1. Types of Information Collected
Lino (hereinafter referred to as "the App") collects information to provide and improve our AI hand-painted illustration conversion services. We collect two categories of information: personally identifiable information (PII) and non-personally identifiable information (non-PII).
1.1 Personally Identifiable Information (PII)
- Account information: Email address (for registration/login), username (self-defined), and optional profile information (such as avatar).
- Payment information: Billing details (e.g., credit card numbers, PayPal account information) collected only when you purchase virtual currency (Coins) for premium services (processed by third-party payment processors).
- Contact information: Voluntarily provided feedback or support requests (e.g., emails sent to Lino@gmail.com).
1.2 Non-Personally Identifiable Information (non-PII)
- Device information: Device model, operating system version, unique device identifiers (UDID), IP address, and network type (Wi-Fi/cellular).
- Usage data: App interaction records (e.g., style templates selected, number of AI generations, works collected/shared), and crash logs (to fix technical issues).
- Content-related data: Original photos/images you upload (processed locally on your device where possible) and AI-generated hand-painted works (stored on our servers only with your consent).
We do not collect sensitive personal information (e.g., race, religion, health records, location data) unless explicitly provided by you for specific purposes (e.g., location-based style recommendations, which are optional).
2. Purpose of Use
We use the collected information solely for the following legitimate purposes, in compliance with applicable data protection laws (e.g., GDPR, CCPA):
- Provide and maintain core App functions: Process photo uploads/shooting, generate AI hand-painted works, store your collected works, and enable community sharing.
- Improve service quality: Analyze usage data to optimize AI algorithms, fix bugs, and enhance user experience (e.g., refining style templates based on user preferences).
- Process payments: Verify and process virtual currency recharge transactions for premium services, and provide payment receipts.
- Communicate with users: Send service-related notifications (e.g., account security alerts, policy updates, or response to support requests).
- Ensure platform security: Detect and prevent fraudulent activities, unauthorized account access, or violations of our User Agreement.
- Comply with legal obligations: Respond to lawful requests from regulatory authorities, courts, or law enforcement agencies.
We will not use your personal information for any purpose not stated in this Privacy Policy without your explicit consent. We do not use your data for targeted advertising without your opt-in permission.
3. Data Processing by Third-Party Services
We may engage trusted third-party service providers to assist in operating the App, and these providers may process your information on our behalf. We only share necessary information with third parties and require them to comply with strict data protection obligations.
- Payment processors: PayPal, Stripe, or mobile payment providers (process payment information to complete Coins recharge; we do not store full credit card details).
- Cloud storage providers: AWS, Google Cloud (store your uploaded photos and generated works securely; data is encrypted in transit and at rest).
- Analytics tools: Google Analytics, Firebase (collect non-PII usage data to improve App performance; data is anonymized).
- Customer support tools: Zendesk (process support requests and communicate with users; data is protected by end-to-end encryption).
We do not allow third-party service providers to use your information for their own commercial purposes. We conduct regular audits of third-party providers to ensure compliance with this Privacy Policy and applicable laws.
Third-party services have their own privacy policies, and we recommend that you review them before using the App. We are not responsible for the data practices of third-party services.
4. Information Sharing Scenarios
We will not sell, rent, or disclose your personal information to third parties for commercial purposes without your explicit consent. We may share your information only in the following limited scenarios:
- With your consent: When you explicitly authorize us to share your information (e.g., sharing your generated works in the App's public community).
- With service providers: As described in Section 3 (only for the purpose of providing App services).
- For legal compliance: When required by law, regulation, court order, or government request (we will challenge excessive or unlawful requests where possible).
- For business transfers: If Lino is involved in a merger, acquisition, or sale of all/part of its assets, your information may be transferred as part of the transaction (we will notify you of such changes in advance).
- To protect rights: To protect the safety, rights, or property of Lino, our users, or the public (e.g., investigating fraud or preventing harm).
We will anonymize or pseudonymize your information whenever possible before sharing it with third parties, to minimize the risk of identifying individual users.
5. Security Measures
We implement industry-standard technical and organizational security measures to protect your information from unauthorized access, disclosure, alteration, or destruction:
- Encryption: Data in transit (e.g., uploads/downloads) is protected by TLS 1.3 encryption; sensitive data (e.g., account passwords) is stored using bcrypt hashing (irreversible encryption).
- Access control: Only authorized personnel with a legitimate business need can access your information, and access is logged and monitored.
- Regular security audits: We conduct periodic security assessments and penetration testing to identify and fix vulnerabilities.
- Device security: We recommend that you enable two-factor authentication (2FA) for your account (if available) and keep your device operating system up to date.
- Data retention: We retain your information only for as long as necessary to fulfill the purposes stated in this Policy, or as required by law (e.g., tax/audit requirements).
Despite our best efforts, no security measure is 100% secure. We cannot guarantee absolute security of your information, and you acknowledge that you use the App at your own risk. If a data breach occurs, we will notify you and relevant authorities in accordance with applicable laws (e.g., within 72 hours of discovery, as required by GDPR).
6. User's Data Rights
Depending on your jurisdiction (e.g., EU/EEA, California), you have the following rights regarding your personal information, in accordance with laws such as GDPR and CCPA:
- Right to access: Request a copy of the personal information we hold about you.
- Right to correction: Request correction of inaccurate or incomplete personal information.
- Right to deletion: Request deletion of your personal information (right to be forgotten), subject to legal retention requirements.
- Right to data portability: Request a copy of your data in a machine-readable format (e.g., CSV/JSON) for transfer to another service provider.
- Right to opt-out: Opt out of non-essential data processing (e.g., analytics, marketing communications).
- Right to withdraw consent: Withdraw your consent to data processing at any time (this does not affect the lawfulness of processing before withdrawal).
To exercise these rights, please contact us at Lino@gmail.com with a clear description of your request. We will respond to valid requests within 30 days (or 45 days for complex requests) and will not charge a fee unless your request is excessive or repetitive.
7. Children's Privacy Protection
Lino is not intended for children under the age of 13, and we do not knowingly collect personal information from children under 13. In compliance with the Children's Online Privacy Protection Act (COPPA) and other applicable laws:
- If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will delete such information immediately.
- Parents/legal guardians of children under 13 may contact us at Lino@gmail.com to request deletion of their child's information or to exercise other rights on behalf of the child.
- We do not display targeted advertising to users we know are under 13, and we do not share children's information with third parties for commercial purposes.
If you are a parent/guardian and believe your child has provided personal information to us without your consent, please contact us immediately, and we will take steps to remove the information and terminate the child's account.
8. Policy Update Mechanism
We may update this Privacy Policy from time to time to reflect changes in laws, regulations, or our services. We will notify you of material changes:
- Via in-App push notifications or email (to the address associated with your account) at least 30 days before the changes take effect.
- By posting the updated Privacy Policy in the App (under "Settings > Privacy Policy") with a prominent notice of the changes.
The updated Privacy Policy will take effect on the date specified in the notice. Your continued use of the App after the effective date constitutes your acceptance of the updated Policy. If you do not accept the updated Policy, you must stop using the App and request deletion of your account and data.
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. We will retain a history of previous versions of this Policy in the App for your reference.