Privacy Policy

This Privacy Policy describes how ToSelf, Inc. (“ToSelf”, “we”, “us” or “our”) processes personal information that we collect through our AI-powered journaling app (the “app”), our website, toself.io (the “website”), and any other digital and online properties or services that link to this Privacy Policy, as well as our marketing activities, live events, and other activities described in this Privacy Policy (collectively, the “Service”).

Notice to European users: Please see the Notice to European users section (Section 8) below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).

S.1 Personal information we collect

1.1Information you provide to us

Personal information you may provide to us includes:

Contact data, such as your first and last name and email address.
Profile data, such as account name, the username and password that you may set to establish an account on the Service, your user ID, and any other information that you add to your profile or other aspects of the Service.
User-generated content, such as messages, writing, photos, images, and other content or information that you generate, or otherwise make available on the Service, as well as associated metadata (e.g., how, when, where and by what/whom a piece of content was collected and how that content has been formatted or edited).
Transactional data, such as information relating to or needed to complete your subscriptions or orders on or through the Service, including order numbers and transaction history.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Other data not specifically listed here, but which you choose to share with the open-text fields of the Service, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

1.2Third-party sources

We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:

Our users, we may obtain your personal information from our users (please see above).
Service providers that provide services on our behalf or help us operate the Service or our business.
Marketing Partners, such as joint marketing partners and ad networks.

1.3Automatic data collection

We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your device's hardware, software, and network information, unique identifiers, and general location.
Location data, which will be approximate (for example, as inferred from network data or device settings).
Communication interaction data such as your interactions with our email, or other communications (e.g., whether you open and/or forward emails). On our website, we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing our website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies. On our website, some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

S.2 How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

2.1Service delivery and operations

We may use your personal information to:

provide and operate the Service (including to process your orders and transactions);
establish and maintain your user profile on the Service;
enable security features of the Service, such as authentication or remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
provide support for the Service, and respond to your requests, questions and feedback.

2.2Service personalization

We may use your personal information to personalize the Service for you, which may include using your personal information to:

personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate the Service.

2.3Research and development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and develop new products and services.

2.4Marketing and advertising

We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt out of our marketing communications as described in the Opt-out of marketing section.

Interest-based advertising. We and our third-party advertising partners may use cookies, pixels and other technologies to collect information about your interaction (including the data described in the Automatic Data Collection section above) with the Service, our communications and other third party online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online properties. You can learn more about your choices for limiting interest-based advertising in the Your choices section and in our Cookie Policy.

2.5Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

2.6Compliance and protection

We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

2.7To create aggregated, de-identified and/or anonymized data

We may create aggregated, de-identified and/or anonymized data from your information. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

2.8Data sharing in the context of corporate events

We may share certain personal information in the context of actual or prospective corporate events – for more information, see the ‘How we share your personal information’ section.

2.9Further uses

In some cases, we may specifically ask for your consent to collect, use or share your personal information for further purposes not set out above, such as when required by law (e.g., if the law requires this where those further purposes are not compatible with the initial purpose for which that personal information was collected).

S.3 How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

3.1Service providers

Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, subscription fulfillment, customer support, online chat functionality, email delivery, marketing, consumer research and website/data analytics).

3.2Artificial intelligence platforms

We share your messages with our third-party generative artificial intelligence (AI) providers to power the keyword, emotional expression, and similar analytics functions of the Service. We select AI providers that promise to not train their AI models with your data. To learn more about how these AI providers process your information, please refer to their applicable terms or privacy policies. For example, you can view the OpenAI API terms at https://developers.openai.com/api/docs/guides/your-data and the Anthropic terms at https://www.anthropic.com/legal/commercial-terms.

3.3Advertising partners / ad networks

Third-party advertising companies for the interest-based advertising purposes described above. This may include certain social networks where we use their ad services to display ads to our customers, or other people like them, on social media.

3.4Professional advisors

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

3.5Authorities and others

Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

3.6Corporate transactions

We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in ToSelf, financing of ToSelf, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your information to an acquirer, successor, or assignee of ToSelf or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets. Any of these third parties would be bound to use your information consistent with this Privacy Policy unless you specifically agree otherwise.

S.4 Your choices

In this section, we describe the choices available to all users. Users who are located in Europe can find additional information about their rights below in the Notice to European Users.

4.1Access or update your information

You may have the right to access and update personal information we hold about you.

4.2Opt-out of communications

You may opt out of marketing-related emails by following the opt out or unsubscribe instructions at the bottom of the email, or by contacting us at support@toself.io. It may take time for your opt-out to be effective. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. You may opt-out of text messages by texting “STOP” in response to a text that you receive or by other reasonable means.

4.3Cookies

For information about cookies employed by the Service and how to control them, see our Cookie Policy.

4.4Declining to provide information

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

4.5Retention period for personal information

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

S.5 Security

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information. Additionally, you should take care to keep your username and password private, as sharing that information could jeopardize the confidentiality of your content in the Service.

S.6 International data transfer

We are headquartered in the United States, and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the information provided below about the transfer of personal information outside of Europe.

S.7 Children and teens

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information, or if information was provided on your behalf when you were under 18, please contact us at support@toself.io. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

S.8 Notice to European users

9.1Where this Notice to European users applies

The information provided in this “Notice to European users” section applies to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy), as well as individuals who reside in jurisdictions with laws similar to European data protection laws that apply to your use of the Service and require the following disclosures, in each case solely to the extent required by local law. References to “Europe,” “Europeans,” and “GDPR” should be construed to include these additional jurisdictions, populations, and similar data protection laws.

9.2Controller

ToSelf, Inc. is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called UK GDPR (as and where applicable, the “GDPR”)). See the “How to contact us” section above for our contact details.

9.3Personal information

References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information that identifies or can reasonably identify a natural person.

9.4Our legal bases for processing

In respect of each of the purposes for which we use your personal information, applicable law requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract we have entered into with you or are about to enter into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see “How we use your personal information.”

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Any and all data types relevant in the circumstances	Contractual Necessity. Legitimate Interests. We have a legitimate interest in ensuring the proper operation of our Service and the performance of our contracts with our users (including with respect to the processing of data about you we get from our users), as well as the ongoing security of the Service, our business and associated IT services, systems and networks.
Service personalization	Profile data Device data Online activity data	Legitimate Interests. We have a legitimate interest in providing you with a good service via the Service, which is personalized to you and that remembers your selections and preferences. Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).
Research and development	Any and all data types relevant in the circumstances	Legitimate Interests. We have legitimate interest in understanding what may be of interest to our users and understanding how our users use our Service. Consent, in respect of any optional cookies used for this purpose.
Direct marketing	Contact data Profile data Communications data Transactional data Marketing data Communication interaction data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Interest-based advertising	Device data Online activity data	Consent, including in relation to any information collected via optional cookies used for this purpose
Service improvement and analytics	Communications data Profile data Data about others Device data Online activity data Communication interaction data	Legitimate Interests. We have a legitimate interest in providing you with a good service and analyzing how you use it so that we can improve it over time, as well as developing and growing our business. Consent, in respect of any optional cookies used for this purpose.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law. Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.
To create aggregated, de-identified and/or anonymized data	Any and all data types relevant in the circumstances	Legitimate Interests. We have legitimate interest in taking steps to preserve our users' privacy as we research how they use our Service.
Data sharing in the context of corporate events	Any and all data types relevant in the circumstances	Legitimate Interests. We have a legitimate interest in pursuing and consummating actual or prospective corporate events and providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations).
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

9.5No obligation to provide personal information

You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. Where required to do so by law, we will notify you if this is the case at the time.

9.6No sensitive personal information

We anticipate that you may voluntarily and intentionally share sensitive details in your messages within the Services. If you provide any sensitive information to the Service, you consent to our processing and use of such sensitive information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive information, you must not submit such sensitive information through our Services. We ask that you not directly provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, information related to sex life or sexual orientation, trade union membership, or information pertaining to criminal convictions) when you communicate with us, such as IT or customer support communications.

9.7No automated decision-making and profiling

As part of the Service, we do not engage in automated decision-making and/or profiling that produces legal or similarly significant effects.

9.8Your rights

Local data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe or a jurisdiction with a similar data protection law, you may ask us to take the following actions in relation to your personal information that we hold, in each case as available to you pursuant to your local applicable laws:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information you have provided to us that we process based on Consent or Contractual Necessity.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we process your personal information for direct marketing purposes.
Withdraw consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

9.9Exercising these rights

You may submit these requests by email to support@toself.io. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information). If we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

9.10Your right to lodge a complaint with your supervisory authority

In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

9.11Data processing outside of Europe or your home country

We are a U.S.-headquartered business and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

It is important to note that the U.S. is not the subject of an “adequacy decision” under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
- However, in these cases:
  - we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorize for this purpose; or
  - In limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at support@toself.io.

Changes to this privacy policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last Updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you depending upon applicable law, please contact us.

Email — support@toself.io

Website — toself.io

Address — ToSelf, Inc., 2193 Fillmore St, San Francisco, CA 94115