Who processes your data
Bandera Negra ("the service") is the controller of the data described in this policy. You can write to contacto@banderanegra.app for anything related to your data.
What data we process
- Account: your email address and the provider you sign in with (Google or an email link). We use these to identify you and to send you the sign-in link.
- Photo: the photo you take or upload when creating an emblem. We use it only to generate your emblem; it is never shown to other users or used to identify you. Only our team can see it, and only during the review period you authorise (see "Additional purposes").
- Features read from your photo: what our system reads from the photo to draw your emblem: hair style, beard, eyebrows, expression, face shape, headwear, glasses and bearing. Used only to draw your emblem.
- Answers and results: your questionnaire answers, the features read from your photo, the design brief, the generated emblem, your rating and any comment you leave.
- Technical data: the date and time of each generation, whether the photo came from the camera or from a file, technical logs of each generation (duration of each step, model and instruction versions, token usage), the versions of the legal texts you accepted, and your language and theme preferences.
- Error reports: when something fails on a page or in a generation, a technical report of the failure: the type of error and where in our code it happened, your browser and operating system versions and language, the page it happened on and the pages visited and buttons pressed just before it (without identifiers or parameters) and, for a failed generation, its internal identifier, error code, step durations and token usage. Error reports never include your email address, photo, answers, role or IP address.
- Sign-in security check: when you open the sign-in pages, Cloudflare Turnstile checks that the visit comes from a person and not from an automated program. To do so it processes your IP address and technical characteristics of your browser and device and of how they interact with the page. We receive only the result of the check.
- Usage data, only if you accept analytics: the pages you visit (without identifiers or parameters), the steps you complete (for example, signing in, sending the questionnaire, downloading or rating your emblem, and whether the photo came from the camera or a file), your browser, device type, language and theme, and an approximate location (country or city) that Google derives from your connection. See "Cookies and similar technologies".
We do not ask for payment details, a phone number or a postal address.
Your photo and express consent
The image of your face and the features read from your photo may be considered sensitive personal data. For that reason we ask for your express consent through a specific checkbox before the first generation, and the photo is processed only for the purposes set out in this notice.
You may withdraw that consent at any time by writing to contacto@banderanegra.app or by deleting your account from "My emblems" (/me). Withdrawal does not affect processing already carried out.
What we use it for
Purposes necessary to provide the service:
- generating your emblem and your role;
- creating and maintaining your account and sending you the sign-in link;
- moderating content and blocking generations that show people under 18;
- recording which versions of the legal texts you accepted and handling your requests;
- detecting, diagnosing and fixing errors in the service;
- protecting sign-in against automated programs.
Additional purposes, which are not necessary and which you can refuse without affecting the service:
- keeping the photo of a creation for up to 30 days to review the result and improve the process, if you say yes when we ask. We ask while your emblem is being generated; you can change your answer until the generation ends and, afterwards, delete the photo at any time from the emblem's page;
- sending you news about the service by email, if you tick the "Send me news about the service" box;
- measuring how the service is used (which pages are visited and which steps are completed) in order to improve it, if you choose "Accept analytics" in the cookie notice.
To refuse these purposes, simply answer "No, thanks" (or do not answer) when we ask about the photo, leave the news box unticked or choose "Decline" in the cookie notice; you can withdraw your authorisation at any time from the emblem's page (for the photo), by writing to contacto@banderanegra.app or, for analytics, from "Cookie settings" at the bottom of every page.
How long we keep each item
- Photo of a creation you never submit: if you take the photo but do not complete the questionnaire, the photo is deleted automatically within a few hours.
- Photo, without the improvement consent: deleted immediately when generation ends, whether the emblem is delivered or the generation is blocked or fails. This is also what happens if you do not answer the question or answer "No, thanks".
- Photo, with the improvement consent: kept for a maximum of 30 days, then deleted automatically; you can delete it earlier from the emblem's page. If generation is blocked (no person visible, or the person appears to be a minor), the photo is deleted immediately even if you said yes.
- Emblems, answers, features read from your photo, briefs, ratings and metadata: until you delete them or close your account.
- Internal review notes: kept against an anonymous identifier, with no photo or personal data.
- Error reports: kept by Sentry for 30 days, then deleted automatically.
- Usage data: kept by Google Analytics at event level for 2 months, then deleted automatically; after that only aggregated statistics remain, which identify no one.
Who else processes your data
We work with providers that process data on our behalf and on our instructions:
- Google (Gemini API, paid tier): receives the photo, your questionnaire answers, the features read from your photo and the design brief in order to generate the emblem. On that tier, Google does not use submitted content to train its models.
- Google Cloud and Firebase (Google): hosting for the application, the database, storage of photos and emblems, and the sign-in system (including sending the sign-in link to your email).
- Google Analytics (Google): only if you accept analytics, receives the usage data described above in order to produce usage statistics for us. We have switched off Google signals, advertising features and the sharing of this data with other Google products and services, so it is not used for advertising or combined with a Google account.
- Sentry (Functional Software, Inc.): receives the error reports described above so that we can detect and fix failures. We have set it not to store IP addresses.
- Cloudflare Turnstile (Cloudflare, Inc.): only on the sign-in pages, receives the data of the sign-in security check described above in order to tell people from automated programs.
These providers process your data on servers located in the United States (Cloudflare, on its network of servers in several countries, including the United States), so your data is processed outside Mexico. We do not sell, assign or share your data with third parties for their own purposes.
Usage data and error reports are not linked to your email address or to your account: Google Analytics tells browsers apart only by a random identifier kept in its cookie, and an error report carries at most the internal identifier of a generation, which only we can relate to you. For that reason deleting your account does not remove them from those providers; they are deleted automatically when the periods in "How long we keep each item" run out.
Your ARCO rights
You may access your data, rectify it if it is inaccurate, cancel it when you consider it is not required for the purposes of this notice, and object to its processing on legitimate grounds. You may also limit its use and disclosure.
Many of these actions you can take yourself from "My emblems" (/me): delete each emblem individually, or delete your whole account, which erases your emblems, photos, answers and account data (as long as no generation is in progress).
For anything else, write to contacto@banderanegra.app including:
- your name and a means of sending you our reply;
- a document proving your identity, or legal representation of the person requesting;
- a clear description of the data and of the right you wish to exercise;
- anything that helps us locate the data.
We will reply within a maximum of 20 business days and, if the request is granted, act on it within the following 15 business days.
Minors
The service is for people aged 18 and over and is not directed at minors. If we find that an account belongs to a minor, we close it and delete the associated photo, answers and emblems.
Security
We apply reasonable administrative, technical and physical measures to protect your data against loss and unauthorised use or access. If a security breach occurs that significantly affects your rights, we will tell you without delay.
Cookies and similar technologies
What we keep in your browser:
- Session cookie (
__session): needed to keep you signed in; always used, and it expires after 14 days or when you sign out. The sign-in system (Firebase Authentication) also keeps your signed-in state in your browser's storage. - Google Analytics cookies (
_gaand_ga_<id>), only if you accept analytics: they hold random identifiers of your browser and of your visit so that visits can be counted; they last up to 2 years. - Firebase Installations identifier, only if you accept analytics: a random identifier of this installation that the Google Analytics library keeps in your browser's storage (IndexedDB).
- Sign-in security check: on the sign-in pages, Cloudflare Turnstile runs in a frame served by Cloudflare, which may keep technical data of the check in your browser while it runs. It is needed to sign in and is not used for advertising.
- Local storage: your language and theme preferences, your analytics choice and, while you sign in with an email link, the address you typed. Your language and theme preferences are also kept in your account when you are signed in.
We use no advertising cookies. Error reports use no cookie and no identifier stored in your browser.
Tracking technologies. Google Analytics is a tracking technology within the meaning of the Mexican personal data protection law. When you allow it, it collects the usage data described in "What data we process" — pages visited (without identifiers), the steps you complete, browser, device type, language, theme and approximate location — for the sole purpose of producing statistics on how the service is used so we can improve it. It stays off until you choose "Accept analytics" in the cookie notice shown on your first visit. To turn it off, choose "Decline" in that notice or, at any time, open "Cookie settings" at the bottom of any page and choose "Decline": we then delete the Google Analytics cookies and identifier from your browser. You can also block or delete cookies from your browser's settings. Declining does not affect any feature of the service.
Changes to this notice
Each version of this notice carries a date. If we update it, we will publish the new version on this page and ask you to accept it before you create another emblem.
Authority
If you believe your right to data protection has been infringed, you may turn to the Secretariat of Anti-Corruption and Good Governance, the competent authority in this area.