Privacy Policy

Human Program, Inc. ("Human Program, we, our, or us") respects your privacy and is committed to protecting the personal information of our users, including students, parents, and educational institutions.

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our website, applications, and services (collectively, the "Service").

Human Program is designed to support learning experiences for students, families, and educational organizations. Because our services may be used by minors and educational institutions, we follow privacy practices designed to comply with applicable laws including:

• The Family Educational Rights and Privacy Act (FERPA)
  
• The Children's Online Privacy Protection Act (COPPA)
  
• Applicable U.S. state student data privacy laws

1. Information We Collect

We collect information in several ways depending on how you interact with the Service.

1.1 Information You Provide Directly

Users may provide information such as:

• Name
• Email address
• Parent or guardian email address
• Phone number
• Language preferences
• Age or date of birth
• Username and account credentials
• Profile information
• Communications with us
• Educational information submitted through the platform
• Payment and transaction information when purchasing services

Parents, guardians, or educational institutions may create accounts for students.

1.2 Student Educational Information

When the Service is used by or on behalf of a school, district, or educational organization, we may collect information related to a student's educational experience, including:

• Learning progress
• Participation in educational activities
• Coursework interactions
• Educational performance indicators
• Feedback and assessments

In certain contexts, this information may qualify as "education records" under FERPA.

1.3 Automatically Collected Information

When users interact with the Service, we may automatically collect certain information including:

• Device type
• Device identifiers
• Browser type
• IP address
• Usage activity
• Log data
• Cookies and similar technologies

This information helps us operate and improve the Service.

1.4 Information from Third Parties

We may receive personal information about users from parents, guardians, educational institutions, application and intake forms, and service providers that support our operations. For example, a school, parent, or guardian may create an account for a student or provide educational information needed to use the Service.

1.5 Product Research and Development

We may invite adult users, parents, guardians, educators, or administrators to participate in surveys, interviews, user testing, or other product research activities. Participation is voluntary. Information provided through these activities may be used to evaluate, improve, and develop our products and services. We do not use student education records for product research except as permitted by applicable law, contract, or school authorization. To request more information about research activities, opt out of research invitations, or request a copy of research-related information you provided to us, contact us at support@humanprogram.com.

1.6 SMS/Text Messaging

If you provide your phone number through our website, application forms, intake forms, or other communications with us, you may choose to receive SMS or text messages from Human Program. These messages may relate to application status, enrollment updates, scheduling, program information, reminders, and other communications related to a student's educational experience.

If you opt in to receive text messages, you are providing consent to receive recurring automated text messages at the number you provided. Consent is not a condition of enrollment or purchase. Message frequency may vary. Message and data rates may apply.

You may opt out of text messages at any time by replying `STOP`. After opting out, you may receive a one-time confirmation message. You may re-subscribe by replying `START`, if that option is made available. For help, reply `HELP` or contact us at support@humanprogram.com.

Mobile information collected as part of our SMS program, including phone numbers, opt-in data, and consent records, will not be shared with third parties or affiliates for their own marketing or promotional purposes. Carriers are not liable for delayed or undelivered messages.

1.7 Fitness Tracker and Connected Device Data

If a student or account holder connects a Garmin device or another approved fitness tracker or connected device to the Service, we may collect activity and wellness information made available through that device or its API, such as step counts, activity goal progress, movement metrics, and similar fitness-related data used for the educational or rewards features of the program.

2. How We Use Information

We use collected information to:

• Provide and operate the Service
• Support educational activities
• Personalize learning experiences
• Maintain and improve platform functionality
• Communicate with users
• Send service-related announcements, reminders, and administrative messages
• Provide customer support
  
• Administer accounts and program participation
  
• Administer activity goals, rewards, and connected-device features
  
• Conduct product research and development
  
• Ensure security and prevent misuse
• Enforce our terms, policies, and agreements
  
• Comply with legal obligations

We do not use student personal information for behavioral advertising.

We may send service-related announcements, product updates, reminder notifications, and other essential communications as part of operating the Service. Where permitted by law or based on your consent, we may also send information about new services, offers, or promotions to adult users, parents, guardians, or educators. We do not use student personal information for marketing directed to students. You may opt out of non-essential marketing communications by using the unsubscribe method provided in the message or by contacting us at support@humanprogram.com.

Human Program does not make student information publicly available. Depending on the features used by a school, program, or account holder, limited profile and educational participation information may be visible on a role-based basis to authorized users of the Service, such as parents, guardians, educators, squad leaders, administrators, or students participating in the same squad or program. Any such visibility is limited to information needed to support the educational experience, collaboration, or program administration, such as profile elements, participation indicators, or progress displays, and is not intended to provide unrestricted access to a student's full education records, private communications, or account details. Fitness tracker and connected-device data are subject to additional restrictions described in Section 7.7.

3. Student Data and FERPA Compliance

Human Program provides services that may be used by schools and educational organizations.

When we provide services to an educational institution, we may receive or process information that constitutes education records under FERPA.

In those situations:

• The educational institution remains the owner and controller of student education records.
• Human Program acts as a "school official" with legitimate educational interests.
• We process student data only under the direction of the educational institution.

Human Program does not disclose student education records except:

• At the direction of the educational institution
• As permitted under FERPA
• As required by law

Human Program does not make student education records publicly available. Where the Service includes collaborative or program-based features, limited student profile or progress information may be displayed within the same school, squad, cohort, or program only to the extent authorized by the educational institution, program configuration, applicable consent, or applicable law.

4. Rights of Parents and Eligible Students (FERPA)

Under FERPA, parents and eligible students (students who are 18 years of age or older or attending a postsecondary institution) may have the right to:

• Inspect and review the student's education records
• Request correction of inaccurate or misleading records
• Provide consent before disclosure of personally identifiable information from education records, except where FERPA permits disclosure without consent
• File a complaint with the U.S. Department of Education concerning alleged failures to comply with FERPA

Requests regarding education records should generally be directed to the relevant educational institution responsible for the records.

5. Children's Privacy (COPPA)

Human Program may be used by children under the age of 13 as part of educational programs.

We comply with the Children's Online Privacy Protection Act (COPPA).

When children under 13 use the Service:

• Personal information may be collected only for educational purposes.
  
• Schools or educational institutions may provide consent on behalf of parents when the Service is used for educational purposes.
  
• We limit the collection of personal information to what is reasonably necessary to provide the Service.

Parents or guardians may:

• Review personal information collected about their child.
  
• Request deletion of their child's personal information.
  
• Refuse further collection or use of their child's information.

Requests may be submitted by contacting us at support@humanprogram.com.

Where our registration flow requires it, we may use age-gating and request a parent or guardian email address before activating an account for a child under 13. We may send authorization or consent instructions, including an authorization code or similar confirmation process, to complete registration where required by law or program design. Any student-to-student visibility for children under 13 is limited to closed educational settings, subject to school or parent authorization where required, and limited to the minimum information necessary for the applicable educational feature.

6. International Users and GDPR Compliance

Human Program operates globally and may process personal information of users located outside the United States, including in the European Economic Area (EEA), United Kingdom (UK), and other jurisdictions with data protection laws.

6.1 Legal Basis for Processing

Where applicable under data protection laws such as the General Data Protection Regulation (GDPR), we rely on the following legal bases to process personal information:

• Performance of a Contract: To provide access to the Service, deliver educational content, and fulfill our obligations to users, parents, and educational institutions.
  
• Legitimate Interests: To improve and maintain the Service, ensure platform security, prevent misuse, and support educational outcomes, provided such interests are not overridden by user rights.
  
• Consent: Where required, including for certain data collection practices or for users under applicable age thresholds. Consent may be provided by a parent, guardian, or educational institution where permitted by law.
  
• Legal Obligations: To comply with applicable laws, regulations, and legal processes.

6.2 Data Subject Rights

Users located in the EEA, UK, and similar jurisdictions may have the following rights under applicable law:

• The right to access personal data we hold about you
  
• The right to request correction of inaccurate or incomplete data
  
• The right to request deletion of personal data ("right to be forgotten")
  
• The right to restrict or object to certain processing activities
  
• The right to data portability
  
• The right to withdraw consent at any time, where processing is based on consent

To exercise these rights, please contact us at support@humanprogram.com. We may need to verify your identity before fulfilling your request.

6.3 Children and Consent

Where required by applicable law, we obtain consent from a parent or legal guardian before collecting personal information from children. In educational settings, schools or educational institutions may provide consent on behalf of parents where permitted by law.

6.4 International Data Transfers

Human Program is based in the United States. Personal information may be transferred to, stored in, and processed in the United States or other countries that may not provide the same level of data protection as your home jurisdiction.

Where required, we implement appropriate safeguards for cross-border data transfers, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
  
• Contractual commitments with service providers to protect personal data

6.5 Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods may vary depending on the nature of the data and the context in which it was collected.

6.6 Supervisory Authority

Users located in the EEA or UK have the right to lodge a complaint with a relevant data protection authority if they believe their rights have been violated.

6.7 Contact for Data Protection Matters

If you have questions about this section or our data protection practices, please contact us at support@humanprogram.com.

7. How We Share Information

We do not sell personal information.

We may share information in limited circumstances:

7.1 Educational Institutions

When the Service is used by schools or educational organizations, those institutions may access student data associated with their programs.

7.2 Other Authorized Users

Depending on the Service features and permissions established by a school, organization, parent, or account holder, limited profile and educational participation information may be made available on a role-based basis to other authorized users within the same program or service environment. This may include parents, guardians, educators, squad leaders, administrators, and, where enabled for an educational feature, students participating in the same squad, cohort, or program. Human Program does not make student information publicly available, and peer visibility is intended to be limited to profile elements, participation indicators, or progress displays relevant to the educational experience rather than full account details, private communications, or complete education records. Connected fitness tracker data, including Garmin Connect API data, is not made visible to other students and is limited as described in Section 7.7.

7.3 Service Providers

Except where a more specific restriction applies, such as Section 7.7 for Garmin Connect API data, we may share information with trusted service providers that help us operate the platform, such as:

• Cloud hosting providers
  
• Infrastructure providers
• Analytics and crash-reporting providers
  
• Customer support services
  
• Search and communications providers
  
• Security services

Service providers are contractually required to:

• Protect personal information
  
• Use data only for authorized purposes
  
• Maintain confidentiality of student information

7.4 Legal Requirements

We may disclose information if required to do so by law or in response to valid legal requests.

We may also disclose information when we believe in good faith that doing so is necessary to protect Human Program, our users, or others; detect, prevent, or address fraud, misuse, security incidents, or illegal activity; or enforce our rights, agreements, or policies.

7.5 Business Transfers

If Human Program is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of company assets, or transition of service to another provider, personal information may be disclosed or transferred as part of that transaction, subject to applicable law, contractual commitments, and restrictions applicable to student records and other protected information. Any successor entity would be expected to honor the applicable privacy, security, educational-data, and third-party platform obligations associated with the transferred information.

7.6 De-Identified and Aggregate Information

We may use, disclose, and share de-identified, anonymized, or aggregated information that does not reasonably identify an individual for lawful business purposes, including analytics, product improvement, research, and reporting. We do not treat information as de-identified or aggregated if it reasonably identifies a particular student or user.

7.7 Garmin Connect Data Restrictions

Data obtained from Garmin Connect APIs or from Garmin-connected devices is used only within Human Program to provide activity tracking, goal monitoring, rewards features, and related program administration for the relevant student. Such data may be made available within the Service only to the relevant student, the student's parent or legal guardian, and authorized Human Program or school/program personnel, such as squad leaders or administrators, who need that information to support the student's participation in the program.

Human Program does not make Garmin Connect API data publicly available and does not disclose Garmin Connect API data to other students, analytics providers, advertising providers, unrelated third parties, or external tools for their own purposes. Garmin Connect API data is not shared with, submitted to, or otherwise processed by external AI providers, model providers, or external AI services. Human Program does not use Garmin Connect API data to train external artificial intelligence models or to obtain external AI-generated analysis, profiling, enrichment, or inference.

Garmin Connect API data may be processed only by cloud, hosting, storage, security, or other infrastructure providers that operate Human Program's service on Human Program's behalf and are bound by contractual confidentiality, security, and data protection obligations. Any transfer or continued processing of Garmin Connect API data in connection with a business transaction remains subject to applicable law, contractual commitments, and any restrictions imposed by Garmin program requirements.

8. Data Retention

We retain personal information only as long as necessary to:

• Provide the Service
  
• Support educational programs
  
• Fulfill contractual obligations
• Comply with legal requirements

When services to a school or user end, data may be deleted or anonymized in accordance with our data retention practices.

Where permitted by law, we may retain de-identified or aggregated information that no longer identifies a particular user.

9. Data Security

Human Program implements reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized disclosure, alteration, or destruction.

Security measures may include:

• Access controls
• Encryption
• Monitoring systems
  
• Secure infrastructure

No system can be guaranteed to be completely secure, but we continuously work to protect user information.

10. User Rights and Choices

Depending on applicable laws, users may have the right to:

• Access their personal information
  
• Request corrections
  
• Request deletion of personal data
  
• Request restriction of, or object to, certain processing
  
• Request a portable copy of certain personal data
• Withdraw consent where applicable

Requests may be submitted to support@humanprogram.com.

When student data is controlled by an educational institution, requests may need to be directed to the relevant school or organization.

Users may also be able to review, update, or correct certain account information through their account settings or through the applicable school or program administrator. Account deletion may be available through the Service or by contacting us.

We may need to verify your identity before fulfilling a request. Some rights are subject to exceptions and limitations under applicable law, including situations where fulfilling a request would interfere with our legal obligations, security measures, or ability to provide the Service.

10.1 U.S. State Privacy Rights

Residents of California and certain other U.S. states may have additional privacy rights under applicable law, which may include the right to know what personal information we collect, access a copy of personal information, request correction or deletion, understand how personal information is disclosed, and opt out of certain types of sharing or targeted advertising where applicable. Human Program does not sell personal information. To submit a state privacy rights request, contact us at support@humanprogram.com.

11. Cookies and Tracking Technologies

Human Program may use cookies and similar technologies to:

• Maintain user sessions
  
• Improve platform functionality
  
• Analyze platform usage

Users may adjust browser settings to control cookies, though some features of the Service may not function properly if cookies are disabled.

We may also use analytics, measurement, and similar technologies provided by third parties, such as website analytics or crash-reporting tools, to better understand how users engage with the Service, diagnose issues, and improve performance. These technologies may use cookies, SDKs, pixels, or similar tools. Where available, users may opt out or limit certain tracking through browser settings, device settings, or third-party opt-out tools, including tools made available by analytics providers such as Google Analytics.

12. Third-Party Links

The Service may contain links to third-party websites or services.

Human Program is not responsible for the privacy practices of third-party services. Users should review the privacy policies of those services separately.

Third-party websites or services that refer users to Human Program, or that are linked from the Service, may apply their own cookies, pixels, or other tracking technologies. Any information submitted directly to those third parties is governed by their own privacy practices and policies.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically.

If material changes are made, we will notify users through the Service or other appropriate means.

The updated policy will include a revised "Last Updated" date.

14. Contact Us

Human Program, Inc.  
361 S Camino Del Rio #203  
Durango, CO 81303-7997  
United States of America

For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact us at support@humanprogram.com.