1. Who We Are

This Privacy Policy explains how TON4STUDIO LLC (“Company”, “we”, “us”) collects, uses, shares, and protects personal information in the Hugami mobile application (the “Application”).

Controller: TON4STUDIO LLC, 254 Chapman Rd, Ste 208 #23632, Newark, Delaware 19702, USA.
Contact: main@ton4studio.com

2. Scope

This Policy applies to users of the Application worldwide. By using the Application, you acknowledge that your information may be processed in the United States and other countries where we or our service providers operate.

3. Information We Collect

3.1 Information You Provide

• Images and prompts you upload to generate content.
• Generated text and preferences (e.g., language, templates).
• Account details if you create an account (name, email, password hash).
• Support communications (messages, attachments, contact details).

3.2 Information Collected Automatically

• Device and usage data: device model, OS version, app version, time zone, settings, and log data (timestamps, crash reports, diagnostics).
• Analytics events about how you use features (e.g., feature taps, session duration).
• Approximate location derived from IP address (city/region level), where necessary for fraud prevention, pricing, or legal compliance.

3.3 Subscription & Payments

Subscriptions are processed by app stores (Apple App Store, Google Play). We receive transaction metadata (e.g., subscription status, country, masked identifiers). We do not receive your full payment card details. App stores act as independent controllers for their processing.

4. How We Use Information (Purposes & Legal Bases)

• Provide and operate the Application (process images, generate text, personalize features). Legal basis: contract performance; legitimate interests.
• Account and subscription management (restore purchases, verify eligibility). Legal basis: contract performance.
• Safety, security, and abuse prevention (detect prohibited content, prevent fraud, enforce Terms). Legal basis: legitimate interests; legal obligation.
• Analytics and product improvement (aggregate usage stats, diagnostics, crash logs). Legal basis: legitimate interests; consent where required.
• Communications (service notices, updates, support). Legal basis: contract performance; legitimate interests.
• Legal compliance (tax, accounting, requests from authorities). Legal basis: legal obligation.

5. AI Processing

The Application uses automated systems to analyze your images and generate text. Outputs may be inaccurate or reflect model limitations. Review outputs before use and avoid uploading sensitive personal data unless necessary.

6. Sharing of Information

We share personal information only as described below:

• Service providers (processors) who host, store, analyze, and support the Application (e.g., cloud hosting, analytics, crash reporting, content moderation). They act under contracts and process data only on our instructions.
• App stores (Apple, Google) for subscriptions and compliance; they may receive device and purchase data.
• Legal and safety when required by law, to protect users, our rights, or prevent harm.
• Business transfers in connection with a merger, acquisition, or asset sale, subject to this Policy or a comparable policy.

We do not sell your personal information for money. We also do not share personal information for cross-context behavioral advertising without your consent.

7. Data Retention

We retain personal information only for as long as necessary to provide the Application, fulfill the purposes described above, and meet legal obligations, then delete or anonymize it.

8. International Transfers

We may transfer and store information in countries outside your own (including the United States). Where required, we implement appropriate safeguards, such as Standard Contractual Clauses for transfers from the EEA/UK/Switzerland.

9. Your Rights

Your rights depend on your location and may include:

• Access to your data and portability.
• Correction (rectification) and deletion (erasure).
• Restriction or objection to processing based on legitimate interests.
• Withdraw consent at any time where processing is based on consent.

To exercise rights, contact us at main@ton4studio.com. We may request information to verify your identity and will respond within applicable timeframes.

9.1 California (CCPA/CPRA)

California residents have the rights to know, delete, correct, and opt out of “sharing” for cross-context behavioral advertising. We do not sell personal information. You may authorize an agent to make requests on your behalf.

9.2 EEA/UK

If you believe we have not resolved your concern, you may lodge a complaint with your local data protection authority.

10. Children’s Privacy

The Application is not intended for children under 13 (or the age required by local law). In the EEA/UK, we do not knowingly process data of users under 16 without verifiable parental consent. If you believe a child has provided personal data, contact us to delete it.

11. Security

We implement reasonable technical and organizational measures to protect personal information (e.g., encryption in transit, access controls). However, no system is completely secure, and we cannot guarantee absolute security.

12. Managing Your Data

• You can delete images and generated content stored in the Application.
• You may turn off analytics/crash reporting in device settings or within the Application (where available).
• To close an account or request deletion, email us at main@ton4studio.com.

13. Third-Party Links and SDKs

The Application may include links or SDKs from third parties (e.g., app stores, analytics). Their processing is governed by their own privacy policies.

14. Changes to This Policy

We may update this Policy from time to time. If changes are material, we will provide notice (e.g., in-app notice or email) and indicate the new effective date. Your continued use of the Application after the effective date signifies acceptance.

15. Contact

Questions or requests about privacy? Contact: main@ton4studio.com
Postal address: TON4STUDIO LLC, 254 Chapman Rd, Ste 208 #23632, Newark, DE 19702, USA