Privacy Policy

1.1The controller (in Russian terms, "operator") of personal data processed through A1 Clip Aladdin (the "Service") is Armosphera LLC, limited liability company, registration number 273.110.1201950 (unique identifier 52893729), Verin Antarayin 131-27, Yerevan 0009, Armenia, Republic of Armenia ("we"). Privacy contact: support.aladdin@armosphera.com.

1.2This Policy is designed to meet the Law of the Republic of Armenia "On Protection of Personal Data", the EU and UK General Data Protection Regulation (GDPR) where applicable, and Federal Law of the Russian Federation No. 152-FZ "On Personal Data" where applicable. Section 13 contains additional information for users in Russia.

• Account data: email, name or nickname, password hash, login method, language, country, plan, account settings.
• Payment and transaction data: plan, amounts, currency, credit balance and history, payment provider transaction IDs, partial card data or payer identifiers returned by the provider (we do not store full card numbers), billing country, invoices.
• Inputs: prompts, text, images, video, audio and voice samples you upload, including images of faces and recordings of voices.
• Outputs: images, video, audio, voice clones, avatars and AI influencer models generated for you.
• Face data: images of your face or of other people's faces that you upload for face-based effects (kiss/hug, age, baby prediction, try-on, talking photo, avatars).
• Voice data: voice recordings and the voice model (voice clone) derived from them.
• Age-verification data: the result of age verification and, depending on the method, data such as date of birth or verification token.
• Marketplace data: your marketplace API keys (encrypted), store identifiers, listing data and any data returned by marketplace APIs.
• Technical and usage data: IP address, device and browser data, log data, timestamps, generation history, error logs, security events, cookies and similar technologies.
• Communications: support requests, abuse reports and takedown notices, consent records.

3.1We use face images and voice recordings only to perform the effect or generation you request (for example, to animate a photo or synthesise speech in a cloned voice). We do not use them to identify or authenticate individuals, do not build face-recognition databases, and do not use them to train AI models.

3.2Because face and voice data may be treated as biometric or special-category data in some jurisdictions, we process them on the basis of your explicit consent, which you give before first using such features and can withdraw at any time (withdrawal does not affect prior processing). When you upload data of another person, you confirm that you have obtained that person's explicit consent to this processing and can show it on request.

3.3Voice clones are stored in your account until you delete them or close your account, and may be deleted by us if consent cannot be confirmed.

• Providing the Service, account management, generation, storing your library — performance of contract (GDPR Art. 6(1)(b); Armenian law: contract; 152-FZ Art. 6(1)(5)).
• Face and voice processing, 18+ age verification — explicit consent (GDPR Art. 9(2)(a); 152-FZ Arts. 9, 11 where applicable; Armenian law consent rules).
• Payments, accounting, tax, fraud prevention — contract, legal obligation (GDPR Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)).
• Safety, content moderation, abuse prevention, enforcement of our policies, responding to legal requests — legitimate interests and legal obligation.
• Service emails (transactional) — contract; marketing emails — consent, withdrawable at any time.
• Marketing emails (news, offers, early access to new models) — your consent (GDPR Art. 6(1)(a); 152-FZ Art. 6(1)(1) and Art. 18 of the Russian Federal Law «On Advertising»), given only by pressing «Claim bonus» next to the statement «Get emails from Aladdin. Unsubscribe in one click.» or by turning on «Email updates» in account settings. It is never pre-selected, is separate from the Terms and is not a condition of using the Service; the one-time bonus credits are a thank-you, not payment for data. We record the time, the source (card or settings), your country (from the request, not the IP address) and the version of the wording you agreed to. Withdraw at any time with the one-click link in every marketing email or the switch in account settings; withdrawal takes effect immediately and does not affect processing before it. Service (transactional) emails are sent under the contract regardless.
• Analytics and service improvement (aggregated, non-content) — legitimate interests or consent where required for cookies.

5.1Prompts and media are checked automatically by filters (including for minors, real people in the 18+ section and illegal content). Blocked requests may be logged and reviewed by authorised staff. Automated filtering may lead to refusal of a generation; it does not produce legal effects about you beyond that, and you can contact us to request human review.

6.1We share personal data only as needed with: (a) AI model and inference providers that process prompts and media to generate Outputs; (b) cloud hosting, storage and CDN providers; (c) payment providers (PayPal and, once launched, СБП participants and acquiring banks such as VTB Bank (Armenia) CJSC); (d) email and communications providers; (e) age-verification provider; (f) analytics and error-monitoring providers; (g) marketplaces you connect (Ozon, Wildberries, Amazon, eBay), at your instruction; (h) professional advisers, authorities and courts where required by law; (i) a successor in a merger or acquisition.

6.2Our processors act on our instructions under written agreements and are bound by confidentiality and security obligations. We require AI providers not to use your data to train their models where contractually available. A list of processor categories and their countries is available on request at support.aladdin@armosphera.com.

6.3We do not sell personal data.

6.4For marketing emails and their measurement we use Mixpanel, Inc. (USA) as a processor. Only if you gave marketing consent, your email address and consent status (granted/withdrawn, time, source, wording version) are stored in your Mixpanel profile, which is keyed by an internal user id; prompts and media are never sent. When you withdraw consent, your email address is removed from that profile and it is marked as opted out. Product analytics in Mixpanel run only after you allow analytics cookies.

7.1We are established in Armenia. Our servers are located in the Republic of Armenia and, for personal data of users in Russia, in the Russian Federation (Yandex Cloud). Our processors may be located in other countries, including the United States and the European Union. Where required, we use appropriate safeguards such as Standard Contractual Clauses, adequacy decisions, or your consent, and comply with notification requirements for cross-border transfers under Armenian and Russian law.

• Account data: for the life of the account and 30 days after deletion.
• Uploaded inputs (including face images): for as long as needed to perform the requested generation and keep it in your library, and in any case until you delete them or close your account.
• Outputs in your library: until you delete them or close your account.
• Voice samples and clones: until you delete them, close your account or the voice owner withdraws consent.
• Logs and security records: for as long as needed for security and fraud prevention.
• Age-verification records: for the life of the account.
• Payment and accounting records: for the period required by tax and accounting law.
• Content and data related to serious violations may be retained longer to comply with legal obligations or defend claims.
• Marketing consent records (decision, time, source, country, wording version): while consent is active and up to 3 years after withdrawal, as proof of consent; your email address is removed from Mixpanel on withdrawal.

9.1We use measures appropriate to the risk, including encryption in transit, encryption of marketplace API keys at rest, access controls, logging, and least-privilege access by staff. No system is completely secure; we will notify you and authorities of personal data breaches where required by law (e.g. within 72 hours under GDPR; within 24/72 hours to Roskomnadzor under 152-FZ Art. 21(3.1)).

10.1Depending on your location, you have the right to: access your data; rectify it; delete it; restrict or object to processing; data portability; withdraw consent at any time; not be subject to decisions based solely on automated processing with legal or similarly significant effects; and lodge a complaint with a supervisory authority (in Armenia — the Personal Data Protection Agency of the Ministry of Justice; in Russia — Roskomnadzor; in the EU/UK — your local authority or the ICO).

10.2To exercise your rights, write to support.aladdin@armosphera.com or use account settings. We respond within the period required by law (generally 30 days under GDPR; 10 working days under 152-FZ, extendable by 5 working days). We may need to verify your identity.

10.3Persons depicted in content uploaded by another user may contact support.aladdin@armosphera.com to request deletion (see Acceptable Use Policy).

10.4You can withdraw marketing consent at any time, in one click, without giving reasons: use the unsubscribe link in any marketing email or turn off «Email updates» in account settings.

11.1The Service is not intended for persons under 18. We do not knowingly collect their data. Images of minors must not be uploaded for any effects that are prohibited by the Acceptable Use Policy. If we learn that we hold data of an underage user, we will delete it.

12.1We use strictly necessary cookies for login and security and, with your consent where required, analytics cookies. You can manage preferences in the cookie banner or your browser.

13.1Where 152-FZ applies, we act as operator. Personal data of citizens of the Russian Federation is recorded, systematised, accumulated, stored, clarified and extracted using databases located in the Russian Federation, as required by Art. 18(5) of 152-FZ. Personal data of users in Russia is stored on servers of Yandex Cloud located in the Russian Federation.

13.2Consent to processing is collected as a separate document/checkbox distinct from these documents where required (Art. 9). Consent to cross-border transfer and to processing of special and biometric data, where applicable, is collected separately.

13.3Cross-border transfers are carried out after notification to Roskomnadzor (Art. 12).

13.4Actions with data: collection, recording, systematisation, accumulation, storage, clarification, extraction, use, transfer (provision, access), depersonalisation, blocking, deletion, destruction; automated and mixed processing.

13.5Requests under Art. 14 may be sent to support.aladdin@armosphera.com or by post to Verin Antarayin 131-27, Yerevan 0009, Armenia.

14.1We process personal data in accordance with the principles of lawfulness, proportionality, reliability and minimal involvement under the Law of the Republic of Armenia "On Protection of Personal Data". Biometric data is processed only with consent. Transfers to third countries are carried out in accordance with Article 26 of that Law (adequate protection, contractual safeguards or authorisation).

15.1We will notify you of material changes. Contact: support.aladdin@armosphera.com, +374 55 98 1151; Armosphera LLC, Verin Antarayin 131-27, Yerevan 0009, Armenia.