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Privacy Policy

Effective as of: December 8, 2025

Important Information

In order to use the Service, we may ask you to enter your gender, date of birth, place of birth, and time of birth. We also automatically collect language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet Service provider, mobile carrier, hardware ID, Facebook ID, and other unique identifiers (such as IDFA and GAID) from your device. We need this data to provide the Service, analyze how our customers use the Service, and serve advertising.

To improve the Service and serve advertising, we may share this data with third parties. Such parties include Meta, TikTok, Google, Apple, Appsflyer, Amplitude, Firebase, Twilio, Pinecone, SendGrid, AWS. As a result of sharing this data with third parties we (1) analyze different interactions (e.g. how often users make subscriptions); (2) serve advertising (and show them only to a particular group of users, for example, to subscribers).

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 5) and who will be the data controller (Section 1). If any questions remain unanswered, you can contact us via contact@humanmatrix.ai

This Privacy Policy explains what personal data is collected when you use our mobile applications, websites and services provided through them (together "App" or "the Service") and how these personal data will be used and shared.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 13 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account using the functionality found in "Settings" in the App, or contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time, or by us if you purchased it directly from our websites; and (c) delete the App from your devices.

"GDPR" means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

"EEA" includes all current member states of the European Union and the European Economic Area.

"Process", in respect of personal data, includes to collect, store, and disclose to others.

1. Personal Data Controller

Human Matrix AI Hub FZ-LLC (with registered office at Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.) will be the controller of your personal data.

2. Categories of Personal Data We Collect

We collect the following data about you:

  1. Data you directly provide to us (for example, date of birth).
  2. Data we receive about you from third parties (for example, when you sign in via Google).
  3. We also collect data automatically when you use the Service (for example, your IP address).

3. Purposes and Legal Bases for Processing Your Personal Data

We collect and use your data primarily to provide and improve our services, as well as to enhance their overall quality. Furthermore, we aim to attract new customers to our Service. Below is a detailed explanation of the legal bases for and purposes of processing your personal data.

Purpose of Processing Category of Data Lawful Basis
To provide Service and administer your account All categories (including Onboarding and product data) Performance of a contract with you
To research, analyze, and enhance performance of the Service All categories Legitimate interest (to improve the Service)
To ensure quality control and safety Identifiers, Onboarding data, Communications, Device data Performance of contract / Legitimate interest
To provide customer support All categories Performance of a contract with you
To enable communication with experts Identifiers, Onboarding data, Communications Performance of a contract with you
To process payments, refunds, and chargebacks Identifiers, Payments data, Online activity Performance of contract / Legal obligation / Consent
To enforce Terms and prevent fraud All categories Legal obligation / Legitimate interest
To send communications about the Service All categories Performance of a contract with you
To send marketing communications Identifiers, Onboarding data Your consent / Legitimate interest
To serve personalized advertising Identifiers, Device data, Advertising IDs, Cookies Your consent / Legitimate interest
To analyze performance of advertising Onboarding data, Payment data, Device data, Advertising IDs Your consent / Legitimate interest
To comply with legal obligations All categories Legal obligation

4. With Whom We Share Your Personal Data

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We strive to conclude specific data processing agreements with all such parties.

The types of third parties we share information with include:

Third-party providers

  • Cloud storage: We use Amazon Web Service to host personal data and enable our Service to operate.
  • Monitoring of the Service: We use Firebase Performance Monitoring and Firebase Crash Reporting to monitor infrastructure and performance.
  • Data analytics: We use Firebase, Amplitude, Meta Pixel, TikTok Pixel, Google Analytics, and Microsoft Clarity to analyze how you use the Service.
  • Payment processing: We use various payment processing providers including Solidgate, Stripe, Pay.com, Checkout, and Worldpay.
  • Email verification and login: We use Debounce.io, Google, Meta, and Apple APIs.
  • Functionality of the Service: We use DivineAPI, OpenAI, and HMX AI solutions to generate readings and reports. Note: We send only de-identified data to OpenAI and HMX AI.
  • Communications: We use Zendesk, Twilio, SendGrid, Firebase, and Apple Push Notification.
  • Security: We use Cloudflare as a content delivery network provider.
  • Marketing and advertising: We use Meta Ads Manager, TikTok Ads Manager, Pinterest Ads Manager, Google Ads, and Bing Ads.

Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and to respond to requests from courts, law enforcement agencies, and other public authorities.

Third parties as part of a merger or acquisition

We may share information in connection with corporate transactions such as the sale of our business, a merger, consolidation, or asset sale.

Affiliates

We may share your personal information with our partner organizations that are part of our corporate group.

5. How You Can Exercise Your Rights

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data

You may review, edit, or change the personal data that you had previously provided in the App in the settings section of the App. You may also request a copy of your personal data collected during your use of the App via contact@humanmatrix.ai.

Deleting your personal data

You can request erasure of your personal data by sending us a request to contact@humanmatrix.ai. In some cases we may be legally required to keep some of the data for a certain time.

Objecting to or restricting the use of your personal data

You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request to contact@humanmatrix.ai.

Additional information for EEA-based users

If you are based in the EEA, you have additional rights:

  • Right to lodge a complaint: You have the right to lodge a complaint with a competent data protection supervisory authority. You can find a list at edpb.europa.eu.
  • Right to data portability: You can request to receive your personal data in a machine-readable format.

6. Age Limitation

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us via contact@humanmatrix.ai.

7. International Data Transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with adequate level of data protection, we rely on the adequacy decision of the European Commission; for example, we transfer personal data to the USA based on the EU-U.S Data Privacy Framework program. If we transfer personal data originating from the EEA to countries without adequate level of data protection, we rely on the Standard Contractual Clauses approved by the European Commission.

8. Changes to This Privacy Policy

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

9. For California Residents

California's Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes.

To obtain this information from us, please contact us at contact@humanmatrix.ai and indicate that this is a "Request for California Privacy Information". If you are a California resident, we will provide the requested information to you at your email address in response.

10. For Virginia Residents

This section supplements our Privacy Policy and only applies if you reside in the Commonwealth of Virginia. It describes how we use and process your personal data and explains your particular rights under the Virginia Consumer Data Privacy Act (VCDPA).

A. Disclosures about the use of your personal data

We may collect and use certain information about you in order to operate the Service and to maximize your experience. For more information about the categories and purposes, please read Sections 2 and 3 above.

B. Data Rights

Section 5 describes the data rights we offer to all users. Additionally, VCDPA provides Virginia residents with these data rights:

  • Opt out of Targeted Advertising: Contact us at contact@humanmatrix.ai to exercise this right.
  • Confirm Processing: You may confirm whether your personal data is being processed by contacting us.
  • Appeal: If we decline your request, you may contact us with the subject line "Appeal of Refusal to Take Action on Privacy Request". If your appeal is denied, you may contact the Office of the Virginia Attorney General.

11. Data Retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy and Terms and Conditions of Use, which includes the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Even if you submit a data deletion request, a small portion of data relating to our compliance obligations may be stored after the request is satisfied.

12. How "Do Not Track" Requests Are Handled

Except as otherwise stipulated in this Privacy Policy, this App does not support "Do Not Track" requests. To determine whether any of the third-party Services it uses honor the "Do Not Track" requests, please read their privacy policies.

13. Contact Us

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us via:

contact@humanmatrix.ai