Halation Privacy Policy

1. Definitions and scope

• The app: the iOS camera app "Halation" developed by the Developer and distributed on the Apple App Store (Bundle ID: com.filmcam.ios).
• Developer / we: superwatermelon (an individual developer), the "personal information handler" under PIPL.
• You / user: any natural person who downloads, installs or uses the app.
• Personal information / sensitive personal information: as defined in Article 4 of PIPL.

This policy applies to all use of the app obtained through the Apple App Store and used on iOS devices. The app is not distributed on any other platform.

2. Item-by-item disclosure under PIPL Article 17

PIPL Article 17 requires a personal information handler, before processing personal information, to disclose the following matters prominently, clearly and understandably, truthfully, accurately and completely. Our disclosures, item by item:

Under China's Cybersecurity Law and the rules on app collection of personal information issued by the Cyberspace Administration and the Ministry of Industry and Information Technology, an app must publish its collection rules even when it collects no personal information. This policy is those rules.

3. We collect no personal information

• The app has no account system — nothing to sign up for or log into; we don't know who you are;
• The app contains no analytics, statistics, crash-reporting or advertising SDKs, and no third-party code;
• The app contains no tracking components — no cross-app, cross-device or cross-service tracking, no profiling, no automated decision-making;
• The app makes no network requests — it contains no networking components and declares no networking capability, and is therefore structurally incapable of connecting to the internet. "No data collected" is thus a structural guarantee, not merely a promise;
• We therefore have no access to your photos, location, contacts, device identifiers (IDFA/IDFV), clipboard or anything else.

The App Store privacy label accordingly reads "Data Not Collected," consistent with this policy.

4. What the app handles on your device

The following are created, exist and disappear locally on your device, managed by iOS, and inaccessible to the Developer:

• Camera frames — used for the live viewfinder and capture. Captured images are developed frame-by-frame on your device in the style of the selected film, then saved according to your actions;
• Photos in your library — with your permission, the app can:
  • Save developed photos to your photo library;
  • When you delete a negative in the app and choose to also delete the saved photo, locate and delete that photo, which the app itself previously saved. The app only recognizes and operates on photos it saved itself; it does not read or use anything else in your library.
• App settings — your selected film, format, exposure compensation, unfinished rolls and other preferences, stored locally only;
• Capture metadata (EXIF) — shown to you on the photo detail screen, and never leaves the device.

None of this is "provided to the Developer"; in the sense of PIPL, the Developer does not process it.

5. System permissions

You can revoke any permission at any time in iOS Settings › Privacy & Security; revocation does not affect photos already saved to your library. The app requests no other permissions — not location, microphone, contacts, Bluetooth, or local network.

6. Minors' personal information

The app collects no personal information from anyone, and therefore none from minors under fourteen; no processing requiring guardian consent takes place. The app contains no social features, chat, advertising or in-app purchases. Parents and guardians can let children use it under guidance, but should still encourage lawful and respectful photography.

If a guardian needs to address a minor's personal information handled outside this app's context, please contact Apple or the relevant service provider directly.

7. Sharing, sale, entrusted processing and cross-border transfer

None of these occur. The app has no network access and the Developer receives no data, therefore:

• no personal information is shared with any third party;
• no personal information is sold;
• no personal information is entrusted to any third party for processing;
• no personal information is jointly processed with any third party;
• no personal information is transferred across borders (data never leaves the device, let alone the country);
• no personal information is used to train algorithmic models.

Your photos live in your own photo library, protected by Apple's system and encryption mechanisms; that processing is governed by Apple's privacy policy.

8. Storage location and security

The Developer runs no servers and holds no user data. On-device data is protected by the iOS sandbox, device encryption and your passcode. Uninstalling the app removes the app and all of its locally stored settings; photos already saved to your library remain under your control in Photos. The risk of data leakage, tampering or loss is thereby confined to your device itself.

9. Data retention

The Developer stores none of your data — we have none to retain, so no retention period arises. Your on-device settings are removed when you uninstall; library photos are managed by you in the Photos app.

10. Your rights and how to exercise them

Under PIPL Chapter 4 and laws such as the GDPR, individuals have rights to know, decide, access, copy, correct, supplement, delete, withdraw consent, and demand explanation regarding their personal information.

Because the Developer collects and stores no personal information, these rights normally have no object in the context of this app — the data does not exist in the first place. If you nonetheless wish to assert a right, raise a question or complain, follow this procedure:

1. Email support@photooapp.com describing your request;
2. We will reply within fifteen (15) business days;
3. If you are unsatisfied with our response, seek remedies as described in Section 11.

11. Complaints and remedies

If you believe the app or this policy has infringed your lawful rights, you may:

• complain to the Developer (contact details in Section 13);
• report to China's national cyberspace authorities (Illegal and Harmful Information Reporting Center: hotline 12377, www.12377.cn);
• report to the App Store, or file suit with a people's court of competent jurisdiction.

12. Changes to this policy

If a future version introduces any networking feature, third-party component, new permission or any change in data handling, we will update this policy before release and announce it through an in-app notice or prominently on this page. We commit to stating any data collection clearly, explicitly and in compliance with PIPL beforehand — never silently — and, where required, seeking your consent again.

• 2026-10-31 · v2.0 — rewritten item-by-item against PIPL Article 17; added rights-exercise procedure, complaint channels, and minors' privacy clause;
• 2026-10-31 · v1.0 — first release.