Hab12 Privacy Policy

1. Scope and wellness purpose

This policy explains how HabTools, Inc. (“HabTools,” “we,” “our,” or “us”) processes information associated with the Hab12 mobile application (the “App”), compatible muscle-activity sensor, related Hab12 web pages, customer support, product testing, and direct-to-consumer purchases in the United States.

Hab12 uses a compatible surface electromyography (sEMG) sensor to transform muscle activity into real-time visual feedback and interactive gameplay. The product is designed to support exercise engagement, muscle awareness, physical training, and general wellness. It is not intended to diagnose, treat, cure, mitigate, prevent, or monitor any disease, injury, or medical condition, and it does not provide medical advice.

Participation in a formal research study, or access through a healthcare provider, employer, rehabilitation organization, or other institution, may be subject to additional notices or agreements.

2. Information processed by Hab12

Muscle-activity readings

The App receives and may store high-resolution sEMG readings from a compatible sensor, along with signal values, timestamps, calibration values, thresholds, and session-related technical information. In the standard direct-to-consumer configuration, these data are stored locally on your device by default. HabTools does not receive your locally stored raw readings merely because you use the App.

Session and gameplay information

Depending on the activity and App version, Hab12 may process session dates and duration; scores, levels, gameplay actions and completion status; repetitions, thresholds, success measures, and time-based measures; derived measures such as effort, peak values, time under tension, or total work; and the sensor or session identifiers and settings needed to operate the product. User-entered names or notes may be included when you choose to create or share a report.

Unless you choose a feature that sends information outside the device, session readings and performance information remain on your device.

Bluetooth and device information

Hab12 uses Bluetooth to discover and communicate with compatible hardware. It may access Bluetooth status, sensor identifiers, App version, device model, and operating-system version needed for operation or troubleshooting. Some Android devices or operating-system versions require location permissions or services for Bluetooth scanning. Hab12 does not use Bluetooth scanning to determine your physical location and does not collect GPS coordinates during ordinary use.

If notification features are offered, the App may request notification permission. You can manage that permission in your device settings.

Information you provide

If you contact us, respond to a survey, participate in beta testing or product evaluation, or request support, we may receive your name, email address, messages, attachments, device details, and information you choose to submit. Beta testers may also send feedback through Apple TestFlight or other platform tools, subject to those services' practices.

Website and purchase information

When you visit HabTools or Hab12 web pages, our website hosting or security providers may process ordinary network information such as IP address, browser details, requested pages, and access time. If you purchase a product from HabTools, we and our payment and fulfillment providers may process contact, billing, shipping, item, order, tax, and transaction information. Payment-card processing is handled by the payment service provider rather than stored as full card numbers by HabTools.

3. Your sharing choices

Manual sharing

When a manual sharing or export feature is available, you choose the report or data file, select a recipient or destination, and initiate the sharing action. This may include a summary of gameplay and derived metrics or a detailed file containing raw sEMG readings. HabTools receives the file only if it is addressed to HabTools or otherwise intentionally provided to us. Other recipients may handle their copy under their own privacy practices.

Optional automatic end-of-session sharing

Some versions of Hab12 may offer an optional feature that sends the complete session report to HabTools at support@habtools.com after each completed session. When available, this feature is off by default and must be enabled through a separate affirmative consent choice that is not preselected. The consent explains what information will be sent, why it is sent, who receives it, and which providers process it.

The complete report may include high-resolution sEMG readings, calculated metrics, session date or time, sensor identifier, game settings, trial results, scores, and user-entered names or notes. If enabled, the report is transmitted over encrypted HTTPS to a Google Firebase Cloud Function, which forwards it to Brevo for email delivery to HabTools. Brevo handles the email message and report attachment for delivery. This workflow is for report delivery, not for enrolling users on an email marketing list.

You may disable automatic sharing at any time using the applicable App setting. Turning it off stops future automatic transmissions; it cannot retrieve reports already delivered. Manual sharing to other recipients remains a separate action initiated by you.

Important: The exact sharing controls available may differ by App version. Automatic session-report sharing requires the separate consent and user control described above.

4. How HabTools uses information it receives

• Provide support, answer questions, and investigate sensor, connectivity, or software issues.
• Conduct product testing, troubleshoot, improve quality, and assess usability when information is provided for those purposes.
• Operate and improve our App, website, sensor, and interactive experience.
• Process and document orders, shipping, refunds, returns, and warranty requests.
• Respond to privacy requests, protect services from misuse, and meet legal obligations.
• Undertake research only with an appropriate separate notice and consent process, when applicable.

HabTools does not use information users share with it to diagnose a medical condition, prescribe treatment, determine eligibility for health insurance or employment, or make treatment recommendations.

5. Service providers and disclosure

Providers may process limited information on HabTools' behalf as needed for services we use. Depending on the features involved, these can include:

• Google Firebase Cloud Functions: a service used to receive and forward an automatically shared report, if you enable that feature. Google may process the report while forwarding it and associated technical request information such as IP address and request time.
• Brevo: an email-delivery provider used to process the complete message and report attachment for delivery to HabTools when automatic sharing is enabled. This report workflow is not intended for marketing-list enrollment.
• Website hosting and security providers: services that deliver and protect our web pages.
• Payment, shipping, and fulfillment providers: services used when products are ordered.
• Professional advisers and support providers: persons or providers with a legitimate business or legal need for relevant information.

We may also share information when required by applicable law, valid legal process, or reasonably necessary to investigate fraud, protect safety, or complete a lawful business transaction subject to applicable privacy obligations.

We do not sell consumer health data or personal information for money, display third-party advertisements in the App, or use personal information for targeted advertising. The Firebase service described here is used for delivering reports when optional sharing is enabled; it is not intended to serve as a permanent database of session readings.

6. Research and de-identified information

Using Hab12 does not automatically enroll you in a research study or authorize research use of identifiable information. Research participation, or any separate permission for research or publication purposes, will be handled through an additional notice and consent process where applicable.

HabTools may create or use aggregated or de-identified information designed not to be reasonably linked to a person. Where law requires, we will maintain such information in de-identified form and will not attempt to reidentify it except as permitted to test de-identification methods.

7. Retention and deletion

Information on your device

Saved readings and session information ordinarily stay on the device until you delete them using available App or device controls, uninstall the App, or reset the device, subject to any operating-system or backup behavior. HabTools cannot ordinarily retrieve or delete data that exists only on your device.

Reports and messages received by HabTools

Session files received by HabTools through manual or optional automatic sharing are ordinarily removed from active systems within 90 days after the relevant support, testing, or quality-improvement purpose is completed, unless longer retention is reasonably necessary for security, legal, warranty, research-consent, or dispute-resolution purposes. Firebase is not intended to function as a permanent report database in this workflow. Firebase and Brevo may keep limited technical or delivery records for operational purposes.

Ordinary support correspondence may be retained for up to 24 months after the last communication. Transaction, accounting, tax, or warranty records may be retained for longer periods as required or reasonably necessary. Routine backups may persist temporarily until overwritten under normal backup schedules.

8. Security

HabTools employs administrative, technical, and organizational safeguards designed to protect information it receives and restrict access to people and providers with an authorized need. No method of storage or transmission is completely secure. Consider the sensitivity of muscle-activity records before sending detailed data through email or other third-party services.

9. Privacy rights and requests

Depending on your location and applicable law, you may have rights to confirm processing, access information, receive a copy, correct inaccurate information, request deletion, withdraw consent for future processing or sharing, obtain recipient information, and appeal a decision on a privacy request.

To exercise a right, email contact@habtools.com with the subject “Hab12 Privacy Request.” We may take reasonable steps to verify your identity and will respond within applicable legal timeframes. Requests to HabTools ordinarily cover information held by HabTools or its providers, not local-only copies on your device. We do not discriminate against people for exercising applicable privacy rights.

See also Consumer Health Data Privacy Policy and Privacy Choices & Requests below.

10. Age restrictions and children

Hab12 is intended for adults age 18 or older and is not directed to children. We do not knowingly collect personal information from children under 13 through ordinary direct-to-consumer use. If we learn we have obtained information about a child that must be deleted under applicable law, we will take appropriate steps to remove it.

11. Third-party services and tracking

Hab12 may use operating-system Bluetooth features, an app store, sharing tools, third-party email services, and web links. Those services have their own policies. We do not use cross-site advertising pixels or sell information for advertising. Because the website and App are not designed for cross-site advertising tracking, they do not vary their behavior in response to browser “Do Not Track” signals.

Information automatically collected by Apple TestFlight or an operating-system service may be handled separately by that provider under its own privacy disclosures.

12. Changes to this policy

We may update this policy as Hab12, service providers, privacy practices, or legal requirements change. We will post a revised effective date and, where required, provide additional notice or obtain new consent before materially different processing begins.

13. Contact