Privacy Policy

HUD Privacy Policy

General information

HUD Studio Limited (company number 1800707), registered at Level 11, 19 Victoria Street West,
Auckland Central, Auckland, 1010, New Zealand ("HUD", “we”, “us” or “our”) is firmly committed
to respecting the privacy of the personal information you supply to us and which will be
processed in accordance with applicable data privacy laws. HUD is the data controller in respect of the personal information it collects and processes.


The following policy explains HUD’s information gathering and dissemination practices for this
website (the "Website") and the use of HUD’s mobile application service (the “Service”). Please
be aware that the Service relies on third party providers in the United States and other places, so your personal information will likely be held by us, or on our behalf, in countries other than your country of residence. If you do not agree with our use of your personal information as set out in this Privacy Policy, you should not use the Website, the Service or submit your personal
information to us.


HUD reserves the right to make changes to this Privacy Policy from time to time by uploading a
revised Privacy Policy on the Website. The changes will apply from the date we upload the
revised Privacy Policy to the Website. Continuing to use the Website and/or the 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: SEPTEMBER 2024


The Website and the Service are intended for use by individuals over the age of 18. Individuals
under 18 years of age are not authorised to use or access the Website and the Service. If we
become aware of anyone using the Service who is under the age of 18 we will suspend their
profile and cancel their account.

What information is collected?


When is information collected?


HUD collects information when you create a profile and account within the Service, when you
use the Service, when you participate in a competition we run or interact with our marketing
activities, when you visit the Website, when you respond to any information requests from us,
and when you contact us (such as via the Website contact form).


What information will you ask me for?


When you create a profile within the Service you will be asked for certain basic information,
comprising your first name, date of birth, gender, pronouns, genders you are seeking, what you
are looking for and a profile photo of yourself showing your face clearly. A profile photo must not contain any text. If this basic information is not provided you will not be able to create a profile and establish an account. The Service also enables you to create a username and provide further information, such as height, weight, languages, smoking, drinking and drug habits, zodiac sign, sexuality, interests, bedroom personality type and a short bio if you wish. A series of questions are provided to assist with determining your bedroom personality type. It is up to you whether or not you provide any further information. Providing this further information may enhance your experience using the Service. However, as this information is accessible by other users please read the section below on information provided to other users before doing so. All information provided by you through answering questions or populating fields made available by the Service is collected by us.


If you wish to verify your profile photo HUD, through the use of third party services, captures a
number of photos from a live video stream that you provide from your device. HUD does not
capture the live video stream. The third party services do not use the live stream for their own
purposes. The photos extracted from the live stream are compared against your profile photo,
using facial recognition technology (involving biometric processing), in order to verify the profile photo’s true likeness. These comparison photos are stored within your account, but not in your profile and so are not separately accessible by you through the Service. You must separately contact us if you would like a copy of them. If you do not want to provide a live video stream for biometric processing HUD will not be able to verify your profile photo.


We may ask you to verify any of the information you provide, and we will collect any verifying
information that you provide.

We also collect your email and postal address to enable us to verify you and communicate with you outside of the Service.


When creating a profile through HUD, you will be given the option to sign in with your Apple ID,
Google account or your mobile 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 policies of Apple and Google govern their use of information provided to them in order to sign in to the Service. HUD recommends that you review these entities’ privacy policies before signing in with these options. If you use your Apple ID or Google account to sign in to the Service, you are permitting them to share your login name and email address with us. These details are linked to your profile and enable you to access your profile within the Service. If you create an account using your mobile phone number you will need to verify that number with us in accordance with the process provided by the Service.


We also collect your information when you subscribe to chargeable features or make in-app
purchases within the Service, send messages, upload media files, use video calling or use the
other features of the Service. The information collected includes features subscribed to or
purchased, your activity in using the Service, and the content of your messages and media files, but not the content of any video call using the Service.


If you use the Website or the Service to report an issue we collect the information that you
provide in that report.


Where we run a competition or undertake a survey the information collected will be outlined in
the form we provide.


What information does HUD collect from third parties?


HUD collects information from third party sites that you may choose to link to your HUD account, currently only 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 has partnered with Spotify to create a feature on the Service which allows you to connect
your Spotify account to your HUD account. This allows you to display your top/favourite artists
(“Music”) on your profile and view other user’s top/favourite artists. If you link Spotify to your
HUD account you permit HUD to access your Spotify accounts for the purpose of accessing your list of top 20 artists. You will then be enabled to display up to 10 of your top 20 artists (as chosen by you) on your HUD account profile. Displaying your Music makes the chosen artists public and other users will be able to view it. If you do not want your Music to be public do not link Spotify to your HUD account. If you no longer want your Music to be displayed just disconnect this link to Spotify. You may disconnect and reconnect this link at any time.


HUD obtains information from third party look up services relevant to your personal information held by us. For instance, your approximate location information (city and country) is obtained by us by using IP address look up services in respect of the IP address we collect from your device or by using location services on your device (where this is turned on). This approximate location is included in your profile and used for matching to other users within a specified range of this location.

HUD uses third parties to deliver its services. These third parties collect information from you or your activity on the Service on behalf of HUD and may also store that information for HUD. The information collected includes user profiles you view, and links clicked in emails sent on behalf of HUD.


HUD also operates social media sites, such as Facebook and Instagram. While HUD does not
link user posts on its social media sites to personal information obtained through the Website or the Service, HUD may collect and use for its business purposes any comments that a user posts to HUD’s social media sites.

Payment information

Some features of the Service require a subscription or are available only through an in-app
purchase.


Your credit card or payment details for any subscriptions or in-app purchases you make are not collected by HUD or processed or transmitted through the Service or via the Website. All
payments are processed via the Apple App Store, Google Play Store, or equivalent third party
application marketplaces. The privacy policies of these third parties govern their use of personal information provided to these third party application marketplaces in order to facilitate payment to us.


We provide these third party application marketplaces with information on the subscription or in-app purchase so that they can process the payment for us. These third party application
marketplaces provide us with confirmation of your payment so that we can activate those
features of the Service to which you subscribe or purchase. HUD recommends that you review
these entities’ privacy policies before using the Service.


What information do you gather from visitors to the Website or when using the Service?


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, the device ID, your domain name, your
IP address, 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. Your
device ID and information associated with the device itself is not stored as a part of your profile.


HUD also gathers information about your use of the Website and Service, including 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 HUD advertising on other websites and to facilitate a more user friendly experience on the Website. Cookies are small pieces of
information that a website places on your computer's hard drive so HUD knows it's you when you visit. For further information on HUD’s use of cookies, please refer to HUD’s Cookie Policy available here: https://www.hudapp.com/cookie.


The above information is collected to help HUD to create a personalised experience for you
when you visit the Website or use the Service.

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


This section describes the purposes for which your personal information is collected and
processed and those types of third parties that might be a recipient of that personal information or who process it on our behalf.


Purposes for which your personal information is collected and processed


We collect and process your personal information for the following purposes:


(a) provide the Service to you, including verifying your profile photo through biometric processing, checking content provided by you complies with our terms and conditions and moderating content where necessary, indicating possible user matches, providing you with push notifications, activity updates and notifying changes to the Service;


(b) verify your identity and authenticate your login to use the Service;


(c) help support the Service, and manage, monitor, maintain, develop or improve the content and functionality of the Service and the Website, including by testing out new technologies and
enabling our third party providers to develop and improve their services that we use to provide
the Service;


(d) run competitions in connection with the Service;


(e) customise the layout of HUD’s pages on the Website and tailor the Service to you;


(f) analyse usage of the Website and the Service, including to understand popular features and
other user engagement and behaviour;


(g) send you marketing material, newsletters, surveys, and information on events, promotional
offers in respect of the Service and the products and services of other organisations that we
partner with;


(h) research and development of new and improved services;


(i) anonymise or aggregate data for our research or business purposes;


(j) resolve disputes and investigate complaints or any other matter concerned with the use of the Service;


(k) enforce our terms and conditions;


(l) detect, investigate, prevent or address, unauthorised access, fraud, scammers, security or
technical issues, and otherwise ensure the safety and security of users of the Service;


(m) protect our property, legal rights, or that of others;


(n) comply with our legal obligations; and


(o) any other purpose made known to you when collecting your personal information.


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.


HUD will only send you marketing communications via email where your account is active and
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 personal information to third parties for marketing, direct marketing or solicitation purposes. Further information on our marketing practices is set out below.


Other sections of this Privacy Policy also set out other specific situations in which your personal information is collected, held, used, disclosed or otherwise processed.


We may use, disclose and otherwise process your personal information for any of these
purposes, where the information is in a form in which the individual concerned is not identified, or for any other purpose authorised by you or by the New Zealand Privacy Act 2020 and any other applicable privacy laws.


Use of Third Parties


We use various third parties to enable us to provide the Service.


Except as otherwise stated in this Privacy Policy, your personal information we collect is held by us. Our address is set out at the end of this Privacy Policy. Where you are outside of New
Zealand, your personal information is transferred to New Zealand (which has an adequacy
decision of the United Kingdom and the European Commission) and the other places referred to in this Privacy Policy.


We also transfer information to other companies (being technology providers, providers of
business and marketing services and providers of software tools used by us in our business) to
provide services on our behalf. These third parties may be based in countries that do not have an adequacy decision by the United Kingdom or the European Commission. For example, your
personal information is stored on AWS servers in various countries including the United States.


Our agreements with our third party providers contain appropriate safeguards in respect of your personal information, such as standard data protection clauses. The third party providers are also required to maintain the confidentiality of the information and are not authorised to use that information for their own general purposes. However, we may permit the third party providers that we use to also use and store your personal information to develop and improve their services including to develop and improve the underlying technologies (which may include artificial technology) used to provide those services. Please contact us if you wish to know which third party providers may use your personal information in this way. If you do not agree with us permitting our third party providers from using and storing your personal information for these purposes you should not use the Service.


For more information on the transfer of personal information to other jurisdictions please read the section entitled “Cross-border data transfers”.


Monitoring and Moderation HUD undertakes


HUD monitors and may moderate any content you provide when using the Service, including
your profile photo and any messages and media files you send to other users. HUD uses AI,
including via services provided by third parties, to assist it with the monitoring and moderating
process. Content moderated by the AI or flagged for review is checked by our team. This may
result in the moderated content or flagged content not being uploaded to your profile, or delivered or a delay in the time it takes to upload or deliver it. Content is checked against the requirements of HUD’s terms and conditions. However, HUD does not monitor or moderate any video calls you make with other users.


If content is found to have breached our terms and conditions we may suspend access to your
profile or terminate your account with us.


Marketing communications


To keep you informed of the latest improvements, we may send you a newsletter and other
marketing communications, where you have signed up to receive such communications. Where
we obtained your consent to receiving the newsletter or other marking communications, you may withdraw your consent at any time.


We may use third parties to assist us to send you our newsletters and other marketing
communications. We provide those third parties with your name and relevant contact
information. Such third parties may be in countries that do not have an adequacy decision by the United Kingdom or the European Commission.


The relevant third party (where applicable) will collect information about your interaction with the communication. The information collected includes whether you opened the email, the links you clicked on, the webpages viewed and the dates and times of such access and activity. Information about the device used to access the marketing communication may also be collected. The third party provides or makes available this information to us for the various
purposes outlined in this Privacy Policy. They may also hold this information on our behalf.


While these third parties are primarily collecting this information on our behalf, some of these
third parties also use the information that we provide them and which is collected from your
interaction with our marketing communications for their legitimate business interests, such as to provide, support and improve the services they provide and to undertake data analytics projects. However, we do not permit them to use your personal information to market their or any other person’s services to you.


We may use MailChimp for the purpose of sending our making communications. MailChimp is
located in the United States, which does not have an adequacy decision by the European
Commission. If we use MailChimp, we will ensure that our agreement with MailChimp contains
safeguards in respect of your personal information, such as standard data protection clauses.

To understand the ways in which MailChimp collects, holds, uses and discloses personal
information, please read their privacy policy available here.


If you do not agree with how MailChimp will handle your personal information then you will need to unsubscribe from receiving marketing communications from us. We will not be able to provide newsletters or marketing communications to you if you unsubscribe.


Third Party Advertisers


HUD may promote third-party advertisers on the Website or the Service. Clicking advertisements may redirect you to websites where the third party’s collection, use or disclosure of personal information you provide to them is beyond HUD’s control. HUD will never share or sell personal information collected by HUD 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.


CleverTap


HUD uses services provided by CleverTap (WizRocket Inc., and its affiliates) to analyse user
engagement and behaviour in relation to the Service and otherwise to assist HUD to provide the Service. Accordingly, your personal information may be sent to CleverTap through the use of CleverTap’s services, where it is also held by CleverTap for us. However, CleverTap acts as a
processor to HUD and does not use any personal information for its own purposes. More
information about CleverTap can be found here.


Other situations where HUD may disclose your personal information


HUD may disclose your personal information to respond to law enforcement requests where we consider it appropriate to make the disclosure; or where we make a compliant to law
enforcement about you; or where required by applicable laws, court orders, or government
regulations; or to protect against misuse or unauthorised use of the Website or the 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).


If you are involved in other court proceedings in connection with the Service we may disclose
your personal information in connection with those proceedings if we consider that you have
breached our terms and conditions.


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


Information provided to other users


Certain information from your profile is accessible by other users. Basic profile information, such as your name, gender, genders you are seeking, what you are looking for and your profile photo can be viewed by other users. You can choose what other profile information (but not your phone number or email or postal address) is visible to other users. Other users could also take a screen shot of any of your information that is visible to other users.


Your profile information is also used to facilitate matching with other users and to enable other users to search for users that match certain profile features determined by the searching user. We use an algorithm to analyse your profile against profiles of other users, based on a variety of factors, in order to make recommendations on potential matches for you. We may use machine learning to analyse your profile and the responses you have made to our recommendations in order to improve our algorithm.


As profile information is visible to other users you should take care in the information you
provide, and you should not include your last name, email or physical addresses, phone
numbers, credit card details or any other information that could lead to other users identifying,
locating or impersonating you.


When you interact with another user, that user can see messages and any media files you send
to them and participate in a video call with you. Care should be exercised in determining what
personal information you provide in messages and media files. While HUD does not record a
video call, that user’s device may permit the user to record and store it locally on their device.
Another user that you send messages or media files to could also use their device to take a copy of that message or media files. We do not condone other users using their devices in such a way, and such behaviour (without your consent) is prohibited by our terms and conditions.


If another user takes a screen shot of any of your visible information, records a video call or
takes a copy of a message or media file you sent them that information will no longer be
controlled by us and that other user could take any action in relation to the information they have obtained, including making that information public. Accordingly, users should assume that
anything they put into their profile or post via the Service can become public, and act accordingly.


Anonymised and Aggregated Information


Where we have anonymised or aggregated your information with others we may disclose that
anonymised or aggregated information to any third party and for any purpose. Aggregated
information is aggregated to a level that your personal information cannot be derived and
anonymised information is information from which you are not able to be identified.

HUD’s legal basis for processing the information


HUD is entitled to process your personal information in the ways set out in this Privacy Policy on the following basis:


- the processing of personal information in this way is necessary for the performance of a
contract with you for provision of the Service, including verifying your identity and your
compliance with our terms and conditions, and sharing personal information with other
users;


- the processing of your personal information is necessary for HUD’s legitimate interests
in:
● ensuring the quality of the products and services HUD provides to you, including
personalising, supporting, maintaining and improving the Service and the Website;
● understanding user behaviour in respect of the Service;
● collecting information and contacting you for marketing purposes, including to run
competitions, provide promotional offers and undertake surveys, and this includes
doing so for the legitimate interests of third parties with which we partner;
● communicating with you, including to resolve disputes;
● statistical analysis, including analysing popular features of the Service and for
research and development of the Service;
● anonymising or aggregating data for our research or business purposes;
● exercising rights existing at law, including enforcing our terms and conditions; and
● the other purposes described in the section above entitled “Purposes for which your
personal information is collected”;
- the processing of your personal information is necessary for HUD’s and other third
parties’ legitimate interests in:
● detecting, investigating, preventing and addressing, unauthorised access, fraud,
scammers, security or technical issues, and otherwise ensuring the safety and
security of users of the Service, including monitoring and moderating content
provided by users;
● protecting our property, legal rights, or that of others;


- the processing of your personal information is necessary for any other third parties’
legitimate interests in improving their services used by us or in bringing proceedings
against you in connection with your use of the Service;


- you have consented to such processing;


- where necessary to comply with our legal obligations; and/or


- to establish, exercise or defend HUD’s legal rights for the purposes of legal proceedings
on the basis of necessary compliance with a legal obligation or otherwise where
necessary for HUD’s legitimate interests in such proceedings.


If you choose not to provide your personal information where requested, 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 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 (including biometric information) for as long as
your profile stays active or hidden (i.e. if your account has been paused). Your personal
information will be deleted from our systems (other than records kept as required by applicable law (such as billing records), to establish, exercise or defend our legal rights, or for general backup, archival or record keeping purposes) if your account is inactive for 270 consecutive days (including if it has been paused). However, we may keep a copy of the personal information in your profile (but not any biometric information) and your activity using the Service for research and analysis. We may also keep any information that is no longer linked to your profile, such as access logs, or where the information is held on an anonymous basis.

Updating your preferences


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 other users of the Service 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 Service. Please also note that changing or deleting your information through the 'Notifications' section of the Service, 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 unrelated to the Service 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 privacy/data protection officer by using the Contact Form., or by tapping the More (...) tab in the Service, then tap on Contact Us.

Security


HUD treats data as an asset that must be protected against loss and unauthorised access. To
safeguard the confidentiality and security of your personal information, HUD uses industry
standard practices and technologies including but not limited to "firewalls", encrypted transmission via SSL (Secure Socket Layer) and strong data encryption when it is stored to disk. However, because the Internet is an open network, HUD cannot warrant or guarantee that your personal information is 100% safe from unauthorised access or use. Your personal information 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 party service providers are based outside the UK and the European Union (“EU”). Accordingly, to the extent you are based within the UK or the EU, 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.


In the case of data transfers to the United States such safeguards are provided by either the EU-US Data Privacy Framework or the UK Extension to the EU-US Data Privacy Framework (see
here) as the case may be, standard contractual clauses approved by the European Commission
or a supervisory authority, or the UK’s international data transfer agreement (IDTA) and the
international data transfer addendum to the European Commission’s standard contractual
clauses for international data transfers (Addendum), Binding Corporate Rules or approved
certifications or codes of conduct to protect the Data so transferred.


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.

Your rights in connection with personal information

Rights of all users

You have the right to:


● 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.
● Request correction/rectification of the personal information that HUD holds about you.
This enables you to have any incomplete or inaccurate information HUD holds about you
corrected.


Other jurisdiction based rights


If you live in certain other jurisdictions, you may have other rights.


For residents of the European Union or the United Kingdom where the General Data Protection
Regulation 2016/679 of the EU (“GDPR”) or the GDPR as applied under the UK’s Data
Protection Act 2018 (“UK GDPR”) applies, you have the right to:


● Object to processing of your personal information where HUD is 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 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 in certain
circumstances. 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.


● Refuse to give or withdraw your consent at any time.


● Receive your personal information in a structured, commonly used and machine readable
format and to transmit it to another data controller (ie data portability) in certain
circumstances.


● Lodge a complaint with a supervisory authority, in particular in the Member State of your
habitual residence or place of work, of an alleged infringement of the GDPR/UK GDPR.

You also have any other rights provided for under relevant data protection laws.


Note that references in this Privacy Policy to ‘personal information’ should be read as ‘personal
data’ for the purposes of the GDPR/UK GDPR.


If you object to processing for direct marketing or withdraw your consent, you can continue to use the Service, but you will not obtain the benefit of the marketing communications we send to other users.


You can opt out of receiving push notifications through your device settings. Please note that
opting out of receiving push notifications may impact your use of the Service.


How to exercise your rights


If you want to exercise any of your rights then please contact HUD through the Contact section
on the 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.


Please contact us for the contact details of any third parties that use and store your personal
information for developing and improving the services they provide to us if you wish to exercise
any rights you have in relation to the personal information held by them. For example, for
residents to which the GDPR or UK GDPR applies, this may be to request such third parties
erase that personal information.


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. Users of the Service can update their profile information (other than your name and date of birth) through the update details feature of the Service.


Fees


You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, 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 personal information (including biometric information), please
contact HUD through the Contact section on the 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 or to the Office of the Privacy Commissioner in New Zealand. You can contact the Office of the Privacy Commissioner on investigations@privacy.org.nz.

How to contact HUD


If you wish to contact HUD’s privacy/data protection officer about this Privacy Policy, including to raise any concern about how we process your personal information (including biometric
information), or to request access, amendments to, or deletion of your personal information, you can contact that person at:


Email: privacy@hudapp.com


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


By post:
Privacy/Data Protection Officer
HUD Studio Limited
PO Box 5800 Victoria St West
Auckland 1142, New Zealand