Reps

Privacy Policy

Effective date: October 13, 2026 · Last updated: October 13, 2026

This Privacy Policy explains how Born Labs, Inc. ("Born Labs," "Reps," "we," "us," or "our"), a Delaware corporation with offices at 183 Madison Ave, Ste 1415, New York, NY 10016, collects, uses, discloses, and protects information in connection with the Reps mobile application, the Reps Strap accessory, the Reps Ultra subscription, the location-sharing program, the Reps Assistant where offered, our websites (including earnreps.com), and related services (together, the "Service"). Reps is a service through which you record everyday activities, complete tasks, and optionally share your location and purchase information, and we compensate you for content that we use — after redaction and de-identification — to develop and license datasets to third parties for training and evaluating artificial-intelligence and robotics systems and for other lawful commercial purposes. Because paying you for content you record is the core of the Service, please read this Policy carefully, in particular Sections 3, 5, 6, and 11.

1. Information We Collect

1.1 Account and identity information

When you create an account we collect your name or display name, mobile phone number (which we verify by SMS through our verification provider, Prelude, which also collects device-integrity signals), country, timezone and language, an avatar if you add one, and, if you use Sign in with Apple or email sign-in, the identifier, email address or password hash involved. We assign you a permanent member number. The app may ask for an age bracket and gender for task matching, and a one-time confirmation that you are 21 or older before age-restricted tasks. If you order a Strap, we collect your shipping address and recipient name. If you set up payouts, our payment processor collects your date of birth and other information required for identity verification ("KYC") under applicable financial regulations (see Section 1.4). If an organization opens a business account, we collect the business contact details of its representatives (name, work email, role), the organization's payout information, and the roster of Members it invites.

1.2 Content you record and submit ("Recordings")

The Service exists to collect content that you deliberately choose to create and submit. Depending on the tasks you accept, this may include:

You control what you record. The app instructs you to keep faces, documents, bystanders, and other sensitive subjects out of frame. Video uploads in chunks while you record so that it is ready to review faster; a take you discard is not used, and a take you leave unsubmitted is submitted automatically about two hours later unless you discard it. Recordings are processed through our redaction pipeline after upload (Section 5), but redaction happens server-side — nothing is blurred or removed on your device before upload, with one exception: for screenshots you select from your gallery, the app detects and blurs personal details on your phone and uploads only the blurred file.

1.3 Biometric-type data contained in Recordings

Recordings may incidentally contain imagery of faces and recordings of voices — yours and, if you do not keep them out of frame, other people's. This data may constitute "biometric identifiers" or "biometric information" under certain laws. Section 3 describes how we handle it. We do not use Recordings to identify individuals, and we do not sell biometric identifiers or biometric information.

1.4 Payment and payout information

Payouts are processed by Stripe through Stripe Connect. When you add a bank account, the raw account numbers are transmitted directly to Stripe and are never stored, returned, or logged by us; we retain only the account-holder name, bank brand, country, and last four digits for display, and we compare the account-holder name with your account and shipping names to prevent fraud. For identity verification you enter your legal name, date of birth and the last four digits of your Social Security number in the app; these are transmitted to Stripe, and we do not retain the full number. We also process the Stripe terms-acceptance record (timestamp and IP address). Stripe collects further identity-verification information as an independent regulated entity; its handling of that data is governed by the Stripe Connected Account Agreement and Stripe's Privacy Policy. We maintain your in-app earnings ledger (including Ultra bonuses, referral, location and quest earnings and any "pockets" you set aside), payout history, and any tax information we are legally required to collect (for example, IRS Form W-9 / Form 1099 information). If you subscribe to Reps Ultra, Apple or Google and our subscription provider RevenueCat process the purchase; we receive your subscription status and renewal dates, never your card number.

1.5 Device, usage, and diagnostics data

1.6 Location

Precise and background location (with your permission). Where the app requests and you grant the iOS location permission, we collect your device's location while you use the app, including at the time you make a Recording, and may associate it with that Recording as metadata — for example to verify task eligibility and authenticity, match you with tasks in your city, detect fraud, and enrich datasets as described in Section 6. If you also turn on the location-sharing program and allow "Always," the app sends your position in the background, roughly every 15 minutes or 200 metres, to our servers. We use these fixes to work out stays of eight minutes or more ("visits"), to label the places you visit using OpenStreetMap data (the coordinates of a place, not your identity, are sent to the OpenStreetMap Overpass service), to classify places as home, work, store or other, to pay you the daily amount shown in the app for each day your phone reports in, and to build the aggregated store-visit trends described in Section 6. Raw fixes and visits are deleted after 90 days; the list of labelled places is kept while your account exists. Brands and partners only ever see trends across many members, never your name, your home address or your individual location history. You can pause sharing in the app or revoke the permission at any time in iOS Settings → Privacy & Security → Location Services; daily payments stop when sharing is off, and the app will function without precise location where feasible. The camera does not geotag your Recordings. Approximate location. Independently of that permission, we infer your approximate country or region from your IP address and the country code of your phone number, for example to operate the international waitlist and to comply with law.

1.7 Referral and waitlist information

If you share or redeem an invite code, we record the referral relationship, the codes involved, and resulting rewards and commissions; the people you refer, and who refer you, see your display name in their activity feed. If you sign up from a country where Reps is not yet available, we place you on a waitlist and process your phone number, country, queue position, and invite activity.

1.8 Communications and community

When you contact support we keep the correspondence, including any screenshot you attach and your app version, device model and OS version. If you join our community spaces (for example, our Discord server), your participation there is also governed by that platform's own terms and privacy policy.

1.9 Receipts and household purchase data

When you submit receipt photos for a task, we extract the store, approximate location (first three digits of the ZIP code), date, totals and currency, payment method and card last four digits, benefit-program indicators printed on the receipt (for example EBT or WIC), a salted hash of any loyalty number, and each printed line item (product, price, quantity). We resolve line items to products, brands and categories using barcode databases, an open food database and AI models that receive only the product text, never the image or your identity. The result is a purchase profile that you can view in the app, that we use for task matching, interview questions and fraud prevention, and that we aggregate into brand and category trends across many members (Section 6).

1.10 Interviews and inferred traits

If you take part in voice or video interviews, we transcribe your answers, reduce them to short facts, and use them, together with your approved submissions, to generate follow-up questions and to infer household traits that help us match you with tasks. Facts are stored in an index that lets us find members with similar answers; the index is used to shape questions and does not expose your identity to other members. Our staff can review your interview data as part of quality control.

1.11 Reps Assistant data (where offered)

If you use the Reps Assistant, we process the goals, role, services and free-text instructions you give it, your chat messages, the "memories" (facts, preferences, goals, subscriptions) it keeps until you delete them, information from your receipts, bills, quests and connected accounts that you let it use, the approval decisions you make, the outcomes it reports, and any mail received at the assistant's own email address or payment activity on a card issued to it. When the assistant asks you to log in to a provider, you type your credentials directly into the provider's page inside a remote session; the assistant does not store your password. Conversations are processed by AI service providers acting on our instructions (Section 7). The chat thread itself is kept in memory on your device and on our servers only as needed to run the assistant.

1.12 Business accounts

If an organization opens a business account, we collect the business contact details of its representatives (name, work email, role), the organization's payout information, its invite codes and the roster of Members, and we record which Member made each Recording under the account.

2. Sources of Information

We collect information (a) directly from you (account setup, Recordings, support requests); (b) automatically from your device (Section 1.5); (c) from service providers acting on our behalf (verification, payments, analytics, attribution, shipping, IP geolocation, product databases, map data); (d) from other users (for example, when someone redeems your invite code); and (e) from the organization you belong to, if you participate under a business account.

3. Biometric Information Policy

This section is provided in light of biometric privacy laws such as the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act, and Washington's biometric privacy law, and applies to the extent any data we process is covered by such laws.

4. How We Use Information

We use the information described above to: provide, maintain, and improve the Service, including matching you with available tasks and quests; review submissions using automated systems (including machine-learning models and AI-assisted tools such as large-language-model services, for example Anthropic's Claude) and human reviewers — including trained personnel of trusted data-annotation and labeling vendors, who view, review, and label Recordings under confidentiality and security obligations — for quality, authenticity (including detection of AI-generated or duplicated content), and compliance with our guidelines; use information about how the Service is used (including the analytics described in Section 1.5) to understand, debug, and improve the app and develop new features; calculate, credit, and pay your earnings (including location, referral, Ultra and quest earnings), operate the wallet, and process withdrawals; check eligibility and detect accounts not operated from a U.S. household; produce aggregated purchase and store-visit insights for brands and other commercial partners from receipt and location data; operate the Reps Assistant at your direction; operate Reps Ultra subscriptions; run the redaction pipeline and prepare redacted, de-identified datasets (Sections 5 and 6); develop, train, evaluate, and improve machine-learning models, other products and services, and related technology, and prepare data products for licensing; detect, investigate, and prevent fraud, abuse, multiple-account schemes, referral manipulation, and security incidents; operate the referral program and international waitlist; send service communications (payout confirmations, shipping updates, review outcomes) and, with your permission, push notifications and marketing communications; measure the performance of our advertising (Section 9); comply with legal obligations, including tax, anti-money-laundering, and sanctions requirements; and establish, exercise, or defend legal claims.

5. Redaction and De-Identification

After you upload a Recording and it is approved, it passes through our server-side redaction pipeline, which is designed to detect and blur or remove faces, license plates, screens, identifiable documents, and other sensitive visual content before the Recording is included in any dataset made available to licensees; the audio track is retained. Review and payment decisions are made before this scan, so our reviewers see unredacted footage. We additionally apply de-identification measures — such as separating Recordings from your account identity and replacing identifiers with pseudonymous codes — before licensing. De-identification is a process, not a guarantee: we maintain technical and contractual safeguards (Section 6) precisely because no automated system is perfect. As part of review, quality control, and dataset preparation, authorized human reviewers and annotators (ours and our vendors') may view Recordings, including before redaction, under confidentiality and access controls. Redaction happens after upload; the unredacted original is retained under restricted access and is permanently deleted within twelve (12) months after review of the Recording is complete, unless a longer period is required for a specific fraud or safety investigation, a legal hold, or applicable law. Unredacted originals are not provided to dataset licensees except where applicable law permits it and the recipient is bound by contractual restrictions at least as protective as those in Section 6; we never sell or disclose biometric identifiers or biometric information in violation of applicable biometric privacy laws.

6. Dataset Licensing — and Your Opt-Out

Our business is building high-quality, consented datasets of everyday human activity and licensing them to third parties of all kinds — including AI research labs, robotics companies, technology companies, research institutions, and other enterprises and commercial partners — to train, evaluate, and improve machine-learning systems and for other lawful business purposes. What we license consists of redacted, de-identified Recordings and associated sensor and task metadata (which may include recording-time location where you granted the iOS location permission). We do not license your name, phone number, contact details, payment information, or account credentials, and we do not sell biometric identifiers or biometric information.

Brand and purchase insights. Separately from datasets, we use receipt and location data to produce aggregated purchase and store-visit trends (for example how often members in a region buy a brand or visit a chain) that we may provide to brands and other commercial partners. These insights are aggregated across many members and never include your name, contact details, receipts or location history.

Every dataset license we grant contractually requires the licensee to (a) refrain from attempting to identify or re-identify any individual, (b) use the data only for the purposes permitted by their license, (c) maintain appropriate security measures, (d) promptly notify us of, and delete or return, any Content discovered to contain residual personal information that should have been redacted, and (e) flow these restrictions down to any permitted sub-recipients.

"Sale" and "sharing" under U.S. state privacy laws. Some state privacy laws define "sale" or "sharing" of personal information broadly enough that licensing de-identified or redacted Recordings could be treated as a sale if any element of the data were deemed personal information. Out of caution, we treat dataset licensing as a potential "sale" for purposes of those laws and give you an opt-out: use the "Do Not Sell or Share My Personal Information" link on this website, which explains how to submit your request by email to support@earnreps.com. We also honor Global Privacy Control signals where required by law, and once the dedicated control ships in the app you will also be able to opt out there. If you opt out, your future Recordings will not be included in newly licensed datasets; note that because paid tasks fund the Service through dataset licensing, opting out may make you ineligible for some or all paid tasks (see the Notice of Financial Incentive in Section 11.4). We do not knowingly sell or share the personal information of anyone under 18.

7. How We Disclose Information

We disclose information to the following categories of recipients, for the purposes described in this Policy:

We do not disclose your phone number or contact details to other users. Users who refer you or whom you refer see only referral status, never your contact information.

8. Website Data

Our websites are informational. We use hosting-level logs and privacy-respecting aggregate analytics to operate them. We honor the Global Privacy Control (GPC) signal on our websites where required by law. Our websites are not directed at children.

9. Advertising, Attribution, and Tracking

We advertise Reps on platforms such as Meta and TikTok and measure those campaigns with AppsFlyer and Apple's SKAdNetwork. On iOS, we will only access the advertising identifier (IDFA) if you allow it through Apple's App Tracking Transparency prompt; if you decline, campaign measurement relies on Apple's privacy-preserving SKAdNetwork postbacks, which are aggregated and do not identify you. You can change your choice at any time in iOS Settings → Privacy & Security → Tracking. We do not display third-party ads inside the Reps app, and we do not use your Recordings for advertising.

10. Your Choices and Controls

11. U.S. State Privacy Rights

11.1 Your rights

Depending on your state of residence (including California, Colorado, Connecticut, Delaware, Montana, New Jersey, Oregon, Texas, Utah, Virginia, and others), you may have the right to: know/access the personal information we hold about you; correct inaccurate personal information; delete personal information; obtain a portable copy; opt out of "sale," "sharing," and targeted advertising; limit the use of sensitive personal information; and not be discriminated against for exercising these rights (subject to the financial-incentive terms below).

11.2 How to exercise them

Email support@earnreps.com with the right you wish to exercise, or use the in-app controls. We will verify your request using your account phone number or other reasonable means, respond within the time required by your state's law, and will not require you to create additional accounts. You may use an authorized agent with written proof of authority. If we deny a request, you may appeal by replying to our decision; we will explain the outcome of the appeal and, where applicable, how to contact your state attorney general.

11.3 California disclosures

In the preceding 12 months we collected the categories of personal information described in Section 1 (identifiers; customer records; commercial information; audio/visual/sensory information; internet and app activity; approximate geolocation inferred from IP; precise geolocation where you grant the iOS location permission; commercial information including purchases extracted from receipts; sensitive personal information you choose to submit in tasks, such as health-related products, medications, financial, insurance and benefit-program information, and precise geolocation; and inferences for task matching, household traits and fraud prevention), from the sources in Section 2, for the purposes in Section 4, and disclosed them as described in Section 7. We treat dataset licensing as a potential "sale" as described in Section 6; we do not otherwise sell personal information for money, and we do not knowingly sell or share personal information of consumers under 18. Where we collect sensitive personal information (such as precise geolocation with your permission), you may exercise the right to limit its use and disclosure as described in Section 11.2, to the extent that right applies. California's "Shine the Light" requests may be sent to the same email address.

11.4 Notice of Financial Incentive

The Service itself is a financial-incentive program: we pay you money for Recordings, task submissions, receipts and interviews, for sharing your location (a daily amount), and for referrals, which fund the Service through dataset licensing and aggregated insights. The material terms — which tasks are available, what each pays, the daily location amount, and the review criteria — are shown in the app before you accept any task or turn on sharing. You opt in by accepting a task or turning on location sharing and can withdraw at any time by not accepting further tasks, pausing location sharing, opting out of dataset licensing (Section 6), or deleting your account. We value the data at the amount we pay for it: our good-faith estimate of the value of your data is the compensation shown for each task, which is reasonably related to the licensing value we expect the data to have.

12. Data Retention

13. Children

The Service is for adults. You must be at least 18 years old to create an account. We do not knowingly collect personal information from anyone under 18, and we do not knowingly allow minors to appear in Recordings; the in-app terms require you to keep other people out of your submissions unless they have consented, and minors cannot consent for these purposes. If you believe a person under 18 has provided us personal information or appears in a Recording, contact support@earnreps.com and we will delete the data.

14. International Users and Data Transfers

Reps is currently offered in the United States, in English and Spanish, and our services are hosted in the United States (AWS, us-east-1). Payouts can be sent to bank accounts in some other countries and currencies (Section 1.4). If you join the international waitlist, we process the information in Section 1.7 to manage the queue and notify you if Reps opens in your country. If you are in the European Economic Area, the United Kingdom, or Switzerland, our legal bases are: performance of a contract (operating the waitlist you joined), consent (marketing and any optional processing), and legitimate interests (security and service analytics). You have the rights of access, rectification, erasure, restriction, portability, and objection, the right to withdraw consent at any time, and the right to lodge a complaint with your supervisory authority. Where we transfer data from these regions to the United States, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses.

15. Security

We protect information using encryption in transit and at rest, access-controlled storage, secrets kept in your device's secure enclave/keychain for local credentials, least-privilege internal access, and contractual security obligations for all processors and licensees. No method of transmission or storage is completely secure; if we learn of a breach affecting your personal information, we will notify you and regulators as required by law. Please report suspected vulnerabilities to support@earnreps.com.

16. Automated Decision-Making

We use automated systems as part of reviewing Submissions (for example, to detect AI-generated, duplicated, or non-compliant content, to check photo provenance, and, for some tasks, to accept or reject without human review), to detect fraud and multiple-account abuse, to compute a contributor quality score that can affect the tasks and rates offered to you, to check each time the app opens that an account appears to be operated from a U.S. household and to block accounts that do not (such a block can be permanent until a person reviews it), to choose the timing and content of reminders, and to route work to human reviewers. Some support replies are automated templates; you can always ask for a person. Actions the Reps Assistant takes with third parties are shown to you for approval first. Decisions with significant effects on you — such as rejecting a body of work, withholding a payout, or suspending an account — are made or reviewed with human involvement, and you may contest such a decision by contacting support@earnreps.com. Where the law of your state or country gives you rights regarding profiling or automated decision-making, you may exercise them the same way. We do not use automated decision-making to determine eligibility for credit, insurance, housing, or employment.

17. Communications, Text Messages, and Do Not Track

Text messages. We send one-time passcodes by SMS to verify your phone number, and we may send transactional texts about your account, payouts, or shipments. Message and data rates may apply; message frequency varies. We will not send you marketing text messages without your prior express written consent. Reply STOP to opt out of non-essential texts (verification codes required to access your account may still be sent when you request them) and HELP or email support@earnreps.com for help. Consent to marketing texts is never a condition of using the Service.

Email and push. Service emails and pushes are described in Sections 4 and 10. Reminder pushes are capped per week, sent at most once per day, and paused during night hours. Marketing emails always contain an unsubscribe link.

Do Not Track. Because there is no common standard for browser "Do Not Track" signals, our websites do not respond to DNT. We do honor the Global Privacy Control (GPC) as described in Section 8.

18. Third-Party Links and Services

The Service and our websites may link to third-party sites and services (for example, Stripe, Discord, carrier tracking pages, or the App Store). This Policy does not apply to them, and we are not responsible for their privacy practices. Review the privacy policy of any third-party service you use.

19. Additional State Notices

Nevada. We do not sell "covered information" of Nevada consumers for money as defined by Nevada law. Nevada residents may nonetheless submit an opt-out request to support@earnreps.com, which we will honor if our practices change.

Removal of content by users under 18. The Service is limited to adults; if, despite our controls, a person under 18 has posted content, California law (Business & Professions Code § 22581) and similar laws entitle them to request removal — contact support@earnreps.com and we will remove the content and delete the account.

Notification of security breaches. Where required by state breach-notification laws, we will notify affected users by email, SMS, or in-app notice without unreasonable delay.

20. Changes to This Policy

We may update this Policy from time to time. If we make material changes — in particular to how Recordings are used or licensed — we will notify you in the app or by other prominent means and, where required by law, obtain your consent before the change applies to previously collected information. The "Last updated" date above reflects the current version.

Contact us.
Born Labs, Inc.
183 Madison Ave, Ste 1415
New York, NY 10016, USA
support@earnreps.com