Privacy Policy

This Privacy Policy explains how Angelo Lamonaca (sole proprietorship), operating as Neuramare (“Neuramare,” “we,” “us,” and “our”), handles personal data when you use GenVista. Our Terms of Service and Community Guidelines also apply when you use GenVista.

The short version

• We are Angelo Lamonaca, a sole proprietorship in Baar, Switzerland, operating as Neuramare. We run GenVista.
• We need your email address to give you an account, and your prompts and files to make what you ask for.
• What you upload and make is deleted 48 hours after the job was created. Download what you want to keep.
• Jobs go through automatic safety checks. One of them finds faces in realistic pictures and estimates whether someone may be under 18. It does not identify anyone.
• We don't sell your personal data. We show no ads and use no analytics or tracking cookies.
• Our servers and most of our service providers are in the United States, and the GPU machines that make your pictures, clips and songs are rented and can be in other countries. Section 10 explains how data is protected when it leaves Switzerland or the EU.
• You can ask to see, correct, export or delete your data, and object to some uses. Write to privacy@genvista.com.

1. Who is responsible for your data

The controller of your data is:

“We,” “us” and “our” mean Angelo Lamonaca. Write to privacy@genvista.com with any question about your data.

2. What this policy covers

This policy covers GenVista:

• the website at www.genvista.com and its studio;
• the GenVista Pictures app for iPhone, iPad and Android;
• the “Check a file” page;
• emails between you and us.

It covers people with a GenVista account, visitors without one, and people who appear in pictures, clips or recordings that our users upload (section 5).

It does not cover other companies' services that we link to or that you use alongside ours, such as CivitAI, Discord, Reddit, the App Store and Google Play. They have their own privacy policies.

3. What we collect, why, and on what legal basis

Legal bases. If you are in the EU, the EEA or the UK, the GDPR and the UK GDPR ask us to name a legal basis for each use of your data. We use these:

• Contract: we need the data to give you the Service you signed up for (GDPR Art. 6(1)(b)).
• Legitimate interests: we have a legitimate reason that is not overridden by your interests, rights and freedoms, for example keeping the Service safe (Art. 6(1)(f)). Section 12 explains how to object.
• Legal obligation: a law of the EU or of an EU country requires it (Art. 6(1)(c)). Where a Swiss law requires something, for the GDPR we rely on our legitimate interest in meeting the laws that apply to us.
• Consent: you agreed (Art. 6(1)(a)). We don't currently rely on consent. If we ask for it, you can withdraw it at any time, as easily as you gave it.

Swiss data protection law (the nDSG) does not ask for a legal basis for each use, but the same reasons justify what we do.

3.1 Your account

• What: your email address; an account number we create; the date you joined; a display name, if you add one; your plan and its limits; and any restriction or suspension of your account.
• Why: to create and run your account, sign you in, apply your plan, and write to you about the Service.
• Legal basis: contract; for restrictions and suspensions, our legitimate interest in enforcing our Terms and preventing misuse.
• Kept: until you delete your account (section 13), except as section 11 says.

3.2 Signing in and keeping the Service secure

• What:
  • the one-time code we email you to sign in;
  • your IP address, your browser and device type, and the time of each sign-in;
  • a security check from Cloudflare (Turnstile) on the sign-in page, which processes signals from your browser or device to tell people from bots;
  • our servers' logs, which can hold your IP address, the page or file requested, the time, your browser and, in error messages, your account number;
  • the country your IP address points to, which we use to show you the version of the Service offered there. We don't store it.
• Why: to sign you in, keep accounts safe, stop bots, spam and attacks (for example, we limit how many requests one address can make), and find and fix errors.
• Legal basis: contract for signing in; our legitimate interest in the security of the Service for the rest.
• Kept: a sign-in code works once and expires after a short time; server logs, 30 days; sign-in and session records, as section 11 says.

3.3 What you make: prompts, uploads and results

• What:
  • the words you type: prompts, descriptions, lyrics and song sheets;
  • the settings and models you choose;
  • the files you upload: photos, drawings, clips, songs and recordings of your voice, as you upload them, with any information stored in them, such as when and where a photo was taken, or its Content Credentials (section 6). If you'd rather not share that information, remove it from the file before you upload it;
  • text our AI writes for you from your words or your photo, for example the description Animate a photo writes on Auto, or a song's lyrics;
  • the pictures, clips, songs and previews a job makes;
  • how the job went: when it ran, whether it succeeded, failed or was refused and why, how long it took, and whether it came from the website or the app.
• Why: to make what you ask for, show it in your gallery and history, and let you download it.
• Legal basis: contract.
• Kept: 48 hours from when the job was created. Then our cleanup deletes the job, every file in it and its entries in your gallery and history. If you delete a result sooner, it disappears from your account at once and is erased when the 48 hours are up. A rule in our storage also deletes any file older than 5 days. Section 11 says when we may keep data longer.
• Who sees it: you. Authorised personnel can access jobs, prompts and files while they exist, where needed to provide support, run and secure the Service, check for misuse and comply with the law. Nothing you make is shown to other users.
• The GPU machines: jobs run on GPU machines we rent (sections 8 and 10). A machine receives what the job needs: your prompt, settings, uploads and links to store the results. For Animate a photo, it receives the whole photo and cuts out the frame you chose. File names contain your account number, never your name or email. The machines keep technical logs of the jobs they run, which can include the job's number, timings, errors and the outcome of safety checks, such as the code of a refusal. We set these logs up to leave out your prompts, the text our AI writes for the job and the scores of the safety checks. Vast.ai's hosting terms forbid hosts to download, store or review users' data.

3.4 Safety checks

• What: your prompts, uploads and results, read by automatic checks; the outcome of each check; a record of some refusals; and fingerprints of some refused uploads.
• Why, legal basis and how long: see section 4.

3.5 Plans and payments

• On the website: Stripe handles payments. Stripe collects what its checkout page asks for, such as your card or other payment details. We never see your full card number. We receive and keep your Stripe customer number, your plan, its price and status, its billing dates, whether it renews, and whether a trial applies. We give Stripe your email address and your account number.
  • One trial per card. When a trial starts, Stripe stores a code that stands for your card (its fingerprint), or your Stripe Link email, on your Stripe customer record. We compare it with earlier trials (section 4.5).
  • Cancelling. Stripe's cancel page may ask why you are leaving. We see your answer.
  • Disputes. If you dispute a payment with your bank, Stripe tells us (section 4.5).
  • Confirmations and withdrawals. If you live in the EU, the EEA or the UK, we email you a confirmation of your plan when you subscribe, with your right of withdrawal. Before checkout we note that you asked for your plan to start at once (“Start my plan now”). If you withdraw with “Withdraw from contract here”, we keep what you send (your name, the plan and the email address for our confirmation), when you sent it, and what we refunded, and we email you a confirmation.
• In the app: Apple (App Store) or Google (Google Play) bills you, under their own terms and privacy policies. RevenueCat manages these subscriptions for us. It receives your GenVista account number and the store's purchase records, and tells us your plan's status.
• Why: to sell and bill plans, confirm them, allow one trial per person and payment method, handle withdrawals, refunds and disputes, and keep our accounts.
• Legal basis: contract; our legitimate interest in preventing repeat trials and fraud, and in being able to show how a withdrawal was handled; legal obligations to confirm plans and handle withdrawals under consumer law, and to keep accounting and VAT records under Swiss law.
• Kept: plan records until you delete your account; withdrawal records, 10 years (section 11); accounting records, including invoices, for 10 years, as Swiss law requires. Stripe, Apple, Google and RevenueCat keep their own records under their own policies.

3.6 Messages and reports

• What: your email address, what you write, any attachments, and our replies. If you report a result with “Report this picture” in the app: the reason you pick, any note you add, the job's prompt and a reference to the result.
• Why: to answer you, to handle reports, complaints, requests for review and legal requests, and to keep the Service safe.
• Legal basis: contract, or our legitimate interest in answering you and keeping the Service safe.
• Kept: emails, as long as needed to answer you and deal with any follow-up; reports from the app, 2 years (section 11).
• How mail travels: mail to addresses @genvista.com reaches us through Cloudflare's email routing. Mail to addresses @neuramare.com is kept by Proton. Sign-in codes and the confirmations of plans and withdrawals are sent through Amazon SES.
• We send no newsletters or marketing emails. If we start sending marketing emails, we will ask first where the law requires it, and every one will have a link to stop them.

3.7 How the Service is used

• What:
  • A line per job, kept after the 48 hours, without your prompt, uploads or results: your account number, the tool, the models, its safety settings, whether the job succeeded, failed or was refused (with the refusal's code), its timings, the GPU machine and its cost, whether it came from the website or the app, whether you deleted it early, and how many marks went into its files.
  • Traffic counts per site and hour: bytes, requests and similar totals, with no addresses.
• Why: to run the Service, plan capacity and costs, set prices and plan limits, find tools that fail, and spot misuse. We look at use per account for these purposes. It has no legal or similar effect on you.
• Legal basis: our legitimate interest in running and improving the Service.
• Kept: as section 11 says. When you delete your account, your lines are unlinked from you: your account number in them is replaced with a random one.

We may also make anonymous statistics that can no longer be linked to anyone. We use no analytics services, advertising networks, tracking pixels or social media plug-ins.

3.8 The GenVista Pictures app

• What: the same account and content data as on the website, and also:
  • the photos you pick, only when you pick them. The app asks before your first photo leaves your phone;
  • the app's version;
  • a random install number that the update service, Expo, uses. It is not linked to your account;
  • on your phone: your sign-in session and whether you agreed to upload a photo.
• The app saves pictures to your photo library only when you ask. It has no access to your camera, microphone, contacts or location, and no advertising or analytics.
• Why: to give you the app's features and keep it updated with fixes.
• Legal basis: contract; our legitimate interest in delivering fixes and security updates.
• Kept: data on your phone stays until you sign out or delete the app; Expo's records, as section 11 says.

3.9 Visitors without an account

• What: our servers' logs (section 3.2). The site's pictures and clips, and the files the “Check a file” page needs, come from our file host, which Cloudflare serves and which receives your IP address, as any website does. Model previews from CivitAI: we copy most of them to our own storage, but your browser sometimes loads a preview straight from CivitAI, which then sees your IP address.
• Why: to show you the site and keep it secure.
• Legal basis: our legitimate interest in delivering a working, secure website.
• Kept: server logs, 30 days; Cloudflare's records, as section 11 says.

4. Safety checks and automatic decisions

4.1 The checks

Jobs pass automatic checks before and after the GPU works on them. Which checks run depends on the tool and the job. They can include:

• Prompt filters. Prompts with words about children or minors that our rules don't allow are refused, and so are other words our rules don't allow. Song lyrics, yours and those our AI writes, are checked, and so is any text our AI writes for a job.
• Picture checks. A classifier reads the pictures you upload and the pictures a job makes, and frames of clips, and refuses sexual content or nudity that our rules don't allow.
• The under-18 check. Realistic pictures and clip frames are checked for people who may be under 18, and drawings for characters who may be children (section 4.2).
• Real-person checks. Where a job could show a real person in a way our rules forbid, we check whether the prompt names a well-known living person (from a public list of names), whether a model you chose is marked by CivitAI as showing a real person or a minor or carries a real person's name, and whether an upload shows a realistic face. None of these checks recognises who anyone is.
• Model checks. For some jobs we ask CivitAI how a model's creator marked it and whether it is still listed. If CivitAI can't answer, the job is refused.
• The blocklist. Pictures and sampled clip frames you upload are compared with fingerprints of uploads we refused before (section 4.3).

When a check refuses a job, nothing is made, or the result is not saved. You see a message that names the check. Some refusals are recorded against your account (section 4.4).

Automated checks can be wrong. If you think a refusal was wrong, write to support@genvista.com, ideally within 48 hours while the job still exists, and ask for a review (section 4.6).

• Legal basis for all checks: our legitimate interests, and those of the people shown and of the public, in keeping illegal and harmful content out of the Service, protecting children and people shown without their consent, and meeting our own legal duties, including under criminal law. Where EU law requires such safeguards, for example the EU AI Act's prohibitions concerning AI-generated sexual images of identifiable people without their consent and child sexual abuse material (from 2 December 2026), the basis is also legal obligation.

4.2 Face detection and age estimation

What it is for. To keep sexual or otherwise harmful pictures of children out of the Service, jobs check realistic pictures for people who may be under 18. The check reads the photos and clips you upload and the pictures and clips a job makes, and for a clip, frames of the clip.

How it works.

1. A model estimates whether the picture is realistic, like a photo, or a drawing, painting or cartoon.
2. In a realistic picture, a face detector finds the faces, and each face is cut out with the shoulders.
3. Two age models estimate, for each face, how likely it is that the person is a child or under 18.
4. A drawing goes to a different model, which estimates whether a drawn character is a child.

If an estimate passes our limits, the job is refused: nothing is made, or the result is not saved.

What it does not do. It does not identify anyone. There is no face recognition, no comparison with pictures of known people, and no face template (“faceprint”) is made or kept. It estimates apparent age only.

What is kept. The check keeps no copy of the picture or of the face cut-outs. Its scores are not saved in our database or written to the GPU machine's technical logs, which can record the check's outcome, such as the code of a refusal, with the job's number (section 3.3). If the check refuses a job, the refusal is recorded like any other (sections 3.7 and 4.4). The upload itself follows the 48-hour rule. If an upload is refused because it may show a real child, its fingerprint goes on our blocklist (section 4.3).

Accuracy. Age estimates are estimates and can be wrong. That is why you can ask for a review (section 4.6).

Legal basis. As for all checks (section 4.1). The faces are not used to identify anyone, so we don't treat them as biometric data in the sense of the GDPR (Art. 9) or the nDSG (Art. 5(c)(4)).

Can I turn it off? No. You can object (section 12), but we will normally have compelling grounds to continue, because the check protects children.

4.3 The blocklist of refused uploads

When an upload is refused because it may show a real person under 18, or for another reason that every job would refuse it, we keep a fingerprint of it. A fingerprint is a short code (a PDQ perceptual hash) worked out from the picture. The picture can't be rebuilt from it. We keep the fingerprint, the reason's code and the time. We don't keep the picture, and we don't keep who uploaded it with the fingerprint. New uploads are compared with the list, and a match is refused, so that the same file can't simply be tried again.

• Legal basis: as for all checks (section 4.1).
• Kept: as section 11 says.

4.4 Abuse detection and automatic restrictions

Some refusals are recorded against the account that asked for the job: for example, refusals for content that may show a minor (in what you upload, what you ask for or what a job makes) and for content about a real person that our rules forbid. A record holds a category, the refusal's code, the time and, for a refused job, its number. It never holds your prompt or your files. These records are deleted after 48 hours.

For some kinds of jobs, our system counts an account's records. Past set limits, it automatically restricts the affected features of the account until the account has been reviewed. We may also restrict or suspend an account by hand. Our Terms of Service explain how you can contest it.

• Legal basis: our legitimate interest in detecting and stopping misuse, and legal obligation where EU law requires providers to address misuse.
• Kept: refusal records, 48 hours; a restriction or suspension, as section 11 says.

This is profiling: an automatic assessment of how an account is used. Section 4.6 sets out your rights.

4.5 Other automatic decisions

• One trial per card. When a trial starts, we compare your card's fingerprint, or your Stripe Link email, with earlier trials. If it has already had one, the new trial is cancelled at once and any trial fee refunded.
• Disputed payments. When your bank tells Stripe that you disputed a payment, every plan your Stripe customer record holds ends at once.
• Usage limits. Your plan sets a wait between jobs and how many can queue. Uploads are limited per account and hour. Our firewall limits how many requests one IP address can make.

4.6 Your rights about automatic decisions

Where a decision based solely on automated processing has legal or similarly significant effects on you, it is necessary for our contract with you (GDPR Art. 22(2)(a)), and you can ask for a person to review it, give your point of view and contest it (GDPR Art. 22; nDSG Art. 21). You can also ask us to review a refused job. Write to support@genvista.com.

5. People who appear in what users upload

Our users upload photos, clips and voice recordings, which can show or contain other people. Our Terms require users to have the right to upload them. Our Community Guidelines forbid using anyone's likeness or voice without permission.

If you appear in something a user uploaded:

• we use it only to make what the user asked for and to run the safety checks in section 4, including face detection and age estimation;
• we don't identify you;
• it is deleted with the job after 48 hours. A fingerprint may stay on our blocklist (section 4.3).

Legal basis: the user's and our legitimate interest in providing the Service the user asked for; for the safety checks, as in section 4.1. We usually can't inform you ourselves, because we don't know who you are and keep the content only briefly (GDPR Art. 14(5)(b)).

If you believe someone used your picture or voice without your consent, write to abuse@genvista.com. You have the rights in section 12.

6. Marks in what you make

Pictures, videos and songs made with our Services generally carry marks that say they were made with AI: a signed label in the file (C2PA Content Credentials, with matching IPTC metadata) and an invisible watermark in the pixels, frames or sound. The marks we add hold no personal data. The label says that the file was made with AI by GenVista, whether from a description or from your own file, with which tool and model, and when. The watermark says only that the file was made with AI by GenVista, and how, so every file made the same way carries the same watermark. Neither names you, your account, your prompt or where you are.

• Tools that only change your own file without making anything new, such as splitting a song into its parts, add no marks.
• If a file you upload already carries Content Credentials (from a camera, another app, or an earlier GenVista file), the label of what we make from it keeps that earlier record as it was, as the EU's Code of Practice on marking asks. That record is whatever its maker wrote into your file, and it can name its author. We add no copy or preview of your file to it.
• To sign the label, our server sends the label's contents to a signing key held by Amazon Web Services in the United States. It never sends your file or anything about you.
• We keep only a count of the marks each job added (section 3.7). We keep no copy or fingerprint of what you make that could recognise it later.
• We also remove from every picture the hidden text that used to record its prompt and settings, so a picture you share doesn't give away your prompt.

7. The “Check a file” page

Our Check a file page reads these marks in your browser: the file you check is not uploaded, stored or logged. To read it, your browser downloads the readers from our file host, which Cloudflare serves and which receives your IP address, as any website does. You don't need an account to use it.

8. Who we share data with

We share data only with the service providers below, and only what each needs to do its job for us. They process it on our instructions under their terms with us, except where the table says otherwise.

We may also share data with our legal advisers, accountants and auditors, who are bound to confidentiality.

We don't sell your personal information, and we don't share it for advertising.

9. When we disclose data for other reasons

• The law, and safety. We may access, keep and disclose information if we believe the law requires it or it is needed: to answer a valid request from the police, a court or another authority; to respond to your own requests; to enforce our Terms; or to protect the rights, property or safety of you, us or others. This includes cases where someone creates illegal content on or through the Service. Our Terms explain what we do when we suspect a serious crime.
• Business transfers. If the business is sold, merged or reorganised, data may pass to the new owner, who must respect this policy.
• With your permission. In any other case, only if you ask us to or agree.

10. Data sent abroad

We are in Switzerland. The EU and the UK recognise Switzerland as giving adequate protection, so your data can come to us from there. Our service providers are mostly in the United States, and the GPU machines can be in other countries. We protect each transfer as follows:

• To the EU, the EEA and the UK: recognised as adequate under Swiss law.
• To the United States: where the provider is certified under the EU-U.S. Data Privacy Framework, its UK Extension and the Swiss-U.S. Data Privacy Framework (Amazon Web Services, Cloudflare, Stripe, LLC and Expo), we rely on those frameworks.
• To other providers outside the EU (Supabase, which is in Singapore and stores our data in the United States, and RevenueCat in the United States): the European Commission's standard contractual clauses in the provider's data processing terms, with the changes Swiss law requires and the UK addendum.
• The GPU machines are rented through Vast.ai from independent hosts. Vast.ai offers machines in many countries, and which one runs a job depends on what is available at the time. The machines we rented between 8 October 2026 and 24 October 2026 were in Bulgaria, Canada, Czechia, Denmark, Estonia, Finland, France, Ireland, Japan, Latvia, the Netherlands, Norway, Poland, Portugal, Singapore, South Korea, Spain, Sweden, Switzerland, Taiwan, the United Kingdom and the United States. Machines can also be in other countries. Some may be in countries whose law the EU or Switzerland doesn't recognise as giving adequate protection. For a machine in such a country, the transfer is needed to run the job you ask for (nDSG Art. 17(1)(b); GDPR Art. 49(1)(b)). A machine receives only what the job needs (section 3.3), over encrypted connections, with no names or emails, and holds no passwords or keys to our other systems.

We don't rely on your consent for these transfers. You can ask for a copy of the safeguards at privacy@genvista.com.

11. How long we keep data

We may keep data longer where the law requires or allows it, for example to handle a report, to comply with a legal obligation, or to establish, exercise or defend legal claims, and only for as long as that need lasts.

12. Your rights

You have these rights over your personal data:

• Access: to know whether we hold data about you, and to get a copy of it with the information in this policy.
• Correction: to have wrong or incomplete data fixed. You can change your display name yourself.
• Deletion: to have your data deleted, for example by deleting your account (section 13).
• Restriction: to have us keep your data but stop using it while a question is settled.
• Portability: to get the data you gave us in a common, machine-readable format, or have it sent to another provider where that is possible.
• Objection: see the box below.
• Withdrawing consent: where we rely on your consent, to withdraw it at any time. This doesn't affect what we did before.
• Automatic decisions: to have a person review them, give your view and contest them (section 4.6).

How to use your rights. Write to privacy@genvista.com, ideally from the email address you sign in with. We may ask you to confirm who you are. We answer within the time limits set by law, free of charge. Much of what you make is deleted after 48 hours, so we may no longer hold it.

Do you have to give us your data? No law requires it. But we need your email address to give you an account, payment details for a paid plan, and your prompts and files to make what you ask for. Without them, we can't provide those parts of the Service.

Complaints. You can complain to a data protection authority:

• Switzerland: the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch.
• EU and EEA: the data protection authority of the country where you live or work, or where you think the problem happened. The list is at www.edpb.europa.eu.
• UK: the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, www.ico.org.uk.

We would welcome the chance to settle your concern first, but you don't have to ask us before you complain.

13. Deleting your account

You can delete your GenVista account and its data at any time. In the GenVista Pictures app for iPhone, iPad and Android, open Account and tap Delete account. You can also email privacy@genvista.com from the address you sign in with and ask us to delete it. Deleting your account permanently removes your profile, your plan record and every image, video and song you made; a plan billed on this website is cancelled at the same time. A plan bought in the app through the App Store or Google Play is billed by that store, so cancel it in your phone's subscription settings to stop being charged.

What stays after you delete your account:

• the files of your most recent jobs, until their 48 hours are up and our cleanup deletes them;
• your job history lines and any reports you sent, no longer linked to you, until their periods in section 11 end;
• any withdrawal from a plan (the name and email address you gave), until its period in section 11 ends;
• accounting records that Swiss law requires us to keep, and the records Stripe, Apple, Google and RevenueCat keep under their own policies;
• data we must keep longer under section 11.

14. Cookies and similar technologies

We use only what the Service needs to work:

• Stripe's checkout and billing pages are on Stripe's own site and use Stripe's cookies, for example to prevent fraud, under Stripe's privacy policy.
• We use no analytics, advertising or tracking cookies, and no social media plug-ins. Our fonts come from our own site.
• Because we use only what is strictly necessary for the Service you ask for, we don't ask for consent and show no cookie banner.

15. Minimum age

GenVista is only for adults aged 18 and over, as our Terms of Service require, and no part of it is directed to children or teenagers. We do not knowingly collect personal information from anyone under 18. If you learn that someone under 18 has given us personal information, contact privacy@genvista.com so we can delete it.

16. Security

We use technical and organisational measures to protect your data, including:

• encryption in transit (HTTPS);
• private storage, reached only through links that expire;
• GPU machines that hold no passwords or keys to our other systems;
• access to accounts and jobs limited to authorised personnel;
• the key that signs the marks kept in a key management service;
• deleting what you make after 48 hours.

No method of transmission or storage is completely secure, and we cannot guarantee the security of your information. If a breach puts your rights at risk, we will inform you and the authorities where the law requires it.

17. U.S. state privacy rights

Depending on where you live in the United States, you may have rights to know, access, delete, or correct personal information, or to opt out of certain processing. Contact privacy@genvista.com to exercise your rights. We may verify your identity before responding. We don't sell personal information or share it for cross-context behavioural advertising.

18. Changes to this policy

We may change this policy. We post changes on this page with a new date and, where the law requires it, tell you before they take effect.

19. Contact

For anything about your data: privacy@genvista.com