Privacy Policy

Effective Date: June 17, 2026

Developer: HA NOI WAREHOUSING DEVELOPMENT JOINT STOCK COMPANY
Country: Vietnam
Contact Email: [email protected]

Introduction

HA NOI WAREHOUSING DEVELOPMENT JOINT STOCK COMPANY ("we", "us", or "our") operates the PortalPix mobile application ("PortalPix" or the "App"). We are committed to protecting your privacy and the security of your personal information.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not use the App.

By using PortalPix, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. We may update this Privacy Policy from time to time. We will notify you of any changes by updating the "Effective Date" at the top of this policy.

1. Information We Collect

PortalPix is designed to minimize data collection. We only collect information that is necessary to provide our AI image generation services.

1.1 Information You Provide

Account Information:

• When you sign in with Apple, we receive your Apple ID email (which may be a private relay email) and name (if you choose to share it)
• We do not store or have access to your Apple password
• For guest users, we do not collect personal information, but we may generate a temporary anonymous identifier to track your in-app coin balance and generated content during your session

User Content:

• Photos you upload for AI generation
• Style preferences and generation parameters you select
• Generated AI images resulting from your use of the App

Facial Data: We do not collect, extract, store, use, or share any facial biometric data, facial recognition data, facial features, or biometric identifiers from your uploaded photos. Your uploaded photos are processed as image files solely for the purpose of AI style transformation, and we do not isolate, analyze, or extract any facial characteristics or biometric information from photos you upload.

Purchase Information:

• We do not collect or store your payment information. All purchases are processed through Apple App Store, and we only receive transaction confirmations and your in-app coin balance updates.

1.2 Information Collected Automatically

We do not automatically collect any device information, usage analytics, or performance metrics. The App operates with minimal data collection, and we do not use any third-party analytics services or tracking tools.

2. How We Use Your Information

We use your information for the following purposes:

1. To Provide Our Services:

   • Process your uploaded photos through our AI generation system
   • Apply your selected style preferences to generate images
   • Store your generated images in your in-app gallery (stored locally on your device and on our servers)
   • Manage your in-app coin balance, which is stored on our servers as part of your account information
   • Enforce content safety filtering for AI-generated images

2. Authentication and Account Management:

   • Authenticate your Sign in with Apple session
   • Allow you to delete your account and associated data

3. Service Improvement:

   • We do not use your uploaded photos or generated images to train our AI models
   • We do not extract or use any facial features, biometric data, or facial recognition information for AI model training or improvement
   • Service improvements are based on internal testing and development, not on user data collection

4. Compliance:

   • Comply with legal obligations and enforce our Terms of Service

3. Data Retention and Deletion

3.1 Photo and Generation Data

• Uploaded photos: Your uploaded photos are transmitted to our servers located in the United States solely for the purpose of AI image generation. Once generation is complete, your original photos and any intermediate processing files are permanently deleted from our servers.
• Facial data handling: During image processing, we do not extract, isolate, analyze, store, or retain any facial biometric data, facial features, facial recognition templates, or biometric identifiers from your uploaded photos. Processing is limited to pixel-level image transformation for style application only. No facial data is retained after generation is complete, and no facial data is used for any purpose other than the immediate style transformation you have requested.
• Generated images: Generated images are stored on our servers associated with your account to allow you to view, save, and access them across sessions. You may delete individual generated images from your gallery at any time, or delete all your generated images by deleting your account.
• AI training: We never use your uploaded photos, generated images, or any user content for training our AI models. We do not use any facial data or biometric information from user photos for model training or development.

3.2 Account Information

• Account information associated with Sign in with Apple, including your in-app coin balance and transaction history, is retained for as long as you maintain an active account
• When you delete your account through the "Delete My Account" option in the App, all associated account information, coin balance, transaction history, and server-stored generated images are deleted permanently.

3.3 Guest Data

• Guest user data (temporary identifiers, local coin balances) is stored locally on your device and is deleted when you log out or uninstall the App.

4. Data Sharing and Disclosure

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

1. Apple Services:

   • Your use of Sign in with Apple and in-app purchases is governed by Apple's Privacy Policy. Apple processes your authentication and payment information according to their own terms.
   • We do not share your personal information with any other third-party service providers, analytics companies, or advertising networks.

2. Legal Requirements:

   • We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

3. Business Transfers:

   • In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice in the App of any change in ownership or uses of your personal information.

5. Data Security

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

• Encryption of data in transit using HTTPS/TLS
• Secure server infrastructure hosted in the United States
• Access controls limiting employee access to user data that we retain (primarily account information and coin balances, as uploaded photos are deleted immediately after processing)
• Regular security assessments and updates

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

6. International Data Transfers

Your information, including uploaded photos and personal data, may be transmitted to and processed on servers located in the United States. Uploaded photos are not maintained on our servers after processing is complete, as described in Section 3. Account information, coin balances, and generated images associated with your account are stored on our servers in the United States.

The data protection laws in the United States may differ from those in your country of residence. By using PortalPix, you consent to the transfer of your information to the United States. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7. Your Rights

Depending on your location, you may have certain rights regarding your personal information. Given the minimal data we retain as described in this policy, the scope of data available under these rights may be limited. For example, uploaded photos are deleted after generation and will not be available for access or portability requests.

Access: You have the right to request copies of your personal account information that we hold.

Correction: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

Deletion: You have the right to request that we delete your personal information. You may exercise this right by using the "Delete My Account" feature in the App or by contacting us at the email provided below.

Restriction of Processing: You have the right to request that we restrict the processing of your personal information, under certain conditions.

Data Portability: You have the right to request that we transfer the account data we have collected to you, under certain conditions.

Objection: You have the right to object to our processing of your personal information, under certain conditions.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 calendar days.

8. Children's Privacy

PortalPix is not intended for use by children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and you believe that your child has provided us with personal information, please contact us so that we can take appropriate action.

We implement content safety filtering for all AI-generated images to prevent the creation of inappropriate or harmful content. Despite these safeguards, we recommend that minors use the App only under parental supervision.

If you reside in the European Economic Area (EEA), you must be at least 16 years old to use PortalPix.

9. Third-Party Links

The App may contain links to third-party websites or services, such as our Terms of Service and this Privacy Policy. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. We strongly advise you to review the privacy policy of every site you visit.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy in the App and updating the "Effective Date" at the top of this policy. We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted in the App.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: [email protected]

We will respond to your inquiry as soon as possible, within 30 calendar days.

Last Updated: June 17, 2026