Privacy Policy

I. Introduction

Heromind Holdings Limited LLC (“we” or “our”) is committed to protecting your privacy. This Privacy Policy outlines our data protection policies and describes the types of information we may process when you install and/or use the SellSurge Al software application (“the App”, “our App”) on your mobile device. The name of the App may vary outside the United States and is subject to change without notice. When we refer to personal data (or personal information), we mean any type of information related to an identifiable natural person, especially by referring to such data. It is information related to a natural person who can be identified, directly or indirectly, particularly through reference to an identifier such as a social security number or one or more factors specific to the physical, physiological, psychological, economic, cultural, or social identity of that person. Our Privacy Policy applies to all users and others who access the App. In terms of GDPR, we are data controllers, unless otherwise stated. California Residents: Important Notice Under the California Consumer Privacy Act (CCPA) of 2018, residents of California have the right to request: Categories of personal information processed; Categories of sources from which personal information is obtained; The purposes for processing user personal data; Categories of third parties with whom your personal information may be shared; Specific pieces of personal information we may have obtained about a user, if the data provided in the request is sufficient and allows user identification. Personal Information Details on categories of information, its sources, and purposes of processing. Note that under CCPA, personal information does not include de-identified or aggregated consumer information. Sharing How we share your information. Note that all third parties involved in processing user data are service providers using such information for business purposes under agreements. Submitting Verifiable Requests Be prepared to provide sufficient information for us to reasonably verify you are the person from whom we collected personal information or an authorized representative, which may include your name, address, city, state, ZIP code, and email address. We may use this information to pose a series of security questions to verify your identity. If the request is made through an authorized agent acting on your behalf, the agent must provide a written authorization or power of attorney signed by you. Response Time We aim to respond to a verifiable consumer request within forty-five (45) days of its receipt. If more time is needed, we will inform you in writing of the reason and extension period. Note that we are only required to respond to two requests per customer each year. Equal Rights Our processing of your requests shall not be construed as discriminatory, meaning if you choose to exercise your rights, we will not provide you with different pricing or products, or a different level or quality of services. However, in some cases, if you choose to have your personal information deleted from our records, we may not be able to provide services. Data Selling We do not sell any of your personal data, except as outlined in Section Four below. Please read the following privacy policy carefully to understand how your personal information may be processed. By using the App, you acknowledge that you have read, understood, and agree to be bound by these terms.

II. Information We Process

Several categories of information can be processed. Automated Processing of Information With your permission, we use third-party automated data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our App (advertiser ID for iOS devices/Ad ID or Android ID for Android devices). Some integrated advertising or analytics tools (please refer to Section Four for a list) initiate automated processing of your personal data, including analysis, which means any form of automated processing of personal data to evaluate certain personal aspects related to you, particularly analysis or prediction of aspects concerning your personal preferences, interests, behavior, location, or movements (please refer to the data list described below). Once you allow our App to track your activities, information processing automatically starts through automated data processing technologies. You can withdraw your permission at any time - please see the opt-out options in Section VIII below. We may process some information about your device and user behavior based on our legitimate interest. This information belongs to the data categories described in the “Automated Processing of Information” section above and is usually non-personal, meaning it does not allow direct association with any specific individual, and we can only access it in aggregated form. We use this information to improve our App and provide the best experience for our users. Device Details When you access our App using a mobile device (tablet/phone/smartwatch), the system reports certain details about your device, including a “device identifier”. A device identifier is a small data file or similar data structure stored on or associated with your mobile device, uniquely identifying your mobile device (but not you personally). Device identifiers support third parties in generic reporting or personalized content and advertisements. Data That Can Be Processed Information about the device itself: device type, operating system type and version, model and manufacturer, screen size, screen density, orientation, volume and battery, device memory usage. Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamps and session duration, speed, browser. Location-related information: IP address, country/region/state/city code associated with your SIM card or device, language settings, time zone, proximity to commercial points of interest (e.g., “coffee shop”). Other device identifiers: such as user identifiers (if set by the app developers). Information about the application: Our app’s name, API key (application identifier), version, attributes, for automated processing and analysis. Some services also record a list of applications and/or processes installed or running on your device. Cookies and Similar Technologies When you use the App, cookies and similar technologies (pixels, web beacons, scripts) may be used. Cookies are small text files containing a small amount of information downloaded to your device when you visit the App. Each time you use the App, the text file is sent back to the server. This enables us to operate the App more effectively. For example, we will understand how many users access specific areas or features of our App and which links or ads they click on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that interest you. We may request advertisers or other partners to provide ads or services to the App, which may use cookies or similar technologies. Log File Information Log file information is automatically reported each time you request access to the App. It can also be provided when the App is installed on your device. When you use our App, analysis tools automatically log certain information, including the date and time you start and stop using the App, and how you interact with it. Advertising-Related Information Data about ads you may view can be reported: the date and time a particular ad was delivered; records of whether the ad was “clicked” or shown as a “conversion” event; what the content of the ad offer was; what type of ad it was (e.g., text, image, or video); which ad placement was involved (where the ad offer appeared within the App); whether you responded to the ad. In-App Events When you use our App, analysis tools automatically log information about your activities (tutorial steps, upgrades, payments, in-app purchases, custom events, progress) events, limiting methods of user data processing). Information automatically provided to advertising or analysis tools is generally beyond our control, and therefore we are not responsible for the processing of such information. Note that some services involving personal data analysis may obtain information related to your personality and/or your device using technologies not under our responsibility. If your user ID is linked to your Facebook account, Facebook may combine your device information with categorized data recorded in its database (e.g., your age, gender, or other demographic indicators). We do not control, oversee, or guarantee how third parties process your personal data, which may be collected by them in their own ways (not through our App). Any requests for information disclosure about your personal data should be made directly to such third parties (see Section Four). Payment Information Our e-commerce providers (Apple / Google) are responsible for billing, processing, and charging for in-app purchases, handling your personal information, and ensuring its absolute security. This information is processed as part of fulfilling the contract between you and us. We do not have access to or use your credit card or debit card information. You can access applicable "in-app" purchase rules and policies directly from the app store.

III. Purpose for Processing Your Personal Data

All images you upload will be permanently deleted automatically from the server 1 hour after you last edited or closed the image processing page. Meanwhile, we will not share your data with any third parties. Our mission is to continually improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes: To provide our services: We use functional information and automated processing information to deliver all requested services. To improve, test, and monitor the effectiveness of our App: We use automated processing information to better understand user behavior and trends, detect potential disruptions and technical issues, and operate, protect, improve, and optimize our App. To offer interest-based (behavioral) advertising or other targeted content: We may use automated processing information for marketing purposes (to display ads that may include content of interest to you based on your preferences). We provide personalized content and information, which may include online ads or other forms of marketing. To communicate with you: We use the information we have to communicate with you through newsletters, send you marketing notifications, receive your feedback on our App experience, and inform you about our policies and terms. When you contact us, we also use your information to respond to you. To prevent fraud and spam, enforce the law: We are keen to ensure our App is free from spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks, and enforce our terms of use.

IV. Sharing Your Information

We share your information with third parties only as described in this Privacy Policy. We adhere to the self-regulatory principles for the mobile environment of the Digital Advertising Alliance in the USA. Please note, when integrating external services, we select third-party organizations that can ensure they adopt all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data due to the fault of third parties. We may share your information with third-party organizations providing automatic data processing technology for our App, such as information from log files, device identifiers, and location data. We do not control or influence these third parties' tracking technologies or how they are used. We may also share certain information with third-party advertising partners, such as cookie data. This information enables third-party ad networks to deliver targeted ads they believe will be of most interest to you. We may engage the following third-party service providers to provide infrastructure needed for delivery and improvement of services: Apple Inc. Cloud Storage Provider (for iOS devices) USA Apple Privacy Policy Mixpanel User behavior analytics Mixpanel Privacy Policy Firebase (Google LLC) Analytics Service Provider USA Firebase Privacy Support AppsFlyer Mobile advertising and data analytics AppsFlyer Privacy Policy Google Analytics Web analytics and traffic statistics Google Privacy Policy Facebook (Meta Platforms, Inc.)https://www.facebook.com/privacy/explanation

For more information about these services and their privacy options (including opt-out), please refer to their respective websites and privacy policies. We are not responsible for any third-party's misuse of your personal data contrary to our instructions. Our App may contain links to third-party websites/services or be accessible from third-party websites. We are not responsible for the privacy practices of these third-party websites or services linked to our App, including the information or content contained within them. In cases of objective necessity, public interest, or other unforeseeable circumstances, we may disclose your personal information: As required by law; When we sincerely believe disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to government requests; In the event of a merger, acquisition, or sale of all or part of our assets, you will be notified via email and/or a prominent notice in our App about any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

V. International Data Transfer

We offer our App to users around the world. Our third-party organizations that provide automatic data processing technology for the App or our third-party advertising partners may transfer the information processed automatically across borders, from your country or jurisdiction to other countries or jurisdictions worldwide. If you are located in the European Union or other regions where laws governing data processing may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. This means your personal information may be transferred to a third country, a territory or one or more specified sectors within that third country, or an international organization where data protection and privacy regulations may not offer the same level of protection for personal data as in your country. We strive to ensure that any recipient of personal data provides suitable protection for such data in accordance with current legislation governing the protection of such information. By using the App, you consent to the transfer of your personal data to any third country, a territory or one or more specified sectors within that third country, or an international organization. For data storage purposes, we resort to the services of hosting organizations. We take your privacy seriously, therefore, where possible, we encrypt your personal data before sending it to hosting organizations for storage. Please note that we only collaborate with hosting organizations that have passed our security and reliability checks.

VI. Exercising Your Rights

Applicable data protection law grants you certain rights regarding your personal information. With respect to your personal information, you have the following choices: Data Access and Portability: You may request a copy of your personal information. Change or Correct Data: If you cannot update the data yourself through your account, you have the right to request correction, update, or rectification of your data. Data Retention and Deletion: User data is generally retained as long as your user profile exists or as needed to provide relevant services. However, the specific retention period may vary depending on the context of the processing performed. You have the right to request deletion of all or part of your personal data that we hold. Restriction on Processing: In certain circumstances, you may have the right to restrict the ways in which your personal information is used. Objection to Processing: In certain circumstances, you may object to the automatic processing of your personal information. If your personal information is processed for direct marketing purposes, you may request to stop processing your data for these direct marketing purposes. To exercise your rights, contact the third-party services listed in Section IV to learn how to object to the processing of your data. Most of them have clear instructions on their privacy pages, functionality APIs, or other options.

VII. Security

The security of your personal information is of utmost importance to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Considering the risks involved in the processing and the nature of personal information, we take reasonable and appropriate measures to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We implement appropriate technical and organizational measures aimed at effectively implementing data protection principles, such as data minimization, and integrating necessary safeguards into the processing. We seek to use appropriate and robust encryption algorithms (including hashing where possible) to encrypt your personal data. Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security. Should your personal information be compromised due to a breach of security, we will notify you immediately in accordance with applicable law. If you have any questions about the security of our App, you can contact us using the email or contact form displayed below. VIII. Changes to the Privacy Policy This Privacy Policy will be updated regularly. Whenever we make changes to this Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate. Depending on the circumstances, we may provide additional forms of notice of modifications or updates.

IX. Sharing of Consumption Data with Apple

As part of our commitment to providing a seamless experience for users, we may share specific consumption data with Apple to assist in refund request evaluations. This data may include details about your usage and interaction with purchased content. The sole purpose of sharing this data is to help Apple make informed decisions regarding refund requests.

We ensure that such data sharing is conducted in compliance with Apple’s policies and applicable privacy laws. Apple will handle this data according to its Privacy Policy and Platform Security Guidelines, and it will not be used for tracking or marketing purposes.

You retain the right to withdraw your consent for this data sharing at any time. If you withdraw your consent, we will cease sharing your data with Apple immediately for refund processing purposes. For further details on managing your privacy preferences, please visit privacy.apple.com.

X. How to Contact Us

If you have any questions about this Privacy Policy, please feel free to contact us at support@allapp.net.