This policy explains what the iPhone app MomentCam 15 (on the App Store as "MomentCam 15th Anniversary", previously "MomentCam Light") does with your information. Last updated: October 15, 2026.
If you use the app in mainland China, the mainland China policy applies to you instead.
The short version
Your classic avatar is made on your phone. The photo you use for it is not uploaded.
The Realistic look is different, and it starts automatically when you create a new avatar. To draw it, an image of your face goes to our server and from there to an AI image service in the United States. We keep that face image and the result for 24 months and use them to improve our avatars, including to train our own avatar-drawing models. You can delete them sooner in the app at any time.
The app has no account, shows no ads and does not track you across other companies' apps or websites. We do not sell your information.
The app is published by Eureka Studios Limited, Rm 902, 9/F, Fu Fai Commercial Building, 27 Hillier Street, Sheung Wan, Hong Kong ("we", "us"). We decide how your information is used, which makes us the "controller" under data protection laws such as the GDPR.
Contact for anything in this policy: feedback@mojipop.com.
When you create a new avatar, the app starts the Realistic look automatically while you still have upgrades left for the day. It also happens when you tap the Realistic card on an older avatar. The app does not ask separately before the upload, and there is no setting to turn the automatic Realistic look off. If you do not want us to keep your face image, delete the avatar or use "Delete all my data" (see section 8); our copies are then deleted.
We process your face image to draw the look because you use that feature (performance of a contract). We keep it to improve our avatars based on our legitimate interest in making the product better. You can object to that at any time (see section 8).
| What | Why | Who processes it | How long |
|---|---|---|---|
| Usage analytics: app events (for example screens opened, an avatar created, the Realistic look started, the subscription screen shown), app version, device model, OS version, language, approximate country (from the IP address), an app-instance ID, and whether you subscribe or have an avatar. | To understand which features work and fix what does not. | Google Firebase Analytics. The app is built without access to the advertising identifier (IDFA). | Event-level data: at most 14 months. Summary reports that identify no one may be kept longer. |
| Crash reports: what the app was doing when it crashed, device model, OS version, a crash-reporting installation ID, and technical notes about the face-detection step (such as how many face points were found, never the photo). | To find and fix crashes. | Google Firebase Crashlytics. | 90 days. |
| Notification token, only if you allow notifications. | To deliver notifications. Reminders such as "your trial ends soon" are scheduled on the phone itself. | Google Firebase Cloud Messaging and Apple Push Notification service. We do not send the token to our own servers. | Until you turn notifications off or delete the app. |
| Content requests: your IP address, app version, language and platform when the app downloads designs and templates. | To deliver the content in your language. | Our servers on Amazon Web Services (Singapore) and the Amazon CloudFront network. In mainland China, the Alibaba Cloud network. | Server logs are kept to run and secure the services, and are not used to identify you. |
| Purchases: the App Store receipt, transaction ID, product, price and currency. Apple handles payment; we never see your card details or your Apple ID. | To check that a purchase is real and unlock it, including when you restore purchases. | Apple, and our servers on Amazon Web Services (Singapore). | As long as needed to provide and restore your purchase, and as long as tax and accounting law requires. |
| Feedback you send: your message, your email address if you give it, a picture if you attach one, plus the app version, device model, OS version, country and language. | To answer you and fix problems. | Our servers on Amazon Web Services (Singapore). If sending fails, the app opens an email to feedback@mojipop.com instead, through your own mail app. | Attached pictures are deleted automatically after 7 days. Messages are kept as long as needed to deal with them; you can ask us to delete them. |
Only with the service providers named above, who process it for us under contract: Google (Firebase and Google Cloud), Replicate, Amazon Web Services, Alibaba Cloud (mainland China network only) and Apple. We may also disclose information when the law requires it, to protect people's safety or our rights, or to a buyer if our business or this app is sold, in which case this policy continues to apply to it.
If you share an image from the app, it goes to the app or person you choose, under their own terms.
We are based in Hong Kong. Your information is processed in the United States (Google Cloud, Firebase, Replicate), Singapore (Amazon Web Services) and, for users in mainland China, mainland China (Alibaba Cloud). These countries may not have the same data protection laws as yours. When information about people in the EEA, the UK or Switzerland is transferred, we rely on the safeguards in our providers' data processing terms, such as the European Commission's Standard Contractual Clauses (and the UK addendum), where they apply.
Depending on where you live, you can ask us to:
California residents also have the right to know, delete and correct, the right to opt out of sale or sharing (we do neither), and the right not to be treated differently for using these rights.
In the app:
Our daily usage counters (how many upgrades were used on a day, with no images) are not removed by these options; they expire automatically after 24 months. If the phone is offline, the app sends the deletion the next time it can.
By email: for any other request, or if you no longer have the app, email feedback@mojipop.com with the subject "Privacy request". Because the app has no account, tell us roughly when you used the Realistic look and from which device, so that we can find your data. We may ask for more details to confirm the request is yours. We answer within one month (45 days for California requests).
Good to know: deleting the app on its own removes your data from your phone only. To delete our copy as well, use "Delete all my data" before you delete the app, or email us. A reinstalled app gets a new anonymous ID and cannot reach data made before, so for that data email us. Otherwise our copy is deleted automatically after 24 months.
You can also complain to your data protection authority. In the EEA that is the authority where you live or work; in the UK it is the Information Commissioner's Office.
The app is not directed at children under 13 (or the minimum age for consent where you live), and we do not knowingly collect their personal information. The app lets you make avatars with a child's look. If a parent or guardian believes a child has sent us a photo, email feedback@mojipop.com and we will delete it.
Information travels over encrypted connections (HTTPS). Face images and results are kept in a private storage bucket that cannot be reached from the internet; only we and our service accounts can open it. We refer to you by an anonymous ID and keep IP addresses only as hashes. No system is perfectly secure, but we will tell you and the authorities about a breach where the law requires it.
When we change this policy we will update the date at the top. If a change is significant, for example a new use of your photos, we will give notice in the app or on our website before it applies.
Eureka Studios Limited, Rm 902, 9/F, Fu Fai Commercial Building, 27 Hillier Street, Sheung Wan, Hong Kong.
Email: feedback@mojipop.com
feedback@mojipop.com · Terms of Use · Eureka Studios Limited