Privacy Policy

Effective Date: February 5, 2026

Last Updated: February 24, 2026

Introduction

Rooster Chicken LLC, doing business as Daily Hue ("we," "us," or "our"), operates the Daily Hue mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your personal information when you use our App and related services (collectively, the "Services").

We are committed to protecting your privacy and handling your data in an open and transparent manner. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use the Services.

If you have questions or concerns about this Privacy Policy, please contact us at the address provided in Section 14 ("Contact Us") below.

Table of Contents

1. Information We Collect
2. How We Collect Information
3. How We Use Your Information
4. How We Share Your Information
5. Data Retention
6. Data Security
7. Your Privacy Rights
8. International Data Transfers
9. Children's Privacy
10. Third-Party Links and Services
11. Your Choices and Controls
12. Changes to This Privacy Policy
13. Additional Disclosures for Specific Jurisdictions
14. Contact Us

1. Information We Collect

We collect the following categories of personal information in connection with the Services:

1.1 Information You Provide Directly

1.2 Information Collected with Your Permission

1.3 Information Collected Automatically

1.4 Information We Derive

2. How We Collect Information

We collect information through the following methods:

• Account Registration: When you create an account, you provide your phone number for SMS verification, and your display name during onboarding.
• Profile Setup and Editing: When you customize your profile by adding or updating your username, bio, or avatar.
• App Usage: When you capture photos, complete grids, add captions, post reactions, write comments, or interact with other users' content.
• Device Permissions: When you grant access to your contacts, camera, photo library, location, or push notifications through your device's native permission dialogs. Each permission is requested individually and can be revoked at any time through your device settings.
• Automated Collection: Analytics and usage data are collected automatically as you use the Services through our analytics service provider's SDK integrated into the App. Crash reports and diagnostic data are collected automatically through our error monitoring service to help us identify and fix issues.

We may integrate additional third-party tools and services as the App evolves. Any new categories of data collection will be reflected in updates to this Privacy Policy.

• Invitations: When you choose to invite contacts to join Daily Hue via SMS, we store the invited phone number to track whether the invitation has been accepted.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Providing and Operating the Services

• Authenticating your identity and maintaining your account session
• Enabling you to create and share daily color grids
• Displaying your profile information to other users
• Delivering your content (grids, reactions, comments) to your followers
• Matching your contacts to existing users to facilitate friend discovery
• Processing and displaying social interactions (follows, reactions, comments)
• Sending push notifications you have opted into
• Calculating and displaying streaks, scores, and leaderboards
• Displaying your optional location tag on your posted grid, visible to users who can view your
  grid

3.2 Improving and Personalizing the Services

• Analyzing usage patterns to improve app features and user experience
• Personalizing your feed based on your social connections and engagement patterns
• Identifying and fixing bugs, errors, and performance issues

3.3 Safety, Security, and Compliance

• Detecting and preventing fraud, abuse, and violations of our terms of service
• Processing content reports and enforcing our community guidelines
• Complying with applicable legal obligations

3.4 Communications

• Sending service-related communications (e.g., security alerts, account verification)
• Delivering push notifications for social activity, daily prompts, and reminders (where you have opted in)

3.5 Social Features and Profile Visibility

The Services include social features that make certain information visible to other users. When you use the Services, the following information may be visible to other users depending on your privacy settings:

• Public Profile Information: Your display name, username, profile photo, bio, Hue Score, streak count, follower count, and following count are visible to other users who view your profile.
• Content You Post: Photos, grids, captions, and associated scores that you post through the Services are visible to your followers and, depending on your privacy settings, may be visible to all users of the Services.
• Social Activity: Your reactions (e.g., fire, thumbs up), comments, and other social interactions with other users' content may be visible to those users and, in some cases, to other users of the Services.
• Friend Connections: Your follower and following lists may be visible to other users.

You acknowledge that any information you make available through the social features of the Services may be viewed, collected, or used by other users. We are not responsible for the actions of other users with respect to your publicly available information. You should exercise caution in deciding what information you share through the Services.

4. How We Share Your Information

4.1 With Other Users

By using the Services, certain information is visible to other users:

• Public Profile Information: Your username, display name, avatar, bio, Hue Score, streak count, grid count, and follower/following counts are visible to other users.
• Grid Content:  Your completed grids (photos, captions, scores, grades, and optional location tag) are visible to your followers.If your account is set to private, only users you approve as followers may view your grids.
• Social Interactions: Your reactions and comments on others' grids are visible to users who can view that grid. Your follower and following lists are visible to users who can view your profile.
• Leaderboard: If you complete a grid, your username, display name, avatar, score, grade, and streak may appear on the daily leaderboard visible to other users.
• Search: Your username and display name are searchable by other users within the App.

4.2 With Service Providers

We share information with third-party service providers who perform services on our behalf, subject to contractual obligations to protect your information. Our current providers are listed below. We reserve the right to change, add, or remove service providers at any time without prior notice to you, provided that any new providers are subject to equivalent data protection obligations. This Privacy Policy will be updated periodically to reflect material changes to our provider relationships.

4.3 Social Sharing

When you choose to share your completed grid to external platforms (such as Instagram Stories or other apps via your device's native share sheet), the shared image is generated locally on your device and passed to the selected application. We do not control the privacy practices of these third-party platforms. This sharing is initiated entirely by you and only occurs when you explicitly tap the share function.

4.4 Legal and Safety Disclosures

We may disclose your information if we believe in good faith that such disclosure is necessary to:

• Comply with applicable law, regulation, legal process, or governmental request
• Enforce our terms of service or other agreements
• Protect the rights, property, or safety of Daily Hue, our users, or the public
• Detect, prevent, or address fraud, security, or technical issues

4.5 Content Safety and Legal Compliance

In compliance with applicable federal and state law, including the TAKE IT DOWN
Act, we may preserve, produce, or disclose User Content and associated account
information (including but not limited to IP addresses, device identifiers,
timestamps, and account metadata) in the following circumstances:

(a) In response to a valid removal request for nonconsensual intimate visual
depictions under Section 17A of our Terms of Service;

(b) When we have a good faith belief that preservation or disclosure is necessary
to comply with applicable law, regulation, legal process, or enforceable
governmental request;

(c) To protect the safety, rights, or property of Daily Hue, our users, or the
public;

(d) To detect, prevent, or otherwise address fraud, security, or technical
issues;

(e) In cooperation with law enforcement investigations related to content that
may violate federal or state criminal law.

We may retain records of removal requests and associated content for a reasonable
period to comply with legal obligations and to enforce our Terms of Service,
even after the content has been removed from public view.

4.6 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. In such event, we will update this Privacy Policy to reflect any changes in ownership or data practices.

4.7 No Sale of Personal Information

We do not sell your personal information to third parties. We do not share your personal information with third parties for their direct marketing purposes.

5. Data Retention

5.1 General Retention Practices

We retain your personal information for as long as your account is active or as needed to provide the Services. Specific retention practices are as follows:

5.2 Deletion of Specific Content

You may delete individual grid photos or entire grids at any time through the App. When you delete a photo or grid, the associated image files are permanently removed from our storage systems and the corresponding database records are deleted. This deletion is irreversible.

5.3 Account Deletion

You may delete your account directly within the App through your profile settings. Upon deletion, we will delete or de-identify your personal information within thirty (30) days, except where we are required to retain certain information for legitimate business purposes or to comply with legal obligations (e.g., fraud prevention, dispute resolution, regulatory requirements).

When your account is deleted:

• Your profile, grids, photos, reactions, comments, and social connections will be permanently removed.
• Content that other users have independently saved or shared (e.g., screenshots) is outside our control and will not be affected.
• Certain anonymized or aggregated data that cannot reasonably be used to identify you may be retained.

6. Data Security

We implement commercially reasonable technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption in Transit: All data transmitted between the App and our servers is encrypted using HTTPS/TLS.
• Phone Number Hashing: Phone numbers are irreversibly hashed using HMAC-SHA256 with a versioned secret key before storage. Raw phone numbers are not retained in user profiles.
• Access Controls: Our database employs row-level security policies that restrict data access based on user identity and relationships.
• Signed URLs: Photo content is served through time-limited signed URLs that expire after a short period, preventing unauthorized persistent access to media files.
• Session Management: Authentication tokens have defined expiration periods and can be invalidated upon sign-out.
• Secure Credential Storage: Authentication credentials and session tokens are stored in your device's secure local storage.

While we strive to protect your personal information, no method of electronic storage or transmission over the Internet is 100% secure. We cannot guarantee absolute security, and you use the Services at your own risk.

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

7.1 General Rights

• Access: You may request a copy of the personal information we hold about you.
• Correction: You may update or correct inaccurate personal information through your profile settings in the App, or by contacting us.
• Deletion: You may request deletion of your personal information, subject to certain legal exceptions. See Section 5.3 for details.
• Data Portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Withdrawal of Consent: Where processing is based on your consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.
• Objection: You may object to the processing of your personal information in certain circumstances.
• Restriction: You may request restriction of processing of your personal information in certain circumstances.

7.2 Exercising Your Rights

To exercise any of these rights, you may use the relevant controls within the App (such as profile editing, content deletion, or account deletion in your settings) or contact us using the information in Section 14 ("Contact Us") for requests that cannot be completed in-app. We will respond to your request within the timeframe required by applicable law (typically 30 to 45 days). We may need to verify your identity before processing your request.

7.3 Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not deny you the Services, charge different prices, provide a different level of service, or otherwise retaliate against you for exercising your rights.

8. International Data Transfers

Your personal information may be transferred to, stored in, and processed in countries other than the country in which you reside. Our service providers, including our cloud infrastructure, database, and analytics providers, may operate servers in the United States and other jurisdictions.

If you are located in the European Economic Area ("EEA"), the United Kingdom ("UK"), or Switzerland, we ensure that transfers of personal information to countries outside these areas are subject to appropriate safeguards, which may include:

• Standard Contractual Clauses approved by the European Commission
• The service provider's participation in recognized data transfer frameworks
• Other legally recognized transfer mechanisms

By using the Services, you acknowledge that your information may be transferred to and processed in jurisdictions that may not provide the same level of data protection as your home jurisdiction.

9. Children's Privacy

The Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. In jurisdictions where a higher minimum age applies (such as 16 in the EEA and UK), the Services are not directed to users below that age.

If we become aware that we have collected personal information from a child under the applicable minimum age without verified parental consent, we will take prompt steps to delete that information. If you believe we have inadvertently collected information from a child under the applicable age threshold, please contact us immediately using the information in Section 14 ("Contact Us").

Parents or guardians who believe their child has provided us with personal information may contact us to request access to, correction of, or deletion of that information.

10. Third-Party Links and Services

The Services may contain features that enable you to share content to third-party platforms (such as social media applications) or may include links to third-party websites or services. This Privacy Policy does not apply to any third-party services. We are not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Services.

11. Your Choices and Controls

11.1 Account Privacy

You may set your account to private in the App settings. When your account is private, only users you approve as followers may view your grids and detailed profile information.

11.2 Push Notification Preferences

You may enable or disable specific categories of push notifications within the App settings, including:

• Daily color of the day alerts
• Follow requests and new followers
• Reactions on your grids
• Comments on your grids
• Streak reminders

You may also disable all push notifications at the device level through your operating system's notification settings.

11.3 Contact Access

You may revoke the App's access to your device contacts at any time through your device's system settings. Revoking contact access will prevent the App from reading your contacts for friend discovery. Contact hashes previously uploaded to our servers will be retained as described in Section 5.1.

11.4 Camera and Photo Library Access

You may revoke the App's access to your camera or photo library at any time through your device's system settings. Revoking these permissions will prevent you from capturing or selecting new photos for your grids and profile.

11.5 Location Access

You may revoke the App's access to your device location at any time through your device's system settings. Revoking location access will prevent the App from detecting your city for grid
tagging. Location tags previously saved to grids will be retained unless you delete those grids.
You may also choose not to add a location tag on any individual grid — location tagging is always optional.

11.6 Content Deletion

You may delete individual photos from a grid, entire grids, or your reactions at any time within the App. Deleted photos and grids are permanently removed from our storage systems.

11.7 Profile Editing

You may update your display name, username, bio, and avatar at any time through the App settings.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Privacy Policy
• Provide notice through the App (such as an in-app notification or banner)
• Where required by law, obtain your consent to the changes

We encourage you to review this Privacy Policy periodically for the latest information on our privacy practices.

13. Additional Disclosures for Specific Jurisdictions

13.1 For Residents of the European Economic Area, United Kingdom, and Switzerland (GDPR)

If you reside in the EEA, UK, or Switzerland, the following additional provisions apply:

Legal Bases for Processing

We process your personal information on the following legal bases under the General Data Protection Regulation ("GDPR") and the UK GDPR:

Data Controller

Rooster Chicken LLC (doing business as Daily Hue) is the data controller responsible for your personal information processed in connection with the Services.

Representative

If you are located in the EEA or UK and we are required to appoint a representative under applicable data protection law, details of our representative will be published on our website or made available upon request.

Privacy Contact

We have not appointed a Data Protection Officer as we do not meet the thresholds requiring one under GDPR. For privacy-related inquiries, please contact us using the information in Section 14 ("Contact Us").

Right to Lodge a Complaint

If you are located in the EEA or UK, you have the right to lodge a complaint with your local data protection supervisory authority if you believe that our processing of your personal information violates applicable data protection law. You can find your supervisory authority at:

• EEA: https://edpb.europa.eu/about-edpb/about-edpb/members_en
• UK: https://ico.org.uk/

Data Retention Under GDPR

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When personal information is no longer necessary, we will delete or anonymize it.

13.2 For Residents of California (CCPA/CPRA)

If you are a California resident, the following additional provisions apply under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"):

Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

Categories of Personal Information Disclosed for a Business Purpose

In the preceding 12 months, we have disclosed the following categories of personal information to service providers for business purposes:

• Identifiers (to cloud infrastructure, SMS verification, push notification, analytics, error monitoring, and hosting service providers)
• Internet or similar network activity (to analytics, error monitoring, and hosting service providers)
• Audio, electronic, visual, or similar information (to cloud infrastructure service providers for storage)
• Personal information from contacts (to cloud infrastructure service providers for friend matching and discovery)
• Geolocation data (to cloud infrastructure service providers for storage and display)

No Sale or Sharing of Personal Information

We have not sold any personal information in the preceding 12 months, and we do not sell personal information. We have not shared personal information for cross-context behavioral advertising purposes.

Your California Privacy Rights

As a California resident, you have the right to:

• Know what personal information we collect, use, disclose, and sell
• Delete your personal information, subject to certain exceptions
• Correct inaccurate personal information
• Opt out of sale or sharing (not applicable, as we do not sell or share personal information)
• Non-discrimination for exercising your CCPA rights
• Limit use of sensitive personal information to purposes necessary for providing the Services

To exercise these rights, please contact us using the information in Section 14 ("Contact Us"). We will verify your identity by confirming your phone number or other account information before processing your request.

You may also designate an authorized agent to submit requests on your behalf. Authorized agents must provide written permission from the consumer and may be required to verify their own identity.

Sensitive Personal Information

Under the CPRA, phone numbers may be considered sensitive personal information. We use phone numbers solely for account verification and friend discovery (via hashing), which are purposes necessary to perform the Services you request. We do not use sensitive personal information for purposes beyond what is necessary to provide the Services.

13.3 For Residents of Other U.S. States

Several other U.S. states have enacted comprehensive privacy laws, including Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), and others. If you reside in one of these states, you generally have rights to:

• Access your personal information
• Correct inaccuracies
• Delete your personal information
• Obtain a portable copy of your data
• Opt out of targeted advertising, sale of personal data, or profiling (where applicable)

We do not engage in the sale of personal data or targeted advertising as defined under these laws. To exercise your rights, please contact us using the information in Section 14 ("Contact Us"). If your request is denied, you may have the right to appeal. Appeals can be submitted by contacting us, and we will respond within the legally required timeframe.

11.7 Tracking and Advertising

We do not track you across other companies' apps or websites for advertising purposes, and we do not participate in ad networks. We do not request access to Apple's App Tracking Transparency framework identifier (IDFA).

13.4 Do Not Track Signals

The App is a native mobile application and does not respond to web browser "Do Not Track" signals. For information on controlling analytics and notification preferences, please see Section 11 ("Your Choices and Controls").

13.5 Apple App Store Privacy Details

In accordance with Apple's App Store requirements, we disclose the following data collection practices. For the most current version of our App Store privacy label, please refer to our App Store listing.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Rooster Chicken LLC (d/b/a Daily Hue) Email: hello@dailyhueapp.com Address: 7353 Highland Rd, STE B PMB 1027, Baton Rouge, Louisiana 70808, United States

For data protection inquiries from EEA or UK residents, please include "GDPR Request" in the subject line of your communication.

For California privacy rights requests, please include "CCPA Request" in the subject line.

We will endeavor to respond to all legitimate inquiries within thirty (30) days. If additional time is needed due to the complexity or volume of requests, we will notify you of the extension and the reason therefor.

This Privacy Policy is provided in English. In the event of any conflict between this English version and any translated version, the English version shall prevail.