EYE HOME CLINIC II Privacy Policy

PRIVACY POLICY FOR EYE HOME CLINIC II (English Version)
Effective Date: July 4, 2025

GANA Holdings Inc. provides the EYE HOME CLINIC II app ("App") as a commercial application. This Privacy Policy explains how we collect, use, protect, and share your information when you use the App. By using the App, you agree to this Privacy Policy and the collection and use of your information as described below. If you do not agree, please do not use the App. The terms used here have the same meanings as in the EYE HOME CLINIC II User Agreement unless otherwise defined.

1. INFORMATION WE COLLECT

We collect the following types of information to provide and improve the App’s services:

• Personal Information: You may provide personal information such as your email address for account creation or communication purposes.
  
  

• Photos and Data: The App collects anterior segment (eye) photos you submit for analysis, along with related data (e.g., image metadata). These photos focus on the eye area and are not used for facial recognition or identity identification. While the App is designed to capture only the eye area, a small portion of surrounding facial features (e.g., eyelids, eyebrows) may inadvertently be included in the frame. These photos are processed solely to provide feedback on image quality (e.g., clarity, brightness).
  
  

• Usage Data: We collect information about how you use the App, such as device type, operating system version, and email, to improve performance and diagnose issues.
  
  

• Log Data: In case of errors, we collect technical data (e.g., device details, crash reports) via third-party services to enhance App functionality.
  
  

• Face Data Clarification: The App does not collect or process face data for facial recognition, biometric identification, or identity verification. Anterior segment photos are limited to the eye area and are used exclusively for non-diagnostic, educational purposes. Any incidental capture of facial features is not used to identify individuals.
  
  

2. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

• To provide the App’s services, such as analyzing anterior segment photos for image quality and providing educational feedback.
  
  

• To improve the App’s performance, features, and user experience.
  
  

• With your explicit consent, to use anonymized data (e.g., aggregated image quality metrics) for research, system improvement, or algorithm validation. You can withdraw consent at any time via in-app settings.
  
  

• To communicate with you, such as responding to inquiries or sending service updates.
  
  

No Medical Use: The App does not use your data for medical diagnosis or treatment. All services, including photo analysis and feedback, are for informational and educational purposes only.

Face Data Usage: Anterior segment photos are processed to evaluate image quality (e.g., focus, lighting) and may be reviewed by experts for educational feedback. These photos are not used for facial recognition, biometric analysis, or identity identification. Any incidental facial features captured are not analyzed or stored for identification purposes.

3. THIRD-PARTY SERVICES

We use third-party services to support the App’s functionality. These services may access your data only to perform specific tasks and are bound by contractual obligations to protect your information. These include:

• Firebase: For analytics, crash reporting, and secure data storage (using HTTPS and AES-256 encryption).
  
  

• Google Drive API / Google Sheets API: For secure data processing and storage.
  
  

• Google Analytics for Firebase: To analyze App usage and improve services.
  
  

You can review the privacy policies of these providers for more details.

Face Data and Third Parties: Anterior segment photos are processed via Firebase and Google Drive API for analysis and storage. These services do not use photos for facial recognition or other purposes beyond what is specified in this policy.

4. DATA SHARING

We do not share your personal information with third parties except:

• With third-party service providers (e.g., Firebase, Google APIs) to facilitate the App’s services, as described above. These providers are contractually prohibited from using data for purposes other than service delivery.
  
  

• With your explicit consent, anonymized data (e.g., aggregated image quality metrics) may be shared for research or system improvement. Anterior segment photos are not shared in identifiable form.
  
  

• When required by law or to protect the rights, safety, or property of GANA Holdings Inc. or others.
  
  

Face Data Sharing: Anterior segment photos are not shared with third parties for advertising, marketing, facial recognition, or identity verification purposes. Anonymized data derived from photos may be used for research only with your consent, obtained via in-app settings.

5. ADVERTISING AND TRACKING

The App may display ads to provide certain features. We may use third-party advertising services that collect data to deliver personalized ads. You can opt out of personalized advertising through your device settings (e.g., Android advertising preferences or Google settings). Disabling tracking may limit some features but will not affect core functionality. Anterior segment photos are not used for advertising or tracking purposes.

6. COOKIES

The App does not directly use cookies. However, third-party services may use cookies or similar technologies to enhance functionality. You can accept or decline these via device settings, but declining may limit some features.

7. DATA SECURITY

We use commercially reasonable measures, including HTTPS protocols and AES-256 encryption, to protect your information, including anterior segment photos. However, no method of internet transmission or electronic storage is 100% secure. While we strive to safeguard your data, we cannot guarantee absolute security.

8. DATA RETENTION AND DELETION

We retain your personal information, including anterior segment photos, only as long as necessary to provide the App’s services or comply with legal obligations.

• Anterior segment photos are deleted immediately after analysis unless retained for optional expert review (with your consent).
  
  

• Photos are not stored beyond the analysis process unless explicitly authorized.
  
  

• To request deletion of your data, use the “Request Data Deletion” button in the App’s settings menu. Requests are processed immediately, and data deletion is completed within 3 days.
  
  

• Anonymized data used for research may be retained indefinitely but cannot be linked to you.
  
  

• If the App’s services are discontinued, we will delete all personal information, including anterior segment photos, unless required to retain it by law.
  
  

9. LINKS TO OTHER SITES

The App may contain links to external websites. We are not responsible for their content or privacy practices. Please review the privacy policies of any third-party sites you visit.

10. CHILDREN’S PRIVACY

The App is not intended for users under 13. We do not knowingly collect personal information, including anterior segment photos, from children under 13. If we learn that a child under 13 has provided personal information, we will delete it immediately. Parents or guardians can contact us if they believe their child has provided such information.

11. INTERNATIONAL DATA TRANSFERS

Your data, including anterior segment photos, may be processed or stored in countries outside your region, including the Republic of Korea. We ensure compliance with applicable data protection laws (e.g., GDPR, CCPA) for all transfers.

12. YOUR RIGHTS

You have the right to:

• Access, correct, or delete your personal information, including anterior segment photos.
  
  

• Withdraw consent for anonymized data use (e.g., for research) via in-app settings.
  
  

• Opt out of non-essential data collection (e.g., analytics or personalized ads) where applicable.
  
  

• Contact us to exercise these rights or for questions about your data.
  
  

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically. Changes will be posted on this page, and users will be notified via in-app announcements. Continued use of the App after changes constitutes acceptance of the updated policy. We reserve the right to modify this Privacy Policy at any time without prior notice, subject to applicable laws.

14. SUBSCRIPTION AND USAGE

Some features require viewing ads or subscribing ($2.99/month, auto-renewable, up to 20 analysis requests/month). Manage subscriptions via Google Play account settings.

15. CONTACT US

For questions or to exercise your rights, contact:
GANA Holdings Inc.
Email: drgby@ganaholdings.com
Address: 64, Apsansunhwan-ro 87-gil, Nam-gu, Daegu, Republic of Korea 203

Data Deletion Requests: Use the “Request Data Deletion” button in the App’s settings. Requests are processed immediately, and data deletion is completed within 3 days.

This Privacy Policy complies with Google Play requirements and applicable data protection laws, including but not limited to GDPR, CCPA, and the Personal Information Protection Act of the Republic of Korea.