Privacy Policy

Effective date: June 27, 2025

At Eido Studios, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data when you use Howdy. By using or accessing our Howdy Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.

Remember that your use of Eido Studios’ Services, including Howdy, is at all times subject to our Terms of Use at howdy-app.com/terms, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting [email protected].

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Eido Studios website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What This Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months through your use of the Services:

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  • Creating and managing your account.
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Improving the Services, including testing, research, internal analytics, and product development.
  • Personalizing the Services, website content, and communications based on your preferences.
  • Analyzing usage patterns and engagement to improve the product and user experience.
  • Doing fraud protection, security, and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Eido Studios or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Eido Studios or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You

  • When you provide such information directly to us.

    • When you create an account or use our interactive tools and Services.
    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise contact us.

  • When you use the Services and such information is collected automatically.

    • For some in-app interactions, audio may be temporarily processed in memory to enable live feedback. This processing only occurs during active participation and is not recorded, stored, or retained, and is never used for advertising, profiling, or any unrelated purposes.
    • Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
    • If you download our mobile application or use a location-enabled browser, we may receive information about your location and device, as applicable.
    • If you download and install certain applications we make available, we may receive and collect information transmitted from your device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
• Third Parties
  • Vendors
    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

  • Hosting, technology and communication providers.
  • Analytics service providers that provide insights regarding our Services.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Voice and audio processing provider that assists with real-time analysis of content, enabling support for product features.
• Business Partners. These parties partner with us in offering various services. They include:
  • Our affiliates, which may use your information for any of the purposes described in this Privacy Policy.
• Parties You Authorize, Access, or Authenticate.
  • Other Users: When you use the app to communicate with others, the username or display name you create may be visible to the individuals you choose to interact with in the app.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking [LINK]. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Data Security

We take the security of your Personal Data seriously and implement appropriate physical, technical, and organizational safeguards based on the sensitivity of the data and the way it is processed. This includes industry-standard encryption and security protocols to protect data in transit and at rest.

For voice interactions, audio data is end-to-end encrypted in transit using a combination of AES (Advanced Encryption Standard) and TLS (Transport Layer Security). Voice data is processed securely in memory and is not stored or retained.

You are also responsible for maintaining the security of your account credentials.

While we strive to safeguard your information, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security, but we continually review and update our practices to help protect your data.

Data Retention

We retain Personal Data about you for as long as necessary to provide our Services or to perform our business or commercial purposes for collecting your Personal Data, as is the case with Web-Based Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• We retain your profile information and credentials for as long as you have an account with us.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

We do not retain audio recordings or transcripts of voice interactions. Voice data is processed securely in memory in real time solely to support select product features. No transcripts or recordings are stored, and no audio data is used for advertising or unrelated purposes.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at [email protected].

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

  • Profile or Account Data
  • Audio Data

• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:

  • Profile or Account Data
  • Audio Data
  • Device/IP Data
  • Geolocation Data
  • App Analytics
  • Web Analytics
  • Other Identifying Information that You Voluntarily Choose to Provide
  • We may also de-identify or anonymize Personal Data to further our legitimate interests.

  Examples of these legitimate interests include (as described in more detail above):

  • Providing, customizing, and improving the Services.
  • Corresponding with you.
  • Meeting legal requirements and enforcing legal terms.
  • Completing corporate transactions.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Disclosing Personal Data

The “How We Disclose Your Personal Data” section above details how we share your Personal Data with third parties.

Your Privacy Rights

You have certain rights with respect to your Personal Data, depending on where you reside. For more information about these rights, or to submit a request, please email us at [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Right to Know / Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

• Right to Correct: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. by providing a Valid Request.

• Right to Delete: You can request that we erase some or all of your Personal Data from our systems.

• Right to Withdraw Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

• Right to Data Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

• Right to Object: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

• Right to Restrict Processing: You can ask us to restrict further processing of your Personal Data.

• Right to Non-Discrimination: You have the right not to be discriminated against for exercising your privacy rights.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Eido Studios and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Eido Studios in the U.S. and will be hosted on U.S. servers, and you authorize Eido Studios to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Email: [email protected]
Address: 350 10th Avenue, Suite 1000, San Diego, CA 92101