Privacy Policy

Horizontals Labs, LLC

Horizontals Labs, LLC ("Horizontals Labs," "we," "us," or "our") is a limited liability company organized under the laws of the State of Delaware, United States, with a registered office at 131 Continental Dr, Suite 305, Newark, DE 19713.

We provide software-as-a-service ("SaaS") platforms, mobile applications, and app development services to users worldwide (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our Services, visit our websites, or interact with our mobile applications (each, an "App").

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use our Services.

1. Information We Collect

We collect the following categories of personal information:

1.1 Information You Provide Directly

• Account Information: When you create an account, we collect your name, email address, username, and password. You may optionally provide a profile photo, phone number, or other profile details.
• Communications: When you contact us for support or feedback, we collect the content of your messages, your email address, and any attachments you provide.
• User Content: Any data, files, or content you upload, submit, or create through our Services.

1.2 Information Collected Automatically

• Device Information: Device type, operating system and version, unique device identifiers (such as IDFV), device model, screen resolution, and language settings.
• Usage Data: Pages and features accessed, time spent on screens, navigation paths, tap and interaction events, session duration, and frequency of use.
• Log Data: IP address, browser type and version, access times, referring URLs, and crash reports or diagnostics.
• Location Data: With your permission, we may collect precise or approximate geographic location data from your device's GPS, Wi-Fi, or cellular network signals. You may withdraw location permission at any time through your device settings.

1.3 Information from Third Parties

• Sign-In Services: If you sign in using a third-party provider (e.g., Sign in with Apple, Google), we receive your name, email address, and a unique identifier from that provider in accordance with their privacy policy.
• Analytics Providers: We may receive aggregated or de-identified analytics data from third-party analytics services.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Providing and maintaining our Services, including account creation, authentication, and customer support.
• Improving and personalizing our Services based on usage patterns, diagnostics, and user feedback.
• Communicating with you about your account, service updates, security alerts, and (with your consent where required) promotional materials.
• Ensuring safety and security, including fraud detection, abuse prevention, and enforcement of our terms of service.
• Analyzing usage trends and performance metrics to improve the functionality and reliability of our Apps.
• Providing location-based features when you have granted location permissions.
• Complying with legal obligations and responding to lawful requests from public authorities.

3. Legal Bases for Processing (EEA/UK)

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), we process your personal data on the following legal bases under the General Data Protection Regulation (GDPR) and UK GDPR:

Purpose	Legal Basis
Providing the Services and performing our contract with you	Performance of a contract (Art. 6(1)(b))
Improving and personalizing the Services	Legitimate interests (Art. 6(1)(f))
Sending promotional communications	Consent (Art. 6(1)(a))
Processing location data	Consent (Art. 6(1)(a))
Safety, security, and fraud prevention	Legitimate interests (Art. 6(1)(f))
Compliance with legal obligations	Legal obligation (Art. 6(1)(c))

Where we rely on legitimate interests, we have conducted a balancing test to ensure that your interests, rights, and freedoms do not override those interests. You may request further details of this balancing test by contacting us.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• Service Providers: We engage trusted third-party companies to perform functions on our behalf (e.g., hosting, analytics, customer support, email delivery). These providers are contractually obligated to use your information only as necessary to provide services to us and in compliance with this Privacy Policy.
• Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as a business asset. We will notify you of any such change in ownership or control of your personal information.
• Legal Requirements: We may disclose your information if required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• With Your Consent: We may share your information for any other purpose with your explicit consent.

5. Third-Party Services and SDKs

Our Apps may incorporate third-party software development kits (SDKs) and services for functionality such as analytics, crash reporting, and authentication. These third parties may collect information as described in their own privacy policies. We require that all third-party partners provide a level of data protection at least as protective as this Privacy Policy.

Key third-party categories may include:

• Analytics: To understand how users interact with our Services (e.g., usage patterns, feature adoption, crash diagnostics).
• Cloud Infrastructure: To host and deliver the Services reliably and securely.
• Authentication Providers: To offer secure sign-in options (e.g., Sign in with Apple).

We do not permit third-party SDKs to use your data for their own advertising or marketing purposes unrelated to our Services.

6. Tracking and Advertising Technologies

We respect your choices regarding tracking. Our Apps comply with Apple's App Tracking Transparency (ATT) framework. We will not track your activity across other companies' apps or websites for advertising purposes unless you have explicitly granted permission through the ATT prompt on your device.

We do not use cookies in our mobile Apps. On our websites, we may use essential cookies strictly necessary for site functionality. We do not deploy third-party advertising cookies.

You may control tracking preferences through your device's Settings > Privacy & Security > Tracking menu on iOS/iPadOS devices.

7. 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. Specifically:

• Account data is retained for the duration of your account and for a reasonable period thereafter (up to 30 days) to allow for account recovery, unless you request earlier deletion.
• Usage and analytics data is retained in identifiable form for up to 12 months, after which it is aggregated or anonymized.
• Location data is processed in real time for the relevant feature and is not stored in persistent, identifiable form on our servers beyond what is necessary to provide the requested service.
• Communications and support data is retained for up to 24 months to ensure continuity of service and to meet legal obligations.

When personal information is no longer needed, we will securely delete or anonymize it in accordance with our internal data management policies.

8. Data Security

We implement industry-standard technical and organizational measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS/SSL) and at rest, access controls, regular security assessments, and employee confidentiality obligations.

While we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to promptly notifying affected users and relevant authorities in the event of a data breach as required by applicable law.

9. International Data Transfers

Horizontals Labs operates from the United States and provides Services internationally. Your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. These countries may have data protection laws that differ from those in your jurisdiction.

For transfers of personal data from the EEA, UK, or Switzerland to countries that have not received an adequacy decision, we rely on appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• The UK International Data Transfer Agreement or Addendum, where applicable.
• Any other valid transfer mechanism recognized under applicable data protection law.

You may request a copy of the relevant transfer safeguards by contacting us at the address provided below.

10. Your Rights and Choices

Depending on your location and applicable law, you may have some or all of the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request that we correct inaccurate or incomplete personal information.
• Deletion: Request that we delete your personal information, subject to certain legal exceptions.
• Portability: Request a machine-readable copy of the personal information you provided to us.
• Restriction: Request that we restrict the processing of your personal information under certain circumstances.
• Objection: Object to our processing of your personal information based on legitimate interests.
• Withdraw Consent: Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
• Location Permissions: You may disable location services for our Apps at any time through your device settings.

To exercise any of these rights, please contact us at privacy@horizontalslabs.com. We will respond to your request within the timeframe required by applicable law (typically 30 days, extendable where permitted). We may ask you to verify your identity before processing your request.

Account Deletion: You may delete your account at any time through the settings within our App, or by contacting us directly. Upon account deletion, we will delete or anonymize your personal information in accordance with Section 7 above, unless retention is required by law.

11. Additional Rights for EEA and UK Residents

If you are a resident of the European Economic Area or the United Kingdom, you have additional rights under the GDPR and UK GDPR:

• The right to lodge a complaint with your local supervisory authority (e.g., the Information Commissioner's Office in the UK, or your national data protection authority in the EEA).
• The right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.
• The right to obtain information about the safeguards in place for international data transfers.

Our designated contact for GDPR-related inquiries is: privacy@horizontalslabs.com.

12. Additional Rights for California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), provides you with additional rights:

Categories of Personal Information Collected:

Category (per CCPA)	Examples	Collected
A. Identifiers	Name, email, IP address, device identifiers	Yes
B. Personal Information (Cal. Civ. Code § 1798.80)	Name, email address	Yes
D. Commercial Information	Service usage records	Yes
F. Internet/Electronic Activity	Browsing and usage data, interactions with the App	Yes
G. Geolocation Data	Precise or approximate location	Yes

Your CCPA/CPRA Rights:

• Right to Know: You may request the categories and specific pieces of personal information we have collected, the sources, the business purposes, and the third parties with whom we share it.
• Right to Delete: You may request deletion of your personal information, subject to certain exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: We do not sell your personal information and do not share it for cross-context behavioral advertising.
• Right to Limit Use of Sensitive Personal Information: We do not use or disclose sensitive personal information for purposes beyond what is necessary to provide the Services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To submit a CCPA/CPRA request, contact us at privacy@horizontalslabs.com. We will verify your identity before fulfilling your request and will respond within 45 days as required by law.

13. Children's Privacy

Our Services are not directed to children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will take steps to delete that information promptly.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at privacy@horizontalslabs.com and we will take steps to delete such information.

14. Apple App Store Disclosures

In accordance with Apple's App Store requirements, the following disclosures summarize our data practices as they relate to our iOS, iPadOS, macOS, watchOS, and tvOS applications:

14.1 Data Used to Track You

We do not track you across apps or websites owned by other companies for advertising or advertising measurement purposes unless you have provided explicit consent via Apple's App Tracking Transparency prompt.

14.2 Data Linked to You

The following data may be collected and linked to your identity:

• Contact Information (name, email address)
• Identifiers (user ID)
• Usage Data (product interaction, feature usage)
• Diagnostics (crash data, performance data)
• Location (precise or approximate location, with your permission)

14.3 Data Not Linked to You

The following data may be collected but is not linked to your identity:

• Diagnostics (aggregated crash and performance data)
• Usage Data (aggregated analytics)

14.4 Data Collection and Purpose

Data Type	Purpose	Required
Name, Email	Account creation, authentication, support	Yes
User ID	Account functionality	Yes
Usage Data	App improvement, analytics	No (opt-out available)
Crash Data	Stability improvements	No (opt-out available)
Location	Location-based features	No (permission-based)

14.5 Account Deletion

In compliance with Apple's account deletion requirements, users may request complete deletion of their account and associated data through the App's settings or by contacting privacy@horizontalslabs.com. We will process deletion requests within 30 days and confirm completion to you.

14.6 Required Reason APIs

Where our Apps use Apple's covered APIs that require declared reasons, we use those APIs only for the purposes disclosed in our App's privacy manifest file (PrivacyInfo.xcprivacy) and do not derive fingerprints from the data returned by such APIs.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this page, and where required by law, we will provide additional notice (such as in-app notification or email).

We encourage you to review this Privacy Policy periodically. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.

16. Contact Us

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

For GDPR-related inquiries or complaints, you may also contact your local data protection authority. A list of EEA data protection authorities is available at https://edpb.europa.eu.