Privacy Policy
Effective as of October 01, 2020.
Last updated October 01, 2020.
This Privacy Policy describes the privacy practices of Gradient in connection with the
Gradient mobile application (the “App”) and website (the “Site”).
Welcome to Gradient’s Privacy Policy!
If you decide not to read this entire Privacy Policy, we want you to walk away with a
few key points about Gradient’s privacy practices:
The App is a photo and video editor that allows users to edit portraits based on
neural network technology that automatically generates highly realistic facial
We use third-party cloud providers – specifically, Google Cloud Platform and
Amazon Web Services – to process and edit photographs.
The App only uploads to the cloud the photographs that you specifically select
for editing.
Photographs are temporarily cached on the cloud servers during the editing
process, and encrypted using a key stored locally on your mobile device.
Photographs remain in the cloud for a limited period of 24-48 hours after you
have last edited the photograph, so that you can return to the image and make
additional changes if you so choose.
We do not use the photographs you provide when you use the App for any
reason other than to provide you with the portrait editing functionality of the
Videos are edited locally on your device, so you don’t provide us with videos
when you use the App, and we don’t collect, use and share your video
If you have any questions about our privacy practices, please
Here’s more on our privacy practices. Individuals located in the European Economic
Area should also read our Notice to European Users below.
Personal Information We Collect
When you use the App, we may collect information about you, including:
Photographs you provide when you use the App, via your camera or camera
roll (if you have granted us permission to access your camera or camera roll),
the in-App internet search functionality, or your social media account (if you
choose to connect your social media account). We obtain only the specific
images you chose to modify using the App; we do not collect your photo albums
even if you grant us your access to them. We encrypt each photograph that you
upload using the App. The encryption key is stored locally on your device. This
means that the only device that can view the photo is the device from which the
photograph was uploaded using the App – the user’s device. Please note that
while we do not require or request any metadata attached to the photographs
you upload, metadata (including, for example, geotags) may be associated with
your photographs by default. We take steps to delete any metadata that may be
associated with a photograph you provide when you use the App.
App usage information, such as information about how you use the App and
interact with us, including your preferred language, the date and time when you
first installed the App and the date and time you last used the App.
Purchase history, if you choose to purchase an App subscription, such as
confirmation that you are a paid subscriber to the App.
Social media information, if you choose to login to the App via a third-party
platform or social media network (for example, Facebook), or otherwise connect
your account on the third-party platform or network to the App. We may collect
information from that platform or network, such as your social media alias, first
and last name, number of “friends” on the social media platform and, if
depending on your Facebook or other network settings, a list of your friends or
connections (though we do not use or store this information). Our collection and
processing of the information we obtain from social media platforms is governed
by the requirements these social media platforms impose on us in their relevant
terms and conditions.
Device data, such as your computer and mobile device operating system type
and version number, manufacturer and model, device ID, push tokens, Google
Advertising ID, Apple ID for Advertising, browser type, screen resolution, IP
address (and the associated country in which you are located), the website you
visited before visiting our Site; and other information about the device you are
using to visit the App.
Online activity data, such as information about your use of and actions on the
App and the Sites, including pages or screens you viewed, how long you spent
on a page or screen, navigation paths between pages or screens, information
about your activity on a page or screen, access times, and length of access. Our
service providers and certain third parties (e.g., online advertising networks and
their clients) also may collect this type of information over time and across third-
party websites and mobile applications. This information may be collected on
our Site using cookies, browser web storage (also known as locally stored
objects, or “LSOs”), web beacons, and similar technologies. We may collect this
information directly or through our use of third-party software development kits
(“SDKs”). SDKs may enable third parties to collect information directly from our
How We Use Your Personal Information
We do not use the photographs you provide when you use the App for any reason
other than to provide you with the editing functionality of the App. We may use
information other than photographs for the following purposes:
To operate and improve the App:
Enable you to use the App’s features;
Establish and maintain your account, if you choose to login to the App using
your social media account;
Communicate with you about the App, including by sending you
announcements, updates, and security alerts, which we may send through a
push notification, and responding to your requests, questions and feedback;
Provide technical support and maintenance for the App; and
Perform statistical analysis about use of the App (including throught the use
of Google Analytics).
To send you marketing and promotional communications. We may send you
marketing communications as permitted by law. You will have the ability to opt-out of
our marketing and promotional communications as described in the Opt-out of
marketing section below.
To display advertisements to you. If you use the free version of the App, we work
with advertising partners to display advertisements within the App. These
advertisements are delivered by our advertising partners and may be targeted based
on your use of the App or your activity elsewhere online. To learn more about your
choices in connection with advertisements, please see the section below titled
“Targeted online advertising.”
For compliance, fraud prevention, and safety. We may use your personal
information and disclose it to law enforcement, government authorities, and private
parties as we believe necessary or Appropriate to: (a) protect our, your or others’
rights, privacy, safety or property (including by making and defending legal claims); (b)
enforce the terms and conditions that govern the Service; and (c) protect, investigate
and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent. In some cases, we may specifically ask for your consent to collect,
use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create
anonymous, aggregated or de-identified data from your personal information and other
individuals whose personal information we collect. We make personal information into
anonymous, aggregated or de-identified data by removing information that makes the
data personally identifiable to you. We may use this anonymous, aggregated or de-
identified data and share it with third parties for our lawful business purposes.
How We Share Your Personal Information
We do not disclose user photographs or videos to third parties (with the exception of
uploading an encrypted image to our cloud providers Google Cloud Platform and
Amazon Web Services to provide the photo editing features of the App). We may share
your non-photograph and non-video information in the following circumstances:
Affiliates. We may share App usage information with our subsidiaries and affiliates, for
purposes consistent with this Privacy Policy.
Service providers. We may share your personal information with services providers
that perform services on our behalf or help us operate the App (such as customer
support, hosting, analytics, email delivery, marketing, and database management
services). These third parties may use your personal information only as directed or
authorized by us and in a manner consistent with this Privacy Policy, and are
prohibited from using or disclosing your information for any other purpose.
Advertising partners. When we use third-party cookies and other tracking tools, our
advertising partners may collect information from your device to help us analyze use of
the Site and the App, display advertisements on the App and advertise the Site and
App (and related content) elsewhere online.
Third-party platforms and social media networks. If you have enabled features or
functionality that connect the App to a third-party platform or social media network
(such as by logging into Gradient using your account with the third-party, providing
your API key or similar access token for the App to a third-party, or otherwise linking
your account with the App to a third-party’s services), we may disclose the personal
information that you authorized us to share (such as when you elect to upload a
photograph or video to your social media account). We do not control the third-party
platforms’ use of your personal information, which is governed by that third party’s
privacy policy and terms and conditions.
Professional advisors. We may disclose your personal information to professional
advisors, such as lawyers, bankers, auditors and insurers, where necessary in the
course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal
information for the compliance, fraud prevention and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of our
business or assets, including your personal information, in connection with a business
transaction (or potential business transaction) such as a corporate divestiture, merger,
consolidation, acquisition, reorganization or sale of assets, or in the event of
bankruptcy or dissolution.
Compliance with Law
We may be required to use and share your personal information to comply with
applicable laws, lawful requests, and legal process, such as to respond to subpoenas
or requests from government authorities.
Your Choices
In this section, we describe the rights and choices available to all users. Users who are
located within European can find additional information about their rights below.
Opt out of marketing communications and other push notifications. You may opt
out of marketing-related communications and other notifications we may send you via
push notification by changing the settings on your mobile device.
Device permissions. You may revoke any permissions you previously granted to us,
such as permission to access your camera, camera roll, or microphone through the
settings on your mobile device.
Cloud processing. You may request that we remove your information, including
photographs, from the cloud before the 24-48 hour period after which Google Cloud
Platform or Amazon Web Services automatically deletes the information by clicking the
“Request cloud data removal” button in the “Support” section of the App Settings on
your mobile device.
Cookies & Browser Web Storage. Most browsers let you remove or reject cookies.
To do this, follow the instructions in your browser settings. Many browsers accept
cookies by default until you change your settings. Please note that if you set your
browser to disable cookies, the Site may not work properly. Similarly, your browser
settings may allow you to clear your browser web storage.
Targeted online advertising. Some of the business partners that collect information
about users’ activities on or through the Site or App may be members of organizations
or programs that provide choices to individuals regarding the use of their browsing
behavior or mobile application usage for purposes of targeted advertising.
Site users may opt out of receiving targeted advertising on websites through members
of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance
by clicking here. App users may opt out of receiving targeted advertising in mobile
apps through participating members of the Digital Advertising Alliance by installing the
AppChoices mobile app, available here, and selecting the user’s choices. Please note
that we also may work with companies that offer their own opt-out mechanisms and
may not participate in the opt-out mechanisms that we linked above.
In addition, your mobile device settings may provide functionality to limit our, or our
partners’, ability to engage in ad tracking or targeted advertising using the Google
Advertising ID or Apple ID for Advertising associated with your mobile device.
If you choose to opt-out of targeted advertisements, you will still see advertisements
online but they may not be relevant to you. Even if you do choose to opt out, not all
companies that serve online behavioral advertising are included in this list, so you may
still receive some cookies and tailored advertisements from companies that are not
Choosing not to share your personal information. Where we are required by law to
collect your personal information, or where we need your personal information in order
to provide the App to you, if you do not provide this information when requested (or
you later ask to delete it), we may not be able to provide you with our services. We will
tell you what information you must provide to use the App by designating it as required
at the time of collection or through other appropriate means.
Third-party platforms or social media networks. If you choose to connect to the
App via a third-party platform or social media network, such as by using Facebook
login, you may have the ability to limit the information that we may obtain from the
third-party at the time you login to the App using the third-party’s authentication
service or otherwise connect your account. Subsequently, you may be able to control
your settings through the third-party’s platform or service. For example, you may
access and change your settings through the Facebook settings page for Apps and
Websites. If you withdraw our ability to access certain information from a third-party
platform or social media network, that choice will not apply to information that we have
already received from that third party.
Other Sites, Mobile Applications and Services
The App may contain links to other websites, mobile applications, and other online
services operated by third parties. These links are not an endorsement of, or
representation that we are affiliated with, any third party. In addition, our content may
be included on web pages or in mobile applications or online services that are not
associated with us. We do not control third party websites, mobile applications or
online services, and we are not responsible for their actions. Other websites, mobile
applications and online services follow different rules regarding the collection, use and
sharing of your personal information. We encourage you to read the privacy policies of
the other websites, mobile applications and online services you use.
Security Practices
We use commercially reasonable security practices to help keep the information
collected through the App secure and take reasonable steps to verify your identity
before granting you access to your account (if you have an account with us). However,
Gradient cannot ensure the security of any information you transmit to Gradient or
guarantee that information on the App may not be accessed, disclosed, altered, or
Please do your part to help us. You are responsible for maintaining the confidentiality
of your login information and device identifiers, and for controlling access to
communications between you and Gradient, at all times. Your privacy settings may
also be affected by changes the social media services you connect to Gradient make
to their services. We are not responsible for the functionality, privacy, or security
measures of any other organization.
We configure Google Cloud Platform and Amazon Web Services to delete
photographs, and the information associated with the photographs within 24-48 hours
after the photograph was last edited using the App. This allows you to revisit the image
for additional modifications during that time.
With respect to non-photograph information that we may collect, we will retain such
information in a personally identifiable format only for as long as necessary to fulfill the
purposes we have set out in this Privacy Policy. You may also ask that we delete your
information using the “Request cloud data removal” button as described above or
by contacting us.
Cross-Border Data Transfers
We store the information we collect in connection with the App on Amazon Web
Services and Google Cloud Platform. For Amazon Web Services, we specify the US as
the data storage location, for Google Cloud Platform, we specify data storage at an
available location closest to you when you use the App. Your personal information may
be accessed by our service providers in other locations outside of your state, province,
or country. Your device ID (and general App usage information) may also be accessed
by the Company’s technical support team in other locations outside of your state,
province, or country. We rely on the Privacy Shield, as described below, for transfers of
data from the EU and Switzerland to Gradient in the United States.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Ticket to the Moon, Inc. is the US entity that publishes and hosts the App. Ticket to the
Moon, Inc. complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks
as set forth by the U.S. Department of Commerce regarding the collection, use, and
retention of personal information transferred from the European Union and Switzerland
to the United States. Ticket to the Moon, Inc. has submitted its certification to the
Department of Commerce that it adheres to the Privacy Shield Principles. If there is any
conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the
Privacy Shield Principles shall govern. To learn more about the Privacy Shield program,
and to view our certification, please visit
Ticket to the Moon, Inc. may transfer your personal information to third parties as
described in this Privacy Policy. Ticket to the Moon, Inc. maintains contracts with its
third-party service providers restricting their access, use and disclosure of personal
information in compliance with our Privacy Shield obligations. Ticket to the Moon, Inc.
may be liable if these third parties fail to meet those obligations and we are responsible
for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Ticket to the Moon, Inc. commits to
resolve complaints about our collection or use of your personal information. European
individuals with inquiries or complaints regarding our Privacy Policy should first contact
Ticket to the Moon, Inc. at Ticket to the Moon, Inc. has further
committed to refer unresolved Privacy Shield complaints to JAMS, an alternative
dispute resolution provider located in the United States. If you do not receive timely
acknowledgment of your complaint from us, or if we have not resolved your complaint,
please visit for more information or to file a
complaint. The services of JAMS are provided at no cost to you. If neither Ticket to the
Moon, Inc. nor JAMS resolves your complaint, you may have the ability to engage in
binding arbitration through the Privacy Shield Panel. Additional information on the
arbitration process is available on the Privacy Shield website
Ticket to the Moon, Inc. may be required to disclose personal data in response to
lawful requests by public authorities, including to meet national security or law
enforcement requirements. The Federal Trade Commission has jurisdiction over Ticket
to the Moon, Inc.’s compliance with the Privacy Shield. Ticket to the Moon, Inc.’s
commitments under the Privacy Principles are subject to the investigatory and
enforcement powers of the Federal Trade Commission.
The App is not directed at children under the age of 13, and our Terms of Use do not
allow children under 13 years of age to use the App. If we learn that we have collected
personal information of a child under the age of 13, we will delete it. We encourage
parents with concerns to contact us.
Changes to the Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material
changes to this Privacy Policy, we will notify you by updating the date of this Privacy
Policy and posting it on the App. We may, and if required by law, will, provide
notification of changes in another way that we believe is reasonably likely to reach you,
such as through the App.
Any modifications to this Privacy Policy will be effective upon our posting the new
terms and/or upon implementation of the new changes on the App (or as otherwise
indicated at the time of posting). In all cases, your continued use of the App after the
posting of any modified Privacy Policy indicates your acceptance of the terms of the
modified Privacy Policy.
How to Contact Us
Please direct any questions or comments about this Policy or privacy practices
to You may also write to us via postal mail at:
Ticket to the Moon, Inc.
Attn: Legal – Privacy
187 E. Warm Springs Rd., Suite B495, Las Vegas, Nevada, 89119, USA
Notice to European Users
The information provided in this “Notice to European Users” section applies only to
individuals who reside in Europe.
Personal information. References to “personal information” in this Privacy Policy are
equivalent to “personal data” governed by European data protection legislation.
Controller and EU Representative. Ticket to the Moon, Inc. is the controller of your
personal information covered by this Privacy Policy for purposes of European data
protection legislation.
We have appointed Legal Bridge as our representative in the European Union for data
protection matters, pursuant to Article 27 of the General Data Protection Regulation of
the European Union. To contact Legal Bridge, please visit
Alternatively, you may call Legal Bridge at +420 775 700 329, or write to Legal Bridge
Сzech Republic, 110 00 Praha 1, ul. Havlickova 15/1682.
Legal bases for processing. We use your personal information only as permitted by
law. Our legal bases for processing the personal information described in this Privacy
Policy are described in the table below.
Processing purpose
Details regarding each processing purpose listed below
are provided in the section above titled “How we use
your personal information”.
Legal basis
To operate and improve the App
Processing is necessary to perform the contract
governing our provision of services in connection
with the App, or to take steps that you request
prior to signing up for the App. If we have not
entered into a contract with you, we process your
personal information based on our legitimate
interest in providing the services you access and
request in connection with the App.
To send you marketing and promotional communications
To display advertisements to you
For compliance, fraud prevention and safety
To create anonymous, aggregated or de-identified data
These activities constitute our legitimate
interests. We do not use your personal
information for these activities where our
interests are overridden by the impact on you
(unless we have your consent or are otherwise
required or permitted to by law).
Compliance with Law
Processing is necessary to comply with our legal
With your consent
Processing is based on your consent. Where we
rely on your consent you have the right to
withdraw it any time in the manner indicated
when you consent or in the App.
Your rights
European data protection laws give you certain rights regarding your personal
information. If you are located within the European Union, you may ask us to take the
following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal
information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you
or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our
processing of your personal information that impacts your rights.
You may submit these requests by email to or our postal
address provided above.
If you would like to submit a complaint about our use of your personal information or
our response to your requests regarding your personal information, you may contact
us or submit a complaint to the data protection regulator in your jurisdiction. You can
find your data protection regulator here.
Notice to California Residents
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to
California residents an explanation of how we collect, use and share their personal
information, and of the rights and choices we offer California residents regarding our
handling of their personal information.
We do not sell personal information. As we explain in this Privacy Policy, we use
cookies and other tracking technologies to analyze Site and App traffic and use, and to
facilitate advertising. If you would like to opt out of our (and our third party advertising
partners’) use of cookies and other tracking technologies, please review the
instructions provided in the Online Tracking Opt-out Guide.
In addition to disclosures of personal information to our service providers and
professional advisors, for compliance, fraud prevention and safety, and in connection
with a business transfer, as described in the “How We Share Your Personal
Information” section of the Privacy Policy, the following chart further describes our
privacy practices with respect to the personal information of our California consumers.
we collect
Sources of
Purposes for which we
may collect and use the
personal information
Data Sharing
To operate and improve
the App
Shared with third-party platforms
(e.g., social media networks) at
your direction
Shared with cloud service
providers (i.e., Google Cloud
Platform and Amazon Web
App usage
Online identifiers
Internet or network
To operate and improve
the App
To send you marketing
and promotional
Shared with affiliates that provide
services to us
we collect
Sources of
Purposes for which we
may collect and use the
personal information
Data Sharing
Online identifiers
The app store
provider through
which you
purchased your
subscription (i.e.,
Google or Apple)
To operate and improve
the App
Social media
Online identifiers
To operate and improve
the App
Shared with third-party platforms
(e.g., social media networks) at
your direction
Device data
Online activity
Online identifiers
Internet or network
To display
advertisements to you
Collected directly by advertising
California Residents’ Privacy Rights
Except as excluded from the scope of this notice above, the CCPA grants California
residents the following rights.
Information. You can request information about how we have collected, used
and shared and used your personal information during the past 12 months. We
have made this this information available to California residents without having
to request it by including it in this notice, in the above chart.
Access. You can request a copy of the personal information that we maintain
about you.
Deletion. You can ask us to delete the personal information that we collected or
maintain about you.
Please note that the CCPA limits these rights by, for example, prohibiting us from
providing certain sensitive information in response to an access request and limiting
the circumstances in which we must comply with a deletion request. If we deny your
request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
How to Submit a Request
To request access to or deletion of personal information:
Identity verification. The CCPA requires us to verify the identity of the individual
submitting a request to access or delete personal information before providing a
substantive response to the request. We may attempt to verify your identity by asking
you to confirm information that we have on file about you or your interactions with us.
Where we ask for additional personal information to verify your identity, we will only
use it to verify your identity or your authority to make the request on behalf of another
Authorized agents. California residents can empower an “authorized agent” to submit
requests on their behalf. We will require the authorized agent to have written
authorization confirming such authority.
CCPA Glossary
Statutory Category
Data Elements within the Category
Commercial Information
Records of personal property, products or
services purchased, obtained, or considered,
or other purchasing or consuming histories or
Real name, alias, postal address, unique
personal identifier, customer number, email
address, account name, social security
number, driver’s license number, passport
number, or other similar identifiers.
The derivation of information, data,
assumptions, or conclusions from any other
category of Personal Information to create a
profile about a person reflecting the person's
preferences, characteristics, psychological
trends, predispositions, behavior, attitudes,
intelligence, abilities and aptitudes.
Internet or Network Information
Browsing history, search history, and
information regarding a person’s interaction
with an Internet website, application, or
Online Identifiers
An online identifier or other persistent identifier
that can be used to recognize a person, family
or device, over time and across different
services, including but not limited to, a device
identifier; an Internet Protocol address;
cookies, beacons, pixel tags, mobile ad
identifiers, or similar technology; customer
number, unique pseudonym, or user alias;
telephone numbers, or other forms of
persistent or probabilistic identifiers (i.e., the
identification of a person or a device to a
degree of certainty of more probable than not)
that can be used to identify a particular person
or device.
Physical Description
An individual’s physical characteristics or
description (e.g., hair color, eye color, height,
Online Tracking Opt-Out Guide
Like many companies online, we may use services provided by Google, Facebook,
Twitter and other companies that use tracking technology. These services rely on
tracking technologies – such as cookies and web beacons – to collect directly from
your device information about your browsing activities, your interactions with websites,
and the device you are using to connect to the Internet. There are a number of ways to
opt out of having your online activity and device data collected through these services,
which we have summarized below:
Blocking cookies in your browser. Most browsers let you remove or reject
cookies, including cookies used for interest-based advertising. To do this, follow
the instructions in your browser settings. Many browsers accept cookies by
default until you change your settings. For more information about cookies,
including how to see what cookies have been set on your device and how to
manage and delete them, visit
Blocking advertising ID use in your mobile settings. Your mobile device
settings may provide functionality to limit use of the advertising ID associated
with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our websites from setting
cookies used for interest-based ads by using a browser with privacy features,
like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock
Origin, and configuring them to block third party cookies/trackers. You can also
opt-out of Google Analytics by downloading and installing the browser plug-in
available at:
Platform opt-outs. The following advertising partners offer opt-out features that
let you opt-out of use of your information for interest-based advertising:
o Google:
o Facebook:
o Twitter:
Advertising industry opt-out tools. You can also use these opt-out options to
limit use of your information for interest-based advertising by participating
o Digital Advertising Alliance for Websites:
o Digital Advertising Alliance for Mobile
o Network Advertising Initiative:
Note that because these opt-out mechanisms are specific to the device or browser on
which they are exercised, you will need to opt-out on every browser and device that
you use.