Privacy policy
1. Introduction
Welcome to HoldDear.app ("we," "our," "us," or "Company"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI avatar service and website (the "Service").
2. Data Collection
2.1 Information You Provide
We collect the following information directly from you:
Name
Gender
Age
Email address
Responses to our website's quiz
Payment information (processed securely through our payment processors)
2.2 Automatically Collected Information
We automatically collect certain information when you visit, use, or navigate the Service:
Cookies and similar tracking technologies
Usage data and analytics prior to purchase
2.3 Conversation Privacy
We do not record or store conversations between users and AI avatars
Conversations are private and not accessible by us
Conversation data is processed in real-time only
3. Use of Your Information
3.1 Business Purposes
We may use your information for various business purposes, including:
Providing and maintaining our Service
Improving user experience
Processing payments and subscriptions
Responding to support requests
Preventing fraudulent activities
Complying with legal obligations
Analyzing usage patterns and trends
Developing new features and services
3.2 Analytics
We perform analytics only until product purchase
Post-purchase user behavior is not analyzed
Analytics are used to improve service functionality and user experience
4. Disclosure of Your Information
4.1 Third-Party Service Providers
We share your information with:
Google Cloud (infrastructure)
OpenAI (AI services)
Google Analytics (analytics)
Meta (analytics)
4.2 Additional Disclosures
We reserve the right to:
Share data with additional third parties without further notification when needed
Transfer data between the US and EU as necessary
Disclose information to law enforcement when legally required
Share information in connection with a business transaction (e.g., merger, acquisition)
5. User Rights and Control
5.1 Accessing Your Data
You can access your personal data:
Directly through the Service interface
By contacting support@holddear.app
5.2 Data Deletion
To request deletion of your data:
Contact support@holddear.app
We will process your request in a timely manner
Account deletion requests will remove all associated personal information
5.3 Data Retention
We retain user data for 180 days after subscription cancellation
After this period, data is automatically deleted
Certain information may be retained longer if required by law
6. Protection of Children
6.1 Age Verification
We verify user age through our website's quiz
Users must confirm they are 18 or older
We do not knowingly collect information from users under 18
6.2 Underage Users
If we discover a user is under 18:
Access to the Service will be immediately terminated
All collected data will be deleted
No refunds will be provided for any purchases made
7. Security Measures
7.1 Data Protection
We implement appropriate technical and organizational measures to maintain the safety of your personal information, including:
Industry-standard encryption protocols
Secure server infrastructure
Regular security assessments
Access control systems
Monitoring and logging systems
7.2 Data Breaches
In the event of a data breach:
We will assess the scope and impact
Notify affected users as required by law
Take immediate steps to prevent further unauthorized access
Cooperate with relevant authorities
7.3 Data Protection Officer
For privacy-related concerns:
Contact our Data Protection Officer at support@holddear.app
Response within 7 working days
Assistance with privacy-related requests and questions
8. Cookie Policy
8.1 What Are Cookies
Cookies are small text files that are stored on your device when you visit our website. They help us provide you with a better website experience by enabling certain features and collecting usage information. We use both session cookies (which expire when you close your browser) and persistent cookies (which stay on your device for a set period or until you delete them).
8.2 Cookies We Use
We use two primary types of cookies on our Service:
8.2.1 Essential Service Cookies
Type: First-party cookies
Purpose: These cookies are necessary for the website to function properly and cannot be switched off in our systems
Duration: Session-based
8.2.2 Analytics and Advertising Cookies
Google Analytics Cookies:
_ga: Used to distinguish users
Duration: 2 years
Purpose: Analytics and user tracking
_gid: Used to distinguish users
Duration: 24 hours
Purpose: Analytics and user tracking
_gat: Used to throttle request rate
Duration: 1 minute
Purpose: Performance
Meta Pixel Cookies:
_fbp: Used to deliver, measure and improve ads
Duration: 3 months
Purpose: Advertising and tracking
fr: Used for Facebook advertising
Duration: 3 months
Purpose: Advertising and tracking
8.3 Cookie Management
You can control and/or delete cookies as you wish. You can:
Delete all cookies that are already on your computer
Set most browsers to prevent cookies from being placed on your device
Configure your browser settings to accept or decline different types of cookies
Please note that if you disable or refuse cookies, some parts of the Service may become inaccessible or not function properly.
8.4 How to Manage Cookies
You can manage cookies through your browser settings. Here's how to do it in common browsers:
Chrome: Settings > Privacy and security > Cookies and other site data
Firefox: Options > Privacy & Security > Cookies and Site Data
Safari: Preferences > Privacy > Cookies and website data
Edge: Settings > Cookies and site permissions > Cookies and site data
8.5 Updates to Cookie Usage
We may update our use of cookies from time to time. Any changes will be reflected in this Cookie Policy, and significant changes will be notified to users as outlined in Section 11 of this Privacy Policy.
9. Marketing Communications
9.1 Marketing Emails
We may send marketing communications to users
Emails will include relevant Service updates and offers
We maintain the right to use data for targeted advertising in the future
9.2 Opting Out
You can opt out of marketing communications by:
Using the unsubscribe link in marketing emails
Contacting support@holddear.app
Your request will be processed within 10 business days
10. International Data Transfers
10.1 Data Location
We maintain servers in both the US and EU
Your information may be processed in either location
We reserve the right to transfer data between these locations
10.2 Transfer Safeguards
We ensure appropriate safeguards are in place for international transfers, including:
Standard contractual clauses
Appropriate security measures
Compliance with applicable data protection laws
11. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy at any time. We will notify you of any changes by:
Posting the new Privacy Policy on this page
Sending an email to users when material changes are made
Updating the "Last Updated" date at the top of this policy
12. Contact Us
If you have any questions about this Privacy Policy, please contact us:
Email: support@holddear.app
Address: Gedimino g. 22A-14, LT-44319, Kaunas, Lithuania