Privacy Policy
Last updated: 14 July 2026
This Privacy Policy explains how ELITEHUB LIMITED ("Hallufox", "we", "us") collects, uses, shares, and protects personal data when you use the Hallufox website, apps, and services (the "Services"). It also explains your privacy rights and how to exercise them.
For the purposes of the EU and UK General Data Protection Regulation (GDPR), Hallufox is the data controller of your personal data. Our contact details are in Section 11.
In short: We collect the data needed to run your account, process payments, keep the platform safe, and improve our AI. We do not sell your personal data in the traditional sense. You can access, correct, or delete your data, and we keep it only as long as necessary.
Table of contents
- Data we collect
- How we use your data
- Legal bases (GDPR/UK GDPR)
- How we share data
- AI model training
- International transfers
- How long we keep data
- How we protect data
- Your privacy rights
- Children
- Contact and complaints
- Changes to this policy
1. Data we collect
Information you give us
- Account data: email address, username, password (stored in hashed form), and any age-assurance information.
- Profile and preferences: settings, AI Characters you create, and customization choices.
- Content: prompts, messages, uploads, and the outputs generated in your sessions.
- Payment data: handled by our payment processors. We receive limited transaction details (such as confirmation and the last digits of a card) but not your full card number.
- Support and communications: messages you send us and reports you submit.
Information we collect automatically
- Device and technical data: IP address, device type, browser, operating system, and app version.
- Usage data: pages viewed, features used, timestamps, and interaction logs.
- Cookies and similar technologies: see our Cookie Policy.
We do not ask you to provide sensitive personal information, and we ask that you do not share real-world identifying details (such as financial details, addresses, or passwords) inside conversations with AI Characters.
2. How we use your data
We use personal data to:
- create and manage your account and provide the Services;
- process payments, subscriptions, and token purchases;
- verify that you are an adult and prevent underage access;
- moderate content and keep the platform safe, secure, and free of abuse;
- respond to your requests, complaints, and support tickets;
- analyze usage to maintain, troubleshoot, and improve the Services;
- develop and improve our AI models and moderation tools (see Section 5);
- send service and, where permitted, marketing communications (you can opt out of marketing at any time); and
- comply with legal obligations and enforce our Terms of Service.
3. Legal bases (GDPR/UK GDPR)
Where GDPR or UK GDPR applies, we rely on the following legal bases:
- Contract — to provide the Services you sign up for.
- Legitimate interests — to secure the platform, prevent fraud and abuse, improve our products, and conduct analytics, balanced against your rights.
- Consent — for certain cookies and optional marketing; you can withdraw consent at any time.
- Legal obligation — to comply with laws, including age-protection and abuse-reporting requirements.
4. How we share data
We do not sell your personal data in the everyday sense. We share it only with:
- Service providers that help us operate the Services (hosting, storage, analytics, payment processing, customer support, content moderation), under contracts that limit their use of the data.
- Legal and safety recipients — authorities, regulators, or third parties where required by law, to respond to valid legal requests, or to protect the rights, safety, and security of users, the public, or Hallufox. This includes mandatory reporting of child sexual abuse material to the relevant authorities.
- Business transfers — a successor entity in the event of a merger, acquisition, or sale of assets, subject to this policy.
5. AI model training
We may use Content and usage data to train, fine-tune, and improve our AI models, content-moderation systems, and related technology. Where feasible, we take steps to reduce the personal data used for this purpose, such as aggregation or de-identification. Where the law requires consent or offers you a choice, we will provide it. You can contact us to ask about the options available to you.
6. International transfers
We may process and store data in countries other than your own. When we transfer personal data internationally, we use appropriate safeguards required by law, such as the European Commission's Standard Contractual Clauses or the UK International Data Transfer Agreement.
7. How long we keep data
We keep personal data only as long as needed for the purposes described here, including providing the Services, meeting legal obligations, resolving disputes, and enforcing our agreements. When data is no longer needed, we delete or anonymize it. Retention periods vary by data type; for example, account data is kept while your account is active, and certain records may be kept longer where the law requires.
8. How we protect data
We use technical and organizational measures designed to protect personal data, such as encryption in transit, access controls, and monitoring. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we work to protect your information and to respond appropriately to any incident.
9. Your privacy rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you;
- correct inaccurate data;
- delete your data ("right to be forgotten");
- restrict or object to certain processing;
- port your data to another provider;
- withdraw consent at any time; and
- opt out of the "sale" or "sharing" of personal data and of targeted advertising where applicable.
EU/UK residents (GDPR/UK GDPR) and California residents (CCPA/CPRA) have specific rights as described above. We will not discriminate against you for exercising your rights. To make a request, contact us using the details below. We may need to verify your identity first, and we will respond within the timeframe required by law.
10. Children
The Services are for adults only. We do not knowingly collect personal data from anyone under 18 (or the higher minimum age that applies where you live). If you believe a minor has provided us with data or is using the Services, contact us immediately and we will take prompt action, including deletion, in line with applicable law (such as COPPA, GDPR, and LGPD). See our Underage Policy.
11. Contact and complaints
To exercise your rights or ask a privacy question:
- ELITEHUB LIMITED
- Registered address: Leoforos Lordou Vyronos, 36 NICOSIA TOWER CENTRE, 6th floor, Flat/Office 601, Lefkosia, 1096, Nicosia, Cyprus
- Privacy email: contact@hallufox.com
12. Changes to this policy
We may update this Privacy Policy from time to time. We will post the new version here and update the "Last updated" date. If changes are material, we will provide additional notice where required.