Privacy Policy
1. Information We Collect
1.1 Account and identity information
When you create an account we collect your name, mobile phone number (which we verify by SMS through our verification provider), country, and, if you use Sign in with Apple, the identifier and email address Apple provides. If you order a Strap, we collect your shipping address. 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).
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:
- first-person (egocentric) video and audio recordings captured with your phone, including while mounted in the Reps Strap;
- voice recordings you make in response to prompts;
- photos and videos you capture or select from your camera roll, which may depict your home, belongings, appliances, documents, surroundings, errands, or city;
- written or spoken responses, opinions, and other task submissions; and
- metadata associated with each submission, such as date, time, duration, device orientation and motion-sensor readings captured during recording, task identifiers, and the version of the consent terms you accepted at the moment of upload.
You control what you record. The app instructs you to keep faces, documents, bystanders, and other sensitive subjects out of frame. 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.
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. Stripe collects identity-verification information (including your date of birth) 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, payout history, and any tax information we are legally required to collect (for example, IRS Form W-9 / Form 1099 information).
1.5 Device, usage, and diagnostics data
- Device data: device model, operating system and version, app version, language, time zone, IP address, battery level, network state, push notification token, and device identifiers (the resettable advertising identifier (IDFA) only if you grant permission through Apple's App Tracking Transparency prompt; otherwise the vendor identifier (IDFV)).
- Usage analytics: in-app events, screens viewed, funnels, and feature usage, collected through Mixpanel.
- Session replay: reconstructions of how you navigate app screens (touches, screens, UI state), collected through Smartlook to diagnose usability problems. Payment fields and sensitive inputs are masked to the extent supported by the tool.
- Crash and performance data: crash logs and diagnostics, collected through Sentry.
- Install attribution: the campaign or link that led you to install the app, collected through AppsFlyer and Apple's SKAdNetwork framework (Section 9).
1.6 Location
The Reps app does not request or collect GPS or other precise location data. We may 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. 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. 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.
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); and (d) from other users (for example, when someone redeems your invite code).
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.
- Purpose. Face imagery and voice audio contained in Recordings are processed solely to (i) operate the Service, including reviewing submissions, (ii) run our redaction pipeline, which detects faces and other sensitive regions in order to blur or remove them, and (iii) prepare redacted, de-identified datasets as described in Sections 5 and 6. We do not use biometric data to identify you or anyone else, and we do not build face or voice recognition profiles of individuals.
- Consent. You provide consent when you accept the recording terms presented in the app before submitting content. Do not submit content containing another person without first obtaining that person's consent — the in-app terms require you to confirm this for every upload.
- No sale. We do not sell, lease, or trade biometric identifiers or biometric information, and we contractually prohibit dataset licensees from attempting to re-identify individuals (Section 6).
- Retention and destruction. We permanently destroy biometric identifiers and biometric information when the initial purpose for collecting them has been satisfied, and in any event within three (3) years of your last interaction with the Service, whichever occurs first, unless a longer period is required by law, legal hold, or court order. Redacted data from which biometric identifiers have been removed is not subject to this schedule.
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 and human reviewers for quality, authenticity (including detection of AI-generated or duplicated content), and compliance with our guidelines;
- calculate, credit, and pay your earnings, operate the wallet, and process withdrawals;
- run the redaction pipeline and prepare redacted, de-identified datasets (Sections 5 and 6);
- develop, train, evaluate, and improve machine-learning models and related technology;
- 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, it passes through our server-side redaction pipeline, which is designed to detect and blur or remove faces, identifiable documents, and other sensitive visual content before the Recording is included in any dataset made available to licensees. 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. Redaction happens after upload; the unredacted original is retained under access controls for as long as needed for review, safety, and legal purposes, and is not provided to dataset licensees.
6. Dataset Licensing — and Your Opt-Out
Our business is building high-quality, consented datasets of everyday human activity and licensing them to carefully selected third parties — such as AI research labs, robotics companies, and enterprises — to train, evaluate, and improve machine-learning systems. What we license consists of redacted, de-identified Recordings and associated sensor and task metadata. 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.
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 licensed machine-learning purposes, (c) maintain appropriate security measures, and (d) 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: email support@earnreps.com with the subject line "Do Not Sell My Personal Information," or use the in-app controls where available. 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:
- Service providers (processors) that act on our instructions: cloud hosting and storage providers; Stripe (payouts and identity verification); Prelude (phone verification and device-integrity signals); Mixpanel (product analytics); Smartlook (session replay); AppsFlyer (install attribution); Sentry (crash reporting); Knock and Expo (push notification delivery); fulfillment partners and shipping carriers (Strap delivery and tracking); and customer-support tooling.
- Dataset licensees, who receive only redacted, de-identified Recordings and associated metadata under the contractual restrictions described in Section 6.
- Advertising and attribution partners (Meta, TikTok, Apple SKAdNetwork), which receive limited install- and event-level signals to measure our ad campaigns, as described in Section 9. We do not provide these partners with your Recordings.
- Professional advisers and authorities: lawyers, accountants, auditors, insurers; and courts, regulators, or law enforcement where we believe disclosure is required by law, or is necessary to protect the rights, safety, or property of Reps, our users, or the public, or to detect and prevent fraud.
- Corporate transactions: a counterparty in connection with a merger, acquisition, financing, reorganization, or sale of assets, in which case this Policy will continue to apply to your information until you are notified of changes.
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
- Delete your account at any time in the app (Profile → Settings → Delete account). Deletion removes your account and stops all future collection; Section 12 describes what happens to previously submitted Recordings.
- Text messages: reply STOP to opt out of non-essential texts (Section 17).
- Tracking: deny or revoke the ATT permission in iOS Settings.
- Push notifications: disable in iOS Settings; transactional messages about payouts and shipping may still be delivered by other means where legally permitted.
- Marketing: unsubscribe links in emails, or email us.
- Dataset licensing opt-out: Section 6.
- Camera, microphone, and photo permissions: managed entirely by you through iOS; the app cannot record without them.
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; and inferences for task matching 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. We do not use or disclose sensitive personal information for purposes requiring a "limit use" right beyond those permitted by the CPRA. 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 and task submissions, which fund the Service through dataset licensing. The material terms — which tasks are available, what each pays, and the review criteria — are shown in the app before you accept any task. You opt in by accepting a task and can withdraw at any time by not accepting further tasks, 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
- Account data: for as long as your account exists, then deleted or de-identified within a commercially reasonable period, except where retention is required for legal, tax, dispute, or fraud-prevention purposes.
- Recordings: unredacted originals are kept under restricted access for review, safety, and legal purposes; redacted, de-identified versions incorporated into datasets may be retained and remain in licensed datasets, because removing individual items from trained models and delivered datasets is generally not feasible. Deleting your account stops all future collection and licensing of new content.
- Biometric-type data: per the destruction schedule in Section 3.
- Financial records: as required by tax and financial regulations (typically seven years).
- Analytics and logs: retained on rolling schedules and then deleted or aggregated.
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, and our services are hosted in the United States. 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 detect fraud and multiple-account abuse, and to route work to human reviewers. 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. 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
Email: support@earnreps.com