Privacy Policy

1. Notice of Collection of Information

This section describes what types of information we collect through the Services.

1.1 User Information

We collect user information such as IP address when you use the Services and, when you install the App, a user ID. We collect your email address and name when you use the App. We also collect information from you when you voluntarily provide it to us (for example, if you contact us for customer support, to provide feedback, or for another matter: your email address and, if provided, your name). Our Services do not provide for a user account to be created.

1.2 Device Information

We may collect information about the device used to use or access the Services. For example, device model and manufacturer, Firebase ID, OS version, and mobile network info. We or our third party service providers may also collect information about whether your mobile device is powered on or off.

1.3 Location Information

We or our third-party service providers may collect approximate location data from your mobile device.

1.4 App Activity

We collect information from the App such as, for example:

• App interactions: How you interact with the App.
• In-app search history: Search terms used within the App.
• Other actions: Other user activity within the App.

1.5 App Performance Information

We collect information from the App such as, for example:

• Crash logs: Data about app crashes, including stack traces.
• Diagnostics: Performance metrics such as battery usage, load times, framerate.
• Other performance data: Any other related technical diagnostics.

1.6 Email Messages

The App may access and process email message content for purposes of app functionality and personalization.

1.7 Contacts and Calendar

Contacts Data: When you grant read permission, we may access your contacts information stored on your device. This data is used solely to facilitate the sending of emails to your contacts within the application. We do not transmit this data to third parties, and it is stored locally on your device.

Calendar Data: When you grant read permission, we may access calendar information stored on your device. This data is used for app functionality. We do not transmit this data to third parties, and it is stored locally on your device.

1.8 Microphone and Media Access

The App processes voice audio from your device’s microphone for purposes of voice search queries for app functionality. The App may access your device’s photos, videos, media files, images, and audio files (such as music files) for purposes of app functionality.

1.9 Camera Access

The App may access your device’s camera for purposes of sending pictures via the App when the feature is actively used.

1.10 App Usage Behavior

We may collect and track app package names and behaviors to personalize the App home screen experience.

1.11 Information from Third Parties

We may receive information about you from third parties you’ve interacted with, which we may use as permitted under their data sharing agreements.

1.12 Publicly Available Information

We may receive information about you from publicly available sources (for example, public records).

1.13 Cookies and Other Tracking Information

We may place and collect information from cookies, web beacon technology, software development kits (“SDKs”), and other device identifiers when you use the Services to analyze usage patterns and personalize ads and content.

Cookies are small data files stored on your computer or device that allows us or third parties we work with to identify your IP address with corresponding information in our Services. We and/or such third parties may use cookies to track behavior, preferences, and responses to or views of advertisements within the Services to help predict what other advertisements may be of interest to you and to enable you to receive customized advertisements or content. To learn more about cookies in general, please visit allaboutcookies.org.

A web beacon is a code that enables us to track interactions with content in our Services. SDKs are pieces of code, which function similar to cookies and web beacons, that are used to analyze and deliver Services. Device identifiers and other identifiers are unique identifiers that are used to identify a computer or device.

1.14 Categories of Information Collected

The information we may collect, and have collected within the last twelve (12) months, includes:

• Identifiers: Real name, email address, postal address (if provided to us for purposes of customer support or another matter), unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.
• Categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code: Name (if provided to us for purposes of providing feedback, customer support, or another matter), telephone number (if provided to us for purposes of providing feedback, for customer support, or for another matter), address (if provided to us for purposes of customer support or another matter). “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
• Commercial information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information: Search history, and information regarding a consumer’s interaction with an Internet Web site, application, advertisement.
• Geolocation data: Approximate location.
• Sensory information: Audio information.
• Inferences drawn from any other information: Data reflecting a consumer’s preferences, characteristics, habits, attitudes, predispositions, intelligences, and abilities.

The categories of information described above are collected from the following categories of sources:

• Directly from you or your agents, such as through your submissions to the Services.
• Directly and indirectly from activity through the Services, such as through your interaction with the Services.
• From third parties that work with us to provide the Services.

We will not use additional categories of information for materially different purposes without first notifying you by updating this Privacy Policy.

1.15 Categories of Information and Data Types Collected or Accessed

As a supplement to the summary of categories of information collected above, the following is a summary of categories of information and data types that the App collects or accesses:

• Personal info: Name (for purposes of app functionality and personalization, such as first name for personalizing push notifications), email address (for purposes of app functionality and account management) and user ID (for purposes of analytics, app functionality, personalization, developer communications, and advertising and marketing).
• Location: Approximate location (for purposes of analytics).
• Device or other IDs: Device model and manufacturer (for purposes of analytics, app functionality, personalization, developer communications, and advertising and marketing).
• Messages: Access to email messages (for purposes of app functionality and personalization).
• Photos, videos, music files, and other audio files: Although not collected, access to photos, videos, music files, and other audio files (for purposes of app functionality).
• Contacts and Calendar: With read permission, although not collected, access to contacts and calendar (for purposes of app functionality).
• App info and performance: Crash logs, diagnostics, and other performance data (for purposes of analytics).
• App activity: App interactions, in-app search history, and other actions (for purposes of analytics, app functionality, personalization, developer communications, and advertising and marketing).

1.16 Mandatory Data Collection

Data collection is required to use the Services. While you may have rights to opt out or request deletion, some of the data is necessary for functionality.

1.17 Minors

We do not knowingly collect personal data from users under 18. If discovered, such data will be deleted promptly.

2. Use and Sharing of Information

2.1 Discretion to Use Information

Information that you voluntarily provide to us, or that we lawfully obtain, may be used for any lawful purpose. This may include sharing or selling data with our publishers, advertisement providers, analytics providers, and data aggregators for purposes such as app functionality, analytics, or advertising and marketing. The App does not process data ephemerally. “Ephemerally” means that data is only accessed and used while it is in memory and is not kept longer than necessary. Data is retained and used beyond in-memory processing.

2.2 General Purposes of Use of Information

We use the information we collect to:

• Fulfill the purpose for which the information was provided.
• Perform activities described to you when collecting your information or as set forth in the California Consumer Privacy Act (“CCPA”) or other applicable law.
• Provide products or services requested, such as app functionality, app features, customer support, analytics, or personalization. For example, first name for personalizing push notifications.
• Provide or perform advertising and marketing (such as the delivery of targeted advertisements and information).
• Carry out obligations and enforce or defend contractual rights.
• Improve our Services through research, testing, analytics, and feature development.
• Respond to lawful government and law enforcement requests.
• Evaluate or conduct a business transaction such as a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets where information may be transferred.
• Detect, prevent, and mitigate fraud and ensure compliance with legal or regulatory standards.

2.3 App Feature Use

The App processes voice audio input from your device’s microphone for purposes of voice search queries for app functionality.

2.4 Permissions Disclosure and App Feature Use

We request specific permissions only when necessary to provide app functionality. These may include:

• Contacts and Calendar: Accessed only when you enable contact or calendar-related features. Contact and calendar data is stored only on your device and not uploaded or shared externally. You can revoke these permissions at any time via your Android device settings.
• Email: Features that use artificial intelligence to summarize, draft, and organize email messages. You can revoke this permission at any time via the App.

With your permission, we may also send push notifications to your device for purposes of App functionality (e.g., to alert you that you received a new email message).

Denying permissions may disable related features, but will not affect core App functionality.

2.5 Targeted Advertising and Personalization

We may use information to serve personalized ads or content based on your behavior or preferences. This includes the use of information such as cookies, web beacons, user IDs, SDKs, and interaction data.

2.6 Aggregated or Summary Data

We may share or sell aggregated, de-identified information that cannot be used to identify you, such as statistical trends or app usage summaries.

2.7 Legal Requests

We may disclose information in response to subpoenas, court orders, regulatory requests, and other legal process as required by law.

2.8 Artificial Intelligence Features

With your consent, we provide features to you in the App that use artificial intelligence functionality provided by third party service providers (such as OpenAI and Google). For example, functionality such as searching, reviewing, summarizing, and/or composing email messages. The content of your emails including, email address, subject lines, email body text, and sender and recipient information may be shared with such service providers for purposes of providing such functionality. The App does not retain data generated through the use of artificial intelligence features. Please see Section 4.3 below in this Privacy Policy regarding privacy practices of third parties.

2.9 Disclosure and Sale or Sharing of Information

We may sell, share, or disclose information for a business purpose. The definition of a “sale” of information is broadly defined under certain applicable laws to include sharing information with advertisers and analytics providers and other service providers. For example, we may provide information (a) to entities wholly owned or controlled by us or under common control with us (these entities are subject to this Privacy Policy or similar obligations), and (b) to service providers who perform services on our behalf (such as ad and analytics providers) or to third party advertisers. In the past twelve (12) months, the following categories of information have been sold or disclosed for a business purpose:

• Identifiers: Used for analytics, app functionality, personalization, advertising or marketing (excluding name), and personalization, and shared for purposes of developer communications, fraud prevention, personalization, and analytics.
• Inferences: Inferences drawn from any other information based on preferences or behavior used and shared for analytics and app performance.
• Messages: Email message content and push notifications used and shared for purposes of app functionality and personalization.
• Photos, videos, and audio files: Used for purposes of app functionality.
• Audio: Used and shared for purposes of analytics, app functionality, personalization, and advertising and marketing.
• App info and performance data: Used and shared for purposes of analytics, such as diagnostics and improvements.
• App activity: Used and shared for purposes of app functionality, such as personalization and usability, and analytics.

2.10 Limits on Use of Your Google User Data

If you provide the App with access to the following types of your Google data, the App’s use of that data will be subject to these additional restrictions:

• The App will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows you to compose, send, read, and process emails and will not transfer this Gmail data to others unless (i) to provide or improve such features, (ii) for security purposes (such as, but not limited to, investigating abuse), (iii) to comply with applicable law, or (iv) as part of a merger, acquisition, or sale of assets.
• The App will not allow humans to read Gmail data unless (i) you provide your affirmative agreement for specific messages, (ii) doing so is necessary for security purposes (such as but not limited to investigating a bug or abuse), (iii) to comply with applicable law, or (iv) the data is aggregated and used for internal operations.
• We will not use, transfer, sell, or use Gmail data for purposes of serving ads including retargeting, personalized or interest-based advertising.

3. How We Store and Protect the Information We Collect or Receive

3.1 Data Security Measures

We implement a combination of physical, technical, and organizational safeguards to protect information under our control from unauthorized access, loss, misuse, or alteration. These measures include secured servers and controlled access protocols. However, no method of transmission or storage is completely secure, and we cannot guarantee that our security protocols will prevent all breaches or unauthorized access. Information is not encrypted in transit.

3.2 Retention of Information

We retain information for as long as necessary to provide our Services, in accordance with our record retention policies, and to meet legal, financial, and operational requirements. This includes for purposes of (a) maintaining financial and transactional records, (b) performing statistical analysis, (c) disaster recovery and business continuity, (d) complying with applicable laws and regulations, and (e) resolving disputes or enforcing our agreements. Our App does not explicitly delete user data. Please see Section 5 below regarding certain rights to request deletion of your information.

4. Privacy Practices of Third Parties

4.1 Third Party Cookies and Web Beacons

Publishers, advertisement providers, and other parties that we work with may use their own cookies, tracking pixels (web beacons), and similar technologies to collect information about your behavior across websites and apps. These technologies may be used for analytics, ad targeting, or other purposes. We do not control the data collection or privacy practices of these third parties. While we may allow advertiser or publisher cookies to be placed on your device, their use is governed by their own privacy policies.

4.2 External Links

The Services may contain links to third party websites or services. We are not responsible for the privacy practices or the content of those websites. We encourage you to read the privacy policies of any third party sites that you visit.

4.3 Third Party Service Providers

With respect to the privacy practices of third party service providers that we use to provide features that use artificial intelligence, please see (a) OpenAI’s privacy policy located at openai.com/policies/privacy-policy and (b) Google’s privacy policy located at policies.google.com/privacy.

We use Braze to enable personalized communications when you use the App. You may review Braze’s privacy policy at braze.com/company/legal/privacy.

We are not responsible for the privacy practices of third party service providers.

5. Your Rights in Information

You may have rights under certain applicable laws regarding your information collected by us (for example, residents of California under the CCPA and residents of Virginia under the Virginia Consumer Data Protection Act (“VCDPA”)). Such rights may include:

• The right to know what categories and specific pieces of information are collected, disclosed for a business purpose, or sold by requesting this information from us.
• The right to request correction of your information that is inaccurate or incomplete.
• The right to opt-out of the sale of collected information.
• The right to opt-out of the processing of your information for targeted advertising.
• Under the VCDPA, the right to opt-out of profiling performed in furtherance of decisions that produce legal or similarly significant effects.
• The right not to receive discriminatory treatment by us for choosing to exercise your privacy rights.
• If applicable, the right to designate an authorized agent for making requests under the CCPA, or other applicable law, on your behalf.

6. How You May Exercise Your Rights and Control Your Information

6.1 Websites

To prevent us from tracking your behavior on a website, turn off cookies from that website and do not click on or interact with any advertisements. Please note that we do not have a mechanism or process to respond to any “do not track” signals which a web browser may send or receive, other than as described in this section.

6.2 Cookies

Check instructions about your web browser to learn how to prevent placement of, or how to remove, cookies placed on your computer or device by us. You can opt-out of receiving cookies from a variety of ad providers and ad servers by visiting the following sites and following the instructions provided: youronlinechoices.com and aboutads.info/choices.

6.3 Push Notifications

You may opt-out of receiving push notifications by going to your device settings and changing settings for the App.

6.5 Request to Opt-Out of the Sale or Sharing of Personal Information

You may opt-out of the sale or sharing of personal information, the processing of your information for targeted advertising, or profiling for advertising or content personalization by:

1. Visiting our homepage at applabstudiosllc.com and submitting requested information through the “Do Not Sell or Share My Personal Information” link;
2. Emailing us at privacy@applabstudios.com (identifying the request in the subject line of the email) or writing to us at the address provided at the end of this Privacy Policy to make your request; or
3. Contacting us by email at privacy@applabstudios.com or the address provided at the end of this Privacy Policy making your request prior to submitting your information through the Services.

To opt-out of the processing of your information for targeted advertising on a device, Android users using Android 12 or above can go to Settings > All services > Ads > Delete advertising ID. You may also limit ad tracking via your device’s privacy settings.

To disable targeted advertising, the sale or sharing of information, or profiling for advertising or content personalization, when available in the App’s settings, open the App, go to Settings > Privacy, and manage your preferences.

If we decline a request you make under this section, you may appeal our decision by emailing us at privacy@applabstudios.com stating that you wish to appeal.

6.6 Designating an Agent

To designate an authorized agent to exercise rights on your behalf, please email us at privacy@applabstudios.com. We may request information from you to verify your identity when designating an authorized agent. We may also ask for your authorized agent to provide a written permission from you giving them authorization and verify their own identity by submitting information requested by us.

7. More Information

7.1 Contact Us

If you have questions about this Privacy Policy or your rights under this Privacy Policy, please email us at privacy@applabstudios.com or write to us at:

7.2 Changes to Privacy Policy

This Privacy Policy may change from time to time. To determine if there have been any updates to this Privacy Policy, please check back frequently as any updates will be posted with a new last updated date at the top of this Privacy Policy.