1. Data controller
Palm Three LLC, a New Mexico LLC, USA, registration number 3059611, is the controller for Boki and getboki.app. Principal and mailing address: 704 Wallace St, Suite 382, Clovis, NM 88101, USA. Privacy and support contact: hello@getboki.app.
2. App data
An anonymous profile lets you start without an email address. We process its technical identifier, preferences, learning progress (lessons, challenges, XP, streaks), submitted photos, descriptions and analysis results. Saving with Apple adds the identifier and information Apple provides. Previously created email accounts retain their associated data.
Useful camera settings may accompany an analysis, such as ISO, aperture, shutter speed, focal length and framing. GPS metadata is removed from the image prepared for upload. The app can display photo metadata locally without sending all of it to the AI. Purchases involve transaction, account and product identifiers, Premium status and credit balances. Technical information needed for operation and security is also processed. Boki does not receive payment card data.
3. Purposes and legal bases
Profiles, progress synchronization, requested analyses and purchase rights are processed to provide the contracted service. Abuse prevention and incident diagnosis rely on our legitimate interest in protecting it. Accounting and legally binding requests rely on legal obligations. Optional reminders and waitlist registration rely on consent, which can be withdrawn. We do not sell data or use it for targeted advertising.
The website flow (getboki.app/start) and purchases on the website are necessary to provide the service you request. The limit on analyses per IP address and the bot check rely on our legitimate interest in protecting the service against abuse. At the end of the journey, if you don’t take an offer, you can leave your email address to be told when the app launches: this waitlist sign-up is based on your consent.
4. AI photo analysis
When you request analysis, Boki sends Google Gemini a prepared copy of your photo, optional description, useful camera settings and lesson or challenge context. An edited-photo comparison may also include the previous photo and report. Your account identifier and GPS coordinates are not included in the context sent to the model.
Photos and reports remain in your private space for progress history. Authorized team members can review them to resolve an analysis dispute or incident. They are not published to other users. Boki does not train its own model with your photos. Google’s processing, including technical retention and security, is governed by its Gemini terms. The service configuration determines Google’s applicable data-use rules.
On the website (getboki.app/start), the photo you choose, or a sample photo, is sent to our server, resized and stripped of its metadata (EXIF, GPS), then analysed the same way as in the app, under an anonymous profile created for that purpose. This profile is not linked to your profile in the app.
5. Providers and international transfers
Supabase hosts app data, authentication and images in us-west-2, USA. RevenueCat manages purchase rights and App Store synchronization. Apple handles payments and optional Apple sign-in. Google provides image analysis. Authorized Palm Three LLC personnel and technical website and email providers process data needed for their roles.
Some processing takes place outside your country, including in the USA. Contact us for details about recipients and transfer safeguards. Authorities may receive information when disclosure is legally required.
The website and waitlist use Hostinger infrastructure. Support email uses Google.
For the website, Cloudflare Turnstile checks that an analysis request does not come from a bot, using technical information about your browser. Purchases on the website are managed by RevenueCat (RevenueCat Billing) and paid through Stripe: they process your email address, payment details and, where needed, your billing address, as well as information used to prevent fraud. Boki does not receive your card details. RevenueCat also sends the receipt and the link that activates the purchase in the app.
6. Retention and deletion
Progress, photos and reports are kept to support use of your profile. Inactive anonymous profiles may be deleted after 30 days, subject to protections for purchases or retained credits. Saving with Apple avoids relying solely on an anonymous profile.
Deleting an account removes its data from the active database. A daily cleanup removes orphaned images and retries failures. Providers retain records needed for legal obligations, security and transactions under their applicable retention duties. Support exchanges are kept while handling your request and, where necessary, a dispute. Waitlist details, including your answers, are used to announce the app’s release and to send you the launch offer reserved for people on the list; they are kept for this purpose or until you withdraw.
Anonymous profiles created for an analysis on the website follow the same rule as other anonymous profiles. Information about a purchase on the website is kept for the duration of the subscription, then for the period required by accounting and tax obligations.
7. Waitlist and cookies
The website form collects your email, registration date, website and browser language, time zone, country and registration source (form location and UTM campaign parameters). Our server estimates country from your IP using DB-IP, CC BY 4.0. The IP is not saved in the waitlist or sent to DB-IP. The sign-up flow also asks three questions: your phone (iPhone or Android), your photography level and the style of photography you like most. These answers help us prepare the launch and email you at the right time, for example when the Android version is released.
The boki_langue cookie remembers your language for one year. Session cookies protect website administration. The app stores information locally for sessions and offline progress. The website also keeps in your browser (local storage) that you closed the banner suggesting another language, so it is not shown again. No audience measurement tool or advertising cookie is used: these cookies and this storage are necessary for the website or reflect your choices, so they do not require consent.
The website flow keeps in your browser (local storage) your progress, your answers to the questions, the chosen photo, an anonymous purchase identifier and, after a purchase, the link that activates it in the app; your answers are not sent to our servers. Your IP address is used in memory, without being stored, to limit the number of analyses. The checkout, provided by RevenueCat and Stripe, may set cookies needed for payment and fraud prevention. At the end of the journey, without a purchase, the email address you leave joins the waitlist (source “parcours”), with the information described above. After a purchase on the website, the email address given at payment, managed by RevenueCat, is used to tell you when the app launches so you can activate your purchase.
8. Rights and choices
Subject to applicable law, you may request access, correction, deletion, portability, restriction or objection and withdraw consent for future processing. Contact hello@getboki.app; we respond within legal deadlines, normally one month for GDPR requests. Delete your account from the account and progress section of Boki settings; contact us for a data copy or waitlist removal. Deleting Boki account data does not cancel Apple subscriptions.
You may complain to your local data protection authority, including the CNIL in France.
A subscription purchased on the website is cancelled from the subscriber area linked in the confirmation email, or by writing to us; deleting your Boki account does not cancel it.
9. Permissions and security
Camera and photo access is requested when needed and controlled through iOS settings. Transfers to services are encrypted in transit. Account data and private images are subject to authentication and authorization controls. Legally required breach notifications will be made.
10. Updates
This policy changes as the service evolves. Material changes will be communicated through an appropriate channel. The version date appears above.