Privacy Policy for HiReel

Effective Date: January 8, 2026

1. Introduction

HiReel ("Company," "We," "Us," or "Our") is committed to protecting and respecting your privacy. By this Privacy Policy (the "Policy"), we describe how we collect, store, use, and share ("process") your personal data when you download, install, and use the Hireel mobile application (the "App") available on the iOS App Store.

Summary of this Policy

• What data do we collect? We collect data you provide (like photos for AI generation), data automatically collected (device info), and data from third parties.
• Do we process sensitive personal data? We process Face Data strictly for AI generation features and do not store it. See Section 3.
• How do we use your data? To provide services, improve functionality, and comply with laws.
• Your Rights: Depending on your location, you may have rights to access, correct, or delete your data.

By downloading, registering with, or using this App, you agree to this privacy policy.

2. Personal Data We Collect

Depending on how you interact with our App, we may collect the following data:

2.1. Personal Data You Provide to Us

• User Content: Photos, videos, and text prompts you upload to utilize our AI generation features.
• Account Information: If you create an account, we collect your email address, username, and password. We may generate a unified ID for you.
• Feedback & Support: Records of your correspondence, including email addresses and crash reports, if you contact us.
• Payment Information: If you make purchases via Apple Pay (In-App Purchase), payment processing is handled by Apple. We may receive transaction receipts (e.g., subscription status, expiration date) but do not store your full credit card details.

2.2. Personal Data Automatically Collected

• Usage Data: Information about your interaction with the App, including click streams, feature usage, and editing activity.
• Device Information: Device model, operating system version (iOS version), unique device identifier (UDID/UUID), IP address, language settings, and time zone.

3. Face Data and Biometric Information (Crucial for iOS Compliance)

Hireel utilizes artificial intelligence technologies to generate stylized videos or images based on the photos you upload. This process involves the analysis of facial features ("Face Data").

In strict compliance with Apple's App Store Review Guidelines, we adhere to the following:

• Collection: We only collect Face Data from photos you explicitly select and upload for AI generation.
• Usage: Face Data is used exclusively to map expressions and movements onto generated characters.
• No Storage: We do not store your Face Data or original photos on our servers after processing.
• Immediate Deletion: Once the video/image is generated and delivered to your device, the original photos and derived Face Data are immediately and permanently deleted from our processing servers.
• No Sharing: We do not share Face Data with third parties. We do not sell Face Data.
• No Identification: We do not use Face Data to identify or authenticate individuals.

4. How We Use Your Data and Legal Bases

We only use your personal data when applicable laws allow us to. Below is an overview of our purposes and legal bases:

Purpose	Type of Data	Legal Basis
To provide the App and Services (account management, AI generation)	Account Info, User Content	Performance of Contract
To process payments and subscriptions	Transaction Data	Performance of Contract
To improve our App (analytics, bug fixing, stability)	Usage Data, Device Data	Legitimate Interests
To provide Customer Support	Feedback Info	Contract / Legitimate Interests
To send marketing communications (if opted in)	Contact Info	Consent
To comply with legal obligations (fraud prevention)	All relevant data	Legal Obligation

5. Cookies, Tracking Technologies & ATT

5.1. Tracking Technologies

We use technologies similar to cookies (such as mobile identifiers) to track the use of our Services, analyze trends, and administer the App.

5.2. App Tracking Transparency (ATT) - iOS Specific

To provide personalized ads or measure advertising effectiveness, we may use the Identifier for Advertisers (IDFA), subject to your permission.

On iOS 14.5+, we will ask for your permission via the ATT prompt:

• If you allow: We may use your IDFA to show relevant ads.
• If you ask App not to track: We will not access your IDFA.

You can change this in Settings > Privacy > Tracking.

6. How We Share Your Personal Data

We do not sell your personal data. We share data only for legitimate purposes:

• Service Providers: We share data with third-party vendors who help us operate the App (e.g., cloud hosting providers like AWS/Google Cloud for AI processing, customer support tools). They are bound by contract to protect your data.
• Affiliates: We may disclose data to our subsidiaries for business operations.
• Legal Requirements: We may disclose data if required by law, court order, or to protect our rights and safety.
• Business Transfers: In the event of a merger, sale, or reorganization, your data may be transferred as part of the transaction.

Note: As stated in Section 3, Face Data is NEVER shared with third parties for their own purposes.

7. International Transfers of Personal Data

We operate globally. Your personal data may be transferred to, stored, and processed in countries other than where you live (e.g., servers in the United States or Singapore).

If we transfer data outside the EEA/UK, we ensure adequate protection through measures like Standard Contractual Clauses (SCCs) or other lawful mechanisms to ensure your data remains secure.

8. Data Security and Retention

• Security: We implement technical and organizational measures (encryption, access controls) to protect your data. However, no internet transmission is 100% secure.
• Retention: We retain personal data only as long as necessary.
• Face Data: Deleted immediately after processing.
• Account Data: Retained until you delete your account.
• Usage Data: Retained for a limited period for analytics.

9. Your Privacy Rights

Depending on your location (e.g., EU, UK, Brazil), you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate data.
• Deletion: Request deletion of your account and data ("Right to be Forgotten").
• Restriction: Request to restrict processing of your data.
• Objection: Object to processing based on legitimate interests.
• Withdraw Consent: Withdraw consent at any time (e.g., for marketing).

To exercise these rights, contact us at hireel999@hotmail.com.

10. Additional U.S. State Disclosures

For residents of California, Colorado, Connecticut, Virginia, and Utah:

• Categories Collected: We collect Identifiers (email), Internet Activity (usage data), and Biometric Information (Face Data - transient use only).
• Do Not Sell or Share: We do not "sell" personal data for money. We may "share" identifiers (IDFA) for cross-context behavioral advertising if you consent via ATT. You can opt-out by selecting "Ask App Not to Track".
• Sensitive Data: We use Face Data (Sensitive Data) solely for the App's primary purpose (video generation) and not for inferring characteristics about you.

11. Third Party Services

Our App may contain links to third-party websites or services (e.g., social media logins). We are not responsible for the privacy practices of these third parties. Please review their privacy policies directly.

12. Children

Our App is not intended for children under 16. We do not knowingly collect data from children under 16. If we learn we have collected such data, we will delete it.

13. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you via an in-app alert or email. The "Effective Date" at the top indicates the latest revision.

14. Contact Us

If you have questions about this Policy or our privacy practices, please contact us:

Email: hireel999@hotmail.com