used for referrals and product analytics.

You can remove locally stored app data by deleting the app from your device. If you reinstall the app, some Apple subscription state may still be available through your Apple ID or App Store account.

6. Backend Services and Referrals

TungMax AI uses a Cloudflare Worker backend for face-analysis requests and referral features. Referral state is stored in Cloudflare KV and may include a device-linked user identifier, referral code, referred-by code, total referral count, used seal keys, scan IDs used for seal key redemption, and timestamps.

Backend logs may include technical information needed to operate and troubleshoot the service, such as request IDs, endpoint names, timing, model names, HTTP status, and error messages. These logs are used for security, debugging, reliability, abuse prevention, and service improvement.

7. Subscriptions and Purchases

In-app purchases and subscriptions are processed by Apple through your App Store account. TungMax AI uses Superwall to present and manage paywall experiences. We do not receive or store your full payment card details. Subscription changes, cancellations, renewals, and refunds are managed through your Apple ID and App Store settings.

8. Notifications

If you enable notifications, the app may request iOS notification permission and store your local notification preference. You can change notification permissions at any time in iOS Settings.

9. How We Use Information

We use information to:

  • Provide face scanning, AI scan analysis, feature insights, and scan history.
  • Create and maintain your profile, routines, progress, streaks, and app settings.
  • Operate referrals, seal keys, unlock status, paywalls, and subscription access.
  • Respond to support requests and troubleshoot issues.
  • Maintain security, prevent abuse, debug errors, and improve app reliability.
  • Comply with legal obligations and enforce our Terms of Use.

10. Service Providers

We use service providers to run the app and related services, including:

  • Apple for App Store purchases, subscriptions, device permissions, and iOS platform services.
  • ARKit on supported Apple devices for on-device face tracking during capture.
  • Cloudflare for backend hosting, referral storage, and service infrastructure.
  • OpenRouter and AI model providers for AI photo-analysis processing.
  • Mixpanel for product analytics about app screens, submitted responses, and feature usage. We do not send selfies, TrueDepth/ARKit tracking data, names, emails, payment details, referral codes, or raw AI text to Mixpanel.
  • Superwall for paywall presentation and subscription-related app flows.

These providers process information according to their own terms and privacy policies, and only as needed for the services they provide to us or to you.

11. Tracking and Advertising

TungMax AI does not sell your face scans and does not use third-party advertising tracking in the app. Product analytics are used to understand app usage and improve reliability and features, not for third-party advertising. If our use of tracking changes, we will update this policy and request any permissions required by Apple or applicable law before enabling tracking.

12. Data Retention

TrueDepth/ARKit tracking data is not retained and is discarded when the camera session ends. Confirmed scan photos and scan results stored locally remain on your device until you delete the app. Backend face-analysis requests are processed transiently by our backend and are not intentionally persisted by us. Backend referral records and operational logs are retained for as long as needed to provide the referral service, operate subscriptions and unlocks, secure the service, troubleshoot issues, comply with legal obligations, or resolve disputes.

13. Security

We use reasonable technical and organizational measures designed to protect information. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

14. Your Choices and Rights

You can:

  • Control camera, photo library, and notification permissions in iOS Settings.
  • Choose whether to submit a photo for AI analysis.
  • Delete the app to remove locally stored app data from your device.
  • Manage or cancel subscriptions through your Apple ID subscription settings.
  • Contact us to request help with access, correction, deletion, or privacy questions related to backend referral or support data.

15. Children's Privacy

TungMax AI is not directed to children under 13, and children under 13 may not use the app. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us information, contact us so we can take appropriate action.

16. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the last updated date above. Your continued use of the app after an update means you accept the updated policy.

17. Contact Us

If you have questions about this Privacy Policy, contact Mementum Lab & Victus Inc. at support@tungmaxai.com.