Privacy Policy

Last Updated: July 11, 2026

This Privacy Policy applies to the mobile application "Holos" (the "App"), owned and operated by Yiwu Heluo Network Technology Studio (operating under the trade names "Holos AI" and "Holos Labs", hereinafter "we", "us", or "our"), registered in the People's Republic of China.

1. Information We Collect and How We Use It

A. Android Sensitive Permissions & Accessibility Service API

Because the core functions of this App (AI floating bubbles, contextual reply suggestions, instant text translation) rely on system permissions, we strictly adhere to Google Play Developer Policies, User Data Policies, and Accessibility API Guidelines:

Prominent Disclosure & Affirmative Consent: In addition to this policy, before you grant the Accessibility Service permission for the first time, the App displays a prominent, blocking in-app disclosure dialog clearly detailing the specific data accessed, the purpose of use, and the security protections. Affirmative consent (Opt-in) is required before opening system settings. You may revoke these permissions at any time via Android System Settings or within the App.

B. Account Authentication Data

We provide account services via Firebase Authentication. When using Google Sign-in or email registration, we collect your email address, name, and profile URL, solely for identity verification, membership management, and account security.

C. Payment and Billing Data

This App processes membership subscription fees via Google Play Billing. All transactions are handled directly by the Google Play platform; we do not collect, process, or store your credit card or billing information on our servers.

2. Data Processing, Storage, and AI Integration

Local-First & Ephemeral Processing: Text captured via the Accessibility Service or Notification Listener is processed locally on your device in volatile memory.

Secure Encrypted Transmission: To generate smart replies, the minimal relevant message context is transmitted over industry-standard encrypted channels (TLS/HTTPS) directly to third-party Large Language Model (LLM) service providers (such as Gemini, OpenAI, DeepSeek) strictly for text inference. The data is processed ephemerally and is not retained or used for AI model training.

No Persistent Storage of Chat History: We do not permanently store or archive your chat conversations, messages, or personal communications on our servers. Temporary text context is immediately purged from memory once the reply suggestion is delivered.

No Data Sales or Advertising Tracking: We never sell, rent, trade, or distribute your personal information or chat content to any third parties for advertising or tracking purposes.

Cross-Border Data Transfer: Where necessary for AI processing, data transmission adheres to recognized international compliance standards (including GDPR Standard Contractual Clauses for EU/EEA users).

3. Third-Party Services

This App integrates the following trusted third-party SDKs, which may collect information to identify you according to their respective privacy policies:

4. International Compliance (GDPR & CCPA)

GDPR (EU Users)

Our legal bases for processing your personal data include: performance of a contract (providing the service), your explicit consent, and our legitimate interests.

You have the rights to access, rectify, erase, restrict processing, data portability, and object to processing.

CCPA (California Users)

Categories of personal information we have collected in the past 12 months include: Identifiers (email, name), account information, and (temporarily processed) communication content.

We do not "sell" or "share" your personal information as defined by the CCPA for monetary consideration.

5. Disclaimer Regarding Third-Party IM Platform Terms

Please Note: This App reads and responds to messages in third-party instant messaging apps via Accessibility Services/Notification Listener. By using this App, you acknowledge that you assume all risks of account restrictions, bans, or other consequences resulting from violations of these third-party platform terms; we bear no responsibility for such actions.

6. Data Security and Retention

We implement industry-standard technical and organizational measures to protect your data. Account data will be deleted from our systems within 30 days after account cancellation, unless otherwise required by law.

7. Children's Privacy

This service is not intended for children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children.

8. Changes to this Policy

We may update this Privacy Policy periodically. Any changes will be notified to you by posting the new version on this page and updating the "Last Updated" date.

9. Contact Us

If you have any questions, suggestions, or wish to exercise your data rights, please contact us at:

Support Email: support@holos.ing
EU Representative: eu@holos.ing