Introduction
Frame is a photo editing app developed by LittleLoop ("we," "us," or "our"). We are committed to protecting your privacy and being transparent about how our app works. This policy explains what information we collect, what we do not collect, and how we handle your data.
LittleLoop is based in England and Wales, United Kingdom. We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the UK Age Appropriate Design Code (AADC).
What Data We Do NOT Collect
Frame is designed with privacy at its core. We never collect:
- Photos and images. All photo editing and processing happens entirely on your device. Your photos are never uploaded to our servers or any third-party server.
- Personal information. We do not collect your name, email address, phone number, or any other personally identifiable information.
- Location data. We do not access or collect your location.
- Contacts or address book. We do not access your contacts.
- User accounts. Frame does not require you to create an account or sign in.
- Camera or microphone recordings. We do not record audio or video. The camera is used solely to capture photos you choose to edit.
On-Device Processing
Frame uses on-device machine learning (powered by ONNX Runtime) to provide AI-powered photo editing features such as background removal, style transfer, and face enhancement. All ML model inference runs locally on your device. No image data is transmitted off your device for processing.
What Data We Do Collect
We use two third-party services that collect limited data to help us improve Frame and process payments:
1. Analytics — Mixpanel
We use Mixpanel to collect anonymous usage analytics. This helps us understand how people use Frame so we can improve the app. The data collected includes:
- Anonymous event data (e.g., which features are used, screen views)
- Device type and operating system version
- App version
- General session information (e.g., session duration)
This data is not linked to your identity. We do not collect or send any personally identifiable information to Mixpanel.
Analytics data is sent to Mixpanel's EU data centre (api-eu.mixpanel.com). For more information, see the Mixpanel Privacy Policy.
2. Subscriptions — Apple StoreKit
In-app subscriptions are managed entirely through Apple's StoreKit framework. When you make a purchase:
- All payment processing is handled by Apple through the App Store
- Transaction and subscription status is verified on-device using StoreKit 2
- No purchase data is sent to any third-party service
We do not operate our own subscription server. Your payment information is managed solely by Apple. For more information, see the Apple Privacy Policy.
Third-Party Services Summary
| Service | Purpose | Data Collected | Link |
|---|---|---|---|
| Mixpanel | Anonymous analytics | Usage events, device info | Privacy Policy |
| Apple App Store / StoreKit | Payment & subscription processing | Payment and transaction data | Apple Privacy Policy |
Children's Privacy
Frame is designed to be safe for users of all ages, including teenagers under 18.
UK Age Appropriate Design Code (AADC)
We have designed Frame with the following principles in mind:
- Best interests of the child. The app is designed to be safe and age-appropriate.
- Data minimisation. We collect the minimum data necessary. No personal information is collected.
- Privacy by default. All photo processing is on-device. Analytics data is anonymous by default.
- No profiling. We do not profile users or serve targeted content based on behaviour.
- No detrimental use. Collected data is used solely to improve the app experience.
- No nudge techniques. The app does not use design patterns that encourage children to provide unnecessary data.
COPPA (Children's Online Privacy Protection Act)
Although Frame is a UK-based app, we also respect COPPA principles:
- We do not knowingly collect personal information from children under 13.
- No personal data is required to use Frame.
- If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete it promptly.
Parental Guidance
Subscriptions are managed through Apple's App Store, which provides parental controls including Ask to Buy and Screen Time restrictions.
Data Retention
- Analytics data (Mixpanel): Anonymous usage data is retained in accordance with Mixpanel's data retention policies. We periodically review and delete data that is no longer needed.
- Subscription data (Apple StoreKit): Transaction and entitlement data is managed by Apple and retained in accordance with Apple's data retention policies.
- On-device data: Any data stored locally on your device (such as edited photos or app preferences) remains on your device and is deleted when you uninstall the app.
Your Rights Under UK GDPR
Under UK data protection law, you have the right to:
- Access the data we hold about you
- Rectification of inaccurate data
- Erasure of your data ("right to be forgotten")
- Restrict processing of your data
- Data portability — receive your data in a structured format
- Object to processing of your data
Because Frame collects only anonymous analytics data that cannot be linked to you, exercising these rights may not be applicable in most cases. However, if you have any concerns, please contact us using the details below.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.
California Consumer Privacy Act (CCPA) Rights
If you are a California resident, you have the right to know what personal information is collected, request deletion, and opt out of the sale of personal information. Frame does not sell personal information. We do not share personal information for cross-context behavioural advertising.
Legal Basis for Processing
Under UK GDPR, our legal basis for collecting anonymous analytics data is legitimate interest — specifically, our interest in understanding how Frame is used so we can improve the app. We have assessed that this processing does not override users' rights given the anonymous nature of the data collected.
For subscription transaction processing, the legal basis is contractual necessity — processing is necessary to fulfil the subscription you have purchased.
Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will update the "Effective Date" at the top of this page and, where appropriate, notify users through the app.
Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:
LittleLoop
Email: support@frameapp.site
Website: frameapp.site
This Privacy Policy is effective as of April 4, 2026.