FaceApp is a smartphone photo-editing application that enables users to modify their images, which are either created using the app or uploaded to the app from users’ phones (by giving FaceApp permission to access users’ cameras).

The app uses artificial intelligence to modify users’ images, such as altering the “age” of users, adding facial hair to images, and/or enhancing images. These transformed images can be shared on social media platforms or stored on users’ personal devices for private use.

FaceApp was made popular by social media challenges involving its most popular filters and celebrities use of the app. FaceApp has faced significant public backlash for some of these filters. First, FaceApp’s “hot” filter, when applied to users’ images, lightened their skin color. Following criticism, the founder of FaceApp and CEO of Wireless Lab (the Russia-based company responsible for FaceApp), Yaroslav Goncharov, apologized for the filter, claiming that the output of the filter was “an unfortunate side-effect of the underlying neural network caused by the training set bias.” Shortly after the “hot” filter was renamed as “spark,” the filter was removed from FaceApp. Second, FaceApp released “ethnicity” filters (“Asian,” “Black,” “Caucasian,” and “Indian”), whereby users’ facial features and hair were changed based on their filter selection. These filters were widely criticized for being racist and offensive, leading FaceApp to remove these features from its app. FaceApp is not the only app that has launched racist and offensive filters. Snapchat has also been on the receiving end of backlash for its “Bob Marley” filter, which darkened users’ skin and placed a knit cap and dreadlocks on the heads of users’ images, and its “anime-inspired” filter that created racist and offensive caricatures of Asians.

FaceApp has been criticized worldwide not only for its racist and offensive filters, but also for its lack of transparency in its data processing practices, which include “any operation or set of operations…performed on personal data or on sets of personal data, whether or not by automated means, such as [the] collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction” of data. Particularly, the breadth of FaceApp’s privacy policy and terms of use agreement in regards to data processing were criticized. Even though FaceApp’s privacy policy and terms of use agreement are similar to those of U.S.-based technology, app, and social media companies, users’ privacy and data protection concerns are warranted. This article critically examines FaceApp’s original and updated terms of use agreement and privacy policy, looking in particular at their data processing practices. The article concludes by providing policy recommendations for apps, like FaceApp, which operate with minimal transparency, opaque terms of service agreements, and vague privacy policies.

Maras, M.-H., & Logie, K. (2021). Understanding What it Really Takes to Control Your Data: A Critical Evaluation of FaceApp. Journal of Internet Law, 24(8), 1 and 11–18. https://www.researchgate.net/publication/354552230_Understanding_What_it_Really_Takes_to_Control_Your_Data_A_Critical_Evaluation_of_FaceApp