Privacy Policy

1. Our commitment

Privacy, data minimisation and the protection of personal data are essential elements of HUGiiNE. This Policy explains what personal data we may collect, receive, generate or infer in the context of HUGiiNE Mood Intelligence, why we process it, the applicable legal bases, who it may be shared with, how long it may be retained and the rights available to users under the General Data Protection Regulation (GDPR) and other applicable law.

2. Data controller

The controller of personal data is the entity responsible for operating the HUGiiNE platform. That entity determines the purposes and essential means of processing carried out through the Platform, without prejudice to situations in which providers act as processors or, where applicable, as independent controllers.

3. Data we may process

Account and profile data

• Name.
• Email address.
• Language.
• Year of birth, country, profession or main activity, industry, relationship status and other profile information provided by the user where those fields form part of the version of the Service being used.
• Internal account identifiers.
• Authentication, security and account management data.

Data used by Mood Intelligence

• Mood check-ins on a 1-to-5 scale.
• Optional comments or notes associated with a mood check-in.
• Date, time, time zone and time-of-day information associated with the check-in.
• Context voluntarily provided by the user, including where they are or the type of place and, where available, who they are with or the social context.
• Activity and movement information made available by the device where the user grants the required permissions, including activity or movement categories and related technical indicators.
• Location information made available by the device where the user grants that permission and where it is required for HUGiiNE context features.
• Weather or environmental information associated with the place and time of a check-in, such as weather conditions and temperature, where this feature is available.
• Historical data required to compare a current check-in with the user’s own previous check-ins.
• Patterns, trends, associations and other inferences produced by HUGiiNE from the user’s own history.
• Usage and notification preferences, where available.
• Text, voice or transcripts only where the user uses a feature that expressly allows that type of input.

Technical and usage data

We may process technical information needed to operate, protect and improve the Platform, including access dates and times, browser, device, operating system, IP address, session identifiers, app version, technical logs, feature usage, errors, security events and information required to prevent fraud or abuse. Location, activity, notification, microphone and other device permissions are controlled by the operating system and by the user. The availability of a permission does not mean it is used continuously: HUGiiNE aims to process only the information needed for the feature actually being used.

4. Special categories and sensitive information

This information may include data relating to health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, sexual orientation, genetic data or biometric data. HUGiiNE does not require these categories of data for normal mood check-ins and recommends that users do not enter them where they are not necessary. HUGiiNE Mood Intelligence is not a diagnostic tool, and mood, activity, location, weather or context data are not used on their own to diagnose or assert the existence of depression, anxiety, stress, fatigue, mental illness or another clinical condition. Where applicable law requires explicit consent or another specific legal basis for processing special-category data, that basis will be obtained or verified as appropriate.

5. How we use the data

• Create, authenticate, administer and protect the user account.
• Allow users to record how they feel quickly and review their history.
• Associate each check-in with the relevant time and context that is available.
• Use activity, location and weather information, where authorised and available, to contextualise mood check-ins.
• Identify recurring associations between mood, time of day, activity, place, weather, social context and other available elements.
• Compare the user’s check-ins mainly with their own history and personal pattern rather than treating them as a classification against a generic profile.
• Present patterns, trends and longitudinal summaries that may help the user better understand the circumstances associated with how they feel.
• Generate reminders and notifications related to Mood check-ins where that feature is active.
• Use artificial intelligence systems or other analytical methods to summarise, organise or explain patterns where that functionality is available.
• Maintain security, prevent fraud, abuse and unauthorised access and diagnose technical problems.
• Produce statistics, test and improve the Platform using aggregated, pseudonymised or anonymised information where appropriate.
• Comply with legal obligations and establish, exercise or defend legal rights.

6. Mood Intelligence and profiling

HUGiiNE relates the user’s mood check-ins to available contextual information, including time of day and, where authorised or provided, activity, location, weather, type of place, social context and comments. From the resulting history, the system may produce individualised patterns, trends and associations. This processing may constitute profiling of the user for the purposes of data protection law.

The patterns shown by HUGiiNE are dynamic computational representations of the available history. They are not an objective, clinical, definitive or immutable definition of the user. An observed association does not, by itself, demonstrate cause and effect. For example, if certain check-ins coincide with a particular place, activity or weather condition, that does not mean the factor caused the recorded mood. Patterns may be incomplete or incorrect and may change as new information is added.

7. Artificial intelligence and technology providers

Some HUGiiNE features may use artificial intelligence systems, statistical models, cloud infrastructure, mapping or location services, weather providers, notification systems and other specialised technology providers. To provide a feature, it may be necessary to transmit only the information required for the relevant operation. For example, a weather request may require sufficient location information to obtain weather conditions relevant to the time and place of the check-in.

Where a provider processes personal data on behalf of HUGiiNE, the contract and data-protection safeguards required by law will be applied and the information transmitted will be minimised. Users’ personal data and private content should not be made available to providers for the general training of their models for independent purposes incompatible with providing the Service. Any identifiable use for development or training that is not necessary for normal Service delivery will depend on transparent information and an appropriate legal basis and, where legally required, specific consent.

8. Automated processing and significant effects

HUGiiNE uses automated processing to organise check-ins, calculate indicators, identify patterns and associations and, where applicable, produce personalised explanations or suggestions. The general logic is to compare the current check-in with the user’s own history and look for statistical relationships or recurring associations between mood and context. The absence of a particular item of data, such as activity, location or weather, is not automatically interpreted as a negative characteristic of the user.

HUGiiNE is intended to support self-understanding and observation of personal patterns. The Service is not intended to subject the user to solely automated decisions that produce legal effects or similarly significantly affect them. If a future feature changes this position, the additional information and safeguards required by applicable law will be provided before that feature is used.

9. Legal bases

• Performance of a contract: to create and manage the account and provide the features requested by the user, including storing check-ins, showing history and producing patterns required for the Service to function.
• Consent: where the law requires it for a specific feature or processing activity, including optional device permissions such as location, activity, notifications or microphone where applicable. Consent or permission may be withdrawn at any time without affecting the lawfulness of processing already carried out.
• Explicit consent or another specific legal basis where applicable: where special-category data are processed in circumstances that require it.
• Legitimate interests: where necessary for security, fraud and abuse prevention, technical diagnosis, defence of rights or limited improvement of the Service, after assessing the interests, necessity and impact on users’ rights and freedoms.
• Compliance with legal obligations: where processing is required to comply with a legal obligation applicable to HUGiiNE.

10. Data sharing and recipients

HUGiiNE does not sell users’ personal data. Data is not made available to third parties so that they can create independent commercial profiles of users unless there is a specific purpose, transparent information and an appropriate legal basis.

We may use providers needed to operate the Platform, including hosting, cloud infrastructure, databases, email, authentication, security, technical monitoring, artificial intelligence, location or mapping services, weather and notifications. We may also disclose data where required by law, by a competent authority or where necessary to establish, exercise or defend legal rights. Each provider should receive only the data appropriate to the purpose of the service it provides, according to its role and legal framework.

11. International transfers

Some technology providers may process personal data outside Portugal or the European Economic Area. In those situations, data may be subject to the data-protection rules of the country in which the provider or infrastructure is located.

Where required by law, HUGiiNE will use transfer mechanisms recognised under the GDPR, including adequacy decisions, standard contractual clauses or other legally permitted mechanisms, and will assess whether supplementary measures are required in light of the transfer risk.

12. Data retention

Personal data will be retained for the period needed to provide the Service and for the purposes described in this Policy. While an account remains active, mood check-ins, comments, associated context and derived patterns may be retained to provide history and longitudinal learning. Activity, location and weather information will be retained only to the extent required by the relevant feature and architecture, with a preference for normalised or contextualised information rather than data that is more precise than necessary. After an account or particular content is deleted, data will be deleted or anonymised when no longer required, subject to limited additional periods strictly necessary for backups, security, fraud prevention, legal compliance or the establishment, exercise or defence of legal rights.

13. Data security and protection

HUGiiNE applies technical and organisational measures appropriate to the risk to protect data against destruction, loss, alteration, disclosure, access or other unauthorised or unlawful processing. These measures may include access controls, authentication, communications protection, security logs, privilege limitation, database protection, content encryption where applicable, backups and incident-response procedures. No system can guarantee absolute security. Where a personal data breach is subject to notification under applicable law, the legally required assessment, recording and communication procedures will be followed.

14. Information relating to other people

Some context fields may allow users to indicate who they are with or enter comments that mention other people. Users should limit that information to what is necessary and avoid sensitive, confidential, excessive or unlawfully obtained data about third parties. HUGiiNE does not need the full identity of another person to identify Mood patterns and is not intended to build autonomous profiles of the people mentioned. Where possible, general social-context categories or non-excessive references should be used.

15. User rights

• The right to access personal data being processed and the information legally associated with that processing.
• The right to rectify inaccurate or incomplete data.
• The right to erasure where the legal requirements are met.
• The right to restriction of processing in the circumstances provided by law.
• The right to object to processing based on legitimate interests where legally applicable.
• The right to data portability where legally applicable.
• The right to withdraw consent at any time for processing based on consent.
• The right to obtain information about profiling and automated processing and to exercise the safeguards provided by law where applicable.
• The right to lodge a complaint with the Portuguese data protection authority, Comissão Nacional de Proteção de Dados (CNPD), or another competent supervisory authority.

16. Account and data deletion

Users may request deletion of their account and, where legally applicable, the associated personal data. Deleting the account may result in the loss of Mood history, comments, contexts, derived patterns and other personal information associated with the Service. Some data may remain temporarily in backups or be retained where required to comply with legal obligations, prevent fraud, resolve disputes or establish, exercise or defend legal rights. Information that has previously been effectively anonymised may cease to be personal data and may therefore not be affected by a deletion request.

17. Cookies and similar technologies

HUGiiNE may use cookies and similar technologies that are strictly necessary for operation, authentication, security and session maintenance. If cookies or technologies that are not strictly necessary are used, including analytics, measurement or other optional purposes, the information and consent choices required by applicable law will be provided before use where necessary. Device permissions for location, activity and notifications are separate from cookies and can be managed through the operating system, app or browser settings.

18. Children

HUGiiNE is intended exclusively for people aged 18 or over. Accounts may not be created by anyone under 18. If we become aware that personal data of a minor has been processed in breach of this rule, steps may be taken to delete that data and close the account, subject to applicable legal obligations.

19. Changes to this Policy

This Policy may be updated to reflect changes to HUGiiNE Mood Intelligence, context features, technologies used, providers or applicable legal obligations. Where a change is materially significant, the user will be appropriately informed before it takes effect where required by law. The date of the applicable version will be shown at the beginning of this Policy.

20. Contact and exercise of rights

Requests relating to personal data, privacy or the exercise of rights may be submitted through the data-protection contact made available by HUGiiNE. HUGiiNE may request information reasonably necessary to confirm the identity of the requester. Users may also lodge a complaint with the Portuguese data protection authority, Comissão Nacional de Proteção de Dados (CNPD), or another competent supervisory authority.