Privacy Policy

Last Updated: February 20, 2026 | Effective Date: February 20, 2026

HCA TREND LTD ("we," "us," "our," or the "Company") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the ValutClean mobile application (the "App") and any related services (collectively, the "Services"). By accessing or using the Services, you agree to the practices described in this Privacy Policy.

This Privacy Policy applies to all users of the App, regardless of how it is accessed or used, including through mobile devices, tablets, or any other technology or software known today or developed in the future.

1. Who We Are

ValutClean is developed and operated by:

HCA TREND LTD
24, 26 Arcadia Avenue Fin009
London, N3 2JU
United Kingdom

For any privacy-related inquiries, you may contact us at: info@valutclean.com

2. Information We Collect

We are committed to minimizing data collection. We design our services around the principle that your private data should stay private. Below is a detailed breakdown of the types of information we may collect:

2.1 Information You Provide Directly

Account Information: When you create an account, we may collect your email address and a username. We do not collect your real name, phone number, or physical address unless you voluntarily provide it for support purposes.
Support Communications: If you contact us for customer support, we may collect the information you provide in your communication, such as your email address, name, and the content of your message.
Subscription Information: When you subscribe to our premium features, your payment is processed entirely through Apple's App Store. We do not collect, process, or store any payment card details, banking information, or financial data. We receive only a confirmation of your subscription status from Apple.

2.2 Information Collected Automatically

Device Information: We may collect certain technical information about your device, including the device model, operating system version, unique device identifiers (such as IDFV), language settings, and time zone.
Usage Data: We may collect anonymous, aggregated data about how you use the App, such as which features you access, the frequency and duration of your activities, crash reports, and performance metrics. This data is collected to improve the App experience and does not identify you personally.
Log Data: When errors occur within the App, we collect log data that may include your device's Internet Protocol ("IP") address, device name, operating system version, the configuration of the App at the time of the error, the time and date of the error, and other diagnostic statistics.

2.3 Information We Do NOT Collect

We want to be transparent about what we do not collect:

Passwords: Your passwords stored within ValutClean are encrypted on your device using AES-256 encryption. We have zero access to your master password or any of the passwords you store in the App. This is fundamental to our zero-knowledge architecture.
Photos and Media: The photo cleanup feature operates entirely on your device. We do not upload, access, copy, transmit, or store any of your photos or media files on our servers. All photo analysis and duplicate detection is performed locally on your device.
Secret Folder Contents: Any files, photos, or documents you place in the Secret Folder are encrypted and stored locally on your device. We have no access to this data.
Browsing History: We do not track your browsing history or online activity outside of the App.
Location Data: We do not collect your precise or approximate geographic location.
Contacts: We do not access or collect your contact list or address book.

3. How We Use Your Information

We use the limited information we collect for the following purposes:

To Provide and Maintain the Services: Including managing your account, processing your subscription status, and ensuring the App functions correctly.
To Improve the App: Analyzing anonymous usage patterns and crash data helps us identify bugs, improve performance, and develop new features that better serve our users.
To Communicate With You: Sending you important notices regarding changes to our terms, policies, or App features. We may also send you technical notices, updates, security alerts, and support messages.
To Provide Customer Support: Responding to your inquiries, troubleshooting problems, and providing technical assistance.
To Ensure Security: Detecting, preventing, and addressing technical issues, fraud, and security vulnerabilities.
To Comply With Legal Obligations: Fulfilling any requirements under applicable law, regulation, legal process, or enforceable governmental request.

4. Legal Basis for Processing (for EEA/UK Users)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data based on the following legal grounds:

Performance of a Contract: Processing necessary to provide you with the Services under our Terms of Use.
Legitimate Interests: Processing necessary for our legitimate interests, such as improving the App, ensuring security, and preventing fraud, provided those interests are not overridden by your rights and freedoms.
Consent: Where you have given us explicit consent to process your personal data for a specific purpose.
Legal Obligation: Processing necessary to comply with applicable laws and regulations.

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties. We may share your information only in the following limited circumstances:

Service Providers: We may engage trusted third-party service providers who assist us in operating the App, such as analytics providers (e.g., to analyze crash reports) and cloud infrastructure providers. These providers are contractually obligated to use your data only as necessary to perform services on our behalf and to maintain appropriate security measures.
Apple: Subscription management and payment processing are handled by Apple through the App Store. Apple's collection and use of your data is governed by Apple's Privacy Policy.
Legal Requirements: We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that such disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a lawful government request.
Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice in the App of any change in ownership or uses of your personal information.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Account Data: Retained for as long as your account remains active. If you delete your account, we will delete your personal data within 30 days, except where we are required to retain it for legal or regulatory purposes.
Usage and Analytics Data: Aggregated, anonymized usage data may be retained indefinitely for analytical and improvement purposes, as it cannot be used to identify you.
Support Communications: Retained for up to 24 months after the issue is resolved, unless a longer retention period is required for legal purposes.

7. Data Security

We take the security of your data seriously and implement appropriate technical and organizational measures to protect your personal information. These measures include:

Encryption: All sensitive data stored within the App (passwords, secret folder contents) is encrypted using AES-256 encryption, an industry-standard encryption algorithm used by governments and financial institutions worldwide.
Zero-Knowledge Architecture: Your master password is never transmitted to or stored on our servers. All encryption and decryption happens locally on your device, ensuring that only you have access to your data.
Secure Infrastructure: Our servers and infrastructure are protected by industry-standard security measures, including firewalls, intrusion detection systems, and regular security audits.
Biometric Protection: The App supports Face ID and Touch ID to prevent unauthorized access to your vault.

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal data:

Right of Access: You have the right to request a copy of the personal data we hold about you.
Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
Right to Erasure: You have the right to request that we delete your personal data, subject to certain exceptions (e.g., legal retention requirements).
Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain circumstances.
Right to Data Portability: You have the right to request that we provide your personal data in a structured, commonly used, and machine-readable format.
Right to Object: You have the right to object to the processing of your personal data where we rely on legitimate interests as the legal basis.
Right to Withdraw Consent: Where we rely on your consent to process your data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at info@valutclean.com. We will respond to your request within 30 days (or sooner if required by applicable law). We may ask you to verify your identity before processing your request.

9. International Data Transfers

As a UK-based company, your data may be processed in the United Kingdom. If you are accessing the Services from outside the UK, please be aware that your data may be transferred to, stored, and processed in the UK or other countries where our service providers operate. We ensure that appropriate safeguards are in place for any international transfers of personal data, including Standard Contractual Clauses approved by relevant data protection authorities or other legally recognized transfer mechanisms.

10. Children's Privacy

The Services are not intended for children under the age of 16 (or the minimum age required by applicable law in your jurisdiction). We do not knowingly collect personal information from children under 16. If we become aware that we have inadvertently collected personal information from a child under 16, we will take steps to delete such information as promptly as possible. If you are a parent or guardian and you believe that your child has provided us with personal information, please contact us at info@valutclean.com.

11. Account Deletion

You have the right to delete your account at any time. You can initiate account deletion directly within the App by navigating to Settings > Account > Delete Account, or by contacting us at info@valutclean.com.

When you delete your account:

Your personal data (email address, username, and any other account-related information) will be permanently deleted from our systems within 30 days.
Encrypted data stored locally on your device (passwords, secret folder contents) will remain on your device until you uninstall the App. We do not have access to this data.
Anonymized, aggregated analytics data that cannot be used to identify you may be retained for product improvement purposes.
Certain data may be retained where required by applicable law (e.g., financial transaction records for tax compliance) for the legally mandated retention period, after which it will be deleted.
Important: Deleting your account does not automatically cancel your subscription. You must separately cancel any active subscription through Apple's subscription management: Settings > [Your Name] > Subscriptions on your iOS device.

12. App Tracking Transparency and Advertising

We do not use Apple's Identifier for Advertisers (IDFA) or participate in any advertising tracking. We do not track you across other companies' apps or websites. We do not share your data with data brokers or any advertising networks. ValutClean does not display any third-party advertisements.

If Apple's App Tracking Transparency (ATT) prompt appears on your device in connection with our App, you may decline tracking without any impact on the functionality of the App. We respect your privacy choices fully.

13. Apple App Privacy Details

In compliance with Apple's App Store requirements, we provide the following summary of our data practices as they relate to Apple's App Privacy "nutrition labels":

Data Used to Track You: None. We do not track you across apps or websites owned by other companies.
Data Linked to You: Email address (for account creation and support purposes only).
Data Not Linked to You: Crash data, performance data, and anonymized usage analytics.
Data Not Collected: Passwords, photos, files, financial information, precise location, contacts, browsing history, search history, sensitive information, or any data from the Secret Folder. All password and vault data is encrypted locally on your device and is never transmitted to our servers.

14. Third-Party Links and Services

The App may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to those third-party services. We strongly advise you to review the privacy policy of every site or service 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.

15. Push Notifications

We may send you push notifications to provide you with updates, security alerts, or information related to the Services. You can opt out of receiving push notifications at any time by adjusting the notification settings on your device or within the App.

16. Analytics and Diagnostics

We may use third-party analytics services to help us understand how the App is used and to improve its performance. These services may collect information sent by your device, such as usage frequency, events within the App, aggregated usage data, performance data, and crash data. This information is collected in an anonymized or pseudonymized form and is not used to personally identify any individual user.

17. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have certain additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you.
Right to Delete: You have the right to request that we delete the personal information we have collected about you, subject to certain exceptions.
Right to Opt-Out: You have the right to opt out of the "sale" or "sharing" of your personal information. We do not sell or share your personal information as those terms are defined under the CCPA/CPRA.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

To exercise these rights, please contact us at info@valutclean.com.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated Privacy Policy within the App and updating the "Last Updated" date at the top of this page. We may also notify you through in-app notifications or by email for significant changes. Your continued use of the Services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

19. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

HCA TREND LTD
24, 26 Arcadia Avenue Fin009
London, N3 2JU
United Kingdom
Email: info@valutclean.com

If you are located in the EEA or UK and are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with your local data protection supervisory authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.