APPLICATION PRIVACY POLICY
Last Updated: July 10, 2026
1. INTRODUCTION AND SCOPE
This Privacy Policy ("Policy") is issued by BILLIONX LABS LIMITED ("we," "us," or "our"). It governs the data practices for our mobile application, HomeGPT - AI Interior Design (the "App"), and all related services (the "Services").
About the App: HomeGPT is an AI-powered home design application that helps you visualize and explore new interior and exterior design possibilities for your living spaces. You upload photos of your rooms or home, and our AI generates redesigned versions—new furniture, wall colors, flooring, landscaping, and more. You can also remove or replace objects, apply a reference style from another image, and find furniture similar to what appears in your design.
This Policy is a legally binding agreement. By downloading, installing, or using our Services, you acknowledge that you have read, understood, and agree to the data practices described herein. If you do not agree with this Policy, you must not use the Services.
For the purposes of applicable data protection laws, such as the EU General Data Protection Regulation (GDPR), we are the Data Controller of your Personal Data.
2. OUR PRIVACY COMMITMENT
Our approach to privacy is founded on the following core principles:
Transparency: We are committed to being open and clear about how we handle your data, especially in the context of our AI-powered features—including how our third-party AI provider may handle it.
Purpose Limitation: We will only collect and process your data for the specified, explicit, and legitimate purposes articulated in this Policy.
Data Minimization: We adhere to the principle of collecting only the data that is strictly necessary to provide and improve our Services.
Responsible AI Disclosure: We believe you have the right to know which AI service processes your images and what that service does with them. Before your data is sent to any AI service, you will be asked for your consent within the App.
Security by Design: We integrate reasonable security measures to protect the confidentiality, integrity, and availability of your Personal Data.
3. DATA WE COLLECT AND PROCESS
To provide and improve our Services, we collect several categories of data.
3.1. User-Provided Content (Processed for AI Functionality)
This is the data you provide to enable the core design features of the App.
What we collect:
Images: Photographs or images of interior spaces, exterior facades, gardens, reference style images, floor plan sketches, or any other images you upload to the App for redesign or analysis ("User Images").
Text Prompts: Descriptive text you may input to guide the AI creative process, or style preferences you select ("User Prompts").
How and why we process it:
When you use an AI feature, your User Images and User Prompts are transmitted to our servers and then forwarded to our third-party AI service provider, HomeDesigns AI, for the sole purpose of generating your requested design. Before any data is sent to the AI service, you will be presented with an in-app consent prompt explaining what data is being shared and with whom.
Server-side Processing (our infrastructure): After the AI processing is complete and the result is delivered to you, the source User Images and User Prompts are deleted from our own servers. They are not stored, cached, or logged on our server infrastructure beyond the time needed to complete your request.
Third-Party AI Provider Processing: Because your images are processed by HomeDesigns AI (see Section 5), HomeDesigns AI may handle your images according to its own privacy and data retention policies. Key details about its data practices are disclosed in Section 5.
Local Storage of Prompts: For your convenience, your User Prompts and recent design history may be saved locally on your device. This data is removed if you uninstall the App or clear the app local data.
3.2. Technical & Usage Data (Collected Automatically)
To ensure our App functions correctly and to resolve technical issues, we automatically collect certain technical data.
What we collect:
Device & Network Information: IP address, device manufacturer and model, operating system version, screen dimensions, time zone, network state (Wi-Fi/cellular), and system language.
Identifiers: App version, device identifiers, advertising identifiers (such as IDFA where permission has been granted), and app-generated user/customer/subscriber identifiers that may be used by enabled advertising, subscription, analytics, crash reporting, fraud prevention, and security systems.
Usage & Interaction Data: App launches, features used, time spent, buttons clicked, product interactions, other usage data, advertisement interactions where advertising features are enabled, and purchase/subscription events.
Advertising Data: Where advertising or attribution features are enabled, we and our partners may process ad impressions, clicks, conversions, campaign attribution, and other information about advertisements displayed or interacted with in the App or about campaigns that led users to the App.
Approximate Location: Country or region information may be inferred from IP address by enabled advertising, analytics, security, or service providers.
Diagnostics Data: Crash data, performance data, and other diagnostic data used to maintain app stability, debug issues, improve app functionality, and analyze technical performance.
Why we collect it: To maintain and improve our Services, analyze usage trends, fix bugs, process subscriptions, provide and measure advertising, personalize advertising where permitted, attribute campaigns, ensure security, and prevent fraud.
3.3. Communications Data (Voluntarily Provided)
When you voluntarily contact us for customer support or to provide feedback, we collect your email address and the content of your communications. This data is used exclusively to respond to your inquiries and is retained only as long as needed for that purpose.
3.4. Subscription, Purchase, and Refund Information
If you purchase a subscription or request a refund for an in-app purchase or subscription through Apple App Store or Google Play, we may collect and share limited consumption information related to your use of the purchased content to help the app store review your refund request. This may include time since installation, usage time of the app or purchased content, whether the purchased content or subscription was actively used or fully consumed, trial status, and purchase details for the relevant transaction.
This information is used solely to process subscriptions, support billing and refund review, prevent fraud, and comply with legal obligations. It is not used for tracking or advertising.
4. OUR USE OF ARTIFICIAL INTELLIGENCE (AI)
Transparency in our use of AI is a cornerstone of our commitment to you.
AI Functionality: The core purpose of our App is to use generative AI to create new interior and exterior design concepts based on your uploaded images and prompts.
AI Features in the App:
Interior Redesign: Upload a room photo → AI redesigns furniture, colors, and layout. Powered by HomeDesigns AI API.
Exterior Redesign: Upload a house photo → AI redesigns facade, materials, and colors. Powered by HomeDesigns AI API.
Garden Redesign: Upload a garden photo → AI redesigns landscaping. Powered by HomeDesigns AI API.
Reference Style: Upload your room and a style inspiration photo → AI applies the reference style to your room. Powered by HomeDesigns AI API.
Remove Objects: Select an object in your photo → AI removes it and fills the background. Powered by HomeDesigns AI API.
Replace Objects: Select an object and describe a replacement → AI replaces it. Powered by HomeDesigns AI API.
New Flooring: Upload a room photo and select flooring type → AI changes the flooring. Powered by HomeDesigns AI API.
New Walls: Upload a room photo and select wall color/material → AI changes the walls. Powered by HomeDesigns AI API.
Furniture Finder: Select furniture in your design → AI identifies similar products. Powered by HomeDesigns AI API.
Floor Plan: Upload a floor plan sketch → AI redesigns the layout. Powered by HomeDesigns AI API.
In-App Consent: Before any of your data, including images, is sent to HomeDesigns AI for processing, the App will present you with a consent screen that clearly explains what data will be sent, identifies HomeDesigns AI as the receiving provider, states that the data will be used solely to generate your requested design, and confirms that your data is not used for model training.
No Training on Your Data: We state unequivocally that your User Images and the resulting AI-generated designs are not used to train or improve AI models—neither by us nor by HomeDesigns AI. We operate under an Enterprise Privacy plan with HomeDesigns AI that explicitly excludes your content from model training. Your content is your own.
5. THIRD-PARTY AI SERVICE PROVIDER
To deliver our AI features, we use the following third-party AI service provider:
5.1. HomeDesigns AI API
Provider: HomeDesignsAI, Inc.
Service: AI image generation and editing for all interior, exterior, garden, style, object editing, wall, flooring, furniture, and floor plan features.
Data Sent: User Images, reference images, floor plan sketches, and associated text prompts or style preferences.
Purpose: The data is sent solely to generate the AI design output requested by you.
Data Retention by Provider: HomeDesigns AI retains Input and Output data for the duration of our active Enterprise account on their platform to enable service continuity and billing validation.
Model Training: Not used for training. We are on an Enterprise Privacy plan with HomeDesigns AI that explicitly excludes your Input and Output from model training or improvement.
Security: AES-256 encryption at rest and SSL/TLS in transit, according to HomeDesigns AI provider documentation.
Policies: https://api.homedesigns.ai/homedesignsai-api-documentation/others/homedesigns-ai-api-privacy-policy
5.2. Future AI Tools
If we integrate an additional AI provider in the future, this Policy will be updated before such provider is used in the App. An in-app consent prompt will also be shown before your data is shared with any new AI provider.
6. ADVERTISING, ANALYTICS, AND SUBSCRIPTION MANAGEMENT PARTNERS
Our App currently uses, or may integrate or activate in future versions, third-party SDKs and networks for advertising, analytics, crash reporting, attribution, fraud prevention, and subscription management. A provider may be enabled only for certain app versions, regions, campaigns, features, or configurations. Listing a provider below does not mean that every provider is active at all times or that advertising is displayed in every version of the App.
When enabled, and depending on your consent, device settings, region, and app configuration, these partners may collect device and advertising identifiers, product and ad interactions, usage data, diagnostics, approximate location inferred from IP address, and purchase/subscription information. These partners process data according to their own privacy policies and may act as independent data controllers or processors.
Google — Advertising, Analytics — https://policies.google.com/privacy
Meta — Advertising — https://www.facebook.com/about/privacy
Unity Ads — Advertising — https://unity3d.com/legal/privacy-policy
IronSource — Advertising — https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy
AppLovin — Advertising — https://www.applovin.com/privacy
Vungle — Advertising — https://vungle.com/privacy
Pangle — Advertising — https://ad.oceanengine.com/union/media/privacy
Mintegral — Advertising — https://www.mintegral.com/en/privacy
RevenueCat — Subscription Management — https://www.revenuecat.com/privacy
Adapty — Subscription Management — https://adapty.io/privacy
On iOS, when a current or future feature requires access to the advertising identifier or tracking across other companies’ apps or websites, the App requests permission through Apple’s App Tracking Transparency framework before such tracking is enabled. If permission is denied, tracking is not enabled; enabled advertising partners may still provide contextual or non-personalized advertising where legally permitted.
We do not sell your personal information for monetary consideration. Certain disclosures to advertising partners may be considered “sharing” or “targeted advertising” under applicable privacy laws, and you may exercise the choices described in Section 11.
7. PURPOSES AND LEGAL BASES FOR DATA PROCESSING
We only process your Personal Data when we have a valid legal basis for doing so under applicable data protection laws such as the GDPR.
To Provide Core AI Design Features — Data: User Images and User Prompts — Legal Basis: Performance of Contract (processing is essential to deliver the AI-generated designs you requested).
To Maintain & Improve the App — Data: Technical & Usage Data — Legal Basis: Legitimate Interest (analyzing usage to fix bugs and improve the user experience).
Advertising and Ad Measurement — Data: Advertising identifiers, device identifiers, advertisement interactions, product interactions, usage data, campaign attribution, diagnostics, and approximate location where applicable — Legal Basis: Consent where required; Legitimate Interest for contextual advertising, measurement, security, and fraud prevention where permitted by law.
Personalized Advertising and Tracking — Data: Advertising identifiers and related usage or interaction data — Legal Basis: Consent, including App Tracking Transparency permission on iOS where required.
Subscription Management and Refund Support — Data: Purchase, subscription, and consumption information — Legal Basis: Performance of Contract, Legitimate Interest, and Legal Obligation where applicable.
Security & Fraud Prevention — Data: Technical & Usage Data — Legal Basis: Legitimate Interest (monitoring for malicious activity and preventing abuse).
Legal Compliance — Data: All relevant categories — Legal Basis: Legal Obligation (when required by law).
8. DATA RETENTION
We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected.
User Images & Prompts (our servers): Deleted after processing and delivery of the result; not stored long-term.
User Images & Prompts (HomeDesigns AI): Retained for the duration of our Enterprise account for service continuity and billing validation. Not used for model training.
Technical, Usage, and Advertising Data: Retained for the limited period necessary for advertising, analytics, attribution, debugging, security, and fraud prevention, then deleted or anonymized according to our and our partners’ retention practices.
Communications Data: Retained until the inquiry is resolved plus a reasonable records period.
Subscription/Consumption Data: Retained for the duration necessary to support subscriptions, refund review, fraud prevention, and applicable legal retention obligations.
9. DATA SHARING
We share your information only as described in this Policy:
AI Service Provider — as detailed in Section 5, to generate your requested designs.
Enabled Advertising, Analytics, Crash Reporting, Attribution, and Subscription Partners — as detailed in Section 6, to provide and measure current or future advertising and campaigns, improve the App, prevent fraud, manage subscriptions, and support billing/refund workflows.
Legal/Regulatory — if required by law, subpoena, or to protect our rights.
Business Transfers — in the event of a merger, acquisition, or sale of assets.
With Your Consent — for any other purpose with your explicit permission.
We do not rent or sell your personal data to any third parties.
10. INTERNATIONAL DATA TRANSFERS
We operate globally. Your Personal Data may be transferred to, stored in, and processed in jurisdictions outside your country of residence, including the United States or other locations where our third-party providers operate. We use legally recognized transfer mechanisms, such as Standard Contractual Clauses where applicable, and appropriate contractual protections for such transfers.
Consumption information may be transferred to Apple, Google, subscription management providers, or other service providers and may involve international data transfers. Where required, we implement appropriate safeguards and contractual protections for such transfers.
11. YOUR PRIVACY RIGHTS AND CHOICES
You have rights concerning your Personal Data, subject to limitations provided by law.
AI Consent: You may decline to use AI features that require image upload if you do not consent to the data sharing described in this Policy.
Advertising and Tracking Choices: On iOS, you may select “Ask App Not to Track” when the App Tracking Transparency prompt appears. You can review or change this choice in Settings > Privacy & Security > Tracking. Denying tracking permission prevents access to the advertising identifier for tracking and cross-app or cross-website tracking, but contextual or non-personalized ads may still be shown where permitted.
Your Rights (GDPR / CCPA / Global): Depending on your jurisdiction, you may have the right to access the Personal Data we hold about you, rectify inaccurate data, erase your data, restrict processing, obtain data portability where technically feasible, object to processing for direct marketing, lodge a complaint with a supervisory authority, and exercise other rights provided by applicable law.
Because we do not store your User Images on our servers beyond processing, erasure requests will primarily apply to Technical Data, Communications Data, and Subscription/Consumption Data. For data held by HomeDesigns AI, we will facilitate your request to the extent reasonably possible.
To exercise your rights, please contact us at support@billionx.co.
12. JURISDICTION-SPECIFIC PROVISIONS
For Residents of the European Economic Area (EEA), UK, and Switzerland (under GDPR): You have the rights detailed in Section 11, as well as the right to data portability and the right to lodge a complaint with a supervisory authority. The legal bases we rely on are detailed in Section 7.
For Residents of California (under CCPA/CPRA): You have the right to know what personal information is collected, to delete it, and to opt out of the sharing of personal information for cross-context behavioral advertising. Certain disclosures to advertising partners may constitute “sharing” under California law. You may exercise available device-level tracking controls and contact us at support@billionx.co for additional privacy requests. We do not sell your data for monetary consideration.
13. SECURITY
We implement reasonable administrative, technical, and physical safeguards to protect your Personal Data, including encryption in transit (SSL/TLS) and at rest where applicable. We require our third-party providers to maintain appropriate security measures. However, no method of transmission over the internet is 100% secure. You acknowledge that you use the Service at your own risk.
14. CHILDREN'S PRIVACY
These Services are not directed to anyone under the age of 13 (or 16 in the EEA/UK). We do not knowingly collect personally identifiable information from children. If we become aware that a child has provided us with Personal Data, we will take steps to delete such information immediately.
15. CHANGES TO THIS POLICY
We may update this Policy from time to time. If we make material changes, we will provide notice through the App, such as an in-app notification or prompt, to allow you to review the changes before they become effective. Your continued use of the Services after a revision becomes effective constitutes your acceptance of the updated terms.
16. CONTACT INFORMATION
For any questions, concerns, or requests relating to this Privacy Policy:
Legal Entity: BILLIONX LABS LIMITED
Support Email: support@billionx.co
Data Protection Inquiries: support@billionx.co (subject: “Privacy Request”)