1. Overview and Scope
Hab12 is a wearable muscle-sensing system that uses muscle-activity measurements to control responsive gameplay and provide immediate feedback. It is designed to support exercise engagement, muscle awareness, physical training, and general wellness. Users connect a compatible muscle sensor to the Hab12 App through Bluetooth and use muscle activity to interact with gameplay.
Hab12 is not intended to diagnose, treat, cure, mitigate, prevent, or monitor any disease, injury, or medical condition. It does not provide medical advice and is not a substitute for advice from a qualified healthcare professional.
This Privacy Policy applies to the direct-to-consumer version of Hab12 offered in the United States. If Hab12 is provided through a healthcare provider, research study, employer, rehabilitation facility, or another organization, additional or different privacy and consent terms may apply.
2. Information Processed and Stored on the Device
A. High-Resolution Muscle-Activity Data
Hab12 records high-resolution raw surface electromyography (sEMG) readings received from a compatible sensor. These readings may include signal values, timestamps, and technical information needed to associate the readings with the correct session.
Raw sEMG data is stored locally on the user’s device. It is not automatically transmitted to HabTools.
B. Gameplay and Session Metrics
Hab12 also processes and stores gameplay and session information locally on the device. Depending on the activity, this may include:
- Scores, levels reached, and completed game actions;
- Repetitions, thresholds, and success measures;
- Session dates, times, and duration;
- Derived measures such as activation, effort, or performance summaries; and
- App, sensor, or session information needed to operate the game and organize saved sessions.
HabTools does not automatically receive the locally stored raw data or summary metrics.
3. User-Directed Sharing
Users may choose to export either a summary file containing gameplay and derived session metrics or a detailed raw-data file containing high-resolution sEMG readings and related session information.
Export occurs through email. The user selects the file, chooses the recipient, and initiates the transmission. Nothing is automatically sent to HabTools or any other recipient.
HabTools receives an exported file only when the user intentionally selects HabTools as a recipient. If a user sends information to another person or organization, that recipient’s privacy practices govern its subsequent use.
When a user contacts HabTools by email, HabTools may receive the sender’s email address, message content, attachments, and any other information the user voluntarily provides.
4. Bluetooth, Location, and Notifications
Hab12 requires Bluetooth permission to discover and connect to a compatible muscle sensor. On some devices or older versions of Android, the operating system may also require location permission or location services for Bluetooth scanning. Hab12 does not use Bluetooth scanning to determine the user’s physical location and does not collect or store GPS location data.
If notifications are enabled, the device may display exercise or activity reminders. Notification permissions can be disabled through the device settings.
5. Information HabTools Does Not Automatically Collect
Hab12 does not require users to create an account or provide a name, telephone number, mailing address, date of birth, or payment information. HabTools does not:
- Automatically receive raw sEMG data or gameplay metrics stored on the device;
- Collect or store GPS location data;
- Sell personal information or consumer health data;
- Use personal information for targeted advertising;
- Track users across unrelated apps or websites; or
- Display third-party advertisements in the App.
6. How We Use Information Voluntarily Sent to HabTools
When a user chooses to send information to HabTools, we may use it to:
- Respond to a question or support request;
- Investigate technical problems;
- Test and improve App and sensor performance;
- Improve gameplay and the user experience;
- Protect the security and integrity of Hab12; and
- Comply with applicable law.
HabTools will not use voluntarily shared information to diagnose a medical condition, provide treatment recommendations, determine eligibility for healthcare services, or make insurance or employment decisions.
7. Product Testing and Research
A user may voluntarily send raw data or summary metrics to HabTools for technical support or product testing. The information will be handled under this Policy and any additional notice shown at the time of sharing.
Formal research participation is separate from ordinary use of Hab12. If HabTools invites a user to participate in a research study, the study will use a separate research notice and consent process and, where applicable, institutional review board or ethics review. This Privacy Policy does not itself constitute consent to participate in research or to use information for an unrelated research purpose.
8. How Information May Be Shared
HabTools does not sell or rent personal information or consumer health data. Information voluntarily sent to HabTools may be accessible to:
- HabTools personnel who need it for support, testing, security, or product improvement;
- Email, information-technology, or storage providers acting on behalf of HabTools;
- Professional advisers subject to confidentiality obligations; and
- Government authorities or other parties when disclosure is required by law or reasonably necessary to protect legal rights or safety.
When a user exports information to a recipient selected through email, HabTools does not control that recipient’s later use or disclosure of the information.
9. Data Retention and Deletion
Information Stored on the Device
Raw sEMG data and gameplay information remain on the device until the user deletes the saved files or sessions using available App or device controls, or uninstalls Hab12. Because HabTools does not automatically receive this information, HabTools generally cannot access, retrieve, or delete the local copy for the user.
Information Voluntarily Sent to HabTools
Raw-data files or session summaries voluntarily sent to HabTools for support or product testing will ordinarily be deleted from active systems within 90 days after receipt, unless continued retention is reasonably necessary to complete the requested support, investigate a security or technical issue, comply with law, or follow separate research-consent terms.
Ordinary support correspondence may be retained for up to 24 months after the last communication. Information may remain temporarily in routine backups until those backups are overwritten under HabTools’ normal backup schedule.
10. U.S. Consumer Health Data and Privacy Rights
Some state laws define consumer health data broadly and may apply to information associated with exercise, muscle activity, or bodily function even when the information is not used for diagnosis or treatment. To the extent information voluntarily sent to HabTools is covered by such a law:
- The categories may include raw sEMG readings, session information, gameplay metrics, derived measures, and information included in a message or attachment;
- The source is the user who intentionally sends the information;
- The purposes are support, troubleshooting, security, testing, product improvement, and any separately consented research;
- Recipients are limited to HabTools and the service providers or other parties described in this Policy; and
- HabTools does not sell consumer health data.
Depending on the user’s state of residence, the user may have rights to access, correct, delete, or obtain a copy of information held by HabTools; withdraw consent for future processing; obtain information about recipients; appeal a denied request; and exercise other rights provided by law. HabTools will not discriminate against a user for exercising a privacy right.
Requests may be submitted to contact@habtools.com. HabTools may need to verify the requester’s identity. Requests generally apply only to information previously sent to HabTools, not to information that remains solely on the user’s device.
11. Security
HabTools uses reasonable administrative, technical, and organizational safeguards designed to protect information received by HabTools, including restricting access to individuals who need the information for an authorized purpose. No storage or transmission method is completely secure. Users should consider the sensitivity of raw muscle-activity data before sending it by email or through another third-party application.
12. Children’s Privacy
Hab12 is not directed to children under 13, and HabTools does not knowingly collect personal information from children under 13. If HabTools learns that a child under 13 has sent information to HabTools without appropriate authorization, HabTools will take reasonable steps to delete it. A parent or legal guardian may contact contact@habtools.com.
13. Changes to This Policy
HabTools may update this Privacy Policy to reflect changes in Hab12, our privacy practices, or applicable law. Material changes will be identified through a revised effective date and, where appropriate, an additional notice within the App or on the HabTools website.
14. Contact Us
Questions, privacy requests, and complaints may be directed to:
HabTools, Inc.
Email: contact@habtools.com