Privacy Policy

1. Who we are

Tonubi LLC (“Tonubi,” “we,” “us,” or “our”) is a Missouri limited liability company based in the United States. We publish mobile applications on Apple’s App Store and provide website, mobile app and web software development services to businesses. Tonubi LLC is the party responsible for the personal information described in this policy.

2. Scope of this policy

This Privacy Policy applies to personal information we process when you:

• visit tonubi.com (the “Website”);
• join the Tonubi waitlist or contact us by email;
• engage us, or represent a company that engages us, for client services (the “Services”); and
• use a mobile application published by Tonubi (the “Apps”), unless an App provides its own privacy notice.

When we build software for a client, the client decides how that software handles its own users’ data. In that case the client’s privacy policy applies, and we act only as a service provider following the client’s documented instructions.

3. Information we collect

Information you provide

• Waitlist: your email address, an optional name, the topic you are interested in, and the date and version of the consent you gave.
• Communications: the content of emails and messages you send us, and your contact details.
• Client services: business contact details (such as name, job title, company, email and phone number), project information, and billing details needed to issue invoices and receive payment.

Information collected automatically

• Server logs: like most websites, our hosting provider automatically records technical data such as IP address, browser type, requested page, referring page and time of request. We use these logs only to operate and secure the Website.
• Abuse prevention: when you submit the waitlist form, we create a one-way, salted hash of your IP address to limit repeated submissions. This hash cannot be used to recover your IP address, is not stored with your waitlist entry, and is routinely deleted.

We do not use analytics, advertising or social media tracking tools on the Website, and we do not collect sensitive personal information such as government identification numbers, precise geolocation, health data or financial account credentials through the Website.

Information from third parties

For purchases made in our Apps, Apple provides us with limited transaction and sales reports. These reports do not include your payment card details. We do not purchase personal information from data brokers.

4. How we use information

• to respond to your questions and requests;
• to manage the waitlist and send you the updates you asked for, such as early-access invitations or an invitation to schedule a project call;
• to prepare proposals, deliver the Services, issue invoices and keep business records;
• to operate, maintain, secure and improve the Website, the Apps and the Services;
• to detect, prevent and respond to fraud, abuse, security incidents and technical issues; and
• to comply with legal, tax, accounting and regulatory obligations, and to enforce our agreements.

Emails we send in connection with the waitlist include a simple way to unsubscribe. You can also reply “unsubscribe” or write to hello@tonubi.com at any time. Opting out of marketing emails does not stop messages about an active project or invoice.

5. Why we are allowed to use it

Where applicable law requires a legal basis, we rely on your consent (for example, joining the waitlist), the performance of a contract (delivering Services you requested), our legitimate interests in running and securing our business in ways that do not override your rights, and compliance with legal obligations. You may withdraw consent at any time without affecting processing that happened before.

6. How we share information

We share personal information only as described below:

• Service providers that help us run our business, such as website hosting, email delivery, cloud storage, accounting, and banking or payment processing providers used to receive client payments. They may use the information only to provide services to us and must protect it.
• Apple, which processes all purchases and subscriptions made in our Apps under Apple’s own privacy policy.
• Professional advisers, such as lawyers and accountants, under duties of confidentiality.
• Legal and safety reasons, when we believe in good faith that disclosure is required by law, subpoena or court order, or is necessary to protect the rights, property or safety of Tonubi, our clients, users or the public.
• Business transfers, in connection with a merger, acquisition, financing or sale of assets, subject to this policy’s protections.
• With your direction or consent.

7. No sale or targeted advertising

Tonubi does not sell personal information, does not share personal information for cross-context behavioral (targeted) advertising, and has not done so in the preceding 12 months. We honor Global Privacy Control (GPC) browser signals as a request to opt out of such activities, although no sale or sharing takes place.

8. Cookies and similar technologies

The Website does not set advertising or analytics cookies, and the waitlist form works without cookies. To display the Website, your browser loads fonts and code libraries from third-party content delivery networks (Google Fonts and jsDelivr). These providers receive your IP address and basic browser information as part of delivering those files, under their own privacy policies. We do not receive any tracking data from them.

9. Tonubi mobile apps

Our Apps are designed to work with the minimum data needed. Each App’s App Store product page includes a privacy label describing its data practices, and an App may provide an additional in-app notice for specific features. In general:

• Payments, free trials, subscriptions and refunds are processed by Apple. Tonubi never receives your full payment card information.
• Content you create in an App (for example, notes or settings) is stored on your device or in your own iCloud account where the App offers that option, unless the App clearly explains otherwise.
• If an App uses crash reporting or aggregated usage statistics, it does so to fix bugs and improve features, not for advertising.
• Any access to device features (such as notifications) is requested through iOS permission prompts and can be changed in your device settings.

10. Data retention

• Waitlist data: until you unsubscribe or ask us to delete it, and in any case no longer than 24 months after our last contact with you.
• Client and billing records: for the duration of the relationship and afterwards as required for tax, accounting and legal purposes (generally up to seven years).
• Server logs: for a limited period, normally no longer than 90 days, unless needed to investigate a security issue.

11. Security

We use administrative, technical and physical safeguards appropriate to the nature of the information, including encrypted connections (HTTPS), access restricted to people who need it, and storage that is not publicly accessible. No method of transmission or storage is completely secure, but we work to protect your information and will notify you and authorities of a data breach where required by law.

12. Your privacy rights

Depending on where you live, you may have the right to:

• know and access the personal information we hold about you;
• correct inaccurate information;
• delete your information;
• receive a portable copy of your information;
• opt out of marketing communications, sale, sharing or targeted advertising; and
• withdraw consent where we rely on it.

To make a request, email hello@tonubi.com with the subject “Privacy request.” We will verify your request using the information we already hold (for example, by confirming access to the email address on file) and respond within the time required by law, typically within 45 days. You may use an authorized agent where permitted by law. We will not discriminate against you for exercising any of these rights.

13. U.S. state privacy rights

Residents of California and of other states with comprehensive consumer privacy laws (such as Colorado, Connecticut, Virginia, Texas and others) may have the rights described above, to the extent those laws apply to Tonubi. For California residents: in the past 12 months we have collected identifiers (such as name and email address), commercial information (such as services requested), internet activity information (server logs), and professional information (such as job title) for the business purposes described in Section 4, and disclosed them only to the categories of recipients in Section 6. We do not use or disclose sensitive personal information for purposes that would require an opt-out.

If we decline your request, you may appeal by replying to our decision with the subject “Privacy appeal.” If you are not satisfied with the outcome of your appeal, you may contact your state Attorney General.

If you are located in Canada, you may have rights under applicable Canadian privacy law, including the right to access and correct your personal information. Contact us using the details below.

14. Children’s privacy

The Website and our Services are intended for adults and businesses. Our Apps are not directed to children under 13, and we do not knowingly collect personal information from children under 13, in line with the Children’s Online Privacy Protection Act (COPPA). If you believe a child has provided us personal information, contact us and we will delete it.

15. Where information is processed

Tonubi is based in the United States, and we store and process information in the United States. If you access the Website from outside the United States, you understand that your information will be transferred to and processed in the United States, where privacy laws may differ from those in your country.

16. Changes to this policy

We may update this Privacy Policy from time to time. The “Last updated” date above shows when it was last revised. If we make material changes, we will provide notice on the Website or by email before the changes take effect.

17. Contact us

Questions or requests about privacy can be sent to hello@tonubi.com. We aim to respond within five business days.