Privacy Policy

Effective Date: March 24, 2026

Huddle ("we," "us," or "our") operates the Huddle AI Coaches mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the App. Please read this policy carefully. By using the App, you agree to the practices described herein.

1. Scope

This Privacy Policy applies solely to information collected through the Huddle AI Coaches iOS application distributed via the Apple App Store. It does not apply to information collected by third-party websites, services, or applications that may link to or be accessible from the App, except as expressly described below.

2. Definitions

3. Data Controller

The data controller responsible for the processing described in this policy is:

Brett Evanson
Email: brettev@gmail.com
Website: huddlecoaches.com

4. Information We Collect

Huddle is designed with a privacy-first architecture. The vast majority of your data never leaves your Device.

4.1 Information Stored Locally on Your Device

4.2 Information Processed by Third Parties

4.3 Information We Do Not Collect

We want to be explicit about what we do not collect:

5. Purposes of Processing

The limited data processing that occurs serves the following purposes:

6. Third-Party Services

The App integrates with the following third-party services:

6.1 Apple (App Store, In-App Purchase, CloudKit)

Apple processes your subscription payments and manages purchase receipts. Apple's handling of your data is governed by the Apple Privacy Policy. If iCloud is enabled on your Device, Apple may sync certain App data through CloudKit per your device settings.

6.2 RevenueCat

RevenueCat manages subscription entitlements. It receives an anonymous identifier and subscription transaction data from Apple. RevenueCat does not receive your conversation data, preferences, or any personally identifiable information from us. See the RevenueCat Privacy Policy.

7. Data Retention

8. Data Security

We take the security of your information seriously:

No method of electronic storage is 100% secure. While we strive to protect your data through the privacy-first architecture described above, we cannot guarantee absolute security.

9. Your Rights

9.1 All Users

Because your data is stored locally on your Device, you have direct, immediate control over it:

9.2 European Economic Area (EEA) Residents

If you are located in the EEA, you have additional rights under the General Data Protection Regulation (GDPR), including the right to access, rectification, erasure, restriction of processing, data portability, and the right to object. Because we do not collect or store Personal Data on our servers, these rights are effectively self-service through the controls described above. If you believe we hold any data about you or wish to exercise your rights, contact us at brettev@gmail.com.

Our legal basis for the minimal processing that occurs is your consent (Article 6(1)(a) GDPR) provided by your use of the App, and the performance of a contract (Article 6(1)(b) GDPR) for subscription management.

9.3 United States Residents

Residents of California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and other states with consumer privacy laws may have rights including the right to know, delete, correct, and opt out of the sale or sharing of personal information. We do not sell or share your personal information as defined by these laws. To exercise any rights, contact us at brettev@gmail.com.

10. Children's Privacy

The App is not directed to children under the age of 13. We do not knowingly collect Personal Data from children under 13. If you are a parent or guardian and believe your child has provided information through the App, please contact us at brettev@gmail.com. If we become aware that we have inadvertently collected Personal Data from a child under 13, we will take steps to delete such information promptly.

11. AI Disclosure

Huddle uses artificial intelligence powered by on-device large language models (LLMs) to generate coaching responses. Key facts about our AI processing:

12. International Data Transfers

Because your data is stored and processed on your Device, no international transfer of your conversation data or preferences occurs. Subscription data processed by RevenueCat may be transferred to and stored in the United States. RevenueCat maintains appropriate safeguards for any such transfers.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Effective Date" at the top of this page and, where appropriate, through an in-app notification. Your continued use of the App after any changes constitutes acceptance of the updated policy.

14. Contact Us

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

Brett Evanson
Email: brettev@gmail.com
Website: huddlecoaches.com