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Legal

Privacy Policy

Version privacy-2026-10-20 · Effective 20 October 2026

The short version

  • We collect what we need to run membership, allocate shares, meet AML/CFT obligations, and communicate with you — including identity and tax information (encrypted where sensitive).
  • We do not sell personal information or share it with portfolio companies without your explicit consent. We may publish aggregated, de-identified statistics.
  • Data is hosted in Germany (Hetzner); email on Huntos mail servers; Cloudflare for security and delivery. No advertising or analytics trackers.
  • You have access, correction, deletion (subject to legal retention), and other rights under NZ, EU/UK GDPR, Australian, and US state privacy laws as described below.

1. Scope and controller

This Privacy Policy explains how Huntos Corporation ("Huntos", "we", "us") processes personal information when you use huntos.hn, huntos.cloud, membership services, and related communications.

Huntos is in formation with intended jurisdiction New Zealand. For GDPR and UK GDPR purposes Huntos is the controller. Contact: [email protected], [email protected].

2. What we collect

We may collect:

  • Account data: email address, magic-link tokens, session identifiers, preferences (including live-feed display choices).
  • Membership and due diligence: legal name, date of birth, nationality, phone, residential address, tax residency, tax identification number or reason for not providing one (encrypted at rest), US person status (FATCA), PEP status, and declarations you submit during a claim.
  • Verification documents and outcomes when KYC is performed.
  • Communications: support messages, security reports, and AI assistant conversations.
  • Technical data: IP address, browser type, and security logs from Cloudflare and our servers (not used for advertising profiles).
  • Huntos Account and payment data when that service is offered, under separate terms.

3. Sources

We collect information directly from you, from your device when you use the Website, from our service providers (hosting, email, identity verification partners when used), and from public sources only where lawful for AML/CFT.

We do not buy personal information lists.

4. Why we use personal information

We process personal information to:

  • Provide membership, allocate shares, and operate your account (contract).
  • Meet AML/CFT, tax, and other legal obligations (legal obligation).
  • Secure the Website, prevent fraud and duplicate claims, and enforce our terms (legitimate interests).
  • Send service messages and, where you opt in, show your first name on the live feed (contract / consent).
  • Improve reliability and understand aggregate usage without tracking ads (legitimate interests).
  • Respond to enquiries and investment applications submitted via the assistant (contract / legitimate interests).

6. Sharing

We never sell personal information. We do not share personal information with Huntos portfolio companies for their marketing without your explicit consent.

We share information with processors under contract: Hetzner Online GmbH (application and database hosting in Germany), Cloudflare (network security, CDN, DNS), Huntos-operated mail servers, and identity verification or payment partners when engaged. They may only process data on our instructions.

We may disclose information if required by law, court order, or to protect rights, safety, and security. We may share aggregated, de-identified statistics publicly.

7. International transfers

Your data may be processed in Germany and other countries where our providers operate. New Zealand benefits from an EU adequacy decision for appropriate transfers from the EEA. Where needed we use Standard Contractual Clauses or UK IDTA/addendum and assess transfer risks.

Cloudflare may process technical data globally for security; see Cloudflare's privacy documentation for details.

8. Retention

We retain personal information only as long as needed:

  • Member records: for the life of membership plus the period required by AML/CFT and tax law (generally seven years after membership ends where applicable).
  • We do not store dates of birth for minors; membership is 18+ only.
  • Magic-link and sign-in records: up to 90 days unless needed longer for security investigations.
  • AI assistant conversations: up to 12 months.
  • Audit and security logs: up to seven years.

9. Security

We use encryption in transit (TLS), access controls, and encryption at rest for sensitive fields such as tax identification numbers. No system is perfectly secure; report concerns to [email protected].

Session cookies are httpOnly and secure. See our Cookie Notice for details.

10. Cookies and local storage

We use essential session cookie huntos_session (7 days) and localStorage for preferences (for example huntos.liveFeed.muted and assistant session identifiers). Cloudflare may set security cookies such as __cf_bm or cf_clearance.

We do not use advertising or analytics trackers. See the Cookie Notice.

11. Live share feed

The feed shows real allocations. Your first name appears only if you opt in. Country appears only if at least five members share that country. You can change preferences anytime in your account.

12. AI assistant

Assistant messages are processed through Huntos's AI gateway and may be routed to third-party AI model providers under contract. Do not enter passwords, full identity document numbers, or unnecessary sensitive data in chat.

Conversations are retained as stated in clause 8 and used to operate and improve the service, not for advertising profiles.

13. Your rights

Depending on your location you may have rights to access, correct, delete (subject to legal retention), object, restrict processing, portability, and withdraw consent. Contact [email protected]; we respond within timeframes required by law.

You may complain to the New Zealand Office of the Privacy Commissioner, the UK Information Commissioner's Office, your EU supervisory authority, or other applicable regulator.

14. Australia

If Australian privacy law applies, we handle personal information in line with the Australian Privacy Act 1988 and Australian Privacy Principles, including rights to access and correction subject to exceptions.

15. United States

We do not sell personal information as defined by US state privacy laws. Residents of states such as California may have rights to know, delete, and correct personal information and to limit certain processing; contact [email protected]. We do not discriminate for exercising rights.

16. Children

Huntos membership is for adults 18+. We do not knowingly collect personal information from children. If you believe a child has provided data, contact [email protected].

17. Automated decisions

We may use automated checks for fraud, duplicate claims, and security. We do not make solely automated decisions with legal or similarly significant effects without human review where required by law.

18. Changes

We may update this Policy. We will post the new version with effective date and provide notice for material changes where required.

19. Contact

Privacy enquiries: [email protected]. Legal: [email protected]. Huntos Corporation (in formation), Founder Michael Smith, intended jurisdiction New Zealand.

Contact

Questions about this document: [email protected]. Privacy matters: [email protected].