This Privacy Policy explains how Yiwu Heluo Network Technology Studio (operating under the international trade names "Holos AI" and "Holos Labs", hereinafter referred to as "we", "us", or "our") collects, uses, processes, stores, and protects your personal data when you use:
- The Holos Android Application (the "App"), including its floating copilot, smart reply, on-device translation, and multimodal vision modules;
- The Holos Web Platform accessible at https://holos.ing (including the Web Chat Workbench, download centers, and checkout systems);
- The cloud synchronization APIs and edge services operating under api.holos.ing; and
- All related services, features, and content (collectively, the "Services").
OUR PRIVACY COMMITMENT: Holos is engineered with a strict Local-First and Data Minimization philosophy. We prioritize on-device machine learning (such as offline neural translation and private local GGUF models), transient memory execution, and zero retention of inference data. We NEVER sell your personal data, and we NEVER use your private messages, uploaded documents, or conversations to train public artificial intelligence models.
1. Android Sensitive Permissions & Data Access (Google Play Policy Compliance)
Certain core features of the Holos Android App rely on Android system permissions to deliver assistive floating tools, contextual smart replies, and instant translation. In strict compliance with Google Play Developer Program Policies, Google Play User Data Policies, and Accessibility API Guidelines, we detail below the exact scope, purpose, and protections governing these sensitive permissions.
A. Android Accessibility Service API (Strict User-Initiated Interaction)
The Holos App includes an Accessibility Service (SmartReplyAccessibilityService). We strictly adhere to the following principles:
- Specific Data Accessed: The Accessibility Service accesses only the visible on-screen text displayed within the active foreground window of supported instant messaging applications (specifically WhatsApp, Telegram, and Meta Messenger; it does NOT inspect WeChat screen nodes) or text explicitly highlighted by the user with the selection magnifier;
- Specific and Limited Purpose: The service is used exclusively to:
- Inspect the latest incoming message or active chat context solely to formulate relevant, multi-tone AI reply suggestions; and
- Backfill the user's selected reply suggestion directly into the target app's text input field upon user request;
- User-Initiated & On-Demand Operation Only: The Accessibility Service operates strictly upon active, affirmative user interaction (such as actively tapping the floating bubble, tapping the '⚡︎' Quick Reply shortcut, or dragging the screen magnifier). The App NEVER silently, passively, or continuously monitors, logs, scrapes, or records your screen, keystrokes, or background conversations;
- Assistive Action Scope (Strictly NO Automated Sending): The service performs assistive text insertion into the input field only. The App strictly refrains from automated UI clicking of "Send", "Submit", or "Dispatch" buttons. The user retains sole and exclusive control to review, edit, and manually send any message;
- No Excluded or Sensitive Data Harvesting: We do not use the Accessibility API to capture passwords, credit card numbers, biometric data, contact lists, phone logs, or complete chat history archives;
- No Sale, Advertising, or Data Brokering: Data accessed via the Accessibility Service is never sold, never rented, never transferred to data brokers, and never used for targeted advertising, marketing, or behavioral tracking;
- No System Abuse: We do not use the Accessibility API to alter system settings without user consent, circumvent Android permission frameworks, or impede user control;
- Prominent In-App Disclosure & Affirmative Consent: Prior to requesting Accessibility permission, the App presents a prominent, blocking disclosure explaining the exact data accessed, its purpose, and security safeguards. The user must provide explicit affirmative consent (Opt-In). You may revoke this permission at any time in Android Settings > Accessibility.
B. MediaProjection & Screen Capture Permission
- Specific Data Accessed: A single visual frame/screenshot of the active screen at the moment of invocation;
- Purpose: Used exclusively for full-screen OCR (Optical Character Recognition) and in-place AR translation overlay when you double-tap the floating ball or trigger screen translation;
- Ephemeral Processing: Screen capture frames are processed transiently in device memory. Captured frames are NEVER recorded as continuous video streams, never stored on disk, never uploaded for surveillance or advertising, and are deleted immediately once text extraction is complete.
C. Notification Listener Service
- Specific Data Accessed: Incoming notification text (sender name and message preview) originating from supported instant messaging applications (including WhatsApp, Telegram, Meta Messenger, and WeChat);
- Purpose: To detect incoming conversations and populate quick reply suggestions via standard Android RemoteInput;
- Data Minimization: Unrelated system notifications (such as banking alerts, email notifications, or system alerts) are ignored. Notification contents are never permanently logged on remote servers.
D. Microphone & Audio Data
- Specific Data Accessed: Audio streams captured via the device microphone;
- Purpose: Speech-to-text voice input within the conversation input capsule;
- 100% On-Device & Offline: Voice audio is transcribed entirely locally on your device using the offline
Whisper Tiny model. Audio streams are NEVER transmitted over the internet, never stored on any remote cloud server, and never used for voice biometric profiling.
E. Camera & Photo / Document Storage
- Specific Data Accessed: Photos captured via the camera or images and PDF documents explicitly selected by the user from the device file picker;
- Purpose: Multimodal visual question answering, diagram analysis, and document translation in ASK mode;
- Ephemeral Transmission: Selected media is converted into temporary Base64 representations and transmitted via encrypted TLS 1.3 to the vision AI endpoint solely for the duration of the inference request. The files are not retained for model training.
2. Information We Collect Across Web and Mobile Platforms
Depending on how you interact with Holos, we collect the following categories of data:
| Data Category |
Specific Data Items |
Collection Purpose |
Legal Basis (GDPR Art. 6) |
| Account & Identity |
Email address, display name, profile avatar URL, unique User ID (UID) via Google Sign-In or Resend OTP. |
Account authentication, membership verification, security, and multi-device session sync. |
Contractual Necessity (Art. 6(1)(b)) |
| Subscription & Payments |
Subscription tier (Free, Go, Pro, Max), purchase token, expiry date, order ID. (Raw payment cards are handled by Google Play / Stripe / PayPal). |
Delivering paid tier quotas, processing renewals, preventing billing fraud, tax compliance. |
Contractual Necessity (Art. 6(1)(b)) & Legal Obligation (Art. 6(1)(c)) |
| Local Memory & Preferences |
Selected personas (5 presets + 1 custom), tone settings, saved vocabulary in Vault (Ebbinghaus review schedules), and local chat history. |
Delivering personalized responses and language study reminders. Stored locally in Room DB (Android) or LocalStorage (Web). |
Consent (Art. 6(1)(a)) & Legitimate Interest (Art. 6(1)(f)) |
| Temporary / Guest Sessions |
Ephemeral prompts and model outputs when using Guest Mode or toggling "Temporary Chat". |
Transient inference. Not logged to Room DB, LocalStorage, or Firebase Realtime Database. |
Contractual Necessity (Art. 6(1)(b)) |
| Technical & Telemetry |
IP address (anonymized at edge), device model, OS version, app crash logs via Firebase Crashlytics. |
Edge security, rate limiting, DDoS mitigation via Cloudflare, diagnosing crashes, performance stability. |
Legitimate Interest (Art. 6(1)(f)) |
3. AI Architecture, Processing Tiers & Zero-Training Guarantee
Holos operates a multi-tiered artificial intelligence pipeline to maximize user privacy and computational speed:
3.1 Tier 1: 100% On-Device Local AI (Zero Network Egress)
- Google ML Kit Translation: On-device neural translation models downloaded locally (~30MB). Translations execute 100% offline with zero network requests;
- Hy-MT Private GGUF Engine: On-device large language model executed via native ARM
llama.cpp STQ JNI. Performs advanced translation and text refinement entirely within device RAM/NPU, completely offline;
- Whisper Tiny ASR: Local offline speech-to-text recognition running entirely on-device.
3.2 Tier 2: Cloud Edge Gateway (api.holos.ing)
Cloud AI requests are routed through our dedicated Cloudflare Workers API gateway (api.holos.ing), which enforces rate limiting, token budget caps, and sliding-window fraud defense. Payloads are processed in memory and encrypted with TLS 1.3 in transit.
3.3 Tier 3: Enterprise Cloud LLM Providers
For complex cloud queries, multimodal image analysis, and advanced reasoning, requests are routed to enterprise AI foundation model providers (such as DeepSeek).
STRICT ZERO-TRAINING GUARANTEE: We contractually mandate through enterprise API terms with our upstream LLM providers (including OpenRouter and DeepSeek) that user prompt inputs, conversation context, uploaded media, and generated outputs are NEVER used to train, retrain, fine-tune, or improve public or commercial AI models. Your data is processed purely for real-time stateless inference and is discarded immediately after completion.
4. Third-Party Service Providers
To deliver our Services securely and reliably, we partner with trusted third-party service providers. Each provider processes data strictly under their respective privacy policies:
- Google LLC (Google Play & Firebase):
- Firebase Authentication: User identity management and Google Sign-In;
- Firebase Realtime Database: Secure cross-device session synchronization;
- Firebase Crashlytics: Anonymized crash reports and stability monitoring;
- Google Play In-App Billing: Processing in-app subscriptions on Android devices. (See Google Privacy Policy).
- Cloudflare, Inc.: Provides edge API routing, DNS, CDN acceleration, DDoS protection, and secure R2 APK distribution (download.holos.ing). (See Cloudflare Privacy Policy);
- Payment Processors (Web Store): Stripe, Inc. and PayPal, Inc. process transactions initiated via our web checkout (https://holos.ing/checkout) under PCI-DSS Level 1 certification;
- Resend, Inc.: Used for transmitting transactional email verification codes (OTP);
- Enterprise LLM Partners: OpenRouter, Inc. (Privacy Policy) and DeepSeek (Privacy Policy), operating under zero-retention inference agreements.
5. Data Retention & User Data Deletion Instructions (Google Play Compliance)
A. Deleting Partial Data Without Deleting Your Account
Holos AI respects your granular control over your information. You may request or perform the deletion of specific, partial datasets without closing or deleting your Holos account:
- Chat Histories & Drafts: In the Holos Android app, navigate to Settings > Data Storage and select Clear Local History to purge all cached chats, or swipe/delete individual chat threads. If cloud synchronization is active, this also clears the respective remote records;
- Memory Vault: Go to Settings > Memory Vault to view and selectively clear personal facts, preferences, or your entire memory summary without affecting your subscription or profile;
- Vocabulary & Translation Records: You can delete individual translation history records or clear the entire vocabulary vault directly within the Translation tool;
- Email Request for Partial Data Erasure: Email support@holos.ing with the subject "Partial Data Deletion Request" specifying the email associated with your account and the specific categories of data (e.g., chat logs, memory records) you wish to have removed. We will process your request within 7 business days.
B. Complete Account & Personal Data Deletion
In full compliance with Google Play's Account Deletion Policy and global privacy frameworks (including GDPR Art. 17 and CCPA), you have the right to request the permanent deletion of your account and all associated personal data through any of the following channels:
- In-App Deletion: Open the Holos Android App, navigate to Settings > Profile (or Account Security), and tap Delete Account. This immediately removes local databases and triggers a remote wipe;
- Web Deletion: Log into your account on the Web Workbench at https://holos.ing, open Settings > Profile, and click Delete Account;
- Direct Web / Email Request: Submit an account deletion request by emailing support@holos.ing with the subject "Delete Account Request" from your registered account email.
C. Data Types Deleted, Retained, and Retention Periods
Scope of Deletion: Upon account deletion, your user credentials in Firebase Authentication, your cloud synchronized chat histories, memory profiles, cached tokens, and vocabulary vault are immediately severed and permanently removed from our active production databases within thirty (30) days.
Retained Data: Basic financial transaction metadata (such as Google Play subscription tokens and transaction IDs) is retained strictly as required by law, taxation, and accounting regulations for up to seven (7) years. No chat logs, prompt content, or AI interaction data is retained following account deletion.
6. International Privacy Rights (GDPR & CCPA/CPRA)
6.1 Rights for European Economic Area (EEA) and UK Users (GDPR)
If you are located in the EEA or the United Kingdom, you have the following rights regarding your personal data under the General Data Protection Regulation (GDPR) and UK GDPR:
- Right of Access (Art. 15): Obtain confirmation as to whether your personal data is processed, and receive a copy thereof;
- Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data;
- Right to Erasure ("Right to be Forgotten", Art. 17): Request deletion of your personal data where retention is no longer necessary;
- Right to Restriction of Processing (Art. 18): Restrict the processing of your data under certain conditions;
- Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, machine-readable format (e.g., JSON or Markdown export);
- Right to Object (Art. 21): Object to processing based on legitimate interests;
- Right to Withdraw Consent: Withdraw your consent at any time for features requiring consent (such as system permissions or optional memory profiling);
- Right to Lodge a Complaint: You have the right to lodge a complaint with your local Data Protection Authority (DPA) regarding our processing of your personal data.
To exercise any of these rights, contact our EU privacy representative at eu@holos.ing or email support@holos.ing.
6.2 Rights for California Residents (CCPA / CPRA)
Under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CPRA), California residents have specific statutory rights:
- Notice at Collection: The categories of personal information collected and the purposes for which they are used are outlined in Section 2 of this policy;
- No Sale or Sharing of Personal Information: We do NOT sell your personal information for monetary consideration. We do NOT share your personal information with third parties for cross-context behavioral advertising;
- Right to Know & Delete: You have the right to request disclosure of what personal information we collect and to request its deletion;
- Right to Correct: You have the right to correct inaccurate personal information;
- Non-Discrimination: We will not discriminate against you (e.g., by denying services or altering service quality) for exercising any of your CCPA/CPRA rights.
To submit a CCPA verifiable consumer request, email support@holos.ing with the subject "CCPA Request".
7. Disclaimer Regarding Third-Party IM Platform Terms
Holos operates as an on-demand, assistive text composition tool that interacts with third-party messaging applications (such as WhatsApp, Telegram, Meta Messenger, and WeChat) via standard Android accessibility (for supported apps) and notification frameworks strictly upon your direct invocation.
You acknowledge that you are responsible for ensuring that your usage complies with the terms and conditions of third-party platforms. We are not responsible for any actions, limitations, or account sanctions imposed on your accounts by third-party platforms.
8. Children's Privacy (COPPA & Global Standards)
Our Services are strictly not directed to children under 13 years of age (or under 16 in the EEA/UK). We do not knowingly collect, solicit, or maintain personal data from children under these age thresholds. If we discover that personal data of a child has been collected without verifiable parental consent, we will promptly take steps to delete such data from our systems. If you believe a child has provided us with personal information, please notify us immediately at support@holos.ing.
9. Data Security and Safeguards
We maintain comprehensive technical, physical, and organizational security measures to protect your personal data against unauthorized access, loss, destruction, alteration, or disclosure:
- Encryption in Transit: All data transmitted between the App, Web Workbench, Cloudflare Workers, and third-party APIs is encrypted using industry-standard TLS 1.3 / HTTPS protocols;
- Encryption at Rest: Cloud databases and authentication tokens are encrypted using AES-256 algorithms;
- Local Sandboxing: Android application data is protected by the Android Linux kernel application sandbox and encrypted device storage;
- Access Control: Administrative access to cloud services is governed by strict principle of least privilege, two-factor authentication, and IP whitelisting.
10. Changes to this Privacy Policy
We may periodically update this Privacy Policy to reflect modifications in our features, operational practices, or applicable legal and regulatory requirements. When revisions occur, we will update the "Last Updated" and "Effective Date" at the top of this document.
For material changes, we will provide prominent notification within the App (such as a dialog notice), through a website banner, or by email prior to the changes taking effect. We encourage you to review this page periodically to stay informed about our privacy practices.
11. Contact Us & Data Protection Inquiries
If you have any questions, concerns, complaints, or requests to exercise your data protection rights, please contact our privacy and data protection team:
Operating Entity: Yiwu Heluo Network Technology Studio (Holos Labs / Holos AI)
Data Protection & Privacy Contact: support@holos.ing
EU Representative Email: eu@holos.ing
AI Safety & Abuse Reports: abuse@holos.ing
Physical Address: Yiwu, Zhejiang Province, People's Republic of China
