Holo-Collector
The data controller responsible for processing your personal data under the Swiss Federal Act on Data Protection (revFADP/nFADP), the EU General Data Protection Regulation (GDPR), and equivalent regulations is:
Holo-Collector
Switzerland
Email: privacy@holo-collector.com
Legal form: Sole proprietorship registered in the canton of Aargau, Switzerland
The following table summarizes which personal data Holo-Collector processes and for what purpose. Details are provided in the relevant sections below.
You can register or sign in via two methods:
We process your email address and a hashed version of your password. This data is used to provide your user account and to enable account recovery.
When you use „Sign in with Apple" or Google Sign-In, we receive a unique user ID from Apple or Google and — if you choose to share it — your email address. Apple offers the option to use an anonymized relay email; we respect this choice.
Legal basis: Performance of contract under Art. 6(1)(b) GDPR (provision of the user account).
The core feature of Holo-Collector is identifying collectible figures from photos.
Important: By default, photos you take are stored only locally on your device (in your photo library or app storage). No automatic upload to our servers occurs. Recognition runs as on-device inference on your device.
Legal basis: Performance of contract under Art. 6(1)(b) GDPR. As long as no data is transmitted to us, this processing is not under our data-protection control.
If figure recognition produces an incorrect result, you can choose — via the „thumbs down" feature — to submit the image to us. We use such images to improve our recognition model (re-training).
Upload occurs only after your active, explicit consent (confirmation in the dialog). You are not required to provide images; the app remains fully usable without this feature.
Please ensure that uploaded images do not contain people, faces, or sensitive background information (e.g. addresses, documents). You are responsible for verifying that only the figure is visible before uploading.
You may withdraw your consent at any time with effect for the future and request deletion of any images you have uploaded. Send your request to privacy@holo-collector.com.
Legal basis: Consent under Art. 6(1)(a) GDPR.
For management of in-app subscriptions we use RevenueCat, Inc. (1 Letterman Drive, Building C, Suite C3-700, San Francisco, CA 94129, USA). RevenueCat processes the following data on our behalf:
The actual payment processing is handled by Apple's App Store or Google Play. We do not receive any credit card or banking details.
More information: revenuecat.com/privacy.
Legal basis: Performance of contract under Art. 6(1)(b) GDPR.
Our server infrastructure (including storage of voluntarily uploaded training images, see Section 5) runs on Microsoft Azure (Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland). Where possible, we choose European data centers.
For security and content delivery we use Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA). Cloudflare processes IP addresses and connection metadata to defend against attacks and optimize performance.
More information: cloudflare.com/privacypolicy.
Legal basis: Legitimate interests under Art. 6(1)(f) GDPR (secure and stable operation of the app).
Some of our processors (in particular RevenueCat and Cloudflare) are based in the United States. Where data is transferred to the US, this is based on the EU Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR or the corresponding Swiss Standard Contractual Clauses (Art. 16 revFADP), as well as — where applicable — the EU-US Data Privacy Framework and the Swiss-US Data Privacy Framework.
From the EU's perspective, Switzerland is recognized as a third country with an adequate level of data protection (EU Commission adequacy decision), allowing data transfers between the EU and Switzerland without additional safeguards.
For users outside the EU/EEA and Switzerland: by using the App, you acknowledge that your data may be processed in Switzerland, the EU, the United States, and other jurisdictions whose data-protection laws may differ from those of your country of residence.
If you are a resident of Switzerland, the EU, or the EEA, you have the following rights at any time under the Swiss revFADP and/or the GDPR:
You also have the right to lodge a complaint with a data-protection supervisory authority:
Holo-Collector is available worldwide. We apply the GDPR data-protection standard as a baseline to all users globally. In addition, the following regional provisions apply:
For users in the United Kingdom, the rights set out in the UK Data Protection Act 2018 and the UK GDPR — substantially equivalent to GDPR rights — apply. You may file complaints with the Information Commissioner's Office (ICO).
If you are a California resident, you have the following additional rights under the California Consumer Privacy Act (CCPA), as amended by the CPRA:
To exercise these rights, contact us at privacy@holo-collector.com. We will respond within 45 days as required by law.
Categories of personal information collected (last 12 months):
Users in Brazil have rights under the Lei Geral de Proteção de Dados (LGPD), substantially equivalent to GDPR rights.
Users in Canada have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA), including access to and correction of personal information.
Regardless of where you are located, you may exercise privacy rights at any time via privacy@holo-collector.com.
We employ appropriate technical and organizational measures to protect your data — including TLS encryption in transit, hashed passwords, access controls, and regular security updates.
Holo-Collector is not directed at children under the age of 13 (or 16 in some EU countries). We do not knowingly collect personal data from children below this age. If you are a parent or guardian and believe your child has provided us with personal data, please contact us — we will delete it promptly.
We may update this Privacy Policy to reflect new features or changing legal requirements. The current version is always available at holo-collector.com/en/privacy. For material changes, we will additionally notify you in the app.
For questions about data protection, exercising your rights, or deleting your data, please contact:
Email: privacy@holo-collector.com