HMU Privacy Policy

Owner

Sparkly LLC
Owner contact email: hello@hmu.life

Types of Data collected

We may collect Personal Data as follows:

• Identity Data includes first name, last name, username or similar identifier, photo, date of birth, country of residence and gender.
• Contact Data includes your email address and any optional social usernames you choose to add to your profile.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Purchase Data includes product, subscription, transaction, and purchase-verification information provided by Apple App Store or Google Play. HMU does not receive your full payment-card or bank-account details.
• Usage Data includes information automatically collected through HMU (or third-party services employed in HMU), about how you use HMU, products and services. This can include the following information: Cookies, the IP addresses or domain names of the computers utilized by the Users who use HMU, the URI addresses, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer, the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit, and other parameters about the device operating system and/or the User’s IT environment.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Personal Data is freely provided by the User, or, in case of Usage Data, collected automatically when using HMU.

Unless specified otherwise, all Personal Data requested by HMU is required, and your failure to provide such Personal Data may make it impossible for HMU to provide its services. In cases where HMU expressly states that Personal Data is optional, Users may choose not to share such Personal Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies or other tracking tools by HMU or by the owners of third-party services used by HMU serves the purpose of providing the Service requested by the User, in addition to any other purposes described in this Privacy Policy and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through HMU and confirm that they have the third party’s consent to provide the Personal Data to the Owner.

Mode and place of processing Personal Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data. The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Personal Data may be accessible to certain types of persons in charge, involved with the operation of HMU (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place of Processing

The Personal Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Personal Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users should review the section of this Privacy Policy containing details about the processing of Personal Data.

The purposes of processing

Personal Data is collected to allow the Owner to provide HMU and related services, as well as for the following purposes detailed below: Advertising, Contacting the User, Handling Payments, Hosting and backend infrastructure, Location-based interactions, Managing contacts and sending messages, Registration and authentication, and Social features.

• Advertising

  We may use your User Profile Data for advertising communication purposes in the form of banners and other advertisements displayed for you on HMU. The third-party services listed below may use Cookies to identify Users or they may use behavioral retargeting, i.e., displaying ads tailored to the User’s interests and behavior, including behavior and interests detected from outside of HMU. For more information, please check the privacy policies of the relevant third-party service.

  AdMob (AdMob Google Inc.) is an advertising service provided by AdMob Google Inc. In order to understand Google’s use of Data, consult Google’s partner policy. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data. Place of processing: US – Privacy Policy – OptOut.

• Contacting the User

  Product updates by email (HMU). HMU sends product-update emails only when a member has opted in through the app. Members can turn this preference off in Account & Privacy or use the unsubscribe link included in each product-update email. Account verification, security, password, data-export, and other service emails are transactional and are separate from this preference. Personal Data collected: Contact Data and communication preference.

• Handling payments

  Apple App Store and Google Play process purchases. HMU receives only the product, subscription, transaction, and verification information needed to provide the purchase. HMU does not receive your full payment-card or bank-account details.

• Hosting and backend infrastructure

  HMU uses contracted cloud infrastructure, database, and media-storage providers, including Heroku, to operate the API, store account content, and deliver the Service. These providers process only the data needed to provide their contracted services.

• Location-based interactions

  Geolocation (HMU). HMU may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by HMU. Personal Data collected: location (Usage Data).

• Managing contacts and sending messages

  This service manages the email addresses HMU uses for account verification, security, and service communications. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message. Mailjet (SAS Mailjet) is an email address management and message sending service provided by SAS Mailjet. Personal Data collected: email address (Contact Data). Place of processing: France – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow HMU to identify them and give them access to dedicated services. Third parties may also provide registration and authentication services. In this case, HMU will be able to access some Personal Data stored by these third-party services for registration or identification purposes. Direct registration (HMU): the User registers by filling out the registration form and providing the Personal Data directly to HMU. Personal Data collected: Identity, Contact, and Profile Data.

• Social features

  Public profile (HMU). Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users’ interactions with HMU. Personal Data collected: Identity and Contact Data.

  Inviting and suggesting friends (HMU). HMU uses profile preferences and activity to suggest relevant people. HMU does not upload your device address book. Personal Data collected: Identity and Contact Data.

Further information about Personal Data

• The Service is not directed to children under the age of 18

  HMU is not intended for children under 18 years of age. No one under age 18 may provide any information on or through HMU. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on HMU or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us.

• Children in the European Union

  If you are in the European Union, you must be at least 18 years old to use HMU. We do not knowingly collect personal information from children under 18. By using HMU, you declare yourself to be an adult as defined by the laws of your country of residence. If you are under 18, do not use or provide any information on HMU or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. Under no circumstances shall persons under the age of 18 in the European Union use HMU. If you believe we might have any information from or about a child under 18, please contact us.

• Push notifications

  HMU may send push notifications to the User.

• Unique device identification

  HMU may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

• User identification via a universally unique identifier (UUID)

  HMU may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of HMU, it persists between HMU launches and updates, but it is lost when the User deletes the HMU mobile application. A reinstall generates a new UUID.

Cookie Policy

HMU uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action. The User’s Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of HMU or the related services. The User acknowledges and agrees that the Owner may be required to reveal Personal Data in response to requests by public authorities.

Additional information about User’s Personal Data. In addition to the information contained in this Privacy Policy, HMU may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance. For operation and maintenance purposes, HMU and any third-party services may collect files that record interaction with HMU (System logs) and use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy. More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this Privacy Policy.

How “Do Not Track” requests are handled. HMU 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.

Information choices and changes. Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. You may send requests about Personal Data to our contact information above. You can request to change contact choices, opt-out of our sharing with others, and update your Personal Data. You can typically remove and reject Cookies from HMU with your browser settings. Many browsers are set to accept Cookies until you change your settings. If you remove or reject our Cookies, it could affect how HMU works for you.

Your California Privacy Rights. California Civil Code Section § 1798.83 permits users of HMU that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us.

Changes to this Privacy Policy. The Owner reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page and possibly within HMU and/or, as far as technically and legally feasible, sending a notice to Users via any Contact Data available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

For Individuals in the European Union (“EU”) – General Data Protection Regulation (“GDPR”)

This Privacy Policy describes how the Owner collects, uses and shares your personal information. If you are in the EU, you are subject to the GDPR, and the following terms also apply to you. The Owner is the Data Controller and responsible for your Personal Data.

Purposes and Lawful Bases to Process Your Personal Data

This Privacy Policy describes the Personal Data we collect from you and the lawful bases for its collection. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need it to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to marketing at any time by contacting us. Specifically, we have a purpose and lawful basis for processing each type of Personal Data as described in this Privacy Policy.

1. The purpose for collecting your Identity and Contact Data is to register you as a new user, and the lawful basis is the performance of a contract with you.
2. The purpose for collecting your Identity, Contact, Financial, Transaction and Marketing and Communications Data is to process and deliver your purchases, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests.
3. The purpose for collecting your Identity, Contact, Profile, and Marketing and Communications Data is to manage a relationship with you, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
4. The purpose for collecting your Identity, Contact, Profile, Usage, and Marketing and Communications Data is to enable you to partake in a contest, competition or complete a survey, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests.
5. The purpose for collecting your Identity, Contact, and Technical Data is to administer and protect our business and HMU, and the lawful basis is that it is necessary for our legitimate interests.
6. The purpose for collecting your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data is to deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, and the lawful basis is that it is necessary for our legitimate interests.
7. The purpose for collecting Technical and Usage Data is to use data analytics to improve HMU, marketing, customer relationships and experiences, and the lawful basis is that it is necessary for our legitimate interests.
8. The purpose for collecting Identity, Contact, Profile, Usage, and Technical Data is to make suggestions and recommendations to you about goods or services that may be of interest to you, and the lawful basis is that it is necessary for legitimate interests.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data.

We may have to share your Personal Data with the parties and for the purposes described in this Privacy Policy. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data. In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS UNDER THE GDPR

Under certain circumstances, EU residents have rights under data protection laws in relation to their Personal Data. If you are an EU resident, you have the right to:

• Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the Personal Data’s accuracy; (b) where our use of the Personal Data is unlawful but you do not want us to erase it; (c) where you need us to hold the Personal Data even if we no longer require it; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Definitions and legal references

Personal Data. Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

User. The individual using HMU who, unless otherwise specified, coincides with the Personal Data Subject.

Data Subject. The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor). The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this Privacy Policy.

Data Controller (or Owner). The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of HMU. The Personal Data Controller, unless otherwise specified, is the Owner of HMU.

HMU. The means by which the Personal Data of the User is collected and processed.

Service. The service provided by HMU as described in the relative terms (if available) and on this site/application.

European Union (or EU). Unless otherwise specified, all references made within this Privacy Policy to the European Union include all current member states to the European Union and the European Economic Area.

Cookies. Small piece of data stored in the User’s device.

Legal information. This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This Privacy Policy relates solely to HMU, if not stated otherwise within this Privacy Policy.

Last updated: July 23 2026