PRIVACY POLICY

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Information automatically collected

In Short: Some information — such as your device type and language — is collected automatically when you use our Services.

We automatically collect certain information when you use the Services. This information does not reveal your specific identity (like your name or contact information) but may include:

• Device and usage data — Device type, operating system, language settings, and app version.
• Crash and performance data — Anonymized crash reports used to identify and fix bugs.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication. We use your phone number to create your account and verify your identity via SMS through Firebase Authentication.
• To provide AI-powered task classification. When you create a task, its text content is sent to our AI provider (DeepSeek API) to automatically detect the task type (task, list, event, reminder, note, poll), generate a concise title, extract dates and times, and provide a description. Only the task text and your locale are sent — never your phone number, name, contacts, or other personal data. See Section 3 for more details.
• To enable task sharing and social features. When you share a task with another user or a Circle, we transmit the task content, your display name, and avatar to the recipient(s) via Firebase Cloud Firestore.
• To store images. When you attach a photo to a task, it is uploaded to Firebase Storage (Google Cloud) and associated with your task. Images are accessible only by you and (if shared) the task recipients.
• To match contacts. When you grant contact permission, phone numbers from your device contacts are hashed locally using SHA-256. These hashes are sent to our servers and stored to enable contact matching — both to find which of your contacts use Toodi, and to allow them to discover you. We never receive or store your contacts' names or plaintext phone numbers.
• To process subscriptions. If you subscribe to Toodi Pro, your purchase is processed by Apple or Google through RevenueCat. We use RevenueCat to verify your subscription status and grant premium features.
• To send notifications. We use Expo Push Notifications to send push notifications about shared tasks, event invitations, and reminders you have configured. See Section 5 for details on Expo as a service provider.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING

In Short: We use AI to classify your tasks automatically. Only your task text and locale are sent to the AI provider. No personal data is included.

What we send to the AI

When you create a task in Toodi, its text content is sent to the DeepSeek API for automatic classification. The data sent includes:

• The raw text of your task (what you typed or dictated)
• Your device locale and current date (for date/time interpretation)

We never send your phone number, display name, contacts, images, location data, or any other personal identifier to the AI provider.

What the AI returns

The AI classifies your task and returns structured data including: task type (task, list, event, reminder, note, poll), a concise title, a description, extracted dates and times, list items, event attendees, poll options, and recurrence patterns. This data is stored as part of your task in Firebase Firestore.

Local-first classification

To minimize external API calls, Toodi uses a 3-level classification system: (1) deterministic rules applied locally on your device, (2) a local cache of previous classifications, and (3) the DeepSeek API as a fallback. This means many of your tasks are classified entirely on-device without any data leaving your phone.

AI provider

Our AI classification is powered by DeepSeek (deepseek.com). DeepSeek processes the task text for the sole purpose of classification and does not retain your data beyond the API call. For DeepSeek's privacy practices, please refer to their Privacy Policy.

No profiling or automated decision-making

The AI classification is used solely to help organize your tasks. It does not produce legal effects, does not affect your access to the Service, and does not constitute profiling as defined by GDPR Article 22. You can always edit or override any AI-generated classification.

4. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services, or at your request prior to entering into a contract with you (e.g., processing your phone number for account creation, AI classification of your tasks as part of the Service).
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms (e.g., anonymized analytics to improve the Service).
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Firebase / Google Cloud. We use Firebase for authentication (phone number verification via SMS), Cloud Firestore (task and user data storage), and Firebase Storage (image uploads). Google processes this data according to their Firebase Privacy Policy.
• DeepSeek.We send your task text and locale to DeepSeek's API for AI-powered classification. No personal identifiers (phone number, name, contacts) are included. See Section 3 for details.
• Expo. We use Expo Push Notifications (expo.dev) to deliver push notifications to your device. Expo receives your device's push token and the notification content (e.g., shared task alerts, reminders). Expo does not receive your phone number, display name, or task content beyond what is included in the notification message. See Expo's Privacy Policy.
• RevenueCat. If you subscribe to Toodi Pro, RevenueCat processes your subscription through the app stores (Apple/Google). RevenueCat receives a pseudonymous app user ID and subscription status. They do not receive your phone number or display name. See RevenueCat's Privacy Policy.
• Apple App Store / Google Play Store. In-app purchases and subscriptions are processed by Apple or Google, depending on your platform. We do not have access to your payment method details.
• Other Toodi users. When you share a task with another user or a Circle, the task content (title, description, dates, images, list items) along with your display name and avatar are visible to the recipient(s). You control what you share and with whom.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Specifically:

• Account data (phone number, display name, avatar) is retained as long as your account is active.
• Task data (including text, images, and AI classifications) is retained as long as the task exists in your account. Deleted tasks are removed from Firestore and Storage.
• Images attached to tasks are deleted from Firebase Storage when the task is deleted.
• AI classification data is not retained by our AI provider (DeepSeek) beyond the API call.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These include:

• All data in transit is encrypted via HTTPS/TLS.
• Firebase Firestore and Storage use security rules to ensure users can only access their own data and data explicitly shared with them.
• Phone contacts are hashed locally on your device before any comparison with our servers.
• Images are stored in user-scoped paths in Firebase Storage with access-controlled rules.

Despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at admin@toodi.app.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

If you have questions or comments about your privacy rights, you may email us at admin@toodi.app.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of certain US states, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

We have updated the following table to reflect the personal information we currently collect:

Your Rights

You have rights under certain US state data protection laws. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at admin@toodi.app, or by referring to the contact details at the bottom of this document.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint to the Office of the Australian Information Commissioner or the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with the manner in which we address any complaint, you can contact the Information Regulator (South Africa):

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at admin@toodi.app or contact us by post at:

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request, or email us at admin@toodi.app.