Privacy Policy

This Privacy Policy describes how Nova Tech AI Limited ("Nova Tech AI," "we," "us," or "our"), a company incorporated under the laws of the Hong Kong Special Administrative Region of the People's Republic of China, collects, uses, discloses, and safeguards your information when you use our web applications, websites, and related services (collectively, the "Services").

We are committed to protecting your privacy and handling your personal data in an open and transparent manner. Please read this policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

1. Company Information

Nova Tech AI Limited is the data controller responsible for your personal data.

2. Information We Collect

2.1 Information You Provide Directly

• Contact Information: When you contact us via email or our feedback form, we collect your name, email address, and the content of your message.
• User Feedback: Any feedback, suggestions, or reports you voluntarily submit to us.

2.2 Information Collected Automatically

• Device Information: Operating system type and version, device model, and browser information.
• Usage Data: Information about how you interact with our applications, including features accessed, actions taken, and session duration.
• Log Data: IP address, browser type, referring URLs, pages viewed, and access timestamps.
• Crash Reports: Anonymized diagnostic data related to application errors.

2.3 Photo Data - Special Handling

Our Services (including RestorePic and FuneralPhoto) involve the processing of photographs submitted by users. We treat photo data with the highest level of care:

• Photos are transmitted using TLS 1.3 encryption.
• Photos are processed in isolated compute environments.
• Photos are permanently and automatically deleted from our systems immediately upon delivery of the processed result.
• We do not store, retain, index, analyze, or use photo submissions for any purpose other than immediate processing.
• We do not use photo submissions to train machine learning models without explicit, separate consent.

3. How We Use Your Information

• Service Delivery: To provide, operate, and maintain our Services.
• Service Improvement: To understand usage patterns and improve our applications.
• Customer Support: To respond to your inquiries and support requests.
• Security: To detect, prevent, and address fraud and security vulnerabilities.
• Legal Compliance: To comply with applicable laws and regulations.

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

4. Legal Basis for Processing (GDPR)

• Contractual Necessity: Processing required to provide the Services you requested.
• Legitimate Interests: Fraud prevention, security, and service improvement.
• Legal Obligation: Processing required by applicable law.
• Consent: Where we have obtained your explicit consent.

5. Data Sharing and Disclosure

• Service Providers: Trusted third-party vendors who assist in operating our Services, bound by confidentiality obligations.
• Legal Requirements: When required by applicable law or court order.
• Business Transfers: In connection with a merger or acquisition, subject to confidentiality obligations.
• Safety: Where necessary to protect the rights, property, or safety of users or the public.

6. Data Retention

• Photo Data: Deleted immediately and automatically upon delivery of processed results.
• Contact and Support Data: Retained for up to 12 months from the date of last interaction.
• Usage and Log Data: Retained for up to 90 days in identifiable form.

7. International Data Transfers

Nova Tech AI is based in Hong Kong SAR. Where data is transferred outside of the EEA or other jurisdictions with data transfer restrictions, we implement appropriate safeguards including Standard Contractual Clauses.

8. Children's Privacy

Our Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe your child has submitted personal information to us, please contact us at developer@novatechai.xyz.

9. Your Privacy Rights

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate data.
• Erasure: Request deletion of your personal data.
• Restriction: Request that we restrict processing of your data.
• Portability: Request transfer of your data in a machine-readable format.
• Objection: Object to processing based on legitimate interests.
• Withdrawal of Consent: Withdraw consent at any time where processing is based on consent.

To exercise these rights, please contact us at developer@novatechai.xyz. We will respond within 30 days.

10. Security

We implement industry-standard security measures including:

• TLS 1.3 encryption for all data in transit
• Encrypted storage for data at rest
• Access controls and authentication requirements
• Regular security assessments
• Automatic deletion policies for sensitive data

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last Updated" date. Your continued use of our Services following notice of changes constitutes your acceptance of the revised Privacy Policy.

12. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region of the People's Republic of China.

13. Contact Us

If you have any questions about this Privacy Policy, please contact us:

14. Product Domains

This Privacy Policy applies to the following product domains operated by Nova Tech AI Limited:

• https://restorepic.xyz
• https://funeralphoto.com