Is my chat sent to the United States? The policy answer
The analysis provider operates in the United States and the policy says so in two separate places. What crosses the border is the masked text, not the conversation as you wrote it.
Yes, in masked form. Portraitor’s privacy policy says the artificial intelligence provider operates in the United States, that data may be processed there, and that such transfers are protected by appropriate safeguards including Standard Contractual Clauses. What is sent is the text after names, email addresses and telephone numbers have been replaced on your own device.
For a reader in the United Kingdom or the European Union this is usually the second question, straight after what is kept.
The policy answers it in section 5 and again in section 11, and the two answers have to be read together to get the real shape of it.
The analysis provider is in the United States
The register of third parties in section 5 lists the artificial intelligence provider with a location printed next to it: United States. Section 11 then says plainly that your data may be processed outside your country, including in the United States, where the artificial intelligence provider, Stripe and Apple operate.
There is no hedging in either place and no attempt to describe the provider as global. The policy also describes the provider by category rather than by name, with its privacy policy and service terms linked from the register, a change the version history records as having been made in version 1.1.
What crosses the border is not the conversation you wrote
This is the distinction the question usually misses. By the time anything is transmitted, the policy says your browser has removed names, email addresses, telephone numbers, postal addresses and credentials and replaced them with anonymous placeholders, entirely on your own device.
So the material that reaches the United States is the masked text. The policy is equally clear about the limit of that, in the very next paragraph: masking removes who is speaking, and it does not remove what was discussed. Subject matter travels. Identity does not.
It also says a long conversation is analysed in sections, each sent separately in anonymised form, with the results combined into one portrait, so what crosses is a series of anonymised fragments rather than one file. What masking removes and what it does not goes through that boundary in detail.
The safeguard is named, and naming it is the whole claim
Section 11 says the transfers are protected by appropriate safeguards, including Standard Contractual Clauses. That is a specific instrument rather than a general reassurance, and naming it is what makes the sentence worth anything.
Section 10 then adds the limits that apply to the provider itself, which matter more in practice than the geography does. Under the terms of its paid tier, it does not use your conversation to train or improve its models and does not review it for that purpose. It does retain submitted content for a limited period to monitor misuse of its own service, and Portraitor says it is unable to disable that retention.
That last clause is the honest one. A reader who wants nothing of their conversation to sit anywhere for any period should know it exists before buying, not after. The training question in full covers what that retention is for.
Stripe and Apple appear in the same paragraph
Section 11 names three companies, not one. Stripe and Apple also operate in the United States, and they receive different material: Stripe receives your email address, card details and billing country, and Apple receives your payment and Apple Account details when you buy inside the iPhone app.
So a reader concerned specifically about transfers has two separate flows to think about. The conversation flow carries masked text and no identifiers. The payment flow carries your identifiers and no conversation. The policy keeps them apart throughout, and says Stripe holds the only copy of your email address.
What a reader in the UK or the EU is actually deciding
Not whether the data leaves, because it does. The decision is whether masked text plus Standard Contractual Clauses plus a named and limited retention is an acceptable shape, set against a tool that keeps the whole thing nearer to home but tells you less about it.
The policy makes that comparison possible by being specific, and it does not make the choice for you. The rights section is worth reading alongside it: the policy says the UK and EU rights it describes are offered to every user wherever they live, with the same procedure and the same thirty day response period.
One competitor comparison built on where the processing happens works the same question from the other side, and the language question is the other thing readers outside the United Kingdom usually ask next. The Portraitor home page states the masking claim before you upload anything.
Frequently asked questions
Frequently asked questions
Does my conversation leave the UK or the EU?
The masked version does. The policy says data may be processed outside your country, including in the United States where the artificial intelligence provider, Stripe and Apple operate, and that the transfers are protected by appropriate safeguards including Standard Contractual Clauses.
Is it my conversation or an anonymised version that is sent?
An anonymised version. Names, email addresses, telephone numbers, postal addresses and credentials are replaced on your own device before anything is transmitted. The policy adds that this removes who is speaking and not what was discussed.
Does the provider keep what it receives?
For a limited period, yes. The policy says the provider retains submitted content to monitor misuse of its own service and that Portraitor is unable to disable that retention. It also says the provider does not use the conversation to train or improve its models.
Do I have the same rights if I do not live in the UK or the EU?
The policy says it makes those rights available to every user of the Service wherever they live, applying the same procedure and the same thirty day response period to everyone.
The answer is yes, in masked form, under a named safeguard, with one retention the company says it cannot switch off. All four of those parts matter.
Masked text, named safeguard
Portraitor publishes where the analysis happens, what is sent, which safeguard applies, and the one retention it says it cannot disable.
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