1. About

Be Humane, co. (“Be Human(e)”, “Rhea”, “we”, “us”, or “our”) respects and is committed to protecting your, the end user or authorized agent of the end user (“you” or “your”), privacy. This Privacy Policy explains how we collect, use, share, and disclose information about you when you access and use our website located at www.behumane.ai (the “website”), when the website is used to navigate to third-party platforms, when you access and use the Be Human(e) mobile application (the “app”), and when connectivity required to utilize the emotional intelligence learning and wellness coaching tools is made available on the website and the app (collectively, the website, the app and the connectivity are referred to in this policy as the “services”).

Generally, you can browse through our website without giving us any information about yourself. When we do need to collect your personal information (including Personally Identifiable Information a.k.a. “PII”) to provide you with the services, or when you choose to provide us with your personal information, this Privacy Policy describes how we collect, use, and disclose your personal data. ‍ Please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.

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2. Scope

This Privacy Policy applies to personal information processed by us, including on our websites (e.g., behumane.ai, and any other websites that we own or operate), our mobile applications, and our platform’s (Rhea) online and offline offerings (collectively, the “Services”).

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Rhea is Be Human(e)’s artificial intelligent (AI) service that offers personalized guidance in a conversational mode to enhance digital well-being and life skills for families. For more information on Rhea refer to our Terms of Use.

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Learn more in section 12 titled Third-Party Websites/Applications.

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3. Personal Information We Collect

Be Human(e) collects information to provide and improve our services. The types of information we collect depend on how you interact with our platform.

Please note that we do NOT sell your data to third party entities. If we ever need to process your data for an unrelated purpose, we will inform you and explain the legal basis which allows us to do so.

 

Definition of Personal Information

For the purposes of this Privacy Policy, "Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. Please note that we only collect the personal information that is necessary to provide and improve our services.

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Important Note: We do not consider aggregated or de-identified information to be Personal Information. This means information that has been stripped of identifying details and cannot be used to identify a specific individual.

 

Information You Provide to Us

1. User Identifiers. Information such as name, email, phone numbers, or any other PIIs you use in your conversations in text or using your voice with Rhea. Some more detail: Email Address: We collect your email address when you create an account or sign in to BeHumane. This is necessary to identify your account and enable you to access our services. Phone Number (Optional): You have the option to provide your phone number during sign-in. This information is used for account verification, security purposes, and to offer additional features (like text-based communication).

2. User Content. We collect conversations that are created by you on the Services, your responses to our personality assessment questionnaire, or the media uploaded to the Services by you. The purpose of this data collection is to enhance AI interactions (Rhea), ensure continuity, personalization, deliver age and gender-appropriate and overall relevant content and services and tools based on your needs. Note that this data is protected by encryption for data confidentiality.

3. Consent. When you provide your phone number while using our Services, you are giving us your consent to send you timely SMS communications. You may revoke your consent at any time by following the instructions provided in our SMS or via your Account Settings.

4. Usage Data. We collect and analyze data and other information relating to the access, use, and performance of the Services (“Usage Data”). Examples of Usage Data include technical logs, metadata, telemetry data, Technical Data, as defined below, and usage information about Customer Content, such as how many times it is accessed. For clarity, Usage Data excludes User Content itself.

5. Customer Service Information (including Training and Quality Assurance). If you call or otherwise interact with Be Human(e) customer service or support personnel, we collect the information you provide to our representatives. In addition, we may record email correspondents, messages, telephone calls or video conferences between you and our representatives for training or quality assurance purposes.

6. Surveys and Events Information. In connection with surveys, conferences, and other events hosted, run or sponsored by us, you may provide information to us, or we may receive information about you, such as name, email address, mailing address, demographic data, and any information specific to the event.

 

Information Collected Automatically (Technical Information)

We automatically collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, cookie identifiers and other unique identifiers, details about your browser, operating system or device, location information (inferred from your IP address), internet service provider, pages that you visit, information about the links you click, and information about how you interact with and use the Services. Here are the details:

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1. Device Identifier. To identify you as a new or existing user, we create user identifiers that help with ensuring service continuity, process subscriptions, and support account management.

2. Browser Locale. We identify your browser locale which is the ‘timezone’ you are located in to communicate with you more effectively during reasonable hours in the day. Communications take place via email, app push notifications, and if you have provided your phone number via SMS. Note that all communications are turned on by default unless you decide to “opt out”. More on that in Section #7 Opt-out.

3. User Database Identifier. We internally generate an ID for your account to ensure we maintain your privacy, support analytics with minimal data, and enhance data transfer security within our Services.

4. Device Data. We collect your operating system information such as version, and your device type and model, and your device time to improve user experience, detect fraud, provide relevant service information, and run analytics.

5. Event Data. We collect data related to your interactions with our Services for internal analytics and service improvement without revealing sensitive details. Note that this data is protected by encryption to ensure confidentiality.

6. Network Data. We collect information such as IP address from your device by CDN to secure and optimize our app and your access to our Services. Note that this data is protected by encryption to ensure confidentiality.

7. Analytics. We use Google Analytics and other service providers to collect and process analytics information on our Services. For more information about how Google uses data, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics’ collection and processing of data generated by your use of our website by going to http://tools.google.com/dlpage/gaoptout.

 

Information from Other Sources

We may obtain information about you from other sources, including from third party services and organizations. For example, if you access our Services through a third-party service, we may collect information about you from that third-party service that you have made available via your privacy settings.

 

4. Our Legal Basis for Processing Your Information

To align with data protection laws, we process your Personal Information based on the following legal bases:

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1. Performance of a Contract. We process your information to fulfill our service commitments to you, such as providing, maintaining, and enhancing our services. Without certain information, we may not be able to offer you our full range of services.

2. Legitimate Interests. We process information to safeguard our services against fraud, abuse, or security risks. This also covers our efforts in developing, improving, and promoting our services, including model training. You can opt out of your information being used for model training by contacting us.

3. Consent. For certain processing activities, we ask for your explicit consent. Remember, you can withdraw your consent at any time, impacting no previously processed data.

 

5. Disclosing Your Information with Third Party Service Providers

We work with vendors, leverage service providers (SP), and collaborate with other partners to enhance our Service by carrying out tasks on our behalf. Occasionally, we might need to share or provide information (including personal information) with them to assist in these business functions. This can include tasks like sending emails for us, managing databases, hosting databases, and ensuring security.

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We may also permit these third-party companies to collect information on our behalf. These providers have restricted access to your personal information strictly for performing these tasks and are contractually obligated to protect and use it solely for the disclosed purpose.

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Moreover, these partners and service providers must comply with confidentiality and security obligations that align with this Privacy Policy. Please refer below for a list of the third parties we work with to deliver our Services.‍

 

1. Amazon Web Services. It hosts our services and database. All the information we collect and use for the service is hosted on Amazon Web Services. All personal data is encrypted.

2. OpenAI. It generates dynamic replies in most chat circumstances. Your messages in chat are sent, with no user identification. These messages are not stored by OpenAI.

3. MailerSend. It sends emails such as sign in link, chat summary, feedback surveys etc. Your first name and last name, along with email metadata (subject line, date sent) and content are disclosed with this SP. Email content is not stored and metadata is only stored for 30 days.

4. Twilio. Sends SMS. Message content, along with SMS metadata (destination phone number, date and time sent) are disclosed with this SP. Data and metadata is stored for 400 days by default. Timeframe can be reduce upon request. ​

5. Firebase. Provides us with insights into how and how often users access our services. Data is retained until we request for deletion, after which data is removed from live and backup systems within 180 days. 

6. Google Analytics. Same as Firebase. The maximum amount of time that Analytics will retain Google-signals data is 26 months, regardless of our settings.

 

Disclosures to Protect Us or Others. We will access, preserve, and disclose information we have associated with you to competent law enforcement bodies, regulatory and government agencies, courts or other third parties if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) enforce Be Human(e)’s policies and contracts; (iv) collect amounts owed to us; (v) prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

 

Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred in accordance with our legitimate interests in administering our business as part of such a transaction, as permitted by law and/or contract.

 

6. Your Privacy Rights

You have certain rights regarding your personal data. In accordance with applicable law, you may have the right to:

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1. Access personal information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);

2. Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

3. Request deletion of your personal information;

4. Request restriction of or object to our processing of your personal information;

5. Withdraw your consent to our processing of your personal information; and

6. Opt-out of optional communications. Please see more on this below.

 

If you would like to exercise any of these rights, please contact us as set forth below.

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We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

 

7. Opt-Out

You have various choices when using our Services. Most of it with regards to privacy comes down to opting out of certain personal information and receiving optional communications.

1. Text. We may periodically send you SMS (text messages) -if you have provided and verified your phone number, that directly reference your interactions with our Services, or to promote our Services. When you receive such communications from us, you have the option to “opt-out” (either through your Account Settings or by following the provided unsubscribe instructions).

2. Email. If you receive a marketing email from us that you no longer wish to receive, you can click the unsubscribe link located at the bottom of the email to stop receiving future marketing communications. Please be aware that you will still receive emails related to any transactions involving products or services you have requested. Additionally, we will continue to send you essential non-promotional communications about our services and updates to our Terms of Service or Privacy Policy, from which you cannot opt out.

3. Mobile Devices. You may receive push notification from us via our mobile application. You have the option to opt out of receiving these notifications at any time by adjusting the settings on your mobile device.

4. Cookies and Interest-Based Advertising. You have the option to accept or decline cookies. If you are in the European Union, you can modify your cookie settings through our cookie consent tool accessible at any time by clicking "cookie settings" in the footer of our website (logging out of your Be Human(e) account may be necessary to reach the footer). Additionally, you can control or limit the use of Technologies on your device, or remove them by altering your browser or device settings as allowed. It's important to note that cookie-based opt-outs do not work on mobile applications. Nevertheless, you can opt out of personalized ads on certain mobile applications by following the instructions for Android and iOS.
   The online advertising industry also offers several websites where you can opt out of receiving targeted ads from data partners and other advertisers participating in self-regulatory programs. You can visit these websites and learn more about targeted advertising, as well as your choices and privacy at www.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. Please note you must separately opt out in each browser and on each device.

5. “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not respond to DNT signals or similar mechanisms transmitted by web browsers.

 

Separate from the optional communication, we need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., account verification text, welcome message, communications regarding updates to our Terms of Use or this Privacy Policy.

 

8. How We Use Your Data

Generally speaking, we collect and utilize your data solely to:

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1. enhance the services we provide and continuously improve your experience,

2. and to safeguard our services against fraud, abuse, or security risks.

 

More details:

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1. Service Enhancement. To deliver, manage, maintain, and improve our Services, we use User Content (substance of the conversations, interactions, etc.) to tailor your experiences, ensuring our offerings meet your needs and preferences. For instance, to ensure Rhea can engage with you in a most effective way, we need to continuously improve its communication skills and expertise in the field.

2. Innovation and Development. We learn from your interactions to develop new educational programs and services, enhancing our ability to support lifelong learning and well-being.

3. Communication. Your personal information helps us keep in touch with you. We use it to inform you about service updates, educational events, and opportunities to engage with our community.

4. Security and Fraud Prevention. To safeguard the integrity of our services, we use personal information to detect and prevent fraudulent activities, unauthorized access, and potential threats to our IT infrastructure.

5. Business Operations. Personal information may be utilized in the context of business transfers, mergers, or acquisitions, ensuring the continuity of our services.

6. Legal Compliance. We process personal information to fulfill our legal obligations, respond to legal inquiries, and protect the rights and safety of Be Human(e), our users, and third parties.

 

9. How We Protect Your Data

We employ a blend of administrative, technical, and physical safeguards designed to secure your data against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Despite our best efforts, no security measures are infallible, and the inherent vulnerabilities of the internet mean we cannot guarantee absolute security. However, we are committed to continuously enhancing the security measures for Be Human(e) and your information, including but not limited to:

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1. Transport Layer Security (TLS). We use this technology for all data transfers between users, our system, and partners. This ensures that your data is encrypted during transmission, meeting high security standards.

2. Regular Security Audits. To maintain the integrity of our security posture, we engage in regular security audits. We employ an ongoing process where our engineering team conducts audits on a monthly or quarterly basis.

3. Continuous Monitoring and Incident Response. We employ monitoring systems to detect and respond to security threats efficiently. This proactive approach allows us to maintain high security standards and to act swiftly in the event of a data breach.

 

10. Data Retention

We retain the personal information collected as outlined in this Privacy Policy for the duration you utilize our Services or as long as necessary to achieve the purposes for which the information was gathered. This includes providing our Services, resolving conflicts, forming legal defenses, conducting audits, engaging in legitimate business activities, enforcing our agreements, and complying with relevant laws. The retention period for specific information varies based on the reasons for its collection and processing, as well as any legal obligations.

 

We will delete or anonymize your personal information when there is no longer a legitimate business need or legal basis for its processing. If neither deletion nor anonymization is feasible (for instance, if your personal information resides in backup archives), we will securely store and protect your personal information from any further processing until deletion becomes possible. As outlined in the "Your Privacy Rights" section below, you can request the deletion of your personal information at any time. However, fulfilling this request necessitates the deletion of your account, as maintaining your account requires access to your personal data (such as email, first name, phone number etc.)

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Account active: Data is encrypted, may include PIIs, and data (excluding the PIIs) may be used for training.

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Account deleted or you request for deletion: Data is encrypted, PIIs are scraped (data is made anonymized), and we will do our best to delete your data from the training set after training is done. However, this does not guarantee that your data is not already part of the model.

 

11. International Considerations

As a global platform dedicated to fostering digital well-being and educational growth, Be Human(e) serve users worldwide. It's important for our international community to understand how we handle personal information:

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1. Global Processing and Storage. Your Personal Information may be processed and stored in the United States or in other countries where Be Human(e) or our service providers and affiliates operate. This enables us to provide you with a seamless experience across our Services.

2. International Disclosure. We may share your information with our service providers and affiliates in different jurisdictions, always ensuring your data is protected.

 

As a global organization, Be Human(e) may store and process personal information in various countries, including the United States. We ensure that international transfers of personal information are conducted in compliance with applicable data protection laws, employing appropriate safeguards. However, it's important to note that other countries have different data protection laws than your own. We are committed to protecting your information regardless of where it is processed.

 

EU Data Protection and GDPR Compliance

Be Human(e) respects and adheres to the EU General Data Protection Regulation (GDPR) (EU) 2016/679, providing the following rights to EU residents:

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1. Right to Access. You can request a detailed report on the personal information we hold about you, including how we use and who we share it with.

2. Right to Rectification. You have the ability to correct inaccurate or incomplete personal information concerning you.

3. Right to Erasure ("Right to be Forgotten"). You can request the deletion of your personal information, subject to certain exceptions.

4. Right to Restriction of Processing. You may request that we limit the processing of your personal information under specific circumstances.

5. Right to Data Portability. You have the right to receive your personal information in a structured, commonly used format and transmit it to another controller.

6. Right to Object. You may object to the processing of your personal information for direct marketing purposes or when processing is based on legitimate interests.

7. Right to Withdraw Consent. Where processing data is based on consent, you have the right to withdraw it at any time.

 

To exercise any of these rights, please contact us directly. We commit to addressing your requests promptly and efficiently.

 

California Privacy Rights (CPRA and CCPA)

In accordance with California privacy laws, residents of California have the right to:

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1. Know and Access. Request disclosure of the categories and specific pieces of personal information collected, including the purposes for collection and the third parties with whom it is shared.

2. Deletion. Request deletion of personal information held by Be Human(e), subject to necessary exceptions such as completing transactions or complying with legal obligations.

3. Correction. Request correction of inaccurate personal information.

4. Opt-Out of Sale or Sharing. Opt-out of the sale or sharing of personal information for advertising and analytics.

5. Non-Discrimination. Exercise your privacy rights without receiving discriminatory treatment.

 

We may need to verify your identity or authority to act on a request, ensuring the security and privacy of user data. Requests deemed unfounded or excessive may incur a reasonable fee or be declined, with an explanation provided.

 

To exercise your California privacy rights, please reach out through the designated channels provided in our privacy policy. We are dedicated to ensuring your rights are respected and upheld.

 

12. Third-Party Websites/Applications

Our Services may include links to third-party websites (such as digital parenting resources) or applications, and likewise, third-party websites or applications may link to our Services. We do not control these external services and encourage you to familiarize yourself with the privacy policies of any website or application you interact with. We do not endorse, review, or approve, nor are we responsible for the privacy practices or content of these other websites or applications. Engaging with any third-party websites or applications is done at your own risk.

 

13. Closing Remarks

 

Updates to This Policy

Should significant updates made to our privacy policy, we will notify you via email and our app. Your continued use of our services after such updates constitutes acceptance of the new policy.

 

Getting in Touch

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at privacy@behumane.co.