HOOM's Privacy Policy

Effective Date: June 5, 2026 · Last Updated: June 5, 2026

A note before you begin

This Privacy Policy explains, in plain language, what information HOOM collects about you and your household, how we use it, who we share it with, and the rights you have to control it.

HOOM is built around a single idea: that the data inside your home — how energy flows through it, how money flows around it, how your family lives in it — belongs to you. Our job is to make that data work for you.

If anything in this policy is unclear, contact us at the address in Section 14. We will respond.

1. Who we are

HOOM is a service operated by Assetive Inc., a federal Canadian corporation headquartered in Toronto, Ontario, Canada ("HOOM," "we," "us," or "our"). Assetive Inc. is the data controller responsible for the personal information collected through HOOM.

This Privacy Policy applies to:

• The HOOM website (hoom.unibootsystems.com and any future production domain we operate)
• HOOM's services delivered through WhatsApp and Telegram
• HOOM's autonomous Chief Energy and Financial Officer ("CEFO")
• All related applications, features, and integrations we provide

2. Summary

In one screen, here is what HOOM does with your information:

• We collect your name, contact details, household information, energy and financial data, conversation content with CEFO, and certain technical information about how you use our service.
• We use it solely to deliver HOOM's services to you — operating CEFO, analysing your home's energy and financial performance, providing recommendations, and acting on your behalf only where you have authorised us to do so.
• We share it only with trusted service providers, only when legally required, or only with your explicit consent. We do not sell your personal information.
• We protect it using industry-standard security measures, including encryption, access controls, and regular security audits.
• You control it. You have the right to access, correct, delete, export, and restrict our use of your information at any time.

The full document below explains each of these points in detail.

3. Information we collect

3.1 Information you provide directly

• Identity information: your first name, mobile number, email address, and preferred messaging platform
• Household information: your home address, region, number of people, and family member details
• Energy information: utility bills, tariff structures, energy providers, smart device details, appliance inventory, HVAC and EV details
• Financial information: household energy spending, payment information, and any financial context you share with CEFO
• Conversational content: messages, voice notes, photos, documents, and any communication you exchange with CEFO
• Preferences and goals: household rhythms, savings targets, comfort preferences, sustainability goals

3.2 Information collected automatically

• Device and technical information: IP address, device type, browser type, operating system, language settings, time zone
• Usage information: pages visited, links clicked, forms submitted, time spent on the service
• Approximate location: derived from your IP address
• Cookies and similar technologies: see Section 10

3.3 Information we generate about you

As CEFO learns your home, we generate insights, predictions, behavioural patterns, energy models, and financial projections specific to your household. This derived data is your personal information and we treat it with the same care as information you provide directly.

3.4 Information from third parties

• Utility providers (when you connect your utility account)
• Smart device platforms (when you connect smart devices)
• Payment processors (for HOOM service fees, where applicable)
• Public data sources (weather, grid load, and tariff databases used to enrich CEFO's intelligence)

4. How we use your information

We use your information only for the purposes described below.

4.1 To deliver HOOM's services

This includes operating CEFO, analysing your household's energy and financial data, generating recommendations, executing actions you have pre-authorised, processing payments, and providing customer support.

4.2 To communicate with you

We use your contact details to deliver CEFO messages, respond to inquiries, send service updates, and provide administrative notices about your account or material changes to our service.

4.3 To improve HOOM

We analyse aggregated, de-identified usage patterns to improve our service and refine CEFO's intelligence. Where we use individual data for service improvement, we do so only with your consent or under a legal basis that respects your rights.

4.4 To ensure security and prevent abuse

We use technical and behavioural signals to detect fraud, prevent unauthorised access, protect our infrastructure, and safeguard our users.

4.5 To comply with legal obligations

We process your information where required by law, including responding to lawful requests from authorities, fulfilling tax and accounting obligations, and complying with regulatory requirements.

4.6 What we do not do

• Selling to third parties
• Targeted advertising
• Training third-party AI models without your explicit, informed consent
• Profiling for purposes unrelated to HOOM's service
• Sharing with data brokers

5. Autonomous AI & automated decision-making

HOOM's CEFO is an autonomous intelligence system. This section explains, with the transparency required by modern privacy law (including EU GDPR, EU AI Act, California's CCPA/CPRA, and Canadian PIPEDA), how CEFO operates and what rights you have.

5.1 How CEFO works

• Large language models (Anthropic/Claude, Google/Gemini, DeepSeek, Alibaba/Qwen) for conversational understanding and voice generation
• Mathematical and statistical models built by HOOM for energy analysis, financial modelling, and household optimisation
• Real-time data from your home and from external sources including weather, grid load, and tariff databases
• Your household's historical context, which CEFO learns over time

5.2 What CEFO may decide or recommend

• Recommend changes to your energy usage patterns
• Predict your bills and identify savings opportunities
• Flag anomalies in your home's energy or financial behaviour
• Initiate pre-authorised actions such as adjusting smart devices or scheduling appliance usage
• Communicate with you proactively about decisions relevant to your home

5.3 Your rights regarding CEFO

• Understand how decisions affecting you are made
• Request human review of any significant decision CEFO has made
• Object to fully automated decision-making in specific cases
• Withdraw consent for automated processing at any time
• Receive an explanation of CEFO's reasoning in plain language

5.4 AI training and your data

We do not use your individual conversations, household data, or financial information to train third-party AI models. Where we use de-identified, aggregated patterns to improve HOOM's own intelligence, we do so under privacy-preserving principles. You may opt out of this at any time.

5.5 Limits and oversight

CEFO operates within boundaries set by HOOM's engineering, ethical, and legal frameworks. It does not provide regulated financial, legal, or energy advice. Human oversight is built into our systems for high-impact decisions, security events, and edge cases.

6. How we share your information

6.1 With service providers

• Infrastructure and hosting (Hetzner)
• Messaging platforms (WhatsApp Business via Meta; Telegram via Telegram Messenger Inc.)
• AI model providers (Anthropic, Google, DeepSeek, Alibaba)
• Form intake and lead capture (Formspark) for non-consumer waitlist forms
• Analytics (Google Analytics 4) for anonymised website usage
• Payment processing (Stripe) for HOOM service fees where applicable

6.2 With legal authorities

We may share your information when required by law, court order, valid government request, or to protect our rights, property, or safety.

6.3 In a business transfer

If HOOM is involved in a merger, acquisition, or sale, your information may be transferred as part of that transaction. We will notify you in advance and offer you meaningful choices.

6.4 With your explicit consent

We may share your information for purposes not covered above only with your prior, explicit consent.

6.5 We do not sell your personal information

Under no circumstances do we sell your personal information for monetary or other valuable consideration. This is a core commitment, not a marketing claim.

7. International data transfers

HOOM operates from Canada and serves users in Canada, the EU, Switzerland, the UK, the United States, and other regions. Your information may be transferred to, stored in, or processed in jurisdictions outside your country of residence. When we transfer your information internationally, we use safeguards including:

• Standard Contractual Clauses for transfers out of the European Economic Area and the United Kingdom
• Adequacy decisions where applicable (such as for transfers between the EU and Canada or Switzerland)
• Our own technical and organisational measures to protect your data regardless of where it is processed

8. How long we keep your information

We retain your information for as long as you have an active relationship with HOOM, plus the period required to comply with legal obligations, resolve disputes, and enforce our agreements.

• Account and household data: retained while you use HOOM and for up to 24 months after account closure
• Conversation history with CEFO: retained for the duration of your account; you may request deletion at any time
• Financial and payment records: retained for the period required by Canadian and applicable tax and accounting law (typically 6–7 years)
• Aggregated, de-identified data: may be retained indefinitely for service improvement
• Security and audit logs: retained for up to 90 days under normal circumstances, longer if a security incident is under investigation

You may request earlier deletion at any time (see Section 9).

9. Your rights and choices

Depending on your jurisdiction, you have the following rights:

• Access — request a copy of the personal information we hold about you
• Correction — request that we correct inaccurate or incomplete information
• Deletion — request that we delete your personal information ("right to be forgotten")
• Portability — receive your information in a structured, commonly used, machine-readable format
• Restriction — request that we limit how we process your information
• Objection — object to specific types of processing, including direct marketing and certain automated decision-making
• Withdrawal of consent — withdraw consent at any time where processing is based on consent
• Complaint — lodge a complaint with a data protection authority

To exercise any of these rights, contact us at hoom@unibootsystems.com. We will respond within 30 days and will not discriminate against you for exercising any of these rights.

Region-specific rights

• EU / EEA / UK: Under GDPR and UK GDPR, you may lodge a complaint with your national supervisory authority.
• California, US: Under CCPA/CPRA, you have the right to know, delete, correct, opt out of sale or sharing, limit use of sensitive personal information, and non-discrimination.
• Canada: Under PIPEDA and applicable provincial privacy laws, you may file a complaint with the Office of the Privacy Commissioner of Canada.
• Switzerland: Under the revised nFADP, you have rights substantially similar to those under the GDPR.
• Other jurisdictions: Residents of other jurisdictions may have additional rights under local law. Contact us to exercise them.

10. Cookies and similar technologies

Our website uses cookies and similar technologies for:

• Essential functions — keeping our site secure, functional, and able to remember your preferences
• Analytics — understanding how visitors use our site, primarily through Google Analytics 4 in an anonymised configuration
• Performance — measuring site speed and reliability

You can control cookies through your browser settings. Where required by law, we obtain your consent before placing non-essential cookies.

11. Security

We protect your information using industry-standard technical and organisational measures, including:

• Encryption in transit (TLS) and at rest
• Access controls based on the principle of least privilege
• Multi-factor authentication for systems handling personal data
• Regular security audits and updates
• Incident response procedures with defined escalation paths
• Employee training on data protection and security

No system is perfectly secure. If you believe your account has been compromised, contact us immediately at hoom@unibootsystems.com.

Data breach notification

In the event of a personal data breach, we will notify you and the relevant supervisory authorities as required by applicable law, typically within 72 hours of becoming aware of the breach.

12. Children's privacy

HOOM is intended for adults. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16 without verified parental consent, we will delete it promptly.

If you are a parent or guardian and believe your child has provided us with personal information, contact us at hoom@unibootsystems.com and we will act on your request immediately.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through:

• A clear notice on our website
• A direct message via WhatsApp, Telegram, or email, as appropriate
• The updated "Last Updated" date at the top of this policy

Your continued use of HOOM after changes become effective constitutes acceptance of the updated policy.

14. Contact us

For questions, requests, or concerns about this Privacy Policy:

We will acknowledge your inquiry within 5–7 business days and respond substantively within 30 days.