PRIVACY POLICIES

SKYLINK GLOBAL PUBLISHING PTE. LTD. (“us”, “we”, or “our”) operates the skylinkstudio.com website and Skylink Studio's mobile applications (the “Service”).

This policy explains data collection, use, and disclosure practices. By using the Service, users agree to information collection per this policy.

Definitions

  • Service: skylinkstudio.com website and Skylink Studio's mobile applications by SKYLINK GLOBAL PUBLISHING PTE. LTD.

  • Personal Data: Information about living individuals who can be identified from that data.

  • Usage Data: Data automatically generated through Service use (e.g., page visit duration).

  • Cookies: Small files stored on user devices.

  • Data Controller: Natural or legal person determining processing purposes and methods.

  • Data Processors / Service Providers: Entities processing data on behalf of the controller.

  • Data Subject / User: Living individuals using the Service.

Information Collection and Use

Face Data

Users may provide face images for editing features including face-swapping, avatar generation, and image enhancement.

AI Processing: User-selected photos may be sent to third-party AI services with explicit consent. Users are informed before data sharing.

What is NOT collected: Biometric identifiers or facial recognition data uniquely identifying persons.

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • Email address

  • Cookies and Usage Data

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies: We use Session Cookies to operate our Service.

  • Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

  • Security Cookies: We use Security Cookies for security purposes.

  • Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

SKYLINK GLOBAL PUBLISHING PTE. LTD. uses the collected data for various purposes:

  • To provide and maintain our Service

  • To notify you about changes to our Service

  • To allow you to participate in interactive features of our Service when you choose to do so

  • To provide customer support

  • To gather analysis or valuable information so that we can improve our Service

  • To monitor the usage of our Service

  • To detect, prevent and address technical issues

  • To provide you with news, special offers and general information about other goods, services and events which we offer

  • To enable photo editing features (face-swapping, avatar generation, image enhancements)

  • To improve user experience through AI-driven features

Face data is used solely for app features and is not used for marketing, profiling, or biometric identification.

Third-Party AI Services

Google Gemini API (Google LLC)

Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States

  • Data Sent: User-selected photos only (explicitly chosen for AI processing).

  • Purpose: AI-powered image generation including AI Photo, Hair Salon, Retouch, Effect, StyleMe, and other editing features.

  • Data Retention: Photos are processed in real-time and NOT stored beyond processing duration. Google does not use submitted photos for AI model training.

  • Data Protection: Data encrypted in transit using TLS/SSL. Subject to Google's Privacy Policy and Cloud Terms of Service. Google LLC complies with applicable data protection regulations.

  • User Consent: Clear consent dialog presented before first data transmission. Dialog discloses what data is sent, who receives it, and the purpose. Users must explicitly agree by tapping “Agree & Continue” before transmission.

  • Opting Out: Users may decline and continue using non-AI features without sharing data with third-party services. Consent may be revoked via app settings anytime.

Retention of Data

Face Data Retention

Face data is retained only during processing (typically seconds to minutes). All face data is permanently deleted immediately after the operation is completed. No face data is stored beyond the processing period.

Personal Data Retention

SKYLINK GLOBAL PUBLISHING PTE. LTD. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.

Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Data Sharing

Third-Party Sharing

Face data may be shared with trusted third-party AI service providers solely for the purpose of processing AI-powered photo editing features.

Currently Used Service: Google Gemini API (Google LLC) for AI image generation and editing.

Third-Party Requirements:

  • Do not retain face data after processing

  • Encrypt all data during transmission and processing

  • Delete all data immediately after operation completion

Consent Required: Users are informed within the app about data sharing details before any sharing occurs. Non-AI features process data internally on Skylink Labs servers without third-party sharing.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

SKYLINK GLOBAL PUBLISHING PTE. LTD. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If SKYLINK GLOBAL PUBLISHING PTE. LTD. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, SKYLINK GLOBAL PUBLISHING PTE. LTD. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

Server-Side Operations

Temporary storage on secure servers occurs only during processing operations. Data is encrypted using AES-256 or equivalent standards. Access is restricted to authorized personnel only with all access logged. Once operations are complete, all data is immediately and permanently deleted.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), SKYLINK GLOBAL PUBLISHING PTE. LTD. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

SKYLINK GLOBAL PUBLISHING PTE. LTD. may process your Personal Data because:

  • We need to perform a contract with you

  • You have given us permission to do so

  • The processing is in our legitimate interests and it is not overridden by your rights

  • For payment processing purposes

  • To comply with the law

Legal Requirements

SKYLINK GLOBAL PUBLISHING PTE. LTD. may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation

  • To protect and defend the rights or property of SKYLINK GLOBAL PUBLISHING PTE. LTD.

  • To prevent or investigate possible wrongdoing in connection with the Service

  • To protect the personal safety of users of the Service or the public

  • To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. SKYLINK GLOBAL PUBLISHING PTE. LTD. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

You have the following data protection rights:

  • The right to access, update or delete the information we have on you.

  • The right of rectification — the right to have your information rectified if that information is inaccurate or incomplete.

  • The right to object — the right to object to our processing of your Personal Data.

  • The right of restriction — the right to request that we restrict the processing of your personal information.

  • The right to data portability — the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

  • The right to withdraw consent — the right to withdraw your consent at any time where SKYLINK GLOBAL PUBLISHING PTE. LTD. relied on your consent to process your personal information.

Face Data Policy Summary

  • Usage: Avatar generation, face-swapping, and image editing features exclusively.

  • Sharing: Only with trusted third-party AI providers (Google Gemini API, Google LLC) with user consent for AI processing.

  • Storage: Temporary secure server storage with immediate deletion after processing.

  • Security: Encryption during transmission and storage.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

  • Firebase — Analytics service provided by Google Inc.

  • Unity Analytics — Provided by Unity Technologies.

Advertising

  • AdMob by Google — Provided by Google Inc.

  • AdColony — Provided by Jirbo Inc.

  • AppLovin — Provided by AppLovin Corporation.

  • Vungle — Provided by Vungle Inc.

  • Unity Ads — Provided by Unity Technologies.

Behavioral Remarketing

  • Google Ads (AdWords) — Provided by Google Inc.

  • Facebook — Remarketing service provided by Facebook Inc.

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS.

The payment processors we work with are:

  • Apple Store In-App Payments

  • Google Play In-App Payments

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

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

Email: contact@skylink.vn