HUM PRIVACY POLICY - COMPREHENSIVE DATA PROTECTION NOTICE

IMPORTANT: This Privacy Policy explains how Hum-App Technologies Inc. ("HUM," "we," "us," "our") collects, uses, discloses, and protects your personal information when you use the HUM mobile application and related services ("Platform," "App," "Service").

Effective Date: January 11, 2026
Last Updated: January 11, 2026
Company: Hum-App Technologies Inc. (Delaware C-Corporation)
Address: 2314 28th Street, Santa Monica, CA 90405

Information We Collect
How We Collect Information
How We Use Your Information
AI & Machine Learning Data Practices
Information Sharing & Disclosure
Data Security & Protection
Data Retention & Deletion
Your Privacy Rights & Choices
Cookies & Tracking Technologies
Third-Party Services & Links
Children's Privacy
International Data Transfers
State-Specific Privacy Rights
Changes to Privacy Policy
Contact Us

1. INFORMATION WE COLLECT

1.1 Account & Profile Information

When you create an account, we collect:

Full legal name
Email address
Phone number
Date of birth
Physical address (street, city, state, ZIP code)
Profile photo (optional but recommended)
Username/display name
Bio/description (optional)
Preferred language and communication preferences

1.2 Identity Verification Information

For security and fraud prevention, we collect:

Government-issued photo identification (driver's license, passport, national ID)
Facial recognition data (to match ID photo)
Social Security Number (last 4 digits) - US users only
Address verification documents (utility bills, bank statements)
Selfie photos for identity confirmation
Background check information (for certain high-value transactions)
Date of birth verification
Citizenship/residency status (if required)

Third-Party Verification: We use Stripe Identity and other verification services that may collect additional data per their privacy policies.

1.2A Student Verification Information

If you subscribe to Student Subscription (discounted rate), we collect:

Student email address (typically ending in .edu)
Current student ID card with photo and expiration date
Enrollment verification documents
Educational institution name and location
Expected graduation date
Student status (undergraduate, graduate, etc.)
Third-party student verification service data (if applicable)

Student Verification Process:

We may use third-party verification services (SheerID, UNiDAYS, or similar)
Student status must be re-verified annually
Verification documents retained for compliance and fraud prevention
Loss of student status automatically converts subscription to Standard pricing

1.3 Payment & Financial Information

Payment data processed by Stripe (our payment processor):

Credit/debit card information (full number, CVV, expiration)
- IMPORTANT: HUM does NOT store full card numbers
- Stripe stores payment data per their PCI-DSS compliance standards
- HUM receives only last 4 digits and card brand (e.g., "Visa ending in 1234")
Bank account information (for payouts to Lenders)
Billing address
Payment transaction history and records
Deposit authorizations and charges
Tax identification numbers (W-9/W-8 forms for US tax reporting)
Stripe Connect account data (for Lenders receiving payments)

HUM Retains:

Transaction amounts, dates, and parties involved
Service fees and platform charges
Deposit amounts and status
Payout records and timing
Tax reporting information (1099-K forms)

1.4 Item Listings & Rental Information

When you list or rent items, we collect:

Item photos (multiple images per listing)
Item title, description, and category
Declared item value (for insurance purposes)
Rental pricing (daily, weekly, monthly rates)
Item location (address, GPS coordinates)
Availability calendar and booking dates
Item condition assessment
AI-generated metadata (brand, model, features, suggested pricing)
Ownership confirmation statements
Receipt photos (optional for high-value items)
Pre-rental and post-rental condition photos
Serial numbers or unique identifiers (if provided)

1.5 Communication & Message Data

We collect all communications on Platform:

In-app messages between Users
Customer support inquiries and responses
Email correspondence with HUM
SMS text messages (verification codes, notifications)
Phone call recordings (with notice, for support quality)
Push notification interactions
Review and rating content
Comments and feedback

Retention: Messages retained indefinitely for dispute resolution, legal compliance, and safety.

1.6 Location Information

We collect various location data:

Precise GPS coordinates: When you use location services for item discovery, listing, or navigation
IP address-based location: General city/region from Internet connection
Item pickup/return locations: Addresses where transactions occur
Search location preferences: Areas where you browse for items
Movement patterns: If you enable background location (for delivery features)

Location Permissions:

"While Using App": Collected only when app is open
"Always": Allows background collection (optional, for delivery tracking)
You can disable location in device settings (limits functionality)

1.7 Device & Technical Information

Automatically collected when you use the App:

Device type, model, manufacturer (e.g., "iPhone 14 Pro")
Operating system and version (e.g., "iOS 17.2")
Device identifiers (IDFA, Android Advertising ID, device UUID)
IP address (IPv4 and IPv6)
Browser type and version (for web access)
Mobile carrier information
Screen resolution and device capabilities
App version and build number
Language and timezone settings
Wi-Fi network name (SSID) - if permitted
Bluetooth and nearby device information (if used for features)

1.8 Usage & Analytics Data

We track how you interact with Platform:

Features used and frequency of use
Screens viewed and time spent
Search queries and filters applied
Items viewed, favorited, or contacted about
Booking and rental history
Cancellations and modifications
Review and rating activity
Click-through rates and navigation paths
Error logs and crash reports
Performance metrics (load times, responsiveness)
A/B test participation and group assignments
Referral sources (how you found HUM)

1.9 Camera, Photo Library & Media

With your permission, we access:

Camera (to photograph items, take selfies for verification)
Photo library (to select existing photos for listings)
Photo metadata (EXIF data: location, timestamp, camera settings)
Videos (if we add video listing features)
Microphone (for future voice features or video)

Photo Data: All uploaded photos are analyzed by AI (see Section 4).

If you connect social accounts (Google, Apple, Facebook):

Profile information (name, email, photo)
Friend lists or connections (if you grant access)
Public profile data
Social media authentication tokens

1.11 Information from Other Users

We may receive information about you from other Users:

Reviews and ratings
Messages and communications
Dispute claims and reports
Referrals and recommendations
Photos/videos where you appear (in transaction documentation)

1.12 Publicly Available Information

We may collect public information:

Business licenses or professional credentials (if you list professional items)
Court records or legal filings (for dispute resolution or fraud investigation)
Public social media posts (for verification or fraud detection)
Government databases (sex offender registries, sanctions lists)

2. HOW WE COLLECT INFORMATION

2.1 Information You Provide Directly

Account registration and profile creation
Item listings and rental bookings
Messages, reviews, and feedback
Customer support interactions
Identity verification submissions
Payment method setup

2.2 Automatic Collection

Cookies and tracking technologies (see Section 9)
Mobile device sensors and APIs
Server logs and analytics tools
App usage monitoring

2.3 Third-Party Sources

Payment processors (Stripe)
Identity verification services (Stripe Identity, etc.)
Social media platforms (if you connect accounts)
Public databases and records
Fraud prevention and risk assessment services
Marketing partners and analytics providers

3. HOW WE USE YOUR INFORMATION

3.1 Core Platform Operations

We use your information to:

Create and manage your account
Verify your identity and prevent fraud
Process and manage subscription payments and renewals
Verify student status for discounted subscriptions
Monitor subscription billing cycles and payment failures
Enable item listings and rental transactions
Process payments, deposits, and payouts
Facilitate communication between Users
Display items based on your location preferences
Match Renters with available items
Calculate rental pricing and fees
Manage rental calendars and availability
Send booking confirmations and reminders
Handle returns and condition verification
Process damage claims and disputes
Enforce Terms of Service and policies

3.2 AI-Powered Features (See Section 4 for Detail)

Analyze item photos to identify brand, model, condition
Generate item descriptions and pricing suggestions
Detect prohibited items and policy violations
Assess fraud risk and pricing anomalies
Provide search recommendations
Calculate environmental impact metrics
Train and improve AI models for Platform enhancements

3.3 Safety, Security & Fraud Prevention

Verify identity and prevent account takeovers
Detect fraudulent listings and transactions
Identify stolen goods or counterfeit items
Monitor for prohibited items or activities
Investigate disputes and policy violations
Protect against unauthorized access and security threats
Comply with legal obligations (AML, sanctions screening)
Respond to legal requests and law enforcement

3.4 Customer Support & Communication

Respond to inquiries and support requests
Troubleshoot technical issues
Provide account assistance
Send transactional emails and SMS (booking confirmations, payment receipts, subscription renewals)
Send push notifications about rentals, account activity, and subscription status
Notify users of subscription renewals, payment failures, and plan changes
Conduct user surveys and feedback collection

Send newsletters and promotional emails
Notify you of new features or items
Provide personalized recommendations
Deliver targeted advertising
Run contests, sweepstakes, or referral programs
Share success stories and user testimonials

You can opt-out of marketing communications (see Section 8.4).

3.6 Platform Improvement & Analytics

Analyze usage patterns and trends
Test new features and A/B experiments
Identify bugs and performance issues
Improve app design and user experience
Develop new products and services
Create aggregated market insights and reports

3.7 Legal & Compliance

Comply with legal obligations (tax reporting, record-keeping)
Respond to subpoenas, court orders, legal processes
Enforce Terms of Service and policies
Protect rights, property, and safety of HUM and Users
Investigate and prevent illegal activities
Resolve disputes and legal claims

3.8 Business Operations

Manage business relationships and partnerships
Conduct due diligence for financing or acquisitions
Maintain business records and accounting
Conduct risk assessments and insurance underwriting (future)
Generate financial reports and analytics

4. AI & MACHINE LEARNING DATA PRACTICES

CRITICAL SECTION: This section explains how we use artificial intelligence (AI) and your data for machine learning.

4.1 AI Technologies We Use

HUM uses Google Gemini AI (Google's generative AI model) for:

Image Recognition: Identifying items, brands, models, and features in photos
Condition Assessment: Analyzing visual wear, damage, or defects
Pricing Intelligence: Suggesting rental prices based on market data
Description Generation: Creating item descriptions automatically
Fraud Detection: Identifying suspicious listings or pricing anomalies
Safety Screening: Detecting prohibited items or policy violations
Search Enhancement: Providing contextual search suggestions
Environmental Impact: Calculating CO2 and resource savings

4.2 What Data is Sent to Google/Third-Party AI

When you upload a photo or use AI features:

Image Data: The actual photo file is sent to Google's Gemini API servers
Metadata: EXIF data (camera settings, timestamp) may be included
Prompts: Text instructions from HUM to guide AI analysis
Context: Item category, user-provided title/description (to improve accuracy)

Google's Role:

Google processes images per their AI Terms and Privacy Policy
Google may use data to improve their AI models (per Google's terms)
HUM has limited control over Google's data practices
See: Google AI Terms and Google Privacy Policy

4.3 AI-Generated Data & Storage

HUM stores AI analysis results including:

Detected brand, model, and features
Suggested item descriptions and titles
Pricing recommendations and confidence scores
Condition assessments
Category classifications
Fraud risk scores
Prohibited item flags

Storage Duration: Indefinitely, for Platform improvement and legal compliance.

4.4 Building HUM's AI Training Datasets

IMPORTANT - READ CAREFULLY:

By using HUM, you consent to your photos and item data being used to build proprietary HUM AI training datasets and machine learning models.

Specifically, we may:

Aggregate your photos with other user photos to create training datasets
Label/annotate images with metadata (brand, category, condition, etc.)
Train custom AI models specific to rental marketplace use cases
Improve AI accuracy through supervised learning and model fine-tuning
Develop new AI features (future visual search, damage detection, authentication)
Create market intelligence (pricing trends, demand prediction)

Data Used for Training:

Item photos (primary training data)
AI-generated labels and classifications
User edits to AI suggestions (correcting errors improves training)
Transaction outcomes (successful rentals validate AI accuracy)
Damage claims data (trains damage detection models)

De-Identification Efforts:

We attempt to remove personally identifiable information (faces, license plates, addresses) from training data where feasible
However, complete anonymization is not guaranteed, especially if identifying info is integral to image content
User profile information is NOT directly linked to training data (images stored separately from identities where possible)

4.5 Third-Party AI Services Beyond Google

We may use additional AI/ML services:

Fraud Detection AI: Specialized models for financial fraud, identity theft
Image Moderation AI: To detect inappropriate or prohibited content
Natural Language Processing: For chatbots, search, and review analysis
Computer Vision: For damage assessment, authenticity verification

Each service has own privacy policies governing data use.

4.6 AI Limitations & User Rights

AI is NOT perfect. AI-generated information:

May contain errors, biases, or inaccuracies
Should be verified by Users
Does NOT constitute professional advice or guarantees
Cannot detect hidden defects, authenticity, or ownership

Your Rights:

You can edit or correct AI-generated information before publishing listings
You can delete listings (which may remove photos from active use, but training data may be retained)
You can request account deletion (see Section 8 for data deletion rights)
You CANNOT opt-out of AI analysis while using HUM (AI is integral to Platform operations)

4.7 Future AI Development

As AI technology evolves, we may:

Implement new AI features (visual search, real-time authentication)
Use additional third-party AI providers
Expand AI training datasets and model capabilities
Apply AI to new use cases (insurance risk assessment, dynamic pricing)

We will update this Privacy Policy to reflect significant changes in AI practices.

5.1 Information Shared with Other Users

Publicly visible to all Platform Users (before login):

Items available for rent (photos, descriptions, pricing, general location area)
Lender first name and profile photo
Lender ratings and review count

Visible to Users you transact with:

Full profile (name, photo, bio)
Contact information (within Platform messaging)
Item details (exact pickup location, instructions)
Rental history between you (past transactions)
Reviews and ratings you receive
Transaction-specific communications

NOT shared with other Users:

Email address, phone number (unless you provide directly)
Payment information
Government ID or verification documents
Precise home address (unless item pickup location)
Social Security Number or tax ID

5.2 Service Providers & Business Partners

We share information with third parties who provide services:

5.2.1 Payment Processing

Stripe, Inc.: Payment processing, payouts, fraud prevention
- Shares: Payment details, transaction amounts, bank account info, identity verification
- See: Stripe Privacy Policy

5.2.2 Cloud Infrastructure & Hosting

Google Firebase: App backend, database, file storage, authentication
- Shares: Account data, item listings, messages, photos, usage analytics
- See: Firebase Privacy Policy
Google Cloud Platform: Server infrastructure and services
- Shares: All Platform data stored on GCP servers

5.2.3 AI & Machine Learning

Google Gemini AI: Image analysis and AI features
- Shares: Photos, prompts, item context
- See: Google AI Terms

5.2.4 Identity Verification

Stripe Identity and other verification providers
- Shares: Government ID, selfie photos, identity documents
- May access public databases for verification

5.2.4A Student Verification Services

Student verification providers (SheerID, UNiDAYS, or similar)
- Shares: Student email, student ID, enrollment documents, educational institution name
- Purpose: Verify current student status for subscription discounts
- Re-verification required annually
- See respective provider's privacy policy

5.2.5 Mapping & Location Services

Google Maps Platform: Map display, geocoding, location search
- Shares: GPS coordinates, addresses, search queries
- See: Google Maps Privacy Policy

5.2.6 Communication Services

Email Delivery: SendGrid, AWS SES (for transactional emails)
SMS Providers: Twilio (for text message verification and notifications)
Push Notifications: Firebase Cloud Messaging, Apple Push Notification Service

5.2.7 Analytics & Performance Monitoring

Firebase Analytics: App usage and user behavior
Crashlytics: Crash reporting and debugging
Google Analytics: Web analytics (if applicable)

5.2.8 Customer Support

Customer Support Platforms: Zendesk, Intercom (may implement)
- Shares: Support inquiries, account details, conversation history

5.2.9 Fraud Prevention & Security

Fraud detection services: Share transaction data, device info, behavior patterns
Background check providers: For identity and criminal record verification

Service Provider Obligations:

Service providers are contractually required to:
- Use data only for HUM's purposes
- Maintain confidentiality and security
- Comply with applicable data protection laws
However, HUM is not responsible for third-party data practices beyond contractual obligations

5.3 Business Transfers

In the event of merger, acquisition, or sale:

Your information may be transferred to acquiring company
We will provide notice before transfer and any changes to privacy practices
Your data rights continue under successor entity

5.4 Legal Requirements & Law Enforcement

We may disclose information to:

Law enforcement: In response to valid legal requests (subpoenas, warrants, court orders)
Government agencies: To comply with legal obligations (tax authorities, regulatory agencies)
Legal proceedings: In lawsuits, arbitrations, or dispute resolution
Public safety: To prevent harm, protect rights, or address emergencies

When we disclose:

We verify legitimacy of requests
We may notify you (unless prohibited by law or emergency)
We challenge overly broad or improper requests
We disclose only information reasonably necessary

5.5 Protection of Rights & Safety

We may share information to:

Enforce Terms of Service and policies
Investigate violations and fraudulent activity
Protect safety and security of Users and public
Prevent illegal activities
Defend against legal claims
Protect intellectual property rights

We may share information for purposes not listed above IF:

You provide explicit consent
You direct us to share (e.g., referrals, social sharing)
You connect third-party services (social media accounts)

5.7 Aggregated & De-Identified Data

We may share aggregated or anonymized data publicly or with partners, such as:

Market trends and rental statistics
Category performance and pricing insights
Environmental impact aggregate metrics
Research and white papers

De-identified data is NOT considered personal information and is not subject to this Privacy Policy.

5.8 We DO NOT Sell Personal Information

HUM does NOT sell your personal information to third parties for their independent marketing purposes.

Note for California Residents: Under CCPA, certain data sharing (e.g., with advertising partners) may be considered "sale." See Section 13.1 for California-specific rights and disclosures.

6. DATA SECURITY & PROTECTION

6.1 Security Measures We Implement

We use industry-standard security practices:

Encryption in Transit: TLS 1.2+ encryption for all data transmission
Encryption at Rest: Sensitive data encrypted in databases and storage
Access Controls: Role-based access limitations, multi-factor authentication for employees
Network Security: Firewalls, intrusion detection/prevention systems
Secure Development: Security code reviews, vulnerability testing
Regular Audits: Third-party security assessments and penetration testing
Data Minimization: Collect only necessary information
Employee Training: Security awareness and confidentiality training
Incident Response: Procedures for detecting and responding to breaches

6.2 Third-Party Security Certifications

Our service providers maintain certifications including:

Stripe: PCI-DSS Level 1 Service Provider (highest payment security standard)
Google Cloud Platform: SOC 2/3, ISO 27001, GDPR compliance
Firebase: Google's security infrastructure and compliance

6.3 User Security Responsibilities

You are responsible for:

Keeping account credentials confidential
Using strong, unique passwords
Enabling two-factor authentication (if available)
Not sharing account access
Logging out on shared devices
Reporting unauthorized access or suspicious activity
Keeping device and app software updated

6.4 Security Limitations

Despite our efforts, NO security system is 100% secure. Risks include:

Hacking, phishing, or social engineering attacks
Unauthorized access due to stolen credentials
Software vulnerabilities or zero-day exploits
Insider threats or employee misconduct
Third-party service breaches

We cannot guarantee absolute security. You use the Platform at your own risk.

6.5 Data Breach Notification

If a data breach occurs:

We will investigate and assess the risk
We will notify affected Users without unreasonable delay (as required by law)
Notification will include:
- Nature of breach and data affected
- Steps we are taking to mitigate
- Recommended actions for Users
We will report to regulatory authorities as legally required

How we notify:

Email to registered address
In-app notification
Notice on Platform or website
Media/public notice (if widespread breach)

7. DATA RETENTION & DELETION

7.1 How Long We Keep Data

Retention periods vary by data type:

7.1.1 Account Data

While account active: Retained for Platform operations
After account deletion: Deleted within 30-90 days (see exceptions below)

7.1.2 Transaction & Payment Data

Transaction records: 7 years (tax and legal compliance requirements)
Payment information: Retained by Stripe per their policy; HUM keeps transaction metadata for 7 years
Tax forms (1099-K): 7 years per IRS requirements

7.1.3 Communications

Messages: Retained indefinitely for dispute resolution and legal purposes
Support tickets: 7 years
Reviews: Retained indefinitely (associated with transactions, not individual accounts after deletion)

7.1.4 Photos & Item Listings

Active listings: While listing is active or account exists
AI training data: Indefinitely (de-identified where feasible)
Deleted listings: Removed from public view; underlying data may be retained for AI training or legal purposes

7.1.5 Identity Verification Documents

Government IDs: 7 years after account closure (fraud prevention, legal compliance)
Verification records: 7 years
Student verification documents: While student subscription is active + 3 years after conversion to Standard subscription or account closure (for audit and fraud prevention purposes)
Student IDs and enrollment records: Deleted within 90 days after subscription conversion or account deletion (unless required for disputes)

7.1.6 Analytics & Usage Data

Aggregated analytics: Retained indefinitely
Individual usage logs: 2-3 years

7.2 Legal & Operational Retention Requirements

We may retain data longer if required for:

Legal obligations (tax laws, record-keeping requirements)
Pending litigation or investigations
Fraud prevention and safety
Resolving disputes or enforcing Terms
Complying with lawful requests

7.3 Data Deletion Process

When you delete your account:

Profile becomes inaccessible to other Users
Active listings are removed
Personal identifiers removed from reviews (reviews remain but anonymized)
Account data deleted within 30-90 days

Exceptions (data NOT deleted):

Transaction records (7-year retention)
Messages and communications (dispute resolution)
AI training datasets (de-identified photos)
Data subject to legal holds
Backups (deleted as backups are rotated/refreshed)

7.4 Backup Retention

We maintain backups for disaster recovery:

Backups may retain deleted data for 90 days
Backups not used for operational purposes
Data in backups eventually deleted as backups are rotated

8. YOUR PRIVACY RIGHTS & CHOICES

8.1 Access Your Information

You have the right to access your personal information:

In-App: View profile, listings, transaction history, messages through app settings
Request Copy: Email privacy@hum-app.com to request complete data export

We will provide:

Copy of your personal information in portable format (typically JSON or PDF)
Information about how we use and share your data
Response within 30 days (may extend to 60 days for complex requests)

8.2 Correct or Update Information

You can correct inaccurate information:

In-App: Edit profile, listings, payment methods directly
Request Correction: Email privacy@hum-app.com for information you cannot change yourself

8.3 Delete Your Information

You have the right to request deletion:

In-App: Go to Settings > Account > Delete Account
Email Request: Send request to privacy@hum-app.com

Deletion limitations (see Section 7.2):

Transaction records retained for 7 years
AI training data may be retained (de-identified)
Legal holds and fraud prevention
Messages retained for dispute resolution

Processing time: 30-90 days

8.4 Opt-Out of Marketing Communications

You can opt-out of marketing (but NOT transactional communications):

Email: Click "Unsubscribe" link in emails
SMS: Reply "STOP" to text messages
Push Notifications: Disable in app settings or device settings
In-App: Manage notification preferences in Settings

Transactional communications (booking confirmations, payment receipts, subscription renewals, payment failures, security alerts) CANNOT be opted-out without deleting your account.

You can control location access:

Device Settings: Disable location permissions for HUM app
- iOS: Settings > Privacy & Security > Location Services > HUM
- Android: Settings > Location > App Permissions > HUM
Choose: "Never," "While Using App," or "Always"

Impact of disabling: Search and item discovery features limited; cannot list items without location.

8.6 Limit Ad Tracking

You can limit personalized advertising:

iOS: Settings > Privacy & Security > Tracking > Disable "Allow Apps to Request to Track"
Android: Settings > Google > Ads > Opt out of Ads Personalization
In-App: Manage ad preferences in Settings (if applicable)

8.7 Object to Data Processing

You may object to certain data processing:

Marketing and profiling
AI training data use (note: cannot use Platform if you object to essential AI features)
Automated decision-making with legal effects

Submit objections to: privacy@hum-app.com

8.8 Data Portability

You can request portable copy of your data:

Email privacy@hum-app.com
We will provide data in structured, machine-readable format (JSON, CSV)
Includes: Profile, listings, transaction history, messages, reviews

Where processing is based on consent (marketing, optional features):

You can withdraw consent at any time
Does NOT affect lawfulness of processing before withdrawal
May limit Platform functionality if you withdraw consent for essential features

8.10 Lodge a Complaint with Regulator

If you believe we violated your privacy rights:

You have the right to lodge a complaint with a data protection authority
United States: Federal Trade Commission (FTC), state attorneys general
EU/UK: Your national Data Protection Authority
Other jurisdictions: Relevant privacy regulator

We prefer you contact us first: privacy@hum-app.com so we can address concerns directly.

9. COOKIES & TRACKING TECHNOLOGIES

9.1 What Are Cookies & Tracking Technologies

Cookies: Small text files stored on your device by websites/apps Tracking Technologies: Include cookies, pixels, beacons, local storage, SDKs

9.2 Types of Cookies & Technologies We Use

9.2.1 Essential/Functional

Purpose: Enable core Platform functionality

Session management and authentication
Remember preferences and settings
Security and fraud prevention
Load balancing and performance

Can you disable? NO (required for Platform to function)

9.2.2 Analytics & Performance

Purpose: Understand Platform usage and improve performance

Firebase Analytics: App usage, user behavior, feature performance
Google Analytics: Web traffic analysis (if applicable)
Crash reporting and error logging
A/B testing and feature experimentation

Can you disable? Partially (see Section 8.6 for opt-out options)

9.2.3 Advertising & Marketing

Purpose: Deliver personalized ads and measure campaign effectiveness

Targeted advertising based on interests and behavior
Conversion tracking
Retargeting campaigns
Social media pixels (Facebook, Instagram, if applicable)

Can you disable? YES (see Section 8.6)

9.3 Third-Party Cookies & Trackers

Third parties may set cookies/trackers:

Google (Analytics, Ads, Firebase)
Stripe (payment processing, fraud prevention)
Social media platforms (if you share content)
Advertising networks

We do not control third-party tracking. See their privacy policies.

9.4 Do Not Track (DNT) Signals

Current Status: We do not respond to "Do Not Track" browser signals, as there is no industry standard for DNT compliance.

Alternative: Use opt-out mechanisms in Section 8.6.

9.5 Managing Cookies

You can manage cookies via:

Browser settings: Delete or block cookies (may limit website functionality)
Mobile settings: Limit ad tracking, reset advertising ID
Opt-out tools: Digital Advertising Alliance (DAA), Network Advertising Initiative (NAI)

10. THIRD-PARTY SERVICES & LINKS

10.1 Third-Party Services We Integrate

HUM integrates services from:

Stripe (payments)
Google (Firebase, Maps, AI)
Apple (Sign-In, Push Notifications)
Social media platforms (if you connect accounts)

Each service has own privacy policy governing their data practices.

HUM is NOT responsible for:

Third-party privacy practices
Third-party data breaches or security incidents
Third-party terms or policy changes
Third-party service availability or functionality

You should review third-party privacy policies.

10.2 Links to External Websites

Platform may contain links to third-party websites:

We do NOT control external sites
External sites have own privacy policies
We do NOT endorse or guarantee external sites
Clicking links is at your own risk

10.3 User-Generated Links & Content

Users may post links in messages or listings:

HUM does NOT screen or approve links
We are NOT responsible for linked content
Report inappropriate links to support@hum-app.com

11. CHILDREN'S PRIVACY

11.1 Age Restriction

HUM is NOT intended for children under 13 years of age.

Users must be 18 years or older to create accounts and use the Platform (per Terms of Service).

11.2 No Knowing Collection from Children

We do NOT knowingly collect personal information from children under 13.

If we learn we have collected child data, we will:

Delete the information promptly
Terminate the account
Notify parents/guardians if identifiable

11.3 COPPA Compliance

We comply with Children's Online Privacy Protection Act (COPPA).

11.4 Parental Notice

If you believe we have collected child information:

Contact us immediately: privacy@hum-app.com
Provide details so we can investigate and delete data

12. INTERNATIONAL DATA TRANSFERS

12.1 Data Processed in United States

Platform is operated from the United States. Information collected is:

Processed and stored in U.S. data centers
Subject to U.S. laws and legal process
May be transferred to/from other countries where service providers operate

12.2 Cross-Border Transfers

Data may be transferred to countries outside your residence, including:

United States (primary)
Countries where Google Cloud Platform operates (global)
Countries where service providers have infrastructure

Data protection laws in destination countries may differ from your jurisdiction.

12.3 Safeguards for International Transfers

We implement safeguards including:

Standard Contractual Clauses (SCCs): EU-approved contracts for data transfers
Data Processing Agreements: Contracts with service providers requiring adequate protection
Privacy Shield (or successor frameworks): Where applicable
Adequacy Decisions: Reliance on government-approved transfer mechanisms

By using HUM, you consent to:

Transfer of your information to United States
Processing in countries with different data protection laws
Application of this Privacy Policy (not local laws) to extent permitted

For users in European Union or United Kingdom:

We comply with General Data Protection Regulation (GDPR) and UK GDPR
Legal bases for processing: Consent, Contract Performance, Legitimate Interests, Legal Obligations
EU/UK users have enhanced rights (see Section 8 and 13.2)
Data transfers use Standard Contractual Clauses
EU Representative: [To be designated if we have substantial EU users]

13. STATE-SPECIFIC PRIVACY RIGHTS

13.1 California Residents (CCPA/CPRA)

California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) grant additional rights.

13.1.1 Right to Know

California residents can request:

Categories of personal information collected
Categories of sources
Business purposes for collection
Categories of third parties with whom we share
Specific pieces of personal information we hold

13.1.2 Right to Delete

Request deletion of personal information (subject to exceptions in Section 7.2).

Do we "sell" or "share" personal information?

We do NOT sell personal information for monetary compensation
However, sharing data with advertising partners may constitute "sharing" under CCPA

To opt-out: Email privacy@hum-app.com with subject "Do Not Sell/Share My Info"

13.1.4 Right to Correct Inaccurate Information

Request correction of inaccurate personal information.

13.1.5 Right to Limit Sensitive Personal Information Use

Sensitive personal information we collect:

Government ID numbers (SSN)
Precise geolocation
Racial/ethnic origin (if inferred from photos - not intentionally collected)

To limit use: Email privacy@hum-app.com (note: may limit Platform functionality)

13.1.6 Right to Non-Discrimination

We will NOT discriminate against you for exercising CCPA rights by:

Denying goods or services
Charging different prices
Providing different quality of service

Exception: We may offer financial incentives or different service levels if reasonably related to value of data.

13.1.7 California "Shine the Light" Law

California Civil Code Section 1798.83 allows California residents to request information about disclosure of personal information to third parties for their direct marketing purposes.

We do NOT share personal information with third parties for their independent direct marketing.

13.1.8 How to Exercise California Rights

Email: privacy@hum-app.com with "California Privacy Rights Request"
Include: Name, email, state "I am a California resident," and specify rights you wish to exercise
Verification: We will verify your identity (may request additional info)
Authorized Agents: You may designate an authorized agent; must provide written authorization

Response Time: Within 45 days (may extend to 90 days if complex)

EU/UK residents have rights under GDPR, including:

Right to access personal data
Right to rectification (correction)
Right to erasure ("right to be forgotten")
Right to restrict processing
Right to data portability
Right to object to processing
Right to withdraw consent
Right to lodge complaint with supervisory authority

Legal Bases for Processing:

Consent: For marketing, optional features
Contract Performance: For providing Platform services and processing transactions
Legitimate Interests: For fraud prevention, analytics, Platform improvement
Legal Obligations: For tax compliance, legal requests

Data Protection Officer (DPO): [To be designated if required based on user volume]

EU Representative: [To be designated if we have substantial EU presence]

To exercise GDPR rights: Email privacy@hum-app.com with "GDPR Request"

13.3 Other U.S. States

Other states with privacy laws (Virginia, Colorado, Connecticut, Utah, Nevada, etc.):

Residents of states with comprehensive privacy laws have rights similar to CCPA, including:

Right to access, correct, delete personal information
Right to opt-out of targeted advertising and sale
Right to data portability

To exercise rights: Email privacy@hum-app.com with subject "[State] Privacy Rights Request"

We will comply with applicable state laws.

14. CHANGES TO PRIVACY POLICY

14.1 Updates & Revisions

We may update this Privacy Policy to reflect:

Changes in Platform features or operations
Legal, regulatory, or compliance requirements
Industry best practices
User feedback

14.2 Notice of Changes

We will notify you of material changes by:

Email to registered address (at least 30 days before effective date)
In-app notification
Notice on Platform or website
Updated "Last Updated" date at top of Privacy Policy

14.3 Your Acceptance

Continued use of Platform after changes constitutes acceptance.

If you disagree with changes:

You may delete your account before effective date
Deletion rights subject to Section 7 retention requirements

14.4 Review Privacy Policy Regularly

We encourage you to review this Privacy Policy periodically to stay informed about our data practices.

15. CONTACT US

15.1 Privacy Questions & Requests

For privacy-related inquiries, requests, or complaints:

Email: privacy@hum-app.com
Subject Line: Include specific request type (e.g., "Data Access Request," "CCPA Deletion Request," "GDPR Inquiry")

Mail:
Hum-App Technologies Inc.
Attn: Privacy Team
2314 28th Street
Santa Monica, CA 90405

15.2 General Customer Support

For non-privacy issues (account help, technical support, billing):

Email: support@hum-app.com
In-App: Use "Help" or "Support" feature in HUM app

15.3 Data Protection Officer (DPO)

If we designate a DPO (required for GDPR if substantial EU processing):
Email: dpo@hum-app.com
[To be designated if applicable]

15.4 EU Representative

For EU users (if we establish EU representative):
[To be designated if we have substantial EU user base]

15.5 Response Time

We will respond to privacy requests within:

30 days (standard)
45-60 days (for complex requests or high volume - will notify you of extension)
As required by applicable law (may be shorter in some jurisdictions)

ACCEPTANCE & ACKNOWLEDGMENT

By creating an account, using the HUM Platform, or continuing to use HUM after updates to this Privacy Policy, you acknowledge that you have READ, UNDERSTOOD, and AGREE to this Privacy Policy.

You specifically acknowledge and consent to:

Collection and use of your personal information as described
Use of your photos and data for AI analysis and training
Sharing of information with third parties as described (including Google, Stripe, other service providers)
International transfer of your information to United States and other countries
Storage of your information as described in retention policies
Use of cookies and tracking technologies
Your photos being used indefinitely for AI training datasets (de-identified where feasible)

If you do NOT agree to this Privacy Policy, you MUST NOT use the HUM Platform.

LEGAL DISCLAIMER: This Privacy Policy was prepared to provide comprehensive privacy disclosures and transparency. However, it does NOT constitute legal advice. Hum-App Technologies Inc. strongly recommends having this Privacy Policy reviewed by a qualified privacy attorney licensed in your jurisdiction before final implementation. Privacy laws vary by location and change over time. This document should be customized for your specific circumstances and updated regularly to reflect legal developments.

Privacy Policy