Privacy statement

1. Who we are

We are Coulbe, Nassau Odijkstraat 11, 4451 AT Heinkenszand, the Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number 69383286. We run Coulbe (coulbe.com and coulbe.nl) and are the controller for the personal data described in this statement.

Questions about your data or your rights? Email support@coulbe.com.

2. In short

• We use your photos only to make your AI version and your new photos, to check them against our rules and to show them to you. We never publish them and never use them for advertising.
• Our database and photo storage are in the EU. Some partners process data outside the EU, including our AI image partner, which makes the photos, and an AI service that describes inspiration images.
• You can delete single photos, shoots, your photos of yourself, an AI version or your whole account yourself.
• We only use cookies that are needed to log in. No analytics, no advertising, no tracking.
• Coulbe is only for adults (18+) and only for photos of yourself.

3. What we collect

Depending on what you do on Coulbe, we use:

• Account: your email address and, for password login, a securely hashed password. If you choose Google login, Google also gives us your name and a link to your profile picture.
• Photos of yourself: the 20 to 80 photos you upload to create an AI version. Before uploading, your browser saves each photo again as a JPEG without hidden data, such as the place where it was taken.
• “About you”: features that help make photos look like you: gender, age group, hair colour, length, texture, parting and fringe, skin tone, build, and whether you have glasses, a nose piercing, visible tattoos, a beard or freckles. We suggest them from your photos and you can change them. Your height is only stored if you enter it. The “About you” form does not separately record eye shape or facial measurements, and we do not ask you to specify ethnic origin. Your photos and personal AI version do contain information about your face and appearance.
• Your AI version: its name, its status and a reference to it at our AI image partner, which keeps the AI version itself.
• Inspiration images: a photo you bring as a style example, chosen on your device, shared from another app or fetched from a link you paste, and the written description we make of it. We don’t store the link.
• Your shoots and new photos: the look or inspiration image, AI version, style, format and number of photos you chose, the text we use to make the photos, the photos themselves, your favourites and the delivery status. Records from the quality check that was discontinued on 26 September 2026 may remain in your shoot history; new results are no longer checked this way.
• Payments: which plan or pack you bought, amounts, dates, invoice references, your credit balance and its history, and that you agreed at checkout to our terms and asked us to start right away, with the time. For invoices and VAT, Stripe asks for your name and billing address. We never receive your full card or bank details.
• Login and security: when you log in, we store your IP address and browser type with your session. To prevent abuse, we count attempts per IP address (for fetching links: a hashed, pseudonymised version of it), per email address and per account.
• Emails: the messages we send you and anything you write to us.
• Photo edits: the selected Coulbe photo, your instruction, selected area and any clothing/example image, plus the result, status and credit transaction. Do not put unnecessary personal information in your instruction.

Your email address is needed to create and secure your account. Photos of yourself are needed to create a personal AI version; without them we cannot provide that feature. Google login and entering your height are optional. Required billing information is shown at checkout. We do not routinely ask for your date of birth, phone number or identity document.

4. What happens to your photos

• Photos of yourself. Every photo you add is checked automatically (see “Automatic checks”). Approved photos go into our storage in the EU. When you create your AI version, we pick the best 20 and our server in Germany sends them to our AI image partner, which uses them to create your AI version. The partner receives them with a neutral code, never with your name or email address. Our server deletes its copies as soon as it has handed them over.
• Inspiration images. An image you bring is checked automatically first. If it doesn’t pass, we don’t store it. If it passes, we store it in the EU and an AI service that describes images turns it into a written description of the scene: setting, outfit, pose, light and style. The description leaves out who the person in the image is. Your inspiration image itself is never sent to our AI image partner.
• Making photos. For each shoot we combine the description of the look or your inspiration image with your “About you” features and the style you chose. We send that text, with a reference to your AI version, to our AI image partner. The partner makes the photos and sends them back through our server into our storage in the EU.
• Delivery. Successfully generated photos are delivered without retouching or an automatic quality check. We do not send these results to a separate AI service for quality assessment.
• Your gallery. Only you can see your photos, when you are logged in. Cloudflare Images makes the small versions for your gallery.
• Optional editing. Only when you request an edit, we send the selected photo, written instruction, area indication and any example image to Google. The result returns through our server to our EU storage and is checked against our content rules. The editor does not receive your training set or personal AI version; the original photo stays intact.

5. Why we use your data, and on what legal basis

The GDPR requires a legal basis for every use of your data. These are ours:

• Providing Coulbe to you (your account, logging in, your photos of yourself, “About you”, your AI version, shoots, optional photo edits, gallery and downloads, service emails and support): necessary to perform our agreement with you (Article 6(1)(b) GDPR).
• Payments, invoices and bookkeeping: necessary for our agreement with you, and required by tax law (Article 6(1)(b) and (c) GDPR).
• Security, preventing abuse and keeping to our content rules (login limits, automatic checks for nudity and minors, handling refunds and disputes): our legitimate interest in a safe, lawful and affordable service (Article 6(1)(f) GDPR).

Before training, we ask for your explicit permission to process your photos and facial features to create your personal AI version. We record your choice, the time and the information shown. You can withdraw this permission for future training on your account page or by emailing support@coulbe.com; withdrawal does not affect the lawfulness of earlier processing. Withdrawal cancels pending training jobs in Coulbe. Unsubmitted training credit is returned; an uncertain provider outcome keeps its reservation pending review. A cancelled job is never automatically resubmitted, and a late result cannot reactivate it. An operation already sent to the image partner may still complete; we request deletion when its reference becomes available. Withdrawal does not itself delete an already completed AI version or stop its use for new photos. To stop that use, delete the AI version or contact us; the deletion limitations below still apply.

We create your personal AI version to generate images resembling you. We do not use it to log you in or verify your identity. Coulbe does not use your photos to train a general model for other customers, or for advertising. The setting that excludes our current API workspace from general model training, and its limits for earlier processing, are explained below. Public use of your photos by Coulbe requires separate, explicit permission, which you can withdraw by emailing support@coulbe.com.

6. People shown in inspiration images

A customer’s inspiration image may show another person. We receive the image from the customer or the link they submit, check it and send it to the image-description service to describe its setting, clothing, pose, light and style. Removing identity from the resulting description does not make the original image anonymous. We do not create an AI version of the person shown in an inspiration image.

If an image of you is used, contact support@coulbe.com to request information, object or ask for erasure. Give enough information to locate it without sending unnecessary sensitive data. We assess your rights separately from the uploading customer’s agreement; their acceptance of our terms is not your consent.

7. Who helps us

These companies and services process data for us. Each only receives what it needs for its task.

• Cloudflare (USA): hosts the website, our database and our photo storage (both bound to the EU), makes small versions of photos (Cloudflare Images) and runs our automatic checks with its AI service.
• Hetzner (Germany): runs our server in Nuremberg that passes jobs to our AI image partner. It only keeps your photos while it works on a job.
• Our AI image partner (United States): creates your AI version from your best 20 photos and keeps it, and makes your new photos from our text description. It receives no name or email address, and never your inspiration image.
• An AI service that describes images (United States): writes the description of your inspiration images. It never receives the photos of yourself that you upload. Before the quality check was discontinued on 26 September 2026, it could also receive a generated result when the first check gave no answer.
• Stripe (Ireland, part of a US group): handles payments, subscriptions, invoices and VAT. For some purposes, such as preventing fraud and meeting financial rules, Stripe is itself responsible for the data it processes.
• Resend (USA): sends our emails.
• Google: if you choose Google login, or explicitly edit a photo. For editing, Google receives the selected photo, your written instruction and any clothing/example image you add. It does not receive your training set, name or email from the editor.

Our AI image partner processes your data under its own terms and privacy policy. We have enabled the setting that excludes inputs and outputs in our current API workspace from training the partner’s general models. This is separate from creating your own personal AI version, which still requires training with your photos. We have not established when the exclusion first took effect or that it applies retroactively. Earlier AI versions may still use the previous processing route; we do not promise the same exclusion for those earlier versions or previously processed content. It may also keep deleted content for some time (see “Deleting your data”).

For the paid Google editing service, Google’s terms exclude our editing inputs and outputs from product and model improvement and include a data processing addendum. Separate security and abuse-monitoring retention still applies, including possible human review and use for models solely enforcing safety policies. This concerns editing and does not change the terms for Google login.

On request we tell you the names of all companies that receive your data: email support@coulbe.com.

8. Where your data is kept

Our database and our photo storage are at Cloudflare and bound to the EU: the data is stored and processed there within the EU. Our job server is in Germany.

Not everything stays in the EU. Cloudflare’s network, Cloudflare Images and its AI service can process data outside the EU. Our AI image partner, the AI service that describes images and Resend are US companies and process data in the United States. Stripe and, if you use Google login or photo editing, Google can also process data outside the EU, including in the United States.

For transfers outside the EU, Cloudflare, the AI service that describes images, Stripe and Resend rely on the EU-US Data Privacy Framework or on the European Commission’s standard contractual clauses in their data processing terms. Our AI image partner processes your data under its own terms and privacy policy; we have not established Data Privacy Framework coverage or standard contractual clauses for this processing. The API terms incorporate a data processing addendum where the partner processes content on our behalf; the applicable transfer annexes for our processing have not yet been established. Google’s processing terms for the paid editing service provide for transfer safeguards, including standard contractual clauses where required. You can request information and a copy of the applicable safeguards from support@coulbe.com.

9. How long we keep your data

• Account: as long as your account exists.
• Photos of yourself and “About you”: until you delete them, the AI version they belong to, or your account.
• Your AI version: until you delete it or your account. For our AI image partner, see “Deleting your data”.
• New inspiration images are saved privately in your account so you can reuse them. You can delete them in the studio; they are also deleted with your account. Deleting a shoot or AI version does not delete a saved inspiration image. Earlier one-use uploads keep their original retention: deleted after the shoot, or after 7 days if unused. An image that does not pass our check is never stored.
• An image you pick before logging in stays only in your browser, for at most 24 hours (an image shared from another app: at most 1 hour).
• Shoots and new photos: until you delete the photo or shoot, or your account. The text we used to make a shoot is deleted with the shoot. The written description of an inspiration image is deleted together with the image.
• Sessions: a session expires 7 days after you last used Coulbe, or when you log out. We delete an expired session, with the IP address and browser type stored with it, 30 days after it expired. All your sessions are deleted with your account.
• Security counters: they only hold a (partial or pseudonymised) IP address, an email address or an account code, a time and a number. We delete a counter 30 days after it was last used. The counter for your email address is also deleted with your account.
• Payments and bookkeeping: the tax records we must retain are normally kept for seven years. Records covered by the Union OSS scheme must be kept for ten years after the end of the transaction year. Account deletion does not remove legally required fiscal records. We pseudonymise our account records; invoices and payment references retained for tax purposes may still identify you.
• Emails: Resend keeps a log of sent emails for a limited time under its own policy. We keep your messages to us as long as we need them to help you.
• Backups: our database keeps automatic restore points for up to 30 days. Deleted data can remain in them until they expire.
• Photo edits: we erase the instruction, selected area and example image from our active storage after definitive completion, failure or cancellation. They remain while an outcome is unresolved. Edited results remain until their original photo, shoot or account is deleted. Limited status and credit records remain for settlement and bookkeeping. Google separately retains editing inputs and outputs for abuse monitoring for 55 days under its published policy; this is not immediate erasure at Google when you delete a photo in Coulbe.

10. Deleting your data

In your gallery, on your AI version and on your account page you can delete:

• a single photo or a whole shoot: it disappears from your gallery, downloads and favourites, including the small versions. Associated edits are deleted too. Deleting does not return spent credits.
• the photos of yourself you uploaded for an AI version: the AI version keeps working, but creating it again needs new photos.
• an AI version: it can no longer be used to make photos. Its uploaded photos and “About you” data are deleted with it. Its free welcome photo is also removed; other photos you already made remain until you delete them.
• your whole account: we block new jobs, cancel jobs where possible, remove late results, end your subscription immediately and log you out everywhere. We erase your AI versions, photos, shoots, inspiration images and descriptions from our storage. After the confirmation email, we remove the email address used for that deletion notification. Limited fiscal and pending refund records are handled as explained below. Logging in again later creates a new, empty account.

We ask you to confirm deletion. Failed steps are retried in the background. While you still have access to your account, it shows available deletion status. After account deletion, contact support@coulbe.com for the status of any outstanding steps.

At our AI image partner: deleting an AI version or account creates an erasure task. For AI versions created through the current API, we send the deletion through that API; earlier versions on the previous route require manual handling. The status becomes “erased at our image partner” only after confirmation for that AI version. This is not confirmation that every source upload, generated photo, request record or backup has also been erased. The partner’s API terms retain request parameters and output metadata while our provider account is active and make generated media available for at least 7 days, after which they may delete it; 7 days is not a maximum retention period. Its privacy policy allows deleted content on active systems for up to 30 days and longer in backups. Contact support@coulbe.com for the scope and progress of a full erasure request; deleting our shared provider account is not an individual customer erasure process.

What we keep: legally required purchase, invoice and balance records as described under “How long we keep your data”. An email address needed to finish a pending withdrawal or refund is retained for that process and then removed from its notification record. Stripe retains its own payment records under its legal obligations.

11. Automatic checks

We check images automatically with Cloudflare’s AI service, so that Coulbe stays within the law and our rules. The initial check is automated; a support review is separate.

• Photos of yourself: exactly one person, the face clearly visible, looks 18 or older, no nudity, and a real photo. The same check suggests your “About you” features and helps pick your best 20 (angle, framing, sharpness). Near-duplicates are skipped.
• Inspiration images: no nudity, nobody who might be under 18, and a real photo.
• Gender: if it doesn’t follow from your photos and you haven’t chosen it, the AI service decides between woman and man from up to 3 of your photos. You can change it under “About you”.

A rejected image is deleted or never stored and costs nothing. The checks estimate whether an image meets our rules, including whether someone appears to be an adult, and can be wrong. A rejection can prevent you from using the service. You can explain your situation and challenge the result by emailing support@coulbe.com; a person will review your complaint and explain the available solution, including any statutory refund right. Do not email an identity document unless we have explained why proportionate evidence is needed.

12. Cookies and storage on your device

We only use cookies that are needed to log in and stay logged in. Coulbe sets them itself. We don’t use analytics, advertising or tracking cookies, and no scripts from other companies, so there is no cookie banner. Your language comes from the web address, not from a cookie.

When you pay, you go to Stripe’s checkout page. Stripe uses its own cookies there, for example to prevent fraud.

Coulbe also uses your browser’s storage for one thing: keeping an image you picked or shared until you log in, for at most 24 hours. If you install Coulbe as an app on Android, a small script in your browser (a service worker) receives the images you share with Coulbe; it stores nothing else.

13. How we protect your data

Your photos are private. You can only reach them when you are logged in to your own account, never through a public link, and accounts are strictly separated from each other.

You can log in with your email and password or with Google. Passwords are stored as secure hashes, never as readable passwords. Email verification and password recovery use time-limited links; a password reset signs you out on all devices. An optional one-use login link expires after 10 minutes. Connections are encrypted (HTTPS). Our emails never contain your photos.

If a data breach puts your rights at risk, we report it to the Dutch Data Protection Authority and tell you, as the law requires.

14. Your rights

You have the right to:

• see which data we have about you, and get a copy;
• have incorrect data corrected;
• have your data deleted;
• limit how we use your data;
• object to uses based on our legitimate interest;
• receive the data you gave us in a common format.

You can download your photos yourself in your gallery, one by one or all at once as a zip file, and delete data yourself (see “Deleting your data”). For anything else, email support@coulbe.com. We may ask you to confirm your request from the email address of your account. We answer within one month.

15. Adults only

Coulbe is only for people aged 18 or older. We don’t knowingly collect data of anyone younger. Photos that seem to show someone under 18 are rejected automatically. If we learn that an account belongs to someone under 18, we close the account and delete its data.

16. Changes to this statement

When we change this statement, we update the date at the top. If a change affects how we use your data, we email you before it takes effect.

17. Contact and complaints

Questions, requests or complaints: support@coulbe.com. Post: Coulbe, Nassau Odijkstraat 11, 4451 AT Heinkenszand, the Netherlands.

You can also complain to a data protection authority: in the Netherlands the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), in Belgium the Gegevensbeschermingsautoriteit (gegevensbeschermingsautoriteit.be), or the authority in the country where you live.