Privacy Policy

How We Collect, Use, Share, and Protect Your Personal Data

Effective Date: October 30, 2026

Last Updated: November 3, 2026

Version: 3.3 (Account deletion)

Habitual Growth, LLC 12081 W Alameda Pkwy, PMB 139, Lakewood, CO 80228, United States

Contact: info@habitualgrowth.com

Important Notice

This Privacy Policy describes how Habitual Growth, LLC (“Habitual Growth,” “we,” “our,” or “us”) collects, uses, shares, and protects personal data relating to users of our website (HabitualGrowth.com), our mobile application, and related online services (together, the “Services”). It should be read alongside our Terms of Service and our Creator Agency Agreement (if you are a Creator).

Your rights under the mandatory privacy and consumer-protection laws that apply to you are preserved. If a provision of this Policy conflicts with a right that cannot lawfully be limited, that law controls.

WHAT CHANGED IN THIS VERSION Version 3.3 extends account deletion to the data Sequoia stores about you, including your Sequoia conversations, capsules and embeddings (Section 12), adds our account-deletion page at habitualgrowth.com/delete-account, and removes the location permission and the map provider, which the app no longer uses. The October 2026 relaunch update described below remains part of this Policy. This version reflects substantial new functionality introduced since June 2026: member-to-member messaging, contact-based discovery using your phone's address book, phone number verification, an expanded Sequoia AI that builds and stores a profile about you (including health-related information) and screens messages for crisis content, a credit system, and a change of cloud hosting provider. If you used the Services before this date, we encourage you to read Sections 4, 5, 8 and 9 in full.

Privacy at a Glance

This summary highlights the most important points in plain language. It is not a substitute for the full Privacy Policy, which follows.

What we collect. Account information (name, email, phone number, username), content you create (habits, goals, Challenges, Plans, ratings), messages you send to other members including voice messages, one-way fingerprints of the phone numbers in your address book if you turn on contact discovery, your conversations with Sequoia AI, device and usage information, and — with your permission — information from device features such as your camera, microphone, photo library and contacts.

What we do with it. Operate the Services, deliver your messages, personalize your experience, power Sequoia AI, process payments, keep the Services safe, and meet our legal obligations.

What we do not do. We do not sell your personal data for money. We do not show advertisements inside the app. We do not use your habit data or your messages for advertising or retargeting. We do not use advertising identifiers.

Things worth knowing. Messages are not end-to-end encrypted. Your Sequoia conversations are stored and are used to build a profile that helps Sequoia support you, and that profile can include health-related information you mention. Deleting your account anonymizes it rather than erasing every record; Section 12 explains exactly what is kept and why.

1. Introduction

We believe you should be able to understand what happens to your information. This Policy is written to be read, not merely to be published. Where a practice is unusual, or where something is kept longer than you might expect, we say so plainly rather than relying on general language.

This Policy applies to personal data we process as a controller.

2. About Us and How to Contact Us

2.1 Who We Are

Habitual Growth, LLC is a Colorado limited liability company with its principal address at 12081 W Alameda Pkwy, PMB 139, Lakewood, CO 80228, United States. We are the controller of personal data processed through the Services described in this Policy.

2.2 Privacy Contact

For any privacy question or request, email info@habitualgrowth.com with the subject line “PRIVACY.” You may include your country and the type of request to help us route it.

2.3 Where the Services Are Offered

We offer the Services only in the countries listed in Section 2.5, and we have limited that list to countries where we can meet our obligations directly, without appointing a local representative. If we open the Services in a country that requires a non-resident company to appoint a local representative or to register a local officer, we will appoint one and identify them here before launching there.

2.4 Data Protection and Information Officers

Nicole Alloro is the individual within Habitual Growth accountable for our compliance with data-protection law. She acts as our Data Protection Officer or privacy officer under the laws that use those titles, and is reachable at info@habitualgrowth.com. You do not need to use a particular subject line; write to us in your own words and we will route your request.

2.5 Launch Countries

The Services are offered in ten countries: the United States, Canada, Australia, New Zealand, the Philippines, Singapore, Hong Kong SAR, India, Malaysia, and Pakistan. Your rights under applicable local law remain in effect. If you are outside these countries, the Services are not offered to you.

3. Scope of This Policy

3.1 What This Policy Covers

This Policy covers the Habitual Growth mobile application, our websites, our messaging service, Sequoia AI, and the systems that support them.

3.2 What This Policy Does Not Cover

• Third-party services you connect to or reach through the Services, which are governed by their own privacy policies.
• Content another member shares with you, or what that member does with content you share with them.

3.3 How This Policy Works With Other Documents

This Policy sits alongside the Terms of Service and, where applicable, the Creator Agency Agreement.

4. Personal Data We Collect

4.1 Information You Provide to Us

• Account information: first and last name, email address, password, phone number, city, state, country, time zone, and your chosen public username.
• Profile information: profile photo, and optional details you choose to add.
• Onboarding information: during onboarding we may ask how you identify, your date of birth, your height, and your current weight, and we ask which areas you want to grow in — options that include reducing stress and managing anxiety. These questions are optional and can be skipped.
• Content you create: goals, Essential Actions, habits, streaks, reflections, comments, Challenges, Plans, ratings, group information, and core values.
• Messages: the content of messages, images, videos, files, stickers, reactions and share cards you send to other members through our messaging service.
• Sequoia conversations: everything you type to Sequoia, any files or links you submit for Challenge or Plan generation, and your intake answers.
• Payment information: we do not receive or store your full card number. Our payment processor collects it directly. We store a token referencing your saved payment method, the card's expiry month and year, your billing country, and transaction records.
• Support and moderation information: what you tell us when you contact support or report content, including any message you choose to attach to a report.

4.2 Information We Collect Automatically

• Device and app information: device model, device name, operating system and version, app version, language, time zone, and a device identifier used to deliver push notifications.
• Usage information: features used, screens viewed, session timing, and events such as creating a goal or joining a Challenge.
• Network information: IP address, and the approximate city, region and country derived from it by our analytics provider.
• Service logs: request and error logs generated by our servers.

4.3 Information From Third Parties

• Our payment processor, which confirms payment outcomes and provides limited card metadata.
• Our verification provider, which confirms whether a one-time code you entered was valid.
• Our marketing and CRM platform, which may supply contact details if you engaged with our marketing before creating an account.
• Other members: for example, if another member reports a message you sent, or invites you to a Group.

4.4 Device Permissions and What They Access

The app asks your permission before using certain device features. You can grant or deny each permission and change your choice at any time in your device settings. The table below covers every permission the app requests, including those for features we are introducing shortly. A permission is only ever requested at the moment you first use the feature it belongs to, so you will not be asked for a permission relating to a feature you never open.

WHAT WE DO NOT REQUEST The app does not request Bluetooth, calendar, motion or fitness sensor, Face ID or biometric, SMS, or phone-state permissions, and it does not read your device's own phone number — you type your number and we verify it with a one-time code. The microphone is never opened except while you are actively recording, and the app has no always-listening, wake-word or background audio capability of any kind. We do not use advertising identifiers and do not present an App Tracking Transparency prompt, because we do not track you across other companies' apps or websites.

4.5 Sensitive Personal Data

The Services are about personal growth, which means you may tell us things that data-protection laws treat as sensitive. This can include information about your physical or mental wellbeing, your spiritual or religious practice, and your health-related behaviours.

Three sources of sensitive data deserve specific mention. First, onboarding asks for your height, weight, date of birth and how you identify. Second, the growth areas you can select include reducing stress and managing anxiety, and selecting one is an indication about your mental health. Third, and most significantly, Sequoia maintains a profile about you that includes a health section, and that section is written by the AI based on what you say in conversation rather than by a form you fill in — see Section 8.5.

We do not require you to provide sensitive personal data to use the Services. Where applicable law requires it, we obtain your explicit, informed consent before processing sensitive personal data, through a mechanism distinct from your acceptance of our Terms. You may withdraw that consent at any time. We do not share sensitive personal data with advertising networks or data brokers and do not use it for advertising. We apply additional access controls to it internally.

5. Contact Discovery and Your Address Book

This section describes how we use your phone's contacts. We have written it in more detail than the law strictly requires, because address-book access is the kind of thing people reasonably want to understand before they agree to it.

5.1 How Contact Discovery Works

With your permission, the app reads the phone numbers in your address book and converts each one into a one-way keyed fingerprint — a cryptographic digest produced using HMAC-SHA256 with a secret key held on our servers. Only those fingerprints are sent to us. The phone numbers themselves, and your contacts' names, do not leave your device through this feature and are never stored by us.

We compare your fingerprints against the fingerprints of members' verified phone numbers to show you which of your contacts are on Habitual Growth. Because the digests are one-way, we cannot recover a phone number from a fingerprint, and if we rotate the secret key, all stored fingerprints are deleted rather than re-computed, because we never held the numbers to re-compute them from.

5.2 Being Found by Others

IMPORTANT — DEFAULT SETTING If someone has your verified phone number saved in their contacts, they can see that you are on Habitual Growth, including your name and profile picture, and can send you a connection request. This setting is ON by default. You can turn it off at any time in Settings → Chat & Contacts using the control described as letting people who have your number find you.

We limit how quickly fingerprints can be submitted and how many can be stored per member, in order to make it harder for anyone to test large numbers of phone numbers against the Services.

5.3 The Invite Feature

A SECOND, DIFFERENT PATH The invite feature in onboarding works differently from contact discovery. When you use it, the app sends the phone numbers from your address book to us in plain form, not as fingerprints, in order to identify which of them already belong to members. If you have used the invite feature, the statement in Section 5.1 that numbers never leave your device does not apply to that use. We are working to bring this feature onto the fingerprint mechanism; until then, we disclose it here so that your understanding matches what the software does.

5.4 Deleting Your Contact Data

You can delete all fingerprints we hold for you at any time through Settings → Chat & Contacts. Doing so also stops the app from re-uploading them. Fingerprints are deleted automatically when your account is closed. We do not otherwise delete fingerprints on a schedule; they are retained while your account is open and the feature is on.

6. Phone Number Verification

We verify phone numbers so that contact discovery and messaging are based on a number that genuinely belongs to you. When you sign up, verify a number, or reset your password, we send a one-time code through our verification provider, Twilio Verify.

• Your phone number in international format is sent to Twilio, which generates, delivers and checks the code. We do not generate or store the code.
• Codes can be delivered by SMS, voice call, WhatsApp or email.
• We store your verified number, the time it was verified, and a keyed fingerprint of it. If you later change your number, the verified status is cleared until you verify again.
• We limit how often codes can be requested and checked.

Sub-accounts. Sub-accounts created by a primary account holder do not go through phone verification at sign-up.

7. Messaging

The Services include member-to-member messaging: one-to-one conversations and group chats, with images, videos, voice messages, files, stickers, reactions, read receipts, typing indicators, and cards that share a Challenge, Plan, goal or invitation.

7.1 What We Collect and Store

• The content of your messages, including any image, video, voice recording or file you attach. A voice message is stored as an audio file on our servers in the same way as any other attachment, and we are technically able to play it back — see Section 7.2.
• Who sent each message, who received it, conversation identifiers, sequence numbers, timestamps, and read positions.
• Your social graph: which members you can message, which connections exist, and whom you have blocked.
• When you report a message, the report reason and, if you choose to attach it, the message content.

7.2 Encryption

NOT END-TO-END ENCRYPTED Messages are encrypted in transit between your device and our servers. They are not end-to-end encrypted. Message content is stored on our servers in a form we can read, which means we are technically able to access it — for example when responding to a report or a lawful legal request. Please do not use Habitual Growth messaging for information you would not want us to be capable of accessing.

7.3 Who Can Message You

Messaging is available between members connected through contact discovery or an accepted connection, and between members of the same group chat. You can block another member at any time, and you can leave any group.

7.4 Notifications About Messages

When you receive a message while offline, we send a push notification that names the sender and, for a group, the group — for example, “Alex sent you a message.” The notification never contains the message text. Our messaging system does not send push notifications itself and does not pass message content to the system that does.

7.5 Deleting Conversations

DELETING A CONVERSATION HIDES IT FROM YOU When you delete a conversation, it is removed from your view. It is not erased from our servers, and it is not removed from the other participants' view. Messages you have sent remain in the recipients' conversations. Message records are deleted automatically 365 days after they are sent (see Section 11).

8. Sequoia AI and Machine Learning

8.1 What Sequoia Does With Your Data

Sequoia is the personalized, supportive engine within Habitual Growth. To answer you usefully it is given your conversation history, your goals, milestones and tasks, your intake answers, and a profile it maintains about you. It can also search the web on your behalf and read files or links you submit.

8.2 Third-Party AI Providers

We use third-party artificial intelligence and machine-learning service providers to operate Sequoia and related AI-enabled features. To deliver a feature you request, we may send the provider your prompts, relevant account and progress information, conversation history, intake answers, profile context, and files, links or audio you submit. This may include sensitive or health-related information you choose to share or that is inferred as described in Section 8.5. Providers act as our processors under contract and are prohibited from using your personal data to train their own general-purpose models.

The third-party AI model providers we currently use, their functions and processing locations are listed at habitualgrowth.com/ai-providers. They act as our processors under contract and may not use members’ personal data to train their own models. Support for other providers in our software does not mean we send them your data.

We may select, add, replace or remove AI providers and models as the Services evolve, including for quality, reliability, safety, capacity and cost. We do not promise access to any particular provider or model. An ordinary substitution of a contracted processor for the same disclosed purposes, data categories and safeguards does not by itself require a new acceptance of the Terms of Use or this Policy. This does not waive any notice, disclosure or consent requirement under applicable law or app-store rules.

Before a new AI provider receives personal data, we will update the current-provider list at habitualgrowth.com/ai-providers and provide any required in-app disclosure and obtain any required explicit permission. Material changes to purposes, data categories, training use or safeguards are subject to Section 18. Acceptance of the Terms or continued use alone does not replace explicit consent where it is required.

8.3 Spoken Input and Audio Transcription

You can speak to Sequoia instead of typing. When you do, the app records audio only while you are actively holding or toggling the record control, and the recording is converted to text before it is used.

Transcription is performed by a contracted AI model provider identified in the current-provider list linked in Section 8.2. Your audio is sent to it only to be transcribed. The same applies to audio and video you submit for Challenge or Plan generation. Once a recording has been transcribed, the resulting text is processed exactly like a typed message.

WHAT HAPPENS TO THE RECORDING A recording you make as spoken input to Sequoia is kept only as long as it takes to transcribe it, and is then discarded — we retain the transcript, not the audio. A voice message you send to another member is different: it is message content, stored like any other attachment, and covered by Section 7 and the retention table in Section 11.

8.4 Conversation Storage

Your Sequoia conversations are stored on our servers. We store each message, compressed snapshots of conversation history used to give Sequoia context, automatically generated titles and summaries, extracted key facts, and per-turn technical records including the model used, token counts and cost. Conversation storage has no fixed expiry; it is retained while your account is open.

8.5 The Profile Sequoia Builds About You

AI-INFERRED INFORMATION, INCLUDING HEALTH Sequoia maintains a profile about you with sections covering basic information, preferences, knowledge, past plans, and health. These are written by the AI from what you say in conversation — not by a form you complete. The health section is designed to capture conditions, injuries, medications, physical limitations, mental-health context, sleep and stress. This means health information you mention in passing may be extracted and stored as part of your profile, and it is used to shape Sequoia's future responses. The profile is also visible to authorized Habitual Growth staff on your account record.

We also extract and store per-conversation signals including topics, decisions, action items, emotional themes, and a sentiment label for each turn. If you do not want information of this kind recorded, do not share it with Sequoia. You may ask us to delete your Sequoia profile at any time by contacting us.

8.6 Semantic Search of Your History

To let Sequoia recall relevant earlier discussion, we convert your conversation exchanges into numerical representations (embeddings) and store them so that past context can be retrieved and included in later prompts. Embeddings are generated by a contracted AI model provider identified in the current-provider list linked in Section 8.2, and stored by us, scoped to your account.

8.7 Safety and Crisis Screening

WE SCREEN MESSAGES FOR CRISIS CONTENT Every message you send to Sequoia is automatically screened for indications of suicidal ideation, self-harm, abuse and hopelessness. If the screening matches, Sequoia responds with crisis resources, including the 988 Suicide & Crisis Lifeline, the Crisis Text Line, and emergency services. A flag recording that a crisis indication was detected is stored with the conversation record, along with a sentiment label for the turn.

Sequoia is not a crisis service, a therapist, or a medical provider, and screening is automated and imperfect. It may miss genuine distress and may flag messages that are not distressing. It does not summon help. If you are in danger or in crisis, contact emergency services or a crisis line directly.

8.8 Training

Before you use Sequoia for the first time we ask for your consent to use your data to improve it. If you give that consent, we may use your content to evaluate and improve our own models and the way we prompt and configure third-party models. We do not sell your data to AI providers, and we do not permit them to train their own general-purpose models on it.

You may withdraw this consent at any time by emailing info@habitualgrowth.com with the subject line “AI OPT-OUT.” Withdrawal applies going forward and does not prevent us from using AI to deliver features you request, to detect abuse, or to meet legal obligations, and does not affect fully de-identified or aggregated data.

8.9 Human Review

Authorized staff may review Sequoia conversations for quality, safety and troubleshooting, and may review AI-generated Challenges and Plans before publication. Staff can also view the profile described in Section 8.5. We do not make decisions producing legal or similarly significant effects about you based solely on automated processing.

9. How We Share Personal Data

9.1 Service Providers and Subprocessors

Each provider receives only the personal data needed for its function, is bound by contract to keep it confidential and secure, and may not use it for its own purposes.

THREE DISCLOSURES ABOUT THIS LIST First, our analytics provider receives more than technical data: some events include your email address, your name, the titles of goals and habits you create, and free-text feedback you submit. Message content and Sequoia conversation content are not sent to analytics. Second, our crash-reporting data is reviewed by an automated debugging service operated by xAI, which reads error reports and may therefore see technical context captured at the moment of a crash. Third, we use an AI observability service, LangSmith, to trace Sequoia requests so we can diagnose failures and improve quality. It receives the full text of prompts and model responses, which means it can receive health-related content you discuss with Sequoia. It is bound by contract as our processor and may not use the content for its own purposes.

Our messaging server and the storage holding message media are operated by us on our own infrastructure, not by a third-party messaging vendor.

We may engage additional providers or change providers in the ordinary course of business and will keep these disclosures and the current AI-provider list at habitualgrowth.com/ai-providers current. AI-provider changes are subject to the disclosure, safeguards and consent commitments in Section 8.2; material changes are subject to Section 18.

9.2 Other Members

• Your username and profile picture are visible to members you message and, where leaderboards are enabled, to members of your Groups.
• Messages and media you send are visible to the recipients, who may retain or screenshot them.
• Group leaderboards show participation metrics — activity counts and streak information — not the content of your habits or reflections.
• Ratings you give to Challenges and Plans are anonymous to other members.
• Challenges and Plans you publish are visible to other members, with the creator name you chose.
• If you are a sub-account, the primary account holder can manage your account and sees the shared credit balance, which reflects AI usage across the household.

9.3 Reserved

This section is reserved for future services.

9.4 Legal and Safety Disclosures

We may disclose personal data where we believe in good faith it is necessary to comply with law or legal process, to enforce our Terms, to detect or prevent fraud or abuse, to protect the rights, safety or property of any person, or in connection with a suspected emergency involving a risk of death or serious injury. Where we detect apparent child sexual abuse material we report it to the National Center for Missing & Exploited Children as required by US law, regardless of your country.

9.5 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization or sale of assets, personal data may be transferred as part of that transaction. We will notify you of any change in control and of any material change to this Policy that results.

9.6 With Your Consent

We share personal data in other ways only with your consent or at your direction.

10. Cookies, Marketing and Notifications

10.1 Cookies and Similar Technologies

Our websites use cookies and similar technologies that are strictly necessary to operate the site, plus limited analytics. We do not use advertising cookies and do not permit third-party advertising networks to set cookies through our sites. Where consent is required in your jurisdiction, we obtain it through a consent banner before setting non-essential cookies.

10.2 Marketing Communications

We send marketing messages only where you have opted in or where applicable law otherwise permits. You can unsubscribe at any time using the link in any marketing email or through your account settings. Transactional messages — billing, security and service notices — are necessary to provide the Services and cannot be disabled while your account is open.

10.3 Push Notifications

Push notification categories you can control in the app include goal check-ins, Essential Action reminders, opening-screen quotes, and motivational notifications. Motivational and re-engagement notifications are promotional in character, and you can turn them off separately without losing functional reminders. You can disable push notifications entirely in your device settings.

11. Data Retention

11.1 Our Retention Principles

We keep personal data for as long as we need it to provide the Services, comply with legal obligations, enforce our agreements and resolve disputes. Where we have a defined period, it is stated below. Where we do not, we say so rather than implying a limit that does not exist.

11.2 Specific Retention Periods

12. Deleting Your Account

You can delete your account in the app. We confirm the request with your password or a one-time code. If you manage sub-accounts, they are closed first.

12.1 What Deletion Does

Deletion closes and anonymizes your account rather than erasing every record. Specifically, we:

• Cancel your subscription and archive your saved payment methods.
• Delete your Sequoia profile, including the health section.
• Delete the data Sequoia stores about you: your Sequoia conversations, including plan coaching chats, with their messages, titles, summaries, extracted facts and per-turn records; capsules; embeddings; the saved conversation states Sequoia uses to resume a chat; the goals, milestones, tasks, intake answers and preferences Sequoia stored for you; your Challenge and Plan generation and draft requests; and Sequoia’s copy of your API key. Sequoia then refuses your former account. While AI-observability tracing (Section 9.1) is on, we also ask our tracing provider to delete the traces of your Sequoia requests; traces recorded before we began labelling traces by member cannot be matched to you and are removed when that provider’s retention period ends.
• Delete your contact fingerprints, device tokens and API keys.
• End your connections, delete pending requests and blocks, and end your messaging sessions.
• Replace your name with “Deleted member,” replace your email and login with a non-functional address, and blank your phone, address, website, photo, time zone and related fields.
• Mark the account deleted and deactivate it so it can no longer be used.

12.2 What Is Kept, and Why

PLEASE READ THIS BEFORE DELETING Deletion is not complete erasure. The following survive, and we would rather tell you now than have you discover it later.

• Invoices, payments and tax records, which we are legally required to keep.
• Content you created, such as Challenges and Plans, retained in anonymized form so that other members who joined them are not disrupted.
• Messages you sent to other members, which remain in their conversations until the 365-day period expires.
• Your record in our marketing and CRM platform, which is archived and marked do-not-contact rather than deleted.
• Staff support audit records, which are permanent by design.
• Records held by our payment processor under its own legal obligations.

12.3 Requesting Erasure

How to delete your account in the app, or to ask us to delete it from the website or by email, is explained at habitualgrowth.com/delete-account.

If you are entitled to erasure under the law of your country and the position above does not satisfy that right, contact us with the subject line “ERASURE” and we will handle your request in accordance with that law.

13. Data Security

We use technical and organizational measures appropriate to the risk, including encryption in transit, encrypted database connections, private networking for our database, access controls, keyed hashing of contact data, session revocation, rate limiting, and audit logging of staff account actions. Our servers deliberately avoid logging phone numbers, contact fingerprints, message content and AI conversation content.

No system is perfectly secure. We cannot guarantee the security of information transmitted to or stored by us. Two specific limitations are worth stating: messages are not end-to-end encrypted (Section 7.2), and media sent in messages is served from addresses that are unguessable but not individually access-controlled, which means someone who obtains the address of a file could retrieve it.

If we become aware of a personal-data breach affecting you, we will notify you and the relevant supervisory authorities where required and within the timeframes set by applicable law.

14. International Data Transfers

14.1 Where We Process Data

Habitual Growth is based in the United States. All of our production infrastructure — application servers, the PostgreSQL database, object storage holding message media, and database backups — runs on Google Cloud Platform in the us-central1 region (Iowa, United States). Our service providers listed in Section 9.1 also process personal data in the United States. One exception is worth naming: certain third-party AI model services use global endpoints and may process a request outside the United States. Current AI providers and their processing locations are listed at habitualgrowth.com/ai-providers. If you use the Services from outside the United States, your personal data will be transferred to and processed in the United States.

14.2 Transfer Safeguards

For transfers from jurisdictions that regulate cross-border transfers, we use the mechanisms permitted by the law that applies to the transfer, which may include consent, contractual safeguards or applicable adequacy findings. We conduct transfer assessments where required. You may request information about the safeguards applicable to your data as described in Section 14.3.

14.3 Copies of Safeguards

You can request a copy of the applicable transfer safeguards, with commercially confidential information redacted, by emailing info@habitualgrowth.com with the subject line “TRANSFER SAFEGUARDS.”

15. Your Privacy Rights

15.1 Rights Available to Everyone

As a matter of policy, and regardless of where you live, you may ask us to give you access to your personal data, correct inaccurate data, delete your account, withdraw consent you have given, and object to processing. You may also exercise any additional rights available under the law that applies to you, including data portability, restriction of processing, review of a decision or appeal where applicable. We will handle requests in accordance with that law.

15.2 How to Make a Request

Email info@habitualgrowth.com with the subject line “PRIVACY” and describe your request. Including your country helps us identify applicable requirements. We verify requests before acting on them and respond within the time required by applicable law.

15.3 Data Portability and Export

NO SELF-SERVICE EXPORT YET We do not currently offer an in-app “download my data” feature. Until we do, portability and access requests are handled manually: email us with the subject line “EXPORT” and we will compile your data and provide it in a structured, commonly used, machine-readable format.

15.4 Complaints

If you are unhappy with our response, you may complain to the privacy or data-protection supervisory authority with jurisdiction over your complaint, where one is available under applicable law. You may also contact us at info@habitualgrowth.com for help identifying the appropriate authority. We would appreciate the chance to resolve the matter first.

16. Children and Sub-Accounts

The Services are intended for people aged 16 and over. This minimum applies to every account, including sub-accounts created by a primary account holder.

HOW AGE IS HANDLED We do not currently operate an automated age gate or age-verification mechanism. When you create a sub-account, you represent that the person who will use it is at least 16, and that you are their parent or legal guardian or otherwise authorized to create and manage the account and to consent on their behalf. We rely on that representation. Sub-accounts have access to messaging, contact discovery and Sequoia AI on the same terms as any other account.

We do not knowingly collect personal data from anyone under 16. If you believe a person under 16 has provided us with personal data, contact us with the subject line “MINOR” and we will investigate and delete the account and associated data where appropriate. Members under 18 in some jurisdictions have additional rights to remove content they posted. Contact us at info@habitualgrowth.com to exercise those rights.

17. Reserved

This section is reserved for future services.

18. Changes to This Privacy Policy

We may update this Policy. The “Last Updated” date at the top shows when it last changed. For material changes that adversely affect your rights, we will give you notice in the app or by email before the change takes effect, and where required by law we will seek your consent.

We maintain an archive of previous versions, available on request.

IF YOU JOINED BEFORE THE EFFECTIVE DATE This Policy takes effect on the Effective Date shown at the top. If you already had an account before that date, we will notify you in the app or by email, and where a change requires your consent under the law that applies to you — for example consent to process sensitive personal data, or consent to contact discovery — we will ask for it before relying on it, rather than treating your continued use as agreement.

19. Contact Us

Habitual Growth, LLC, 12081 W Alameda Pkwy, PMB 139, Lakewood, CO 80228, United States. Email info@habitualgrowth.com. For the fastest routing, include your country and request type in your message.

Habitual Growth, LLC · Privacy Policy v3.3 · Effective October 30, 2026