Privacy Policy

HUD Privacy Policy

HUD Studio Limited (company number 1800707), registered at Level 11, 19 Victoria Street West, Auckland Central, Auckland, 1010, New Zealand ("HUD") is firmly committed to respecting the confidentiality of the personal information you supply to us and all data will be processed in accordance with applicable data privacy laws.

The following policy discloses HUD’s information gathering and dissemination practices for this website (the "Website") and use of HUD’s mobile application service (the "Service"). If you do not agree with our use of your personal information as set out in this Privacy Policy, you should not submit your personal information to us. HUD reserves the right to make changes to this Privacy Policy from time to time by uploading a a revised Policy on the Website. The changes will apply from the date we upload the revised Policy to the Website. By continuing to use HUD’s Website and Service, constitutes your acceptance to any such changes. Accordingly, you should review this Privacy Policy from time to time for changes. THIS PRIVACY POLICY WAS LAST UPDATED: October 2023

The Website and the Service are intended for use by individuals over the age of 18. Individuals under 18 years of age are not authorized to use or access the Website and the Service. The protection of your privacy is very important and HUD has adopted the following practices to safeguard the confidentiality of your personal information.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Object to processing of your personal information where HUD is are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where HUD is processing your personal information for direct marketing purposes.
  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information HUD holds about you and to check that HUD is processing it lawfully.
  • Request correction of the personal information that HUD holds about you. This enables you to have any incomplete or inaccurate information HUD holds about you corrected.
  • Request erasure of your personal information. This enables you to ask HUD to delete or remove personal information where there is no good reason for HUD continuing to process it. You also have the right to ask HUD to delete or remove your personal information where you have exercised your right to object to processing (see above).
  • Request the restriction of processing of your personal information. This enables you to ask HUD to suspend the processing of personal information about you, for example if you want HUD to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.

If you want to exercise any of these rights then please contact HUD through the Contact section on our Website or using the contact details set out at the end of this Privacy Policy. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, HUD may need to discuss with you whether HUD’s use of your data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.

HUD will respond to your request within one month of receipt of your request. In some cases HUD may not be able to fulfil your request to exercise the right before this date and may need to request more time. Where HUD cannot provide a full response to you for any reason, HUD will let you know about this in HUD’s initial reply to your request.

Your duty to inform HUD of changes

It is important that the personal information HUD holds about you is accurate and current. Please keep HUD informed if your personal information changes while you are using HUD’s Website and Service.

Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, HUD may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, HUD may refuse to comply with the request in such circumstances.

What HUD may need from you

HUD may need to request specific information from you to help HUD confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to complain

If you wish to request further information about any of the above rights, or if you are unhappy with how HUD has handled your information, please contact HUD through the Contact section on our Website or using the contact details set out at the end of this Privacy Policy. If you are not satisfied with HUD’s response to your complaint or believe HUD’s processing of your information does not comply with data protection law, you can make a complaint to the relevant supervisory authority in your jurisdiction. For example, the Office of the Privacy Commissioner in New Zealand.

What information is collected?

HUD collects two types of information: personally identifiable information ("PII") and non-personally identifiable information ("Non-PII"), which is also referred to as aggregate and anonymous data.

What information do you gather from visitors?

HUD gathers information about how you access the Website and use the Service, including the type of device you use to access the Website or Service, your domain name, your IP address, your phone number, and your internet browser software, operating system and platform. HUD may also derive your approximate geolocation from your IP address or from your mobile device.

HUD also gathers information about your use of the Website and Service, including statistical data about your visit such as the date and time of your visit, the number of links you have clicked on, the pages you have visited, and the number of times you have visited, and the advertising you view on the Website. HUD uses cookies to identify traffic that comes through advertising and to facilitate a more user friendly experience. Cookies are small pieces of information that a web site places on your computer's hard drive so HUD knows it's you when you visit. This helps HUD to create a personalized experience for you when you visit the Website or use the Service. The use of cookies is a very common practice on the Internet and provides for a more customized user experience of the Website. For further information on HUD’s use of cookies, please refer to HUD’s Cookie Policy available here: https://www.hudapp.com/cookie.

What information will you ask me for?

When you create a profile on the Service you will be asked for PII and Non-PII which will enable HUD to provide you with a custom Service. HUD may collect and use information you provide HUD with, including (but not limited to) information such as your first name, date of birth, gender, pronouns, genders you are seeking, what you are looking for, photos, account user name, email address, height and any other information you have provided to HUD through your use of the Service or otherwise.

When creating a profile through HUD, you will be given the option to sign in with, your Apple ID, Google account or your phone number. If you do not sign in with one of these options, you will not be able to set up a profile and use the Service. The relevant privacy and data policies of Apple and Google govern their use of PII and financial information provided to these third-party application marketplaces. HUD recommends that you locate and review these entities’ privacy and data sharing policies before signing in with these options.

While creating a profile, you will need to confirm your first name, date of birth, gender, pronouns, genders you are seeking, what you are looking for and be required to upload a profile photo of yourself showing your face clearly.

What information does HUD collect from third parties?

HUD may collect information from other sources, including third party sites that you may choose to link to your HUD account, such as, Apple, Google and Spotify. HUD may obtain the information that you have provided to that third party, to the extent allowed by the third-party site and authorised by you. HUD recommends that you locate and review these entities’ privacy and data sharing policies before using these to link your HUD account.

How will this information be used and who has access to it?

Non-PII

Your Non-PII is used to personalize your experience, allow other members to find you through search filters, and to deliver targeted advertising and promotional offers to you from external companies that are of the highest relevance to your demographic profile. HUD may share some of this information for HUD’s own analysis and research purposes with HUD’s professional advisors or consultants and third-party partners in order to deliver, manage, monitor, maintain, develop and improve HUD Services and/or the Website.

PII

The PII HUD collects from you is used in the course of providing HUD’s Service to you and to manage, monitor, maintain, develop or improve the content and functionality of HUD’s Service and Website, or customize the layout of HUD’s pages for each individual member. HUD may use your contact information to send you HUD Service activity updates regarding your profile, email verification, marketing material, newsletters, events we are part of and timely notices of promotions we are offering. HUD may also use your PII to send electronic mail to you, for the purpose of informing you of changes or additions to the Service, or of any HUD products and related services. HUD will only send you marketing communications where HUD has your consent to do so. You have the option to withdraw your consent at any time. If you do not wish to receive these email updates, you can unsubscribe by clicking ‘unsubscribe’ in the email sent to you. HUD does not rent, sell or otherwise provide your PII to third parties for marketing, direct marketing or solicitation purposes. The PII HUD collects is not released to any non-affiliated third party without your prior consent except as provided below:

Payment

Your credit card or payment details are not processed or transmitted through the Service or via the Website. All payments are processed via the Apple App Store, Google Play Store, or equivalent mobile application marketplaces. The privacy policies of these third parties govern their use of PII and financial information provided to these third-party application marketplaces. HUD recommends that you locate and review these entities’ privacy and data sharing policies before using our Service.

Advertisers and Third-Parties

HUD may disclose your Non-PII to third party organisations, agents and service providers to assist HUD in providing the Services (for example, Spotify), as well as conducting market and business research and analysis for any of the purposes set out in this Privacy Policy. HUD promotes third-party advertisers on HUD. Clicking advertisements may redirect you to websites where the third party’s collection, use or disclosure of Non-PII or PII you provide to them is beyond HUD’s control. HUD will never share or sell PII to advertisers - even when you are logged in and click an advertisement. Different sites have very different privacy practices and policies. HUD recommends you locate and read the privacy policy of any site you are redirected to.

Third-Party Social Networking Sites

When you have enabled the use of HUD’s Services through a third-party social networking site, mobile application, or similar websites or applications (a "Social Networking Site"), you permit HUD to access certain information about you that is made available to HUD through or from that Social Networking Site. The information obtained by HUD varies by Social Networking Site and may be affected by the privacy settings you establish at that Social Networking Site, but can include information such as your name, profile picture, network, gender, username, user ID, age range or birthday, language, location, country and other information. By accessing or using HUD’s Services through a Social Networking Site, you are authorizing HUD to collect, store, retain and use, in accordance with this Policy, any and all of your information that HUD has obtained from the Social Networking Site, including to create a HUD profile page and account for you. Your agreement to the foregoing takes place when you "accept" or "allow" or “go to" (or other similar terms) HUD’s application on a Social Networking Site or the transfer of information to HUD from such site. If there is information about your “friends" or people you are associated with in your Social Networking Site account, the information HUD obtains about those persons may also depend on the privacy settings such people have with the applicable Social Networking Site. You acknowledge and agree that HUD is not responsible for, and has no control over, any applicable privacy settings on any Social Networking Sites (including any settings related to any messages or advertisements about HUD that the Social Networking Site may send to you or your friends). You should always review, and if necessary, adjust your privacy settings on Social Networking Sites before getting or using applications such as HUD’s or linking or connecting your Social Networking Site account to the Services. You may also unlink your Social Networking Site account from the Services by adjusting your settings on the Social Networking Site.

To enforce legal rights

HUD may disclose your PII to respond to law enforcement requests; or where required by applicable laws, court orders, or government regulations; or to protect against misuse or unauthorized use of our Website or Service; or to protect the personal safety or property of HUD’s users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

Sale or Merger

HUD may disclose and sell PII in connection with the sale, assignment, or other transfer of the business or a portion of the business of HUD’s Website or Service, including a corporate merger, consolidation, restructuring, sale of assets or other corporate change of HUD’s direct or indirect parent companies that affects HUD.

How does HUD respond to Do Not Track signals?

The Website supports the Do Not Track browser setting. Do Not Track (“DNT") is a preference you can set in your web browser to let the websites you visit know that you do not want them collecting certain information about you. For more details about Do Not Track, including how to enable or disable this preference, visit the Electronic Frontier Foundation page. Website users who send Do Not Track signals will not experience an adverse effect on their experience with the Website.

HUD’s basis for collecting and using the information

HUD is entitled to use your PII in the ways set out in this Privacy Policy on the following basis:

  • the use of personal information in this way is necessary for the performance of a contract with you for provision of HUD’s Services;
  • the use of your personal information is necessary for HUD’s legitimate interests in:
  • ensuring the quality of the products and services HUD provides to you;
  • collecting information for marketing purposes;
  • communicating with you; and
  • statistical analysis;
  • you have consented to such use; and/or
  • to establish, exercise or defend HUD’s legal rights for the purposes of legal proceedings.

HUD processes your sensitive and special categories of information where HUD has asked for your explicit consent or otherwise where this is necessary for the establishment, exercise or defence of legal claims.

In the case that you have obviously made information public (e.g. on social media) HUD will process sensitive/special categories of information for the purposes of carrying out HUD’s legal obligations.

If provision of your PII is a legal or contractual requirement or a requirement necessary to enter into a contract with HUD, and you choose not to provide it, HUD may not be able to perform some of the tasks HUD needs to in order to provide certain services to you. If you do choose to provide your consent you can withdraw it at any time by contacting HUD through the registered access section of HUD’s Website or using the contact details set out at the end of this Privacy Policy.

How long does HUD keep the information that users have provided to HUD?

HUD keeps the information you have given HUD for as long as your profile stays active or hidden (i.e. if your account has been paused). Your PII will be deleted from our systems (other than records kept as required by applicable law or for general backup, archival or record keeping purposes) if your account is inactive for 270 consecutive calendar days.

Updating your preferences

By accessing and updating your email notification preferences, personal information and public information You have the opportunity to opt-out of certain communications and modify personal information or demographic information you have provided to HUD, and to hide information visible to the public users of the Website at any time by going to the 'Settings' -> 'Notifications' section on your profile.

Please be aware that it may take several hours for any custom changes you make to take effect on the public areas of the system. Please also note that changing or deleting your information through the 'Notifications' section of the system, or opting-out of email notifications from HUD, will only change or delete the data in HUD’s database for the purpose of future activities and communications. These changes and deletions will not change or delete information or emails that are queued to be sent or have already been sent.

Unsolicited Contact (SPAM)

HUD does not send unsolicited email at any time. You may opt-out of receiving email messages at any time. Any abuse or evidence of unsolicited email that appears to have been initiated from HUD, directly or indirectly, should be brought to the immediate attention of HUD’s compliance officer by using the Contact Form., or by tapping the More (...) tab in the App, then tap on Contact Us.

Does HUD monitor online behaviour?

HUD’s users communicate with each other through on-site Mail Messaging. While HUD does not, as a rule, moderate or monitor members' private exchanges, HUD reserves the right to do so if HUD suspects users of being under the age of 18 or of using HUD’s Service for the purpose of solicitation or any other violation of HUD’s Terms & Conditions or Privacy Policy. Submissions that appear on the public area of the site are moderated and, if necessary, HUD reserves the right to edit, delete, remove or not use any communication on a public area of the site.

Security

HUD treats data as an asset that must be protected against loss and unauthorized access. To safeguard the confidentiality and security of your PII, HUD uses industry standard practices and technologies including but not limited to "firewalls", encrypted transmission via SSL (Secure Socket Layer) and strong data encryption of sensitive personal information when it is stored to disk. However, because the internet is an open network, HUD cannot warrant or guarantee that your PII is safe from unauthorised access or use. Non-PII and PII may be kept on computer systems operated by third parties. HUD will take reasonable precautions against unauthorised access and disclosure by those third parties.

Cross-border data transfers

HUD is a New Zealand-based company and many of HUD‘s external third parties are based outside the UK and the European Economic Area (“EEA”). Accordingly, to the extent you are based within the UK or EEA, the processing of your personal information may involve a transfer of information outside of these jurisdictions. Where your information is transferred to any country outside the UK or EEA, HUD ensures that this is done using specific legally-approved safeguards. You can request further details and a copy of these safeguards by contacting HUD using the contact details set out at the end of this Privacy Policy.

How to contact HUD

If you wish to contact HUD about this Privacy Policy, including requesting access, amendments to, or deletion of your PII and Non-PII, you can contact HUD at:

Email: privacy@hudapp.com

Online: Contact Us Form or by clicking the ‘request info’ button under settings on your account on HUD’s Service.

By post:

Privacy Officer

HUD Studio Limited

PO Box 5800 Victoria St West

Auckland 1142, New Zealand