Effective date: 20/08/2025

Inter Platforms Pty Ltd ("we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and protect your information when you use Halo, our AI skincare application.

1. Information We Collect

When you use Halo, we may collect the following types of information:

• Personal Information: such as name, email address (if provided), and payment details (processed securely by third-party providers).
• Skin & Routine Data: photos you upload, skincare preferences, and responses to questionnaires.
• Usage Information: how you interact with the app (e.g., features used, time spent).
• Device Information: such as device type, operating system, and app version.

We only collect information necessary to provide and improve the Halo service.

2. Face Data (Photos)

Halo allows you to upload selfies to track your skincare progress over time.

Retention: Uploaded photos are stored securely for as long as you maintain your Halo account. When you delete your account, all stored photos are permanently deleted.

Purpose: Photos are used only to analyze visible skin conditions (such as acne, redness, or texture) and to generate progress reports and personalized skincare routines.

Length of Storage: Photos are stored only while your account is active, so that you can review and compare your skin progress over time. We do not retain photos indefinitely once your account is deleted.

Biometric Data: We do not create, collect, or store biometric identifiers (such as facial recognition templates or faceprints). Analysis is limited to visible skin conditions.

Third Parties:

• We use trusted third-party service providers, such as Amazon Web Services (AWS), to securely host and process user data (including uploaded photos). These providers act only as data processors on our behalf and do not access, use, or retain your photos for any purpose other than providing the Halo service.
• In some cases, we may use additional secure third-party services to process uploaded photos for analysis. These providers delete the photos immediately after analysis and do not store face data beyond what is necessary to deliver the service.

3. How We Use Your Information

We use your information to:

• Provide personalized skincare routines and recommendations.
• Improve and enhance app features and performance.
• Communicate with you regarding updates, new features, and support.
• Ensure security, fraud prevention, and compliance with applicable laws.

4. Data Storage & Security

• Your data is stored securely on servers located in the United States using Amazon Web Services (AWS)..
• We use industry-standard encryption and security practices to protect your information.
• Access to your personal data is restricted to authorized personnel only.

5. Data Sharing

We do not sell, rent, or trade your personal information to any third party.

We may only share data in the following limited circumstances:

• With service providers (such as AWS, generative model providers, and payment processors) who assist in delivering the Halo service, under strict confidentiality agreements.
• Where required by law, regulation, or legal process.

6. Your Rights

As a user, you have the right to:

• Access, correct, or update your personal information.
• Request deletion of your data.
• Withdraw consent for data processing (which may limit app functionality).

7. Data Retention

We retain your information only as long as necessary to provide the Halo service, comply with legal obligations, and resolve disputes. Data that is no longer required will be securely deleted. You may delete your account at any time, and all of your data will be immediately deleted.

8. Children's Privacy

Halo is not directed at individuals under the age of 13. We do not knowingly collect personal information from children.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be reflected by the "Effective Date" at the top of this page. Significant changes will be communicated to you through the app or by email (if provided).