Last updated: October 1, 2024
Welcome to HalluApps (“we,” “us,” or “our”). This Privacy Policy is intended to inform you of how we collect, use, share, and safeguard your personal information when you access or use our application, website, and related services (collectively referred to as “Services”). We are committed to protecting your privacy and handling your personal information with transparency and integrity. By using our Services, you consent to the practices described in this Privacy Policy. If you do not agree with the terms of this policy, please do not use our Services.
This Privacy Policy applies to all users of our Services globally, including users of our mobile applications, official websites, and any other services we may provide. It outlines how we handle personal information across all platforms and devices. This Privacy Policy supplements other notices and is not intended to override them unless explicitly stated. Please read this Privacy Policy in conjunction with any other privacy or fair processing notices we may provide on specific occasions when we are collecting or processing personal information about you, so you are fully aware of how and why we are using your data.
We may update this Privacy Policy from time to time at our sole discretion. Any changes will be posted on this page, with an updated ""Last updated"" date. If we make significant changes to this policy, we will notify you through a notification on our website or application. Your continued use of the Services after the posting of changes constitutes your acceptance of such changes. It is your responsibility to review this Privacy Policy periodically for updates."
PersonAR Solutions Kft. acts as both the data controller and data processor with respect to the personal information collected through our Services. This means we determine the purposes and methods for processing personal data. You can reach out to us with questions about this Privacy Policy, our data handling practices, or to exercise your rights regarding your personal information at contact@halluapps.com.
Users may upload images to generate avatars or other digital renderings. These images are used exclusively for the generation process and are automatically deleted from our servers immediately after the rendered images are downloaded to the user's device or automatically after 30 days.. We do not retain or reuse these images for any other purpose.
The images are analyzed for facial features to create personalized avatars, but no biometric data is extracted or stored.
We use the personal information collected from you to:
Provide and Improve Services: To render avatars and other digital products based on user-uploaded images, enhance user experience, troubleshoot technical issues, and optimize the performance of our Services.
Manage Transactions: To process in-app purchases, manage user credits, and maintain transaction records in collaboration with third-party payment processors.
Communicate with Users: To respond to inquiries, provide customer support, notify users about updates, changes to our terms or policies, or important security notices.
Legal and Regulatory Compliance: To comply with applicable laws, regulations, and legal processes, and to respond to governmental or regulatory requests.
Analytics and Research: To understand usage patterns, improve our Services, and develop new features or services. This involves analyzing anonymized data for research and statistical purposes.
Our legal basis for collecting and using your personal information as described in this Privacy Policy depends on the personal information concerned and the specific context in which we collect it:
Performance of a Contract: We process personal information to provide Services that you have requested, such as rendering avatars.
Legitimate Interests: We process personal information to improve our Services, secure our systems, and communicate effectively with users. We do this in a manner that does not override your privacy rights.
Compliance with Legal Obligations: We process personal information where necessary to comply with applicable laws, regulations, or legal processes.
Consent: Where we have obtained your consent to process your personal information for specific purposes, you have the right to withdraw consent at any time.
We may share your personal information with third parties under the following circumstances:
Service Providers: We may share data with third-party service providers who assist us in operating our Services, including cloud storage, analytics services, and payment processing. These service providers are contractually obligated to protect your information and use it only for the purpose of providing the services on our behalf.
Compliance with Laws and Legal Requests: We may disclose your personal information to law enforcement, regulatory authorities, or other government officials as required by law or if we believe disclosure is necessary to protect our rights or comply with a legal process.
Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of our assets, personal information may be transferred as part of that business transaction.
Advertising Partners: Although we do not directly share your personal information for advertising purposes, third-party advertising networks and partners may collect information about you when you interact with our ads on their platforms. These parties may use cookies and other technologies to gather information about your activities to deliver targeted advertising based on your interests.
All personal information collected through our Services is securely stored using cloud-based storage services provided by Google Cloud. We ensure that these storage providers implement adequate security measures to protect your data. Data may be transferred to and processed in locations outside of your country of residence, including the United States, where our service providers operate. We adhere to legal requirements for such data transfers and take measures to safeguard your personal information.
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, or as required by applicable laws. User-uploaded images are deleted either immediately after the rendered images are downloaded to the user's device or automatically after 30 days. Transactional records and anonymized data may be retained for longer periods for legal, tax, or analytical purposes.
We employ a variety of physical, technical, and administrative measures to protect your personal information from unauthorized access, use, alteration, or disclosure. These include encryption, access controls, network security measures, and regular security audits. Despite our efforts, no security measure is completely impenetrable, and we cannot guarantee the security of your data. In the event of a data breach, we will take appropriate measures to mitigate the breach and notify affected users as required by law.
As a user, you have the following rights concerning your personal information:
Right to Erasure: You may request the deletion of your personal information, subject to certain legal obligations or rights to retain data.
Right to Restriction of Processing: You have the right to request that we restrict the processing of your data under specific circumstances.
Right to Data Portability: You can request a copy of your personal information in a structured, machine-readable format.
Right to Object: You may object to the processing of your personal data, particularly for direct marketing or profiling purposes.
Right to Withdraw Consent: If we process your personal information based on your consent, you can withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal information infringes data protection laws.
To exercise these rights, please contact us at support@halluapps.com. We may need to verify your identity before fulfilling your request.
Our application and website use cookies and similar technologies to improve user experience, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device by our website. You can control cookie settings through your browser preferences. Disabling cookies may affect your ability to use certain features of our Services.
We do not control third-party cookies and tracking technologies used by advertising partners. These third-party services may collect information about your online activities over time and across different websites. Please review the privacy policies of these third-party services to understand their data handling practices.
Our Services include AI-based photo processing features that detect facial key points (such as eyes, nose, and mouth) for the purpose of generating avatars. We do not extract or store biometric information. Photos uploaded to our application are analyzed in real-time and are deleted either immediately after the rendered images are downloaded to the user's device or automatically after 30 days. The data is not used for any other purpose or retained beyond the specified time frame.
We operate internationally and may transfer information collected from you to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. These countries may not have the same data protection laws as your jurisdiction. We ensure that appropriate safeguards are in place to protect your information in compliance with applicable data protection laws.
Our commitment to data privacy and protection is paramount. We comply with the General Data Protection Regulation (GDPR) as it applies to the processing of personal data for individuals located in the European Union (EU), the European Economic Area (EEA), and the United Kingdom (UK). The GDPR grants individuals specific rights concerning their personal data, and we have implemented measures to uphold these rights:
Data Collection and Use: We only collect personal data that is necessary for the functioning of our Services, such as information provided during account registration, usage data for app functionality, and customer support inquiries. We ensure that data collection is lawful, fair, and transparent.
Lawful Basis for Processing: We process personal data based on the following lawful grounds:
Consent: Users give explicit consent for processing activities that are not strictly necessary for the Service’s operation, such as marketing communications.
Performance of a Contract: Data is processed to fulfill the contractual obligations we have with our users.
Legal Obligation: Compliance with legal requirements that necessitate the processing of personal data.
Legitimate Interests: Processing activities necessary for our legitimate interests, such as improving our Services, fraud detection, and ensuring IT security, provided these interests do not override the user’s rights and freedoms.
Data Subject Rights: Under the GDPR, individuals have the following rights, which we fully support:
Right to Erasure (Right to be Forgotten): Users can request the deletion of their personal data under certain circumstances, such as if it is no longer necessary for the purposes it was collected or if the user withdraws their consent.
Right to Restriction of Processing: Users can request the restriction of processing their data in certain scenarios, such as disputing the accuracy of the data or objecting to processing.
Right to Data Portability: Users have the right to receive their personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
Right to Object: Users can object to processing activities based on legitimate interests, direct marketing, or profiling.
Rights Related to Automated Decision-Making: Users have rights concerning decisions made solely on automated processing, including profiling, which produce legal effects or significantly affect them.
Data Security: We implement technical and organizational measures to ensure a level of security appropriate to the risk, including encryption, access controls, and secure storage to protect personal data against unauthorized access, alteration, disclosure, or destruction.
Data Breach Notification: In the unlikely event of a data breach, we have procedures to promptly inform data subjects and supervisory authorities when the breach is likely to result in a high risk to their rights and freedoms.
Data Transfers: When transferring personal data outside the EEA, we ensure adequate safeguards are in place, such as using standard contractual clauses, to ensure that personal data is protected consistently with GDPR standards.
Data Retention: Personal data is retained only as long as necessary to fulfill the purposes for which it was collected, after which it is securely deleted or anonymized.
Complaints: Users have the right to lodge a complaint with a supervisory authority if they believe that their data protection rights have been violated.
For more information on our GDPR compliance practices, users can contact our Data Protection Officer at [contact information].
We are committed to protecting the privacy of California residents and adhere to the California Consumer Privacy Act (CCPA). This overview outlines our practices and your rights under the CCPA:
Categories of Personal Information Collected: We may collect the following categories of personal information:
Identifiers: Such as name, email address, IP address, device identifiers.
Commercial Information: Records of products or services purchased or considered.
Internet or Other Electronic Network Activity: Browsing history, search history, and information regarding a consumer’s interaction with our website, application, or advertisements.
Geolocation Data: Location-based data derived from the user’s device.
Purposes for Collecting Personal Information: Personal information is collected for the following purposes:
To provide and improve our Services.
To process transactions and manage subscriptions.
For marketing and promotional purposes, if the user has opted-in.
To comply with legal obligations and respond to lawful requests from public authorities.
To protect against fraudulent or illegal activities and ensure the security of our Services.
User Rights Under CCPA:
Right to Know: Users have the right to request information about the categories and specific pieces of personal information we have collected, the purposes for collecting such data, the sources from which we collected it, and the categories of third parties with whom we share the information.
Right to Delete: Users can request the deletion of their personal information, subject to certain exceptions such as completing a transaction, detecting security incidents, complying with a legal obligation, or for other internal uses consistent with user expectations.
Right to Opt-Out of Sale: While we do not sell personal information in the conventional sense, we respect the right of users to opt out of any potential “sale” of personal information as defined under CCPA.
Right to Non-Discrimination: Users will not be discriminated against for exercising their rights under the CCPA, which means no denial of goods or services, charging different prices, or providing a different level or quality of service.
Verification Process: To protect user privacy and maintain security, we will take steps to verify a user’s identity before complying with any requests under the CCPA.
Exercising Rights: Users can exercise their rights by contacting us via support@halluapps.com or through the designated forms available on our website. We will respond to requests within the timeframe required by CCPA.
Data Retention and Deletion: Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected, after which it is securely deleted or anonymized.
Authorized Agents: Users can authorize another person or business entity to act on their behalf concerning their CCPA rights, provided that the authorized agent provides proof of authorization.
Updates to the CCPA Policy: We may update this CCPA policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons.
Our Services are distributed and managed through major app distribution platforms, including the Apple App Store and Google Play Store. We comply with all applicable rules, guidelines, and regulations set forth by these platforms to ensure a safe, secure, and lawful environment for our users. The following points outline our compliance and user rights related to these app store regulations:
In-App Purchases and Subscriptions:
All in-app purchases and subscription transactions are processed through the app stores’ secure payment systems. We do not store or have access to your complete payment details.
Users agree to the terms of service and privacy policies of the respective app store (Apple App Store, Google Play Store) when making purchases or subscribing to services.
Refund Policy:
Refunds are subject to the policies of the respective app stores. Users should refer to the Apple App Store or Google Play Store policies for detailed information on obtaining refunds.
Generally, refund requests must be submitted directly to the app store through which the purchase was made. Our support team can provide guidance on this process but cannot process refunds directly.
Compliance with App Store Guidelines:
We ensure that our application adheres to the app store guidelines regarding user privacy, data security, and content standards. This includes implementing age-appropriate content ratings, not engaging in deceptive practices, and providing accurate information about our Services.
We regularly review updates to app store guidelines to maintain compliance and make necessary adjustments to our application and policies.
User Data and Privacy:
Any collection, use, or sharing of user data is conducted in accordance with our Privacy Policy, which aligns with the requirements set forth by app store regulations. Users are informed of data collection practices and consent is obtained where necessary.
We do not collect unnecessary data or share user data with third parties without proper consent, except as required for the functionality of our Services or as mandated by law.
In the event of a data breach involving your personal information, we will take immediate steps to mitigate the impact and notify affected users and relevant authorities as required by applicable laws. We maintain incident response protocols to handle such events effectively.
If you have any questions, concerns, or complaints about this Privacy Policy or our privacy practices, or if you wish to exercise your rights regarding your personal information, please contact us:
Email: support@halluapps.com
Address: 1171 Budapest Pöszméte street 4. 2.