PRIVACY POLICY

Effective Date: 01 August, 2024

This Privacy Policy (‘Policy’) describes the processing of information provided by the Users (‘User’, ‘you’ or ‘your’) and/or collected by Hunch (collectively with its Affiliates hereinafter referred to as ‘Hunch’, ‘we’, ‘us’, ‘our’ and ‘Company’) on the websites and applications where this Policy is published. Here is a breakdown of what Policy covers:

• Collection of Information: We’ll explain what information we collect from you and how we do it.
• Use of Information: We’ll outline how we use the information we collect.
• Sharing of Information: We’ll specify who we share your information with and under what circumstances.
• Retention of Information: We’ll disclose how long we keep your information.
• Transfer of Information: We’ll describe how and where we transfer your information, including across borders.
• Deletion and Anonymization of Information: We’ll explain your opt-out options and how you may delete or anonymize your information.  

This Policy is in accordance with Applicable Laws in the jurisdictions where the Platform is available. In some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. Those notices are to be read in conjunction with this Policy.

This Policy when read with our Terms of Use and Community Guidelines, together forms the ‘User Agreement’. The User Agreement, including any additional documents referenced, forms a binding legal contract between You and Hunch. Any term used in this Policy and not described herein shall have the same meaning as given in the Terms of Use. By continuing to use or access the Platform, you acknowledge that you have read, understood, and accepted the information given in this Policy. If you do not agree with this Policy in general or any part of it, you should immediately navigate away from the Platform.

1. Definitions and Key Terms

1. ‘Account’ on Hunch is a personal profile created by a user to access and utilize the Platform.
2. ‘Applicable Laws’ means all statutes, enactments, acts weof legislature or parliament, laws, ordinances, rules, by-laws, regulations, notifications, guidelines, policies, directions, directives, and orders of any governmental authority, as may be applicable to the User.
3. ‘Chat Feature’ refers to the interactive instant messaging feature on the Platform that allows Users to communicate in real-time. This also includes any AI based chat system that may send messages to Users.
4. ‘Community Guidelines’ or ‘Guidelines’ outline what is considered unacceptable Content and behavior on Hunch, as well as the actions that may be taken in the event of any violation of the Guidelines.
5. ‘Company’ refers to INKS Technology Services Pte. Ltd.
6. ‘Content’ refers to all data and materials created, shared, or uploaded by users on the Platform. This includes, but is not limited to, polls, poll options, text descriptions, image descriptions, comments, user profiles, profile photos, bios, and any other form of interaction, reaction, or communication. This encompasses text, images, generative AI outputs, links, attachments, emojis, and other creative tools available on the Platform.
7. ‘Platform’ means the Hunch website or mobile application, including any webpages through which our users may access our Services.
8. ‘Services’ refers to all the functionalities, features, and offerings provided through the Platform. This encompasses a wide range of activities and interactions available to users, including but not limited to accessing and participating in polls, using the Chat Feature, engaging with user-generated content, and any other tools, applications, or services that are part of the Platform experience.
9. ‘Users’ refers to individuals or entities who access, browse, register, or use the Hunch Platform in accordance with the Terms of Use, Privacy Policy, and Community Guidelines provided by Hunch.

2. Information we collect

1. Information you provide to us

1. ‘Personal Information’ means information that identifies (whether directly or indirectly)  a particular individual, and may include the individual’s name, email address, profile picture, telephone number, date of birth, age, gender, interests, education history, location, or any other information which we may have access to. However, we do not consider Personal Information to include information that has been aggregated, anonymized or encrypted in a manner which makes an individual non identifiable. Personal Information that may have undergone pseudonymisation but can be attributed to a natural person by the use of additional information will be considered Personal Information.
2. ‘Chats’. When you use the Platform’s Chat Feature, we collect information you provide when composing, sending, or receiving messages. This includes, but is not limited to:

• The content of the message
• The time it was sent, received, or read
• The participants in the Chat
• Any Chat requests made

3. Please be aware that while we facilitate message exchanges, the messages you choose to send to other Users of the Platform will be accessible by the recipients. We encourage responsible sharing, as we cannot control how recipients use or share your messages. Additionally, please note that our Chats are not end-to-end encrypted, and our authorized personnel may access this data to ensure compliance with the User Agreement, provide customer support, or comply with Applicable Laws.
4. We may collect information that you provide in your correspondence with us. This includes any information you choose to provide when seeking support or responding to our feedback requests.

2. Information we automatically collect

When you use our Platform, we automatically gather certain information to enhance your experience and maintain the security and efficiency of our Services. This may include your location and IP address, engagement data, technical information about your device and operating system, usage information, and other such data.

This information helps us analyze Platform usage, improve our services, ensure that our Platform remains relevant and useful for you, and comply with Applicable Laws. Please keep reading for a more detailed understanding of the information we automatically collect from you:

1. Usage Information. We may collect information on how you interact with the Platform including the polls you view, vote and comment on; the profiles you visit and profiles that visit yours; engagement metrics like your vibe score, the number of followers and Accounts you follow, and engagement timelines; frequency and timing of your posts; your usage of the Chat Feature, etc. This helps us understand how you use the Platform and guides our improvements. Please note that the usage information being tracked may change based on new features released on the Platform.
2. Log Data. Log Data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use the Platform and which we record in log files. Depending on your usage of the Platform, this log data may include browser type and settings and information about your activity on the Platform (such as the date and time stamps associated with your usage, pages, and files viewed, searches and other actions You take such as which features you use), device event information (such as system activity, error reports/crash dumps and hardware settings).
3. Device Information. We may collect information about the computer, phone, tablet or any other devices you use to access the Platform. Depending on the device used, this device information may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system and system configuration information. This information ensures a secure and reliable connection to our Platform and optimizes its compatibility and performance with your device.
4. Location Information. We may collect information about the location of your device, which can be either precise or imprecise. The extent of the location information we gather depends on your device’s type and its settings. You have the option to prevent us from collecting this information by disabling the location settings on your device. Please note that restricting your location data may limit some functionality of our Services. 
5. Information collected by Cookies and other Tracking Technologies. We may use cookies and other technologies to collect information about your activity, browser, and device. These cookies and similar tracking technologies are designed to enhance your experience on our Platform. You can manage your cookie preferences in your browser settings, allowing you to control if and how cookies are stored on Your device. Please note, however, that disabling cookies might affect the functionality and features available on our Platform.
6. Aggregated Data. We may collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your Personal Information but is not considered Personal Information by law if it does not directly or indirectly reveal your identity. This data helps us to understand how our services are used, improve our services, develop new products, and conduct research. For instance, we may analyze aggregated data to enhance user experience or to publish insights on overall user trends. Occasionally, we may publicly disclose aggregated or anonymized information, such as the total number of users or general usage patterns, ensuring that it cannot reasonably be used to identify you.

3. Information Collected from Other Sources

1. Ad Partners and other marketing partners. We may receive information from public databases, joint marketing partners, third-party programs, data providers, and other third parties for targeted advertising purposes. This information may be combined with the data you share with us to deliver a more personalized user experience.
2. Linked Third-Party Services. Data from services you link to your Hunch Account, such as social media or email accounts, to enhance functionality and personalization.
3. Embedded Content and Integrations. Data collected through third-party content or services embedded in our Platform.
4. Audience Measurement and Demographics. Information from service providers that perform audience measurement to understand the demographics of our users.
5. Compliance and Legal Requirements. Information received from law enforcement, government authorities, and other organizations to comply with Applicable Laws and ensure user safety.
   
6. Other Users and third parties. Information from other users, third-parties, and partners that helps us understand user interactions and improve services.

3. How we use your Information

We use your information for lawful purposes as listed below:

1. To facilitate Account creation and login

We use social sign-in or phone number/OTP (One Time Password) login to facilitate the sign up and login process. This may involve collecting some Personal Information including your name, email address and phone number.

2. To provide and maintain the Platform

We use the information we collect to operate and maintain the Platform, enhance your experience by training our machine learning models and artificial intelligence models, and provide personalized Content and ads.This includes suggesting people and topics to follow and helping you discover third-party services. If you connect your Account with other services, we may use information from those accounts for features like cross-posting and cross-service authentication. Your profile information from those services may be visible to other users on the Platform.

3. For Research and Analytics

We use the information we collect to analyze user interactions and usage patterns to measure Platform effectiveness and make data-driven improvements to enhance your experience on Hunch.

4. For Promoting Safety and Security

We may use the information we collect to ensure the safety and security of the Users, the Platform and your Account. This includes enforcing the User Agreement and complying with Applicable Laws. We monitor the Platform to prevent any unlawful practice on the Platform which may include fraud, unauthorized access and other such illegal activities.

5. To Respond to Legal Requests

If we receive a summon or any other law enforcement requests, we may need to inspect, verify and/or share your data. This is in compliance with Applicable Laws.

6. To communicate with you

We use the information we collect to communicate with you about our products and Services, including product updates and changes to the User Agreement. We may also send you marketing and promotional messages, or any other relevant information.

7. To manage your requests

We may use your information to respond to your inquiries and resolve any issues you might have with the use of the Platform.

4. How we share information

Please note that we do not sell your personal information to third parties. Listed below are the ways in which your information is shared by us:

1. With your consent

We may process your information for a specified purpose if you consent to such processing.

2. With Third Party Service Providers

We may sometimes share your information with third party service providers that perform functions and services on our behalf. This could include third parties that help us provide customer support, analytics platforms, maintain/store data, service providers/tools that improve the functionality of Hunch, help us market and promote our Services, help maintain security of the Platform, etc.

3. For Business Transfers

We may share or transfer information about you in connection with a transaction such as a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such a situation, the terms of this policy will continue to apply, and any changes to the terms shall be communicated to you in a timely manner. 

4. With Advertisers

We may provide valuable insights to advertisers or sponsors about the performance of their ads or sponsored content on the Platform. Such insights usually include general trends and patterns but do not contain personal details that can directly identify you, such as your name, email address or number.

5. With Other Users

Information about you, such as your username, profile picture, bio, vibe score, list and count of following and followers, polls participated in, polls commented on (‘Profile Information’), and the Content created by you on Hunch is available for all other Users on the Platform to view and interact with.

6. Legal, Safety and Compliance

We may share your information to comply with Applicable Laws, protect rights, property, or safety, investigate violations of our User Agreement, and prevent fraud, or for Business Transfers per section (c) of this Clause.

5. How long we retain your information for

1. We retain your information as long as required to provide for legitimate uses or to comply with Applicable Laws. We retain Personal Information for legal and security purposes as required, including for enforcing legal rights, processing judicial functions, or conducting financial assessments.
2. If you decide to stop using the Platform  you can delete your Account  and your profile  will no longer be visible to other users on the Platform. Please note that your Content may be available for a while even after your Account has been deleted.
3. Where you violate the User Agreement and your Account is terminated, we may keep, inter alia, the identifiers used to create the Account (e.g. email address or phone number) to prevent repeat policy offenders from creating new Accounts, in accordance with Applicable Laws.
4. After it is no longer necessary for us to retain information about you, or otherwise upon your request, we will dispose of it in a secure manner or anonymize the information. We may keep certain information in order to comply with legal requirements and for safety and security reasons, in compliance with Applicable Laws.
5. Publicly available Content may persist elsewhere even after you remove it from the Platform. For instance, search engines and other third parties may retain copies of your Content based on their policies.

6. Third Party Integrations

1. When you interact with third-party platforms through the Platform, we may access, collect, and share certain information necessary for these interactions. This includes but is not limited to your Profile Information on the Platform and third-party platforms, your Content, and the content you put on such platforms.
2. We may share User data with third-party entities, including analytics tools, advertising networks, third-party software development kits (SDKs), and any parent, subsidiary, or other related entities. This is to enhance User experience and app functionality, such as improving app performance, personalizing User experience, or delivering targeted advertising within the legal framework.
3. Please note that when you use the Platform to share content on third-party platforms, your use of these platforms is governed by their respective privacy policies and terms of service. We encourage you to carefully review these third-party policies before sharing content through our Services on these platforms. Hunch is not responsible for the privacy practices or the content of these third-party platforms. If you have any questions or concerns about how these platforms handle your Personal Information, we recommend reaching out to them directly or consulting their respective privacy policies.

7. Transfer of your Personal Information

1. Your information, including Personal Information, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained located outside of your state, province or country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
2. Your consent to this Policy and continued use of the Platform, represents your agreement to such transfer of data.
3. We are committed to ensuring the secure and lawful handling of your data. We take all necessary steps to ensure that your Personal Information is securely processed in accordance with this Policy.

8. Opting out

1. You can always opt out of using the Platform, choose not to disclose certain information to us, or withdraw consent at any time by contacting us at legal@hunch.in or via the Account Deletion Form, as explained in Section 9 below.
2. However, it is important to note that some information may be essential for registration or to fully utilize the Platform. By providing limited information, or by exercising your right to opt-out, you may not be able to access the full functionalities of the Platform and some features may be disabled for you. For example, not providing a location may disable location-based services or recommendations.
3. We reserve the right to retain your Personal Information if required under Applicable Laws.

9. Account, Data Deletion and User Data Handling

1. Account and Data deletion: Users have the right to request the deletion of their Accounts and associated Personal Information. This can be done directly within the Platform or via the Account Deletion Form. Upon receiving a deletion request, we will securely and completely remove the User’s Personal Information from our records, subject to Applicable Laws.
2. User Data Transparency and Security: We are committed to the transparent handling of User data. This includes a clear disclosure of our practices regarding the access, collection, use, and sharing of User data. We ensure that the handling of personal and sensitive User data, including but not limited to identification and location information, is conducted securely, using modern secure methods. This is in adherence to app store requirements and applicable data protection laws. We provide disclosures regarding data collection practices, ensuring users are fully informed about how their data is utilized.

10. Privacy of Children

1. Hunch requires people accessing the Platform to be 18 years of age or older. 
2. If you do not meet the age requirements as per Applicable Laws, you should immediately navigate away from the Platform. If you believe we may have mistakenly or unintentionally allowed access to the Platform or collected any information from a person below the legal or permissible age as per Applicable Laws, please contact us using the contact information provided below.
3. Accessing the Platform signifies that you warrant being of legal age to do so. Before processing the information of anyone restricted from accessing the Platform as per Applicable Laws, we may obtain verifiable consent from the parent or guardian of such an individual if required by Applicable Laws.

11. Control over Your information

We want you to be in control of your information, so we provide you with a range of tools, including:

1. You may delete your Account and associated information as per Section 9 of this Policy.
2. You may object, limit, or withdraw consent for processing your data per Section 9 of this Policy, or by restricting access to certain permissions using the in-app features or your device settings.
3. You may ask for information on how your data is shared, including the third parties with whom it may have been shared.
4. You may request a summary of the personal information we hold about you.
5. You may correct, complete or update  your information for accuracy by navigating to your profile on Hunch.
6. You may nominate another individual to exercise your rights in the event of death or incapacity.
7. You may change permissions granted to Hunch by navigating to settings on Hunch, or on your device settings, as applicable.

12. Complaint Resolution Mechanism

We are committed to the responsible handling of your Personal Information and addressing any concerns you may have. If you wish to file a complaint or have requests regarding your information, you may use the following channels:

1. In-app mechanism: For immediate assistance, we provide an in-app mechanism through which you can report or request support from our customer support team. This feature is designed for ease of use and quick response, ensuring that your concerns are promptly and efficiently addressed.
2. Reporting: You can report content and users by following the steps mentioned within the Hunch Trust and Safety Center here.

13. Grievance Reporting for Users in India

Name: Anvi Jha
Email: go.india@hunch.in

14. Changes to these Terms & additional Terms

We may periodically update this Policy. When we do, we'll post the updated version and note the date of the latest revision. For significant changes, we may also inform you by email (if you've provided one) or through a notification on the Platform. By continuing to use the Platform after these updates, you agree to the revised Policy. If you disagree with the changes, please discontinue using the Platform before they take effect

15. Contact Us

For any support, concerns, or clarifications regarding this Policy, you may contact us at legal@hunch.in.