Privacy Policy
Effective Date: September 8, 2026
Last Updated: September 8, 2026
This Privacy Policy explains how Halley Trade and Service Co., Ltd. ("Foneo", "Foneo AI", "we", "us", or "our") collects, uses, processes, stores, and protects information when you use Foneo AI, including our website at https://foneoai.com/, our desktop and mobile applications, and related services (collectively, the "Services").
Foneo is an AI-powered photo editing and image processing service. We understand that the photos you process through Foneo may include personal, professional, client, or otherwise sensitive content. Protecting the privacy of this content is an important part of how Foneo is designed and operated.
By using the Services, you acknowledge the practices described in this Privacy Policy. Where required by applicable law, we will request your consent before processing certain types of personal data.
1. Who We Are
Foneo AI is operated by:
Halley Trade and Service Co., Ltd.
Business Registration No./Tax Code: 0315059335
Issued on: May 22, 2018
Issuing Authority: Ho Chi Minh City Department of Planning and Investment
Address: 121/4 Truong Chinh, Dong Hung Thuan Ward, Ho Chi Minh City, Vietnam
Email: [email protected]
Phone: +84 81 9900 003
For purposes of applicable data protection laws, Halley Trade and Service Co., Ltd. acts as the controller of personal data collected through Foneo, except where otherwise specified.
2. Information We Collect
We collect only information that is reasonably necessary to provide, secure, improve, and support the Services.
2.1 Account Information
When you create or maintain a Foneo account, we may collect information such as your name, email address, phone number, authentication credentials, and account preferences.
You may also create or access your account using Google Sign-In or Sign in with Apple. When you use these services, we may receive information made available by the relevant provider, such as your name, email address, and a provider-specific account identifier, depending on your settings and the information you choose to share.
We do not receive your Google or Apple account password.
2.2 Photos and Image Content
When you use Foneo to edit or process photos, the images you select are transmitted to Foneo's cloud infrastructure for processing.
Foneo does not permanently store your uploaded or processed photos.
Uploaded images and generated or processed results may remain temporarily on Foneo's servers for up to approximately 48 hours for purposes such as processing, delivering results, and allowing you to retrieve your completed images. After this period, the images are automatically and permanently removed from Foneo's storage systems.
Foneo is not intended to function as a permanent cloud photo storage or backup service. You are responsible for saving any images you wish to keep to your own device or storage system.
2.3 Processing History
Foneo may retain limited information about your image-processing activity so that you can view or reuse your processing history.
This may include information such as prompts, selected templates, processing settings, timestamps, or similar processing metadata.
The images themselves are not retained as part of this long-term processing history after the temporary image-storage period described above.
Processing history remains associated with your account until you delete it, delete the relevant history where such functionality is available, or delete your Foneo account.
2.4 Device, Technical, and Security Information
To operate and secure the Services, Foneo may collect technical information such as a Foneo-generated Device ID, IP address, operating system information, application version, device or system information, connection information, and security or diagnostic logs.
Foneo generates its own Device ID for purposes such as account security, device management, fraud prevention, abuse prevention, licensing, service integrity, and troubleshooting.
We do not use the Foneo Device ID to track you across unrelated third-party applications or services for advertising purposes.
2.5 Website Analytics
We use Google Analytics on the Foneo website to better understand how visitors interact with our website.
Google Analytics may process information such as browser type, device information, pages visited, interactions, referring pages, approximate location derived from network information, and similar website usage data.
Google Analytics is currently used for the Foneo website and is not used to analyze the contents of photos processed through the Foneo application.
Google may process information according to its own privacy policies and applicable data protection terms.
Where applicable law requires consent for non-essential analytics cookies or similar technologies, we will request such consent before activating them.
2.6 Customer Support and Error Reports
When you contact Foneo support or submit an error report, we may collect the information you voluntarily provide, including your email address, description of the problem, technical information, logs, and attachments.
During normal use of Foneo, Foneo employees do not access or view the photos you process.
A Foneo employee may view a photo only when you intentionally attach or submit that photo as part of a support request, error report, or similar communication requiring investigation.
Images submitted for customer support are used only for the purpose of investigating and resolving the relevant issue and are retained only for as long as reasonably necessary to complete that support process, after which they are deleted.
2.7 Transaction and Payment Information
Foneo may collect transaction-related information such as the service plan purchased, payment status, transaction identifier, payment date, amount, and other information necessary to manage your purchase or account.
Payments may be processed through third-party payment providers, including PayPal and SePay.
Foneo does not store your payment card number, bank account credentials, PayPal password, or other complete payment credentials. Such information is processed directly by the applicable payment provider under its own privacy and security policies.
3. How We Use Information
We use personal data and other information collected through Foneo to provide and operate the Services; create, authenticate, and manage user accounts; process images and deliver requested results; maintain processing history; process and confirm payments; provide customer support; diagnose technical problems; maintain system security; manage devices and licensing; detect fraud, abuse, unauthorized access, or violations of our Terms; analyze and improve the Foneo website; send essential account and service communications; and comply with applicable legal obligations.
We may also use information to protect Foneo, our users, our infrastructure, and third parties from security threats, fraud, misuse, or unlawful activity.
4. How Foneo Handles Your Photos
Your photos are processed for the purpose of performing the editing or image-processing operation that you request.
Foneo does not claim ownership of photos that you upload to the Services.
Foneo does not permanently retain your uploaded photos or processed images. Temporary copies used for processing and result delivery are automatically deleted within approximately 48 hours.
Foneo employees cannot ordinarily browse or access users' photos.
The only ordinary circumstance in which Foneo personnel may manually view an image is when you voluntarily submit that image to us as part of a support request or error report.
5. AI Training and Your Content
Foneo does not use your uploaded photos, processed photos, reference images, or other image content to train Foneo's AI models.
Your photos are processed only as necessary to provide the image-editing or AI-processing function you request, maintain security, troubleshoot a problem you specifically report, or comply with applicable law.
We do not sell user photos, provide user photos to advertisers, or use user photos for advertising purposes.
6. Facial Analysis and Face-Related Features
Certain Foneo features may need to temporarily analyze facial characteristics in an image in order to perform functions such as facial enhancement, retouching, makeup, face-related image editing, face replacement, or similar requested operations.
During processing, Foneo may temporarily generate technical information such as facial landmarks, facial features, or similar machine-readable representations necessary to perform the requested operation.
This information exists only as necessary during the processing operation and is deleted after processing is completed.
Foneo does not use this information to identify who a person is, authenticate a person's identity, track individuals across services, build identity profiles, or create a permanent facial-recognition database.
Foneo does not use facial analysis data to train its AI models.
7. Service Communications
Foneo may send you service-related emails necessary to operate your account.
These communications may include account registration or verification messages, payment confirmations, subscription or service-plan notifications, notices that your plan or credits are approaching expiration, security alerts, important product or service notices, and customer support communications.
Foneo does not automatically add users to a promotional advertising email list merely because they create a Foneo account.
Where we offer optional promotional or marketing communications in the future, we will provide appropriate choices and opt-out mechanisms as required by applicable law.
8. When We Share Information
We do not sell your personal data.
We may disclose limited information to service providers that help us operate Foneo, only to the extent reasonably necessary for them to provide their services.
These providers currently include Cloudflare for network, security, and infrastructure-related services; Amazon Web Services / Amazon SES for email delivery; Google Analytics for website analytics; and PayPal and SePay for payment processing.
Foneo's AI image-processing workloads are performed using infrastructure operated by Foneo, including GPU servers located in the United States and Japan.
When you choose Google Sign-In or Sign in with Apple, information is also exchanged with Google or Apple as necessary to complete authentication.
We may also disclose information where reasonably necessary to comply with applicable law, a court order, legal process, or a valid request from a competent authority; protect the rights, safety, property, or security of Foneo, our users, or others; investigate fraud, abuse, security incidents, or unlawful activity; or establish, exercise, or defend legal claims.
Our service providers are permitted to process information only for the purposes for which the information is provided to them and subject to applicable contractual and legal obligations.
9. International Data Transfers
Foneo is operated from Vietnam and provides Services to users internationally.
Depending on where you are located, your information may be transferred to or processed in countries other than your country of residence, including Vietnam, the United States, and Japan.
Privacy and data protection laws may differ between jurisdictions.
Where applicable data protection law requires additional safeguards for international transfers of personal data, we take reasonable steps to use appropriate legal and contractual mechanisms for those transfers.
10. Data Retention and Deletion
Foneo follows a data-minimization approach and does not retain information longer than reasonably necessary for the purposes described in this Privacy Policy.
Uploaded and processed images are automatically deleted within approximately 48 hours under normal use.
Temporary facial analysis information is deleted after the relevant processing operation is completed.
Processing history, including prompts and template selections, may remain associated with your account until you delete the relevant information or delete your account.
Account and associated personal data remain while your account is active, unless earlier deletion is requested.
Support information and images voluntarily attached to support reports are retained only as long as reasonably necessary to investigate and resolve the relevant issue and are then deleted.
Technical and security information is retained only for as long as reasonably necessary for security, troubleshooting, fraud prevention, and service integrity.
When you delete your Foneo account, Foneo will initiate deletion of the personal data and processing history associated with that account. Deletion from Foneo's active systems will normally be completed within a maximum of 24 hours.
If applicable law requires us to retain a limited record for purposes such as accounting, taxation, fraud prevention, dispute resolution, or compliance with legal obligations, that information may be retained only for the period required by law or reasonably necessary for that specific purpose. Access to such retained information will be restricted.
Third-party service providers may also retain limited information according to their legal obligations and their own applicable retention policies.
11. Account Deletion
You may delete your Foneo account using the Delete Account function available in Foneo's account settings.
Deleting your account permanently removes the account rather than merely disabling or deactivating it.
When deletion is requested, Foneo will delete the personal information, processing history, and other data associated with the account within a maximum of approximately 24 hours, subject only to information that must be retained because of an applicable legal obligation.
Any images still temporarily stored in connection with the account will also be removed as part of the account-deletion process.
If you experience difficulty deleting your account, you may contact us at [email protected] for assistance.
12. Data Security
Foneo uses reasonable administrative, organizational, and technical safeguards designed to protect personal data against unauthorized access, disclosure, loss, misuse, alteration, or destruction.
Access to production systems and personal information is restricted according to operational needs.
However, no network, service, server, transmission method, or storage system can be guaranteed to be completely secure. We therefore cannot guarantee absolute security.
If we become aware of a personal data breach for which notification is required under applicable law, we will take appropriate steps to investigate and address the incident and provide notifications to affected users or competent authorities where legally required.
13. Your Privacy Rights
Depending on where you live and the laws that apply to you, you may have rights concerning your personal data.
These rights may include the right to obtain information about how your data is processed, access personal data held about you, correct inaccurate information, request deletion, restrict certain processing, object to certain processing, receive certain information in a portable format, and withdraw consent where processing is based on consent.
You may exercise applicable rights through available account controls or by contacting [email protected].
We may need to verify your identity before completing certain requests in order to protect your account and personal information.
We will not discriminate against you for exercising privacy rights provided to you by applicable law.
Some rights may be subject to exceptions or limitations permitted by law.
14. European Economic Area and United Kingdom Users
If you are located in the European Economic Area, European Union, or United Kingdom and applicable data protection law applies to our processing of your personal data, Foneo processes personal data under one or more applicable legal bases.
We process information where necessary to perform our contract with you, including creating and operating your account, processing your images, providing requested Services, maintaining your processing history, and managing payments.
We may process information where necessary for our legitimate interests, including maintaining service security, preventing fraud and abuse, troubleshooting, improving service reliability, and understanding general website usage, provided those interests are not overridden by your applicable rights and interests.
Where required, we rely on your consent for processing activities such as non-essential analytics cookies. You may withdraw consent at any time, without affecting the lawfulness of processing performed before withdrawal.
We may also process information when necessary to comply with legal obligations.
Where applicable, you may have rights of access, rectification, erasure, restriction, portability, objection, and the right to lodge a complaint with the data protection authority responsible for your jurisdiction.
15. California Privacy Rights
If you are a California resident and the California Consumer Privacy Act, as amended, applies to Foneo's processing of your information, you may have certain additional privacy rights.
These may include the right to know the categories and specific pieces of personal information collected about you; the purposes for which the information is collected, used, or disclosed; the categories of third parties to whom information is disclosed; the right to request correction of inaccurate personal information; the right to request deletion subject to applicable exceptions; and the right not to receive discriminatory treatment for exercising your privacy rights.
Foneo does not sell personal information.
Foneo does not use users' uploaded photos or Foneo account information for cross-context behavioral advertising.
If practices described in this Privacy Policy change in a way that creates additional rights under California law, we will update this Privacy Policy and provide any controls or notices required by applicable law.
California residents may submit an applicable privacy request by contacting [email protected].
16. Cookies and Similar Technologies
The Foneo website may use cookies and similar technologies that are necessary for website functionality, account authentication, security, and user preferences.
The website also uses Google Analytics to understand general website usage and performance.
You may control or delete cookies through your browser settings. Blocking certain necessary cookies may affect the operation of some website features.
Where applicable law requires consent before the use of non-essential analytics cookies or similar technologies, Foneo will provide an appropriate consent mechanism.
17. Children's Privacy
Foneo is not specifically directed to children.
If you are below the age at which you may lawfully consent to the processing of personal data in your jurisdiction, you should use Foneo only with the involvement and authorization of a parent or legal guardian where required by applicable law.
We do not knowingly seek to collect personal information from children in violation of applicable law.
If we become aware that personal data has been collected from a child in circumstances that do not comply with applicable law, we will take reasonable steps to delete that information.
Parents or legal guardians who believe that a child has provided personal information to Foneo in violation of applicable law may contact us at [email protected].
18. Third-Party Websites and Services
The Foneo website or Services may contain links to websites or services operated by third parties.
This Privacy Policy does not govern third-party websites or services that Foneo does not control.
We encourage you to review the privacy policies of third-party services before providing personal information to them.
19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to Foneo's Services, technology, legal requirements, or privacy practices.
When we make material changes, we will update the "Last Updated" date at the top of this Privacy Policy and, where appropriate or legally required, provide additional notice through the website, application, email, or another reasonable method.
Your continued use of the Services after an updated Privacy Policy becomes effective will be subject to the updated policy, except where applicable law requires us to obtain additional consent.
20. Contact Us
If you have questions, privacy requests, complaints, or concerns regarding this Privacy Policy or Foneo's handling of personal data, please contact:
Halley Trade and Service Co., Ltd.
Business Registration No./Tax Code: 0315059335
Address: 121/4 Truong Chinh, Dong Hung Thuan Ward, Ho Chi Minh City, Vietnam
Email: [email protected]
Phone: +84 81 9900 003
We will review privacy-related requests and complaints and respond in accordance with applicable law.