Privacy Policy

( doing business as Hilaya ) (hereinafter referred to as “we”)’s Privacy Policy describes how and why we collect, store, use and/or share ( “process” ) your information when you use our services (“Services”) , such as when you:

● Visit our website cnyang0818@gmail.com , or any website that links to this Privacy Policy

● Download and use our mobile application ( Hilaya ), or any other application that links to this Privacy Policy

● interact with us in any other relevant way, including any sales, marketing or events

Have questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our services. If you still have any questions or concerns, please contact us at cnyang0818@gmail.com .

Summary of key points

This summary provides the key points of our Privacy Policy, but you can learn more detailed information on these topics by clicking on the links following each key point or using the table of contents below to find the section you are looking for.

What personal information do we process? When you access, use or browse our Services, we may process personal information based on how you interact with us and our Services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us .

Do we process any sensitive personal information? We may process sensitive personal information with your consent, where necessary, or as permitted by applicable law. Learn more about the sensitive information we process .

Do we obtain any information from third parties? We do not collect information from third parties.

What do we do with your information? We process your information to provide, improve and administer our services, to communicate with you, to ensure security and prevent fraud, and to comply with laws. We may also use your information for other purposes with your consent. We only process your information when we have a legitimate legal reason to do so. Learn more about how we process your information .

Under what circumstances and with what types of third parties is personal information shared? We may share information with certain categories of third parties in certain circumstances. Learn more about when and with whom we share your personal information .

How do we keep your information secure? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals or other unauthorized third parties will not be able to defeat our security measures and improperly collect, access, steal or modify your information. Learn more about how we keep your information secure.

What are your rights? Depending on where you are located, applicable privacy laws may mean that you have certain rights with respect to your personal information. Learn more about your privacy rights .

How can you exercise your rights? The easiest way to exercise your rights is to contact us. We will consider and process any request in accordance with applicable data protection laws.

Want to learn more about what we do with the information we collect? Please review our full privacy policy .

Table of contents

1. What information do we collect?

2. What do we do with your information?

3. What legal basis do we rely on to process your information?

4. When and with whom do we share your personal information?

5. What is our stance on third-party websites?

6. How do we handle your social login information?

7. Will your information be transferred internationally?

8. How do we keep your information secure?

9. Do we collect information from minors?

10. What are your privacy rights?

1 1. Data and account deletion

1 2. Will we update this notice?

1 3. How can you contact us about this notice?

14. How can you review , update or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Service, when you express an interest in obtaining information about us or our products and services while participating in an activity on the Service, or when you contact us.

Personal information you provide. The personal information we collect depends on the context of your interactions with us and our Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

● Name

● Phone number

● Email address

● Mailing address

● Job title

● Username

● Password

Sensitive Information. Where necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

● Data about an individual’s sex life or sexual orientation

Social Media Login Data. We may offer you the option to register with us using your existing social media account details (such as Facebook, Twitter or other social media accounts). If you choose to register in this way, we will collect the information described in the “What do we do with your social login information?” section below .

Application Data. If you use our applications and you choose to provide us with access or permission, we may also collect the following information:

● Mobile device access. We may request access or permission to use certain features of your mobile device, including your mobile device’s camera, microphone, social media accounts, storage, and other features. If you wish to change our access or permissions, you can do so in your device’s settings.

● Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our Apps, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our Apps that you access.

● Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt out of receiving such communications, you may turn them off in your device settings.

This information is primarily used to maintain the security and operation of our applications, for troubleshooting, and for our internal analytics and reporting purposes.

All personal information you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information Collected Automatically

In Short: When you visit our Services, certain information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically.

We collect certain information automatically when you access, use, or browse the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Like many businesses, we collect information through cookies and similar technologies.

The information we collect includes:

● Log and Usage Data. Log and Usage Data is diagnostic, usage, and performance information related to the Services that our servers automatically collect and record in log files when you access or use our Services. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activities on the Services (such as date/time stamps associated with your use, pages and files viewed, searches, and other actions you take, such as the features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

● Device Data. We collect device data, such as information about the mobile phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.

2. What do we do with your information?

In Short: We process your information to provide, improve, and administer our services, to communicate with you, for security and fraud prevention, and to comply with laws. We may also use your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including to:

● Facilitate account creation and verification, and otherwise manage user accounts. We may process your information to enable you to create and log into your account, and to keep your account running properly.

● Provide services to users and facilitate the provision of services. We may process your information in order to provide you with the services you have requested.

● Respond to user inquiries/provide support to users. We may process your information to respond to your inquiries and resolve any potential issues you may have when requesting services.

● Send you administrative information. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

● Enable communication between users. We process the necessary information to enable direct communication between users within our applications to enhance the social interaction experience.

● Request feedback. We may process your information as necessary to request feedback and contact you about your use of our services.

● Send you marketing and promotional communications. We may process the personal information you send us for marketing purposes, if in accordance with your marketing preferences. You can opt out of receiving marketing emails from us at any time. For more information, see "What are your privacy rights?" below .

● Provide you with targeted advertising. We may process your information to develop and display personalized content and advertising tailored to your interests, location, etc.

● To protect our services. We may process your information in an effort to ensure that our services are safe and secure, including for fraud monitoring and prevention.

● Identify usage trends. We may process information about how you use our Services to better understand how those Services are used so that we can improve them.

● Determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to deliver marketing and promotional campaigns that are most relevant to you.

● To save or protect important personal interests. We may process your information when necessary to save or protect important personal interests, such as to prevent harm.

3. What legal basis do we rely on to process your information?

In Short: We only process your personal information when we deem it necessary and have a valid legal reason (i.e. a legal basis) under applicable law, such as with your consent, to comply with laws, to provide you with services, to enter into or perform our contractual obligations, to protect your rights, or for our legitimate business interests.

If you are located in the European Union or the United Kingdom, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. Therefore, we may rely on the following legal bases to process your personal information:

● Consent . We may process your personal information if you allow (i.e. consent) us to use it for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing consent .

● Performance of a contract . We may process your personal information when we believe it is necessary to perform our contractual obligations to you (including providing our services) or at your request before entering into a contract with you.

● Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for the following purposes:

● Send users information about special offers and discounts on our products and services

● Develop and display personalized and relevant advertising content to our users

● Analyze the use of our services so that we can improve them and attract and retain users

● Support our marketing activities

● Diagnose problems and/or prevent fraudulent activity

● Understand how users use our products and services so we can improve the user experience

● Legal obligations . We may process your information where we believe it is necessary to comply with a legal obligation, such as cooperating with law enforcement or regulatory agencies, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.

● Vital Interests . We may process your information when we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. explicit consent) to use your personal information for a specific purpose, or where your consent can be inferred (i.e. implied consent). You can withdraw your consent at any time .

In certain special circumstances, we may be legally permitted under applicable law to process your information without your consent, such as:

● If the collection of information is clearly in the individual’s interest and consent cannot be obtained in a timely manner

● For investigation, fraud detection and prevention

● For commercial transactions that meet certain conditions

● If it is included in a witness statement and collection is necessary to evaluate, process or settle an insurance claim

● To identify injured, sick or deceased persons and communicate with next of kin

● If we have reasonable grounds to believe that a person has been, is or may be a victim of financial fraud

● If there is reason to believe that collecting and using the information with consent would compromise the availability or accuracy of the information and the collection of the information is reasonable for the purpose of investigating a breach of the agreement or a violation of Canadian or provincial law

● If disclosure is necessary to comply with a subpoena, warrant, court order, or court rule relating to the production of records

● If the information is generated by the individual in the course of his/her employment, business or profession and the purpose for which the information was collected is consistent with the purpose for which it was generated

● If the collection is intended only for journalistic, artistic or literary purposes

● If the information is public and required by law

4. When and with whom do we share your personal information?

In Short: We may share information in the specific circumstances described in this section and/or with the categories of third parties listed below.

● Firebase: We use Firebase for backend infrastructure, including database, authentication, and hosting services. Your data, including personal identifiers and chat history, may be stored and processed through Firebase to enable app functionality.

● Facebook SDK: Our app integrates the Facebook SDK for social media interaction and authentication. This may involve sharing your public profile information and friend lists with Facebook to enhance social connections within our app.

● Live Chat: To provide customer support and interaction, we use Live Chat. This involves sharing your chat history with Live Chat and any personal information provided during the support interaction.

● Adjust: Adjust is used for marketing analytics and attribution. Data related to app usage, user behavior, and marketing campaign performance will be shared with Adjust to optimize our marketing strategy.

● Google Analytics: Google Analytics is used to collect app usage and user interaction data. This includes sharing non-personal information and aggregated data with Google Analytics to understand user behavior and improve app performance.

● Amazon Rekognition: Amazon Rekognition is used for image and video analysis, including moderation and content filtering. Visual content within applications is processed by Amazon Rekognition to maintain community standards and user safety.

● Amazon Comprehend and DetectDominantLanguage: These services are used for natural language processing, including sentiment analysis and language detection in chat interactions. Analyze text content to enhance communication capabilities and user experience.

● Amazon Translate: We use Amazon Translate for real-time language translation in chat. This involves processing chat messages through Amazon Translate to enable cross-language communication between users.

● Amazon CloudFront, Simple Storage Service (S3), Elastic Compute Cloud (EC2), and Amazon Lambda: These Amazon Web Services (AWS) components are used for cloud storage, content delivery, computing power, and serverless functions. Use these services to process and store user data (including uploaded content and application interactions).

We ensure that these third parties comply with data protection and privacy laws that are relevant to our users. We also require them to maintain the confidentiality and security of shared data. For more details on how these third parties handle your personal information, please refer to their respective privacy policies.

We may also need to share your personal information in the following circumstances:

● Business Transfers . We may share or transfer your information with another company in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.

● Other Users. When you share Personal Information (for example, by posting comments, contributions or other content on the Services) or otherwise interact with public areas of the Services, such Personal Information may be viewed by all users and may become publicly available outside of the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

5. What is our stance on third-party websites?

In Short: We are not responsible for the security of any information you share with third parties that we may link to or that advertise our services but are not affiliated with our services.

The Services may link to third-party websites, online services or mobile applications, and/or contain third-party advertisements that are not affiliated with us, which may link to other websites, services or applications. Therefore, we do not make any warranties about any such third parties and are not responsible for any loss or damage arising from the use of such third-party websites, services or applications. The inclusion of links to third-party websites, services or applications does not imply our endorsement of them. We cannot guarantee the security and privacy of data you provide to any third party. Data collected by any third party is not protected by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third party, including other websites, services or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to answer your questions.

6. How do we handle your social login information?

In Short: If you choose to register or log into our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using third-party social media account details (such as your Facebook or Twitter login information). If you choose to do so, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the relevant social media provider, but will typically include your name, email address, friends list and profile picture, as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes described in this Privacy Policy or as made clear to you in the relevant services. Please note that we cannot control and are not responsible for other uses of your personal information by your third-party social media providers. We recommend that you review their privacy policies to understand how they collect, use and share your personal information, and how to set your privacy preferences on their websites and applications.

7. Will your information be transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your country.

Our servers are located in Germany. If you access our Services from outside of Germany, please be aware that your information may be transferred to, stored, and processed by us and third parties with whom we may share your Personal Information (see “When and with whom do we share your Personal Information?” above ) in Germany and other countries.

If you are a resident of the European Economic Area (EEA), the United Kingdom (UK) or Switzerland, these countries may not necessarily have data protection or other similar laws that are as comprehensive as those in your country. However, we will take all necessary steps to protect your personal information in accordance with this Privacy Policy and applicable laws.

European Commission’s Standard Contractual Clauses:

We have taken steps to protect your personal information, including using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and third-party providers. These clauses require all recipients to protect all personal information from the European Economic Area or the UK that they process in accordance with European data protection laws and regulations. Our data processing agreements include the Standard Contractual Clauses and are available on request. We have implemented similar appropriate safeguards with our third-party service providers and partners and can provide further details on request.

8. How do we keep your information secure?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our security measures and efforts to protect your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals or other unauthorized third parties will not be able to defeat our security measures and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, you transmit your personal information to our services at your own risk. You should only access the services in a secure environment.

9. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18. By using the Services, you represent that you are 18 or older, or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that we have collected personal information from a user under 18, we will deactivate the account and take reasonable steps to promptly delete such data from our records. If you become aware that we might have collected any data from a child under 18, please contact us at cnyang0818@gmail.com .

10. What are your privacy rights?

In Short: In some regions, such as the European Economic Area (EEA), the United Kingdom (UK), Switzerland, and Canada, you have additional rights to access and control your personal information. You can review, change, or terminate your account at any time.

In some regions (such as the European Economic Area, the United Kingdom, Switzerland, and Canada), you have certain rights under applicable data protection laws. These rights may include: (i) requesting access to and obtaining a copy of your personal information; (ii) requesting correction or erasure; (iii) restricting the processing of your personal information; (iv) where applicable, data portability; and (v) not being subject to automated decision-making. In certain circumstances, you also have the right to object to the processing of your personal information. You may make such a request by contacting us using the contact details provided in the “How can you contact us about this notice?” section below .

We will consider and process any request in accordance with applicable data protection law. If you are located in the European Economic Area or the UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your member state data protection authority or the UK data protection authority .

If you are located in Switzerland, you can contact the Federal Data Protection and Information Commissioner .

Withdraw your consent: If we rely on your consent to process your personal information, which may be express and/or implied consent under applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the “How can you contact us about this notice?” section below .

Please note, however, that this will not affect the lawfulness of the processing prior to its withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent, where permitted by applicable law.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in an email we send, replying to a text message from us saying “STOP” or “UNSUBSCRIBE”, or contacting us using the details provided in the “How can you contact us about this notification?” section below . You will then be removed from our marketing lists. However, we may still contact you — for example, to send you service-related information necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

account information

If you would like to review or change the information in your account or terminate your account at any time, you can:

● Log into your account settings and update your user account.

● Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

If you have any questions or comments about your privacy rights, you can contact us at cnyang0818@gmail.com .

What categories of personal information do we collect?

In the past twelve (12) months, we have collected the following categories of personal information:

We may also collect additional personal information beyond these categories through your interactions with us in person, online, by phone or mail when you:

● Get help through our customer support channels;

● Participate in customer surveys or contests; and

● Assist us in providing our services and responding to your inquiries.

How do we use and share your personal information?

Learn more about how we use your personal information in the "What do we do with your information?" section.

Will your information be shared with others?

Learn more about how we disclose personal information in the “When and with whom do we share your personal information?” section.

We may use your personal information for our own business purposes, such as internal research for technology development and demonstration. This is not considered a "sale" of your personal information.

In the past twelve (12) months, we have not sold or shared any personal information with third parties for business or commercial purposes.

The categories of third parties to whom we disclose personal information for a business or commercial purpose can be found in the “When and with whom do we share your personal information?”

Your rights regarding your personal information

Right to request erasure of data – Request erasure

You can request deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) other consumers exercising their free speech rights, compliance requirements arising from our legal obligations, or any processing that may be necessary to prevent illegal activity.

Right to be informed – Request for information

Depending on the circumstances, you may have the right to know:

● Whether we collect and use your personal information;

● The categories of personal information we collected;

● The purpose for which the collected personal information will be used;

● Whether we sell or share personal information with third parties;

● The categories of personal information we sold, shared, or disclosed for a business purpose;

● The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

● The business or commercial purpose for collecting, selling or sharing the personal information; and

● The specific pieces of personal information we collected about you.

Consistent with applicable law, we have no obligation to provide or delete de-identified consumer information in response to a consumer request, or to re-identify personal data to verify a consumer request.

Consumers’ right not to be discriminated against when exercising their privacy rights

We will not discriminate against you if you exercise your privacy rights.

Right to restrict use and disclosure of sensitive personal information

We do not process sensitive personal information of consumers.

Verification Process

Once we receive your request, we need to verify your identity to confirm that you are the person whose information we have in our system. These verification efforts require us to ask you for information so that we can match it with information you have previously provided to us. For example, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with information we already have on file, or we may contact you through the communication methods you previously provided to us (such as telephone or email). We may also use other verification methods depending on the circumstances.

We only use the personal information you provide in your request to verify your identity or authority to make the request. To the extent possible, we will avoid asking you for more information for verification purposes. However, if we cannot verify your identity from the information we already have stored, we may ask you to provide more information to verify your identity and for security or fraud prevention purposes. We will delete such additional information immediately after completing the verification.

Other Privacy Rights

● You can object to the processing of your personal information.

● If your personal data is incorrect or no longer relevant, you can request that it be corrected, or request that the processing of that information be restricted.

● You may designate an authorized agent to make a request on your behalf under the CCPA. We may deny the authorized agent’s request if the authorized agent does not submit evidence that the agent has valid authorization under the CCPA to act on your behalf.

● You may request to opt-out of the future sale or sharing of your personal information to third parties. Upon receipt of an opt-out request, we will process the request as soon as possible, but no later than fifteen (15) days from the date the request was submitted.

To exercise these rights, you can contact us by email at cnyang0818@gmail.com , or refer to the contact details at the bottom of this document. If you have any complaints about the way we process your data, we would love to hear from you.

● The right to know whether we are processing your personal data

● Right to access your personal data

● The right to correct inaccuracies in your personal data

● The right to request erasure of your personal data

● The right to receive a copy of the personal data you have previously shared with us

● You have the right to opt out of the processing of your personal data if it is used for targeted advertising, personal data sales, or for further analysis for making a decision that has a legal or similarly significant impact (“profiling”)

To submit a request to exercise the rights listed above, please send an email to cnyang0818@gmail.com .

If we decline to act on your request and you wish to appeal our decision, please email cnyang0818@gmail.com Within forty-five (45) days of receiving your appeal, we will notify you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decision.

11. Data and Account Deletion

using our Hilaya application, you can delete or disable your account by following these steps:

Click "Settings" within the app to access your profile.

Find the "Delete Account" button at the bottom of the settings page.

To delete your account:

Clicking the "Delete my account" button will hide your profile. If you do not log in within 30 days, your account will be permanently deleted. If you log in within 30 days, your profile will become active again.

IMPORTANT: All user data (photos, names, messaging data, etc.) will be permanently deleted 30 days after the account deletion process begins.

1 2. Will we update this notice?

In Short: Yes, we will update this notice as necessary to comply with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective immediately when it is accessible. If we make material changes to this Privacy Policy, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to frequently review this Privacy Policy to learn how we are protecting your information.

1 3. How can you contact us about this notice?

If you have any questions or comments about this notice, you may send an email to cnyang0818@gmail.com

1 4. How can you review, update or delete the data we collect from you?

Depending on applicable law in your country, you may have the right to request access to the personal information we have collected from you, change or delete that information. To request to review, update or delete your personal information, please email: cnyang0818@gmail.com or you can do so in the app settings.