Privacy Policy

1. Introduction

DIALIGHT INTERNATIONAL LIMITED ("we," "our," or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you use our mobile application development services.

2. Information We Collect

We may collect and process the following types of information:

• Personal Information: Name, email address, phone number, company name, and job title
• Project Information: Details about your mobile app requirements, business objectives, and technical specifications
• Communication Data: Records of correspondence, meeting notes, and project updates
• Usage Data: Information about how you interact with our services and website

3. How We Use Your Information

We use your personal information to:

• Provide mobile application development services
• Communicate with you about your project
• Send project updates and deliverables
• Improve our services and customer experience
• Comply with legal and regulatory requirements

4. Information Sharing

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:

• With your explicit consent
• With trusted service providers who assist us in delivering our services
• When required by law or to protect our legal rights
• In connection with a business transfer or acquisition

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. This includes:

• Encrypted data transmission and storage
• Regular security assessments and updates
• Limited access to personal information on a need-to-know basis
• Employee training on data protection practices

6. Your Rights

Under applicable data protection laws, you have the right to:

• Access your personal information
• Correct inaccurate or incomplete information
• Request deletion of your personal information
• Object to or restrict processing of your information
• Data portability
• Withdraw consent where processing is based on consent

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Project-related information is typically retained for 7 years after project completion.

8. International Data Transfers

Your personal information may be transferred to and processed in countries other than your own. We ensure that such transfers are protected by appropriate safeguards in accordance with applicable data protection laws.

9. Updates to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on our website and updating the "Last updated" date.

10. AI and Facial Data Processing

10.1 Data We Process

When a user voluntarily takes or selects a photograph for facial analysis, we process:

• the photograph containing the user's face;
• visual facial characteristics necessary to generate the requested analysis;
• information voluntarily provided by the user, such as age, gender, goals, preferences, or other answers provided during onboarding;
• instructions required to perform the analysis;
• AI-generated scores, reports, recommendations, routines, hairstyle suggestions, and other requested results.

We only access photographs that the user actively selects or captures for analysis. We do not access the user's entire photo library.

We do not collect Apple Face ID data or data from Apple's TrueDepth API. We do not create biometric identifiers or facial recognition templates, and we do not use facial images to identify or authenticate users.

The user's name, email address, phone number, advertising identifier, and contact information are not included with photographs sent for AI analysis.

10.2 Purpose of Processing

Facial photographs and related information are processed exclusively to:

• perform the facial analysis requested by the user;
• generate personalized scores, reports, recommendations, routines, hairstyle suggestions, and other AI-powered results;
• display and save the generated results inside the application;
• maintain the security and technical operation of the AI-powered functionality.

We do not use facial photographs or facial analysis data for advertising, tracking, marketing, identity verification, or the creation of advertising profiles.

We do not sell, rent, or use facial photographs or facial analysis data for any unrelated purpose.

10.3 Third-Party AI Provider and User Consent

The application uses the Gemini API, a third-party artificial intelligence service provided by:

Google Cloud EMEA Limited
70 Sir John Rogerson's Quay
Dublin 2, Ireland

Before any photograph or related personal data is transmitted to Google Gemini, the application displays a clear disclosure explaining:

• what data will be transmitted;
• that the recipient is Google Gemini;
• why the data is transmitted;
• how the data will be used and retained.

The application obtains the user's explicit permission before transmitting the data.

If the user declines permission, the photograph and related personal data are not transmitted to Google Gemini and the requested AI analysis is not performed.

The user may withdraw consent for future AI processing through the application's privacy settings or by contacting us at [email protected]. Withdrawal of consent does not affect processing that occurred before consent was withdrawn.

10.4 How Google Uses and Retains the Data

We use the paid version of the Gemini API through a Google Cloud project with active billing.

Under the terms applicable to paid Gemini API services, Google does not use submitted prompts, photographs, files, or generated responses to train its AI models or improve its products.

Google may retain prompts, contextual information, submitted photographs, and generated responses for up to 55 days solely to:

• detect and prevent violations of its prohibited-use policies;
• protect the security and integrity of the Gemini API;
• comply with applicable legal or regulatory obligations.

Google automatically deletes this information after the applicable retention period, unless longer retention is required by law.

We do not voluntarily contribute user photographs, prompts, analysis results, or other personal data to Google datasets, model-training programs, product-improvement programs, or human-review programs.

Google processes the data under the applicable Google Data Processing Addendum, Gemini API Terms of Service, and Google Privacy Policy.

10.5 Our Retention of Facial Photographs and Analysis Results

Original facial photographs are stored by DIALIGHT INTERNATIONAL LIMITED only for the time required to complete the requested analysis and for no longer than 24 hours after the analysis is completed.

After this period, the original photographs are automatically deleted from our active systems.

AI-generated analysis results may be retained so that the user can access their reports, recommendations, progress, and previously generated results. These results are retained until the user deletes them, deletes their account, or requests their deletion.

Following a valid deletion request, the associated photographs and analysis results are deleted from our active systems within 30 days. Any remaining backup copies are deleted or overwritten within an additional 30 days.

We do not retain facial photographs indefinitely.

We do not use retained analysis results for advertising, user tracking, facial recognition, biometric identification, or training AI models.

10.6 Data Deletion

Users may delete available photographs and analysis results through the application.

Users may also request deletion of their photographs, AI-generated results, and other personal data by contacting:

[email protected]

We may request limited information necessary to verify and process the deletion request.

Valid deletion requests are completed within 30 days, unless a longer period is required by applicable law.

Deletion from our systems does not override the limited retention performed independently by Google for security, abuse-prevention, or legal-compliance purposes. Google's maximum applicable retention period is described above.

10.7 Data Security and Third-Party Protection

Photographs and related information are transmitted using encrypted HTTPS/TLS connections.

Where personal data is stored by us, it is protected using appropriate technical and organizational security measures, including:

• encryption during transmission;
• restricted access on a need-to-know basis;
• access controls for authorized personnel;
• monitoring and protection against unauthorized access, disclosure, alteration, or destruction.

We require Google and any other service provider processing personal data on our behalf to process the data under applicable contractual data-protection terms and to provide the same or an equivalent level of protection described in this Privacy Policy and required by applicable law.

Google and its authorized subprocessors may process data in countries outside the user's country of residence. Where required, international transfers are protected through applicable contractual and legal safeguards.

Additional information is available in:

Google Privacy Policy: https://policies.google.com/privacy
Gemini API Terms: https://ai.google.dev/gemini-api/terms