Privacy Policy
Last updated: October 30, 2026
This Privacy Policy explains how Fifth Floor Labs, LLC (“we”, “us”, “our”), the company that operates Pablo, collects, uses, and shares information when you use the Pablo iOS app and related websites and APIs (the “Service”). Pablo is a private personal archive — not a social network.
Contact: hello@pablo.pictures. For users in the EU/EEA/UK, this is also the contact for privacy requests.
1. Who this applies to
Pablo is intended for adults 18 and older. We do not knowingly collect personal data from anyone under 18. If you believe a minor has created an account, contact us and we will delete it.
2. Information we collect
Account information. When you sign in with Google or Sign in with Apple, we receive a provider account identifier and, when available, your email address, name, and profile photo URL. If you use Apple’s Hide My Email, we receive a private relay address instead of your personal email. We also store profile information you choose to provide, such as a display name or selected avatar, and session credentials needed to keep you signed in.
Archive content. Photos you upload; AI-generated studio images (including prior renders kept for history); titles, stories, tags, memory dates and their precision, photo capture timestamps, favorites, collection names, chapter names and date ranges; and any correction notes you provide when regenerating a render.
Location and place information. We may collect and use location information you provide, include in content you import, or allow your device to share. This may include place names, addresses, approximate or precise coordinates, and related metadata. We use this information to provide location-based features, organize and display your content, and include saved places in exports. Mapping services such as Apple Maps may process location information and searches to provide these features. Access to your device’s location is subject to your permission and device settings.
Safety and support records. We record content-safety decisions, including flagged categories, confidence scores, reasons, timestamps, the model used, and account-level violation counts. These records are linked to your account and may remain even when a rejected upload is discarded. We also log support-console actions, including the staff account, the account or item accessed, the action and time, and relevant lookup or action details. When you report shared content, we store your account identifier, your required written explanation, the reported item and its source, a snapshot of its title and story, references to its studio images, and submission and review records. These reports are available to authorized staff, not to the person whose content you reported. We do not make extra image copies for reports.
AI permission records. We store your AI-sharing permission, the disclosure version you accepted, and dated acceptance and withdrawal records linked to your account.
Purchase and entitlement data. If you buy a subscription or consumable item pack through the App Store, we (and our billing processor, RevenueCat) process purchase and entitlement information such as your Pablo user id as the App Store / RevenueCat customer id, product identifiers, transaction ids, subscription status, renewal and expiration timing, and credit or quota balances. We also record welcome-item grants given when a new account is created. We do not collect or store payment card numbers, bank details, or Apple ID passwords. Apple processes your payment method under Apple’s terms and privacy policy. For introductory free trials, this information also includes trial status, expiration, and usage.
Promotion and reward information. If you participate in an invite program, promotion, or other reward feature, we process information about your participation. This may include account and referral identifiers, associated codes and offers, eligibility and redemption records, rewards granted or adjusted, related dates, and credit balances. Where a reward involves another account, we may record that relationship to attribute and administer the reward.
Technical information. IP address and basic request metadata used for rate limiting, security, and operating the Service. Our hosting provider may also process standard server logs.
On your device only. Optional Face ID / App Lock, grid and similar preferences, on-device cutouts used in the Chaos archive view, motion/tilt data for that view, and optional story dictation audio processed through Apple’s on-device speech APIs stay on your device (or are handled by Apple under Apple’s privacy terms) and are not uploaded to Pablo as audio or biometric templates. Dictated story text is saved as archive content; if you edit a publicly shared story, that text is checked by our AI providers.
Optional usage analytics. Pablo uses PostHog to understand which features people use, how reliably captures finish, and whether purchases complete. This includes actions, screen names, item and shelf identifiers, counts, outcome codes, app versions, and a random anonymous identifier that is connected to your Pablo account identifier after sign-in. PostHog uses your network IP address to estimate your country, region, and city, then discards the IP address before storing the analytics event. These estimates can be inaccurate, especially with VPNs or mobile networks. Analytics does not request device location access or use GPS. We do not send photos, stories, titles, search text, coordinates, email addresses, share links or tokens, or raw error messages to analytics. We exclude location coordinates and postal codes from geographic enrichment. We disable session recording and automatic interaction capture. We do not collect contacts or advertising identifiers.
Usage analytics is on by default in supported versions. You can turn it off in Settings → Account → Usage analytics without losing app features. Turning it off stops collection and clears queued analytics on that device immediately, even when offline. The setting is saved on this device; choose separately on each device you use. Turning it off does not erase previously sent events; deleting your account also requests deletion of linked analytics data.
3. How we use information
We use personal data to:
- Create and maintain your account and private archive
- Classify items and generate studio-style images with AI
- Provide subscriptions, consumable item packs, welcome items, promotions, rewards, and usage limits
- Administer promotions and invites, assess eligibility, attribute rewards, maintain participation history, and prevent fraud or duplicate claims
- Provide settings, export to Photos, and related features
- Organize memories by dates, chapters, and places you choose
- Check content for safety, prevent abuse, and enforce rate limits
- Improve render quality and operate the Service
- Understand feature use and reliability when usage analytics is enabled
- Resolve support and billing requests and meet legal obligations
4. Photos, AI processing, and cloud storage
We check uploaded photos for content safety. Accepted photos are stored privately with our cloud storage provider and linked to item records held by our database provider. Rejected uploads are discarded rather than stored as photos; we retain a placeholder item and safety records. We use third-party AI service providers to process content on our behalf. Depending on the feature, this may include original photos, generated images and prior renders, titles, stories or notes, correction requests, image descriptions, and existing tag names. We use this processing to:
- Check uploads, correction notes, generated images, and edits to publicly shared titles and stories for safety
- Generate and edit studio-style images
- Describe and classify items, generate titles and shape hints, and suggest tags or image corrections
- Evaluate render quality and guide corrections or retries
We may route different processing steps to different providers or models and change those providers or models over time. The content shared depends on the task: some steps use images and related text, while others use text alone. This processing remains subject to the purposes and choices described in this policy.
We store generated descriptions for tag suggestions and archive search; they do not replace your story. You decide which suggested tags to add.
Generated images are stored in your private archive and linked to your account. A background processing provider coordinates render jobs. AI providers may receive both original and generated images to check safety and quality or produce corrections.
AI providers process content under the service terms, privacy commitments, and data-processing arrangements that apply to our use of their services. Retention and data-use practices may differ by provider and configuration; AI processing does not imply zero retention. For questions about the providers we use or their handling of content, contact hello@pablo.pictures.
You can turn AI processing off in Settings → Account → AI processing. This stops future AI processing calls, including remaining stages of queued processing. It cannot recall content already sent to our AI providers. You can continue viewing and exporting your archive and editing private text. Uploading new photos, regenerating images, and edits requiring AI moderation are unavailable while AI processing is off. We will update this disclosure and provide additional information, notice, or consent requests as required by applicable law or platform rules.
Cutouts used in the Chaos view are created on your device from the studio image and are not generated or stored by our servers.
5. Legal bases (EU/EEA/UK)
Where the GDPR or UK GDPR applies, we process personal data on these bases:
- Contract — to provide the Service you request (account, archive, rendering, subscriptions, and requested reward features)
- Legitimate interests — to secure the Service, prevent fraud or abuse, maintain accurate reward records, resolve disputes, and improve render quality, balanced against your rights
- Legal obligation — when we must retain or disclose data to comply with law
- Consent — for sharing your content with our AI providers for the processing described in section 4, and where required for device permissions you grant in iOS
6. How we share information
We do not sell your personal data. Your archive is private by default — nothing in it is public unless you choose to make it so.
Profile visibility. Your profile is private by default. We share profile information with other users or make it public only when you opt in through a feature or setting that makes it visible. Depending on the feature and your choice, this may include your display name, avatar, or other profile information described to you. This applies to profile sharing through item links, invitations, and other features we may offer. Opting in to profile sharing does not make your entire archive public. Your email address is not included in your public profile. People who can see your profile information may copy or forward it, and withdrawing permission cannot recall copies or previews already saved by others.
People you choose to share with. You can create a share link for a single item. Anyone with that link can view that item — the studio image, its title, its story, and its date — without signing in or having an Pablo account. Profile information may accompany it when you opt in as described above. We do not attach your email address or the item’s saved place or chapter. However, the image, title, story, or date you share may itself contain personal information about you or others. The link covers only that item, and the shared page reflects updates to it.
Anyone with the link can forward it, save content, or take screenshots. Messaging and other services may create and retain link previews. You can stop sharing at any time; archiving an item or deleting your account also removes its link. Removing a link stops access through Pablo but cannot recall copies or previews already saved by others. To report inappropriate shared content in the app, choose “Report content” from the item’s More menu. You can also email hello@pablo.pictures with the link.
Invite and reward participation. We use information about participating accounts to attribute and administer rewards. People whose invitations you redeem may receive reward confirmations or aggregate participation and reward totals. These can reveal that an invitation was used, particularly when only one person was invited. We do not provide them with your email address or a list of redeeming accounts through the current invite feature.
We use service providers (“processors”) only as needed to run Pablo:
- AI providers — processing as described in section 4
- Google — sign-in (OAuth)
- Apple — Sign in with Apple; App Store billing for purchases and subscriptions; Apple Maps place search and maps
- RevenueCat — purchase and entitlement processing (not payment card storage)
- Cloud storage providers — private storage of your images (accessed via time-limited URLs)
- Database providers — hosting account and archive records
- Application hosting providers — running the Service
- Background processing providers — coordinating render jobs
We may also disclose information if required by law, to protect rights and safety, or in connection with a merger, acquisition, or sale of assets (with notice where required).
7. Staff access for support, safety, and quality
Authorized Fifth Floor Labs, LLC personnel may access relevant account, purchase, activity, and archive information, including originals, renders, and item details, as needed to resolve support requests, reconcile billing, administer promotions and rewards, investigate abuse, and evaluate and improve render quality. Support actions may include adjusting item credits, synchronizing purchase status, or revoking a share link. Personnel do not publish your items. Access is restricted to accounts marked as admin, and support-console actions are logged for accountability and security.
8. International transfers
We and our providers may process data in the United States and other countries. Where we transfer personal data from the EU/EEA/UK to countries without an adequacy decision, we rely on appropriate safeguards used by our providers (such as Standard Contractual Clauses), where applicable.
9. Retention and deletion
We keep your account and archive data while your account is active. Content reports remain available for staff review when an item is unshared or removed. Deleting an account also removes reports submitted by that account and reports linked to that account as the source owner.
Archiving an item in the app hides it from your main archive and is not the same as deleting your account or permanently erasing that item’s data from our systems.
Deleting your account immediately and permanently removes your item records and the images we store for you (both the originals you captured and the studio renders), your collections, tags, titles, and descriptions, along with your email address, name, and profile photo, and unlinks your Google and Apple sign-ins. None of it is recoverable afterwards, by you or by us. Delete from the Delete account control in Settings, or by emailing hello@pablo.pictures. We retain limited information where we must for legal, security, tax, fraud-prevention, or dispute-resolution purposes. This may include billing and reward records, account or referral identifiers, redemption and adjustment history, and related audit records needed to reconcile transactions, prevent abuse, or resolve disputes. These records may remain linked to a deleted account and are not necessarily anonymous. We retain them only for as long as needed for those purposes or required by law, taking into account outstanding transactions, applicable recordkeeping requirements, fraud risks, and relevant dispute periods. Backups may take a short additional period, up to 30 days, to fully clear.
Deleting your Pablo account does not cancel an App Store subscription. Manage or cancel billing in your Apple ID subscription settings; Apple may retain purchase records under Apple’s policies.
10. Your choices and rights
You can:
- Sign out in the app at any time
- Allow or withdraw permission in Settings → Account → AI processing
- Archive or restore items in the app
- Export studio images to your Photos library from Settings
- Export a full archive of your original and studio images together with a spreadsheet of their titles, descriptions, dates, and tags, offered as the first step of account deletion
- Delete your account in Settings, or request access, correction, or deletion by emailing hello@pablo.pictures
- Manage App Store subscriptions and purchases in your Apple ID settings
If you are in the EU/EEA/UK, you also have the right to request data portability, restrict or object to certain processing, and lodge a complaint with your local supervisory authority. You may withdraw consent where processing is based on consent, without affecting prior lawful processing.
Optional Face ID / App Lock uses Apple’s biometrics on your device only. We never receive Face ID or fingerprint data.
11. Security
We use reasonable technical and organizational measures to protect personal data, including private object storage and authenticated API access. No method of transmission or storage is completely secure.
12. Children
The Service is not directed to children. You must be 18 or older to use Pablo. See also our Terms of Service.
13. Changes
We may update this Privacy Policy from time to time. We will post the revised policy on this page and update the “Last updated” date. If changes are material, we will take additional steps as required by law.
14. Contact
Fifth Floor Labs, LLC (operator of Pablo) — hello@pablo.pictures