TinyTunes Photo Likeness & Biometric Privacy Notice
Last updated: September 16, 2026
At TinyTunes, we take the privacy and security of your family's information seriously. This notice explains how TinyTunes handles photos and related facial information when you choose our Photo Likeness feature.
The Photo Likeness feature allows an adult customer to upload a child's photograph so that TinyTunes can create a personalized animated character that is designed to resemble the child.
Who May Upload a Child's Photo
The Photo Likeness feature is intended for adults. By uploading a child's photograph, you represent that you are the child's parent or legal guardian, or that you otherwise have legal authority to consent to the processing described in this notice.
You should not upload a photograph of a child if you do not have the legal authority to authorize its use and processing.
What We Collect
When you use Photo Likeness, you may provide a photograph of a child. The photograph may contain facial characteristics that are processed to create the personalized character.
To the extent that information derived from the photograph is considered a biometric identifier or biometric information under applicable law, TinyTunes will handle that information in accordance with applicable legal requirements.
A photograph is not automatically treated as biometric information under every law. This notice is intended to address the processing of facial information conservatively where applicable biometric privacy laws may apply.
Why We Use the Photo
Your uploaded photograph and related facial information are used for the limited purpose of creating the personalized character and video you request.
We may use the photo or resulting character information to:
- Create a personalized animated character based on the uploaded photograph
- Generate and display a preview of the personalized character
- Create the personalized video you purchase
- Provide customer support or correct an issue with your order when reasonably necessary
- Maintain security, prevent fraud, investigate misuse, or comply with legal obligations
TinyTunes does not use your child's photograph or facial information for facial recognition, identity verification, advertising profiles, or unrelated commercial purposes.
Your Photo Is Not Used to Train AI Models
TinyTunes does not use customer-uploaded photographs to train its own artificial intelligence models.
Our AI technology providers are instructed and contractually required, where applicable, to process customer content only as necessary to provide the services requested by TinyTunes and our customers.
Our current image-generation provider, xAI, states that it does not train on API inputs or outputs without explicit customer permission.
Third-Party AI Processing
TinyTunes uses third-party technology providers to process photographs and generate personalized images and videos.
When you use Photo Likeness, your photograph may be transmitted securely to our third-party image-generation provider, xAI, through its API so that the requested personalized character can be generated.
TinyTunes' xAI account is configured for Zero Data Retention (ZDR). Under this configuration, xAI does not store API request or response data — including uploaded photographs — beyond the time needed to process and return the result. TinyTunes does not authorize xAI to use submitted customer photographs to train its models.
How Long TinyTunes Keeps Your Photo
TinyTunes is designed to retain uploaded photographs only for as long as reasonably necessary to provide the Photo Likeness feature and fulfill the requested order.
The original uploaded photograph is used only for the brief period required to generate your personalized character. TinyTunes deletes the original uploaded photograph from TinyTunes-controlled systems immediately after that conversion process completes — it is not retained afterward, unless a longer period is reasonably necessary for security, fraud prevention, customer support, legal compliance, or another legitimate operational purpose.
The animated character generated from your photograph is a separate, newly created image rather than the photograph itself. Because that generated character is used throughout your personalized video, TinyTunes retains it — along with the resulting personalized video and related order information — for as long as reasonably necessary to provide, deliver, support, and administer your purchase.
Because TinyTunes' xAI account is configured for Zero Data Retention, xAI does not independently retain uploaded photographs after processing. TinyTunes' own retention period described above governs how long the photograph and generated files exist within TinyTunes' systems.
Biometric Retention & Destruction Policy
TinyTunes maintains a retention and destruction policy for information that may constitute biometric identifiers or biometric information under applicable law.
Where biometric information is processed, TinyTunes intends to retain it only for the period reasonably necessary to fulfill the specific purpose for which it was collected, subject to applicable legal requirements, security needs, customer support, fraud prevention, and other lawful exceptions.
When the applicable purpose has been satisfied and continued retention is no longer reasonably necessary, TinyTunes will take reasonable steps to permanently delete or destroy the applicable information from systems under its control.
Your Consent
Before you upload a photograph using Photo Likeness, TinyTunes will provide notice of the collection and intended use of the photograph and related facial information.
Where applicable law requires a written release or other authorization, TinyTunes will obtain the required electronic consent before processing the photograph, to the extent permitted by applicable law.
TinyTunes may maintain a record of your consent, including the date and time of consent, the version of the notice presented to you, and information reasonably necessary to document the consent.
We Do Not Sell Your Biometric Information
TinyTunes does not sell, lease, trade, or otherwise sell for profit any biometric identifier or biometric information collected through the Photo Likeness feature.
We also do not use biometric information to create advertising profiles or to identify or track individuals across unrelated services.
Security
TinyTunes uses reasonable administrative, technical, and organizational safeguards designed to protect customer information against unauthorized access, disclosure, alteration, or destruction.
Photos are transmitted to our technology providers through secure connections, and access to customer information is limited to systems and personnel who reasonably need access to provide, maintain, or support the TinyTunes service.
Children's Privacy
TinyTunes is designed for adults who create personalized songs and videos for children. Children are not asked to create accounts, submit photographs, or provide personal information directly to TinyTunes.
All Photo Likeness uploads are intended to be submitted by an adult who represents that they are the child's parent, legal guardian, or otherwise have legal authority to authorize the processing described in this notice.
Federal COPPA generally regulates personal information collected online from children, rather than information about children that is provided online by adults. TinyTunes nevertheless takes children's privacy seriously and applies the protections described in this notice to the Photo Likeness feature.
Other Personal Information
Information you provide when creating an order — such as your name, email address, child's first name, song details, messages, and order information — is used to create, deliver, and support your TinyTunes purchase.
TinyTunes does not sell or rent your personal information to third parties.
Requests to Delete or Remove Information
If you have questions about your privacy, want to request deletion of information that TinyTunes still maintains, or have concerns about a photograph or personalized character, please contact us.
Email: keith@tinytunesongs.com
We will review and respond to privacy requests in accordance with applicable law.
Changes to This Notice
TinyTunes may update this notice from time to time to reflect changes to our technology, services, legal requirements, or privacy practices. The date at the top of this page indicates when this notice was most recently updated.
By using the Photo Likeness feature, you acknowledge that you have reviewed this notice and, where required, provided the applicable consent or authorization before uploading a photograph.