Daniel Davis

By Daniel Davis

An associate at Dunlap Bennett & Ludwig, with a focus on intellectual property law.

[07.24.19 Leesburg]  More than 150 million people have downloaded the viral photo editor FaceApp, and many have been entertained (and possibly traumatized) by the app’s ability to digitally ‘age’ photos of their faces. But what else is FaceApp doing with these photos? The answer is not clear, but the FaceApp Terms of Use (https://faceapp.com/terms) say users grant FaceApp the right to “… use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, publicly perform and display …” any content they create using FaceApp.

Many users are uncomfortable with this use (or potential use) of their photos. If you used FaceApp in the European Union, you have a legal right to request deletion of your personal information from FaceApp servers. While the law that created this right, the General Data Protection Regulation (GDPR), does not apply in the United States, FaceApp has indicated in public statements (see, e.g., https://techcrunch.com/2019/07/17/faceapp-responds-to-privacy-concerns/) that FaceApp will accept deletion requests from all users if they take the following steps:

  1. Open FaceApp and tap on the “Settings” icon.

  1. In the “Settings” menu, tap the option to “Report bug and send logs.”



  1. Write a brief request that all personal information you have submitted to FaceApp, including photos, be deleted, and be sure to include the word “privacy” in your request. When you are finished, tap the “Report” button to submit your request to FaceApp via email.



NOTE: If you follow this approach, you will give FaceApp your email address and possibly information about your mobile device, such as the device’s hardware ID, which may be included in the email generated by FaceApp.

 If you want to speak to an attorney to make sure your website or app is compliant with your jurisdiction’s privacy laws, Dunlap Bennett & Ludwig would be happy to assist you.

Posted in: Cyber Law, Internet