Grug Notes

A simple self-organizing tool for text.

Privacy Policy

Last updated: September 17, 2026


INTRODUCTION

Welcome to Grug Notes, operated by Kamanu Composites, LLC ("we," "us," or "our"). This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our note-taking service at grugnotes.com (the "Service").

We take your privacy seriously. Please read this policy carefully to understand our practices regarding your data.

By using Grug Notes, you agree to the collection and use of information in accordance with this Privacy Policy.


SUMMARY OF KEY POINTS

What personal information do we collect?
We collect information you provide when creating an account (email, username, password), content you create in notes and chats, voice recordings for transcription, emails sent to your email forwarding addresses, messages you send through the optional Telegram integration, and — only if you turn them on in the iOS app — workout summaries from Apple Health (see section 6A) and, for the optional location diary, the names of places you visit with arrival and departure times (see section 6B).

How do we use your information?
We use your information to provide the Service, enable AI features, process payments, communicate with you, and improve our Service.

Do we share your information with third parties?
Yes. We share your content with third-party AI providers (OpenAI, Anthropic, Google, Groq, Fireworks AI, Baseten, ElevenLabs, TypeSafe AI, and — only when you pick their models — xAI and Meta) to deliver AI features, and use infrastructure providers (AWS, Google Cloud Platform, Pinecone) to operate the Service. These providers do not use your data to train their AI models. Some AI processing happens automatically, including organization and dictation assistance; section 4 explains the content sent and provider data practices, including TypeSafe's use of technical and usage information. If you connect optional integrations (Google Calendar, Telegram), your data also flows through those platforms as described below. Apple Health workout data you choose to import is read from your device only; its use and sharing are subject to the additional limits in section 6A, including no sharing with advertisers or data brokers. The optional location diary sends only place names and times to Grug Notes; coordinates are never sent to or stored by us, though the iOS app may send a coordinate to Apple's geocoding service to look up a place name (section 6B).

How long do we keep your information?
We retain your data while your account is active. If you request account deletion, we will work with you to remove your data, except for billing records required by law.

What are your privacy rights?
You can access and export your notes in Markdown format at any time through the app. You can delete your account directly in the iOS app (Settings > Delete Account) or by contacting us at keizo@grugnotes.com. For corrections or full data export (JSON/CSV), contact us at keizo@grugnotes.com. You may also object to processing or request data portability under applicable laws.

How can you exercise your rights?
Contact us at keizo@grugnotes.com to exercise your privacy rights. You can manage some preferences and export notes directly in your account settings.


TABLE OF CONTENTS

1. INFORMATION WE COLLECT
2. HOW WE USE YOUR INFORMATION
3. THIRD-PARTY SERVICES AND DATA SHARING
4. AI SERVICES AND DATA PROCESSING
5. EMAIL INGESTION AND TELEGRAM INTEGRATION
6. GOOGLE CALENDAR INTEGRATION
6A. APPLE HEALTH INTEGRATION
6B. LOCATION DIARY
7. COOKIES AND TRACKING TECHNOLOGIES
8. SOCIAL MEDIA LOGINS
9. INTERNATIONAL DATA TRANSFERS
10. DATA RETENTION
11. DATA SECURITY
12. CHILDREN'S PRIVACY
13. YOUR PRIVACY RIGHTS
14. GDPR RIGHTS (EUROPEAN USERS)
15. CCPA/CPRA RIGHTS (CALIFORNIA RESIDENTS)
16. OTHER US STATE PRIVACY RIGHTS
17. DO-NOT-TRACK SIGNALS
18. UPDATES TO THIS POLICY
19. CONTACT INFORMATION
20. DATA SUBJECT ACCESS REQUESTS


1. INFORMATION WE COLLECT

Personal Information You Provide

When you create an account or use our Service, we collect:

- Account Information: Email address, username, password
- Profile Information: Display name, preferences
- Payment Information: Processed and stored by Stripe (we do not store full payment card numbers)
- Note Content: All text, links, and data you create in your notes
- Chat Conversations: Messages you send and AI responses you receive
- Voice Recordings: Audio you submit for transcription or live voice editing (see Sections 3 and 4 for the providers we use)
- Dictation Context and Preferences: Speech transcripts, recent edits and surrounding note text, saved names, and spelling preferences used to interpret dictation and personalize corrections
- Email Content: Emails you send to your unique @add.grugnotes.com address
- Telegram Messages: Messages and voice notes you send to the Grug Notes Telegram bot, if you link a Telegram account (see Section 5)
- Push Notification Subscriptions: If you enable browser push notifications, the push subscription details (endpoint URL and encryption keys) needed to deliver them
- Support Communications: Any messages you send to our support team

Automatically Collected Information

When you use the Service, we automatically collect:

- Technical Information: IP address, browser type, device information, operating system
- Usage Data: Pages visited, features used, time spent on Service, click patterns
- Cookies and Similar Technologies: See section 7 for details

Sensitive Information

We do not intentionally collect sensitive personal information such as biometric data or financial account numbers. The exceptions are opt-in: if you explicitly enable the Apple Health workout import in the iOS app, we collect the workout summaries described in section 6A, and only those; if you explicitly enable the location diary in the iOS app, we collect the place names and visit times described in section 6B, and only those. Separately, you may choose to include sensitive information in your notes, chats, voice recordings, or emails. If you do, that content is processed and stored like any other content in your account.

Information We Do NOT Collect

We do not collect:
- Information from third parties (except through social login or integrations you enable, such as Google Calendar or Apple Health)
- Location data beyond general location from IP address (unless you turn on the optional location diary, which sends place names and visit times — never coordinates — as described in section 6B)


2. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

Service Delivery
- Provide access to your account and notes
- Enable AI-powered features (chat, content enhancement, semantic search)
- Process voice transcriptions
- Interpret spoken editing requests and personalize dictation using saved names and spelling corrections
- Process emails sent to your email ingestion address
- Sync your data across devices
- Provide customer support

Service Improvement
- Analyze usage patterns to improve features
- Fix bugs and technical issues
- Develop new features
- Ensure Service security and prevent abuse

Communications
- Send account notifications and service updates
- Respond to your support requests
- Send product updates and announcements (when you create an account we send you a confirmation email, and you are added to our mailing list only if you confirm; you can unsubscribe at any time)
- Notify you of changes to Terms of Service or Privacy Policy

Legal and Security
- Comply with legal obligations
- Enforce our Terms of Service
- Protect against fraud and abuse
- Resolve disputes


3. THIRD-PARTY SERVICES AND DATA SHARING

We share your information with the following third-party service providers:

Payment Processing
- Stripe: Processes payments made on our website and stores payment information
- Privacy Policy: https://stripe.com/privacy
- Apple: Processes payments for subscriptions purchased in our iOS app
- Privacy Policy: https://www.apple.com/legal/privacy/

Cloud Infrastructure
- Google Cloud Platform: Hosts our application (Cloud Run, Cloud Tasks, Secret Manager)
- Privacy Policy: https://cloud.google.com/privacy
- AWS: Email infrastructure for inbound email ingestion and outbound email delivery (SES, S3, SNS)
- Privacy Policy: https://aws.amazon.com/privacy/

AI Service Providers (See Section 4 for details)
- OpenAI: GPT models for chat and content processing
- Anthropic: Claude models for chat and content processing
- Google: Gemini models for chat and content processing
- Groq: AI inference services
- Fireworks AI: AI inference services, including automatic fallback for the default Grug chat model
- Baseten: Primary AI inference service for GLM 5.3 and the default Grug chat model
- TypeSafe AI, Inc.: Jev for text classification, dictation intent detection, and identifying reusable spelling and name corrections (see Section 4)
- xAI: Grok models, used only when you select them in the model picker
- Meta: Muse Spark models, used only when you select them in the model picker

Vector Database
- Pinecone: Stores semantic embeddings of your content for search functionality
- Privacy Policy: https://www.pinecone.io/privacy/

Voice Transcription and Live Voice Features
- Groq: Primary provider for single-speaker voice transcription (Whisper)
- Privacy Policy: https://groq.com/privacy-policy/
- Fireworks AI and OpenAI: Fallback transcription providers used automatically if the primary provider is unavailable
- ElevenLabs: Processes multi-speaker (meeting) voice recordings for diarized transcription
- Privacy Policy: https://elevenlabs.io/privacy-policy
- OpenAI and Google: Live voice editing streams your audio in real time to OpenAI's Realtime API or Google's Gemini Live API, depending on the mode you select
- TypeSafe AI: Jev processes text transcripts and related context for dictation assistance; our Jev integration does not send original audio recordings

Messaging Integration (optional)
- Telegram: If you link a Telegram account, messages and voice notes you send to the Grug Notes bot are transmitted through Telegram's platform, and messages from Grug Notes (including AI agent messages) are delivered to you through Telegram
- Privacy Policy: https://telegram.org/privacy

Push Notifications (optional)
- If you enable browser push notifications, notifications are delivered through your browser vendor's push service (e.g., Apple, Google, or Mozilla)

Email Marketing
- Mailchimp (Intuit): Manages our mailing list for product updates and announcements
- Privacy Policy: https://www.intuit.com/privacy/statement/
- When you create an account, we send you a confirmation email; you are added to our mailing list only if you confirm (double opt-in)
- You can unsubscribe at any time using the link in any marketing email

We do NOT:
- Sell your personal information to third parties
- Share your information for third-party marketing purposes
- Allow service providers to use your personal information outside the purposes and limits described in this policy and our agreements with them


4. AI SERVICES AND DATA PROCESSING

How AI Services Work

Grug Notes is a self-organizing note-taking tool. Your content is sent to third-party AI providers for processing in two ways:

When You Use AI Features:
- Your chat messages and conversation history
- Note content you request AI assistance with
- Voice recordings you submit for transcription or live editing
- Speech transcripts, recent edits, relevant note context, saved names, and spelling preferences used for dictation assistance
- Context needed for AI to provide relevant responses

Automatically, to Power Organization and Dictation Features:
Because automatic organization is a core part of the Service, some processing happens without you explicitly invoking an AI feature. When you create or edit content, or use dictation, it may be automatically processed by AI providers to enable:
- Semantic search (embeddings are generated using OpenAI's embedding API)
- Automatic linking between related notes
- Automatic tagging and entity extraction (people, companies, places)
- Date extraction and reminder organization
- De-duplication of repeated reminders
- Interpretation of spoken editing requests and, when dictation learning is enabled, identification of reusable spelling and name corrections

The additional restrictions in sections 6, 6A, and 6B apply to content imported through Google Calendar, Apple Health, and the location diary. The general AI processing described here does not override those restrictions or any required consent.

What Is NOT Shared with AI Providers:
- Your password or payment information
- Data from other users

AI Provider Data Usage

We use enterprise/API services under arrangements that do not permit providers to use your content to train or fine-tune their AI models. We do not opt in to provider model training on your content. Saving names and spelling preferences to personalize your dictation is different from training a provider's underlying model.

Providers process content to deliver AI features, including automatic decisions and corrections. Their handling of operational information and their retention practices are governed by the applicable service agreements and data protection terms. Retention varies by provider and is not necessarily limited to the duration of a request; see Section 10 and the TypeSafe-specific disclosure below.

TypeSafe AI (Jev)

We use Jev to help distinguish spoken editing requests from new note content and identify corrections that may improve future dictation. This processing may happen automatically during or after dictation. Depending on the task, we send speech transcripts, relevant note text, recent proposed or applied edits and undo history, saved names, and existing spelling rules. This text may contain personal information. Our Jev integration does not send original audio recordings.

We may also use Jev to evaluate how notes should be organized. For this purpose, context may include note text and dates, notebook names and summaries, and example excerpts from your notes.

TypeSafe's customer agreement permits it to derive technical and usage information ("telemetry"), including logs, hashes, summary statistics, classifications, and metrics, and use it to improve its services and other products. Its Data Processing Addendum limits processing of personal data to providing the services under our documented instructions and applicable legal requirements, and takes precedence over conflicting agreement terms. Telemetry that contains personal data remains subject to those restrictions.

TypeSafe may use contracted subprocessors to provide its services. Its current subprocessor list is available at https://trust.typesafe.ai/subprocessors. Its customer agreement and Data Processing Addendum are available at https://typesafe.ai/legal/mca and https://typesafe.ai/legal/data-processing.

AI Provider Selection

For automatic features (organization, search, summaries, and dictation assistance) we select providers based on availability and performance. TypeSafe's Jev may be used for these background classification tasks without you selecting it in a model picker. In chat and some other features you can choose the model yourself; when you pick a model, that request — including any notes it reads — is sent to that model's provider. Models from xAI (Grok) and Meta (Muse Spark) are only ever used when you select them.

Each provider's privacy policy:
- OpenAI: https://openai.com/privacy/
- Anthropic: https://www.anthropic.com/privacy
- Google: https://policies.google.com/privacy
- Groq: https://groq.com/privacy-policy/
- Fireworks AI: https://fireworks.ai/privacy-policy
- Baseten: https://www.baseten.co/privacy-policy/ (privacy policy) and https://docs.baseten.co/observability/security (inference data handling)
- TypeSafe AI: https://typesafe.ai/legal/privacy-policy
- xAI: https://x.ai/legal/privacy-policy
- Meta: https://www.facebook.com/privacy/policy/

Vector Embeddings

To enable semantic search, we:
- Create mathematical representations (embeddings) of your note content
- Store these embeddings in Pinecone's vector database
- Use embeddings to find related content when you search

Embeddings are mathematical representations that are not human-readable. While extremely difficult, they are not cryptographically guaranteed to be irreversible. The risk of content reconstruction from embeddings alone is very low but not zero.


5. EMAIL INGESTION AND TELEGRAM INTEGRATION

How Email Ingestion Works

You can send or forward emails to create notes in Grug Notes using forwarding addresses that you generate for individual prompts in your account settings. Each forwarding address contains a random 7-character key unique to that prompt (over 78 billion possible combinations), and you can regenerate or remove it at any time.

Personal addresses issued before September 2026 (your username plus a 5-character key) continue to work. That format is no longer issued to new accounts.

Email Processing Flow

1. You send email to one of your forwarding addresses
2. AWS SES receives the email
3. Email is stored temporarily in AWS S3 bucket (grugnotes-incoming-emails)
4. AWS SNS notifies our Service
5. Our Service downloads the email from S3
6. Email content is converted to a note in your account
7. Successfully processed emails are deleted from S3 within 1 day (via S3 lifecycle policy). Emails that fail processing are retained for up to 30 days so delivery problems can be investigated, then deleted.

Information Processed
- Email subject line
- Email body content (text and HTML)
- Email sender address
- Attachments (if supported)
- Email metadata (date, time)

Security Considerations
- Anyone with one of your forwarding addresses can create notes in your account
- Keep your email address confidential
- You can regenerate your email address in account settings if compromised

Telegram Integration (Optional)

You can optionally link a Telegram account to Grug Notes:

- You link your account using a one-time code; we store your Telegram user ID to route your messages
- Messages and voice notes you send to the Grug Notes Telegram bot become part of an AI chat conversation with your Grug Notes assistant or agent, stored in your account like other chats
- The AI assistant's responses may create or update notes in your account
- Voice notes sent via Telegram are transcribed using the providers described in Section 3
- If you enable Telegram for an AI agent, that agent's messages are delivered to you through Telegram
- Message content passes through Telegram's platform and is subject to Telegram's privacy policy (https://telegram.org/privacy)
- You can disconnect Telegram at any time in the app; disconnecting stops all Telegram message processing


6. GOOGLE CALENDAR INTEGRATION

If you enable Google Calendar sync, we access your calendar data through Google's API.

What Calendar Data We Receive

When you enable calendar sync, Google's API sends us your calendar events. While Google returns full event data, we only extract and use:
- Event titles (summary)
- Event dates
- Event descriptions (notes)
- Event status (to detect deletions)
- Metadata for sync (event IDs, modification timestamps)

What We Do NOT Extract or Store

We do not extract, store, or process: attendees, locations, video conference links, reminders, recurrence rules, or other event metadata.

How We Use Calendar Data

- Create events in your Google Calendar from your notes
- Import events from Google Calendar as notes
- Sync changes bidirectionally based on your settings

Data Storage

- Calendar event content (titles, descriptions, dates) is stored in our database (Cloud SQL) as notes
- Sync metadata (event IDs, change detection hashes) is stored to enable synchronization
- This data is retained while your calendar sync is active
- When you disable sync, the sync mappings are removed. Your notes remain until you delete them.
- When you delete your account, all associated data including calendar sync data is deleted.

What We Do NOT Do

- We do NOT share calendar data with third parties beyond Google (whose API is required to provide the sync feature)
- We do NOT use calendar data for advertising
- We do NOT train AI models on your calendar data

Google API Limited Use Disclosure

Grug Notes' use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.

You can disconnect Google Calendar at any time in Settings.


6A. APPLE HEALTH INTEGRATION

If you enable the Apple Health workout import in the Grug Notes iOS app, we read workout data from Apple Health (HealthKit) and turn each workout into a note, sorted into a prompt per activity (for example Run, Ride, Swim) that is created automatically as that activity first appears, with anything unrecognized going to an "Apple Health" prompt. You can re-point any activity at a different prompt in the app. This feature is off by default, requires your explicit consent to a versioned disclosure in the app, and additionally requires granting read access in iOS's own Health permission screen.

What Health Data We Receive

We read only workout summaries, and only from source apps you individually approve:
- Workout type and name
- Start and end time, including the workout's time zone
- Distance and duration
- Average and maximum heart rate
- Active energy (calories)
- Elevation gain, when the recording app provides it
- The identity of the app that recorded the workout

We do not read routes or GPS coordinates, and we never write anything to Apple Health. Access is read-only and one-way.

How We Use Health Data

- Imported workouts become regular notes in your account, dated to the day the workout happened
- Like your other notes, imported workout notes are processed by the AI service providers listed in section 4 (OpenAI, Anthropic, Google, Groq, Fireworks AI, Baseten; and xAI or Meta only if you choose their models) to power search and the AI note features you use. These providers process the data on our behalf under terms that prohibit using it for their own purposes or to train their models
- The general provider and telemetry disclosures in section 4 do not authorize additional uses of imported health data beyond the limits in this section and your health consent
- We do NOT use health data for advertising or marketing
- We do NOT use health data to train AI models (ours or anyone's)
- We do NOT use health data for cross-user analytics
- We do NOT store health data in iCloud

Data Storage and Retention

- Imported workout notes are stored in our database like any other note, and in our search index to make them searchable
- A small import ledger (workout identifiers and sync bookkeeping) is stored to prevent duplicate imports
- Imported notes are yours: they remain until you delete them, and deleting a note in Grug Notes never deletes anything from Apple Health

Stopping and Deleting

- You can pause the import, remove approved source apps, or revoke your health consent at any time in the iOS app (Settings > Connections > Apple Health); pausing is also available on the web settings page
- Revoking consent stops all syncing immediately; already-imported notes stay in your account until you delete them
- Deleting your account deletes imported workout notes, the import ledger, and derived search data, as described in section 10


6B. LOCATION DIARY

If you enable the location diary in the Grug Notes iOS app, your iPhone tells Grug Notes when you arrive at and leave a place, using iOS's low-power visit detection (CoreLocation visit monitoring). Grug Notes never runs continuous location tracking. Each arrival and each departure becomes one line in a "Places" note for that day, in the prompt you choose; lines are appended as they happen and never rewritten. This feature is off by default, requires your explicit consent to a versioned disclosure in the app, and additionally requires granting location access in iOS's own permission screen.

What Location Data We Receive

For each arrival and each departure, the iOS app sends us only:
- The name of the place (a name you gave it, a point-of-interest name, or a street and locality from reverse geocoding)
- The time of the arrival or departure, and the time zone it is in

Coordinates (latitude and longitude) are never sent to or stored by Grug Notes, rounded or otherwise. To look up a place name, the iOS app may send the coordinate of a place to Apple's geocoding service (CLGeocoder / MapKit); that request goes from your phone to Apple under Apple's privacy terms, and Grug Notes does not receive the coordinate. Places you mark "Don't log this place" are dropped on the phone and never sent.

How We Use Location Data

- Visit lines become part of a regular note in your account, dated to the day of the visit
- Like your other notes, Places notes are processed by the AI service providers listed in section 4 to power search and the AI note features you use, under terms that prohibit using the data for their own purposes or to train their models
- The general provider and telemetry disclosures in section 4 do not authorize additional uses of imported location data beyond the limits in this section and your location consent
- We do NOT use location data for advertising or marketing
- We do NOT use location data to train AI models (ours or anyone's)
- We do NOT use location data for cross-user analytics
- We do NOT build movement profiles or share location data with data brokers

Data Storage and Retention

- Places notes are stored in our database like any other note, and in our search index to make them searchable
- A small import ledger (visit identifiers and sync bookkeeping, with no coordinates) is stored to prevent duplicate lines
- Places notes are yours: they remain until you delete them. Deleting a Places note deletes its visit lines from your account; the corresponding ledger entries stop being used and are removed with your account
- Raw visit coordinates kept on your phone for matching repeat visits are pruned after 30 days and never leave the phone for Grug Notes

Stopping and Deleting

- You can pause logging or revoke your location consent at any time in the iOS app (Settings > Connections > Location); pausing and revoking are also available on the web settings page
- Revoking consent stops logging immediately; already-written Places notes stay in your account until you delete them
- Turning off location access in iOS Settings also stops logging
- Deleting your account deletes Places notes, the import ledger, and derived search data, as described in section 10


7. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to:

Essential Cookies (Required)
- Maintain your login session
- Remember your preferences
- Ensure security and prevent fraud

Analytics Cookies
- We do not currently use analytics cookies or third-party analytics services
- We may introduce analytics in the future to understand usage patterns and improve the Service
- If we add analytics, we will update this policy and provide opt-out options

You can control cookies through your browser settings. Disabling essential cookies may prevent you from using certain features.

We do not use advertising cookies or track you for advertising purposes across other websites.


8. SOCIAL MEDIA LOGINS

We offer the option to register or log in using your Google Account.

When you use Google social login, we collect:
- Your name and email address from the social media provider
- Profile picture (if you grant permission)
- Other information you authorize the provider to share

We do not access your social media content, friends list, or post on your behalf without explicit permission.


9. INTERNATIONAL DATA TRANSFERS

Our Service is operated from the United States. If you access the Service from outside the US, your information will be transferred to, stored, and processed in the United States.

Third-party service providers may be located in various countries:
- AI providers may process data in the US and other regions
- Cloud infrastructure operates globally

We ensure that international transfers comply with applicable data protection laws, including using:
- Standard contractual clauses
- Adequacy decisions
- Other lawful transfer mechanisms


10. DATA RETENTION

Account Data
- We retain your account information and content while your account is active
- You can delete your account directly in the iOS app (Settings > Delete Account) or by contacting us at keizo@grugnotes.com

Account Deletion Process
- In-app deletion requires you to re-authenticate, and is scheduled with a 48-hour grace period during which you can cancel
- For email requests, we will confirm your identity and intent upon receiving the request
- We will delete your account data from our active systems
- Some data may be retained temporarily in backups during normal backup retention cycles
- We may retain certain information if required by law (e.g., transaction records for tax purposes)
- Third-party services (AI providers, Pinecone) will also delete or stop processing your data per their retention policies

Specific Retention Periods

Notes and Chats: Retained until you delete them or request account deletion
Email Ingestion Data: Original emails deleted from S3 within 1 day; notes persist until you delete them
Voice Recordings: Audio uploaded for transcription is deleted from our storage after transcription completes (with a storage lifecycle policy as a backstop); the resulting transcript persists as part of your notes until you delete it
Vector Embeddings: Automatically deleted from Pinecone when corresponding notes are deleted
Payment Records: Retained for 7 years for tax and legal compliance
Support Communications: Retained for 3 years

AI Provider Retention

Provider retention periods may differ from our own. TypeSafe's published terms do not specify a fixed retention period for API inputs and outputs. They provide for retention based on the processing purpose and legal requirements, and allow confidential information to remain in standard backups subject to confidentiality protections. We do not promise zero retention or immediate deletion by TypeSafe. Requests to exercise your data rights can be made through us as described in sections 13 and 20.


11. DATA SECURITY

We implement industry-standard security measures to protect your information:

Technical Safeguards
- Encryption in transit (TLS/SSL)
- Encryption at rest for sensitive data
- Secure password hashing (industry-standard algorithms)
- Regular security updates and patches

Organizational Safeguards
- Limited employee access to personal data (on a need-to-know basis)
- Appropriate vetting for personnel with data access
- Security training for staff
- Incident response procedures

Access Controls
- Unique email address security for email ingestion
- Regular access reviews

Third-Party Security
- All third-party providers are required to maintain appropriate security measures
- We review providers' security practices before engagement

Limitations

No security system is 100% secure. While we take reasonable precautions, we cannot guarantee absolute security. You are responsible for:
- Keeping your password secure
- Not sharing your account credentials
- Keeping your email forwarding addresses confidential


12. CHILDREN'S PRIVACY

Grug Notes is not intended for children under 13 years of age.

We do not knowingly collect information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at keizo@grugnotes.com and we will delete the information.


13. YOUR PRIVACY RIGHTS

Depending on your location, you may have the following rights:

Self-Service (available anytime in the app)
- Access: View all your notes and chats through the Service
- Export: Download your notes in Markdown format
- Correction: Edit your notes and profile information directly
- Deletion: Delete your account directly in the iOS app (Settings > Delete Account)

Request-Based (contact keizo@grugnotes.com)
- Full Data Export: Receive all your data (notes, chats, preferences) in machine-readable format (JSON or CSV)
- Deletion: Request permanent deletion of your account and all associated data
- Object: Object to processing of your personal information
- Restrict: Request restriction of processing
- Withdraw Consent: Withdraw consent where processing is based on consent

See Section 20 for data subject access request procedures.


14. GDPR RIGHTS (EUROPEAN USERS)

If you are in the European Economic Area (EEA), UK, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

Legal Basis for Processing

We process your information based on:
- Contract: To provide the Service you've signed up for
- Legitimate Interests: To improve the Service, prevent fraud, and ensure security
- Consent: For optional features like marketing communications
- Legal Obligation: To comply with applicable laws

Your GDPR Rights

- Right to access your personal data
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object to processing
- Right to withdraw consent
- Right to lodge a complaint with a supervisory authority

Data Protection Officer

For GDPR-related inquiries, contact: keizo@grugnotes.com

Supervisory Authority

You have the right to lodge a complaint with your local data protection authority if you believe we have violated your rights under GDPR.


15. CCPA/CPRA RIGHTS (CALIFORNIA RESIDENTS)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights:

Your CCPA Rights

Right to Know: Request information about the categories and specific pieces of personal information we collect, use, and disclose

Right to Delete: Request deletion of your personal information (subject to certain exceptions)

Right to Opt-Out: Opt-out of "sale" of personal information (Note: We do not sell personal information)

Right to Non-Discrimination: Not receive discriminatory treatment for exercising your CCPA rights

Categories of Information We Collect

- Identifiers (email, username)
- Commercial information (subscription, payment history)
- Internet activity (usage data, interactions with Service)
- User-generated content (notes, chats, emails)
- Audio/voice data (for transcription)

How We Use Information

- Provide and improve the Service
- Process transactions
- Communicate with you
- Ensure security and prevent fraud
- Comply with legal obligations

Third Parties We Share With

- Service providers (cloud hosting, payment processing, AI services)
- Professional advisors (lawyers, accountants)
- Law enforcement (when required by law)

How to Exercise Your Rights

Email: keizo@grugnotes.com
Subject: "CCPA Privacy Request"
Include: Your name, email, and specific request

We will respond within 45 days.


16. OTHER US STATE PRIVACY RIGHTS

If you reside in a US state with comprehensive privacy legislation (such as Virginia, Colorado, Connecticut, Texas, Oregon, and others), you may have similar rights to those described in the CCPA/CPRA section, including:

- Right to access your personal information
- Right to correct inaccuracies
- Right to delete your information
- Right to opt-out of certain processing activities
- Right to data portability

To exercise these rights, contact us at keizo@grugnotes.com.


17. DO-NOT-TRACK SIGNALS

We do not currently respond to Do-Not-Track (DNT) browser signals. We do not track users across third-party websites for advertising purposes.


18. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect:
- Changes to our practices
- Changes in applicable laws
- New features or services
- User feedback

When we make material changes, we will:
- Update the "Last Updated" date at the top
- Notify you via email
- Display a notice on the Service
- Request your consent if required by law

Continued use of the Service after changes constitutes acceptance of the updated policy.


19. CONTACT INFORMATION

For questions, concerns, or requests regarding this Privacy Policy:

Email: keizo@grugnotes.com

Company:
Kamanu Composites, LLC
Hawai'i, United States

Response Time:
We aim to respond to all inquiries within 7 business days.


20. DATA SUBJECT ACCESS REQUESTS

How to Submit a Request

To exercise your privacy rights, you may:

1. Email us at keizo@grugnotes.com with subject: "Privacy Rights Request"

2. Submit a request through our data subject access request form: https://app.termly.io/notify/99d00b31-49d5-4b58-97b3-8d840fd40a84

3. Access your data anytime through your account

4. Delete your account directly in the iOS app (Settings > Delete Account)

Information to Include

Please provide:
- Your full name
- Email address associated with your account
- Specific request (access, delete, correct, export, etc.)
- Description of information you're requesting (if applicable)
- Proof of identity (to prevent unauthorized access)

Verification Process

To protect your privacy, we must verify your identity before processing requests. We may:
- Send a verification email to your registered email address
- Ask security questions about your account
- Request additional identification if necessary

Response Timeline

We will respond to your request:
- Within 30 days (GDPR)
- Within 45 days (CCPA and other US state laws)
- Extensions may apply for complex requests (we will notify you)

No Fee

We do not charge a fee to process privacy requests unless:
- The request is clearly unfounded or excessive
- You request multiple copies of the same information

We will notify you of any fees before processing.

Available Request Types

Access Request: Receive a copy of your personal information in a structured, commonly used format (JSON or CSV)

Deletion Request: Request permanent deletion of your account and all associated data
- We will process your request and confirm when deletion is complete
- Some data may be retained as required by law (e.g., billing records)
- Data in backups will be removed during normal backup rotation cycles
- Third-party services will stop processing your data per their retention policies

Correction Request: Update inaccurate or incomplete information
- You can make some corrections directly in your account settings

Export Request: Download all your data (notes, chats, preferences) in machine-readable format

Objection Request: Object to certain types of processing (subject to legal limitations)

Restriction Request: Limit how we process your information (subject to legal limitations)

Portability Request: Receive your data in a format that can be transferred to another service

Appeal Process

If you are not satisfied with our response to your request:
1. Email keizo@grugnotes.com with subject: "Privacy Request Appeal"
2. Explain why you believe our response was inadequate
3. We will review and respond within 30 days

You also have the right to lodge a complaint with your local data protection authority.


MISCELLANEOUS

Entire Agreement

This Privacy Policy, together with our Terms of Service, constitutes the entire agreement regarding your use of the Service.

Severability

If any provision of this Privacy Policy is found to be unenforceable, the remaining provisions will remain in full effect.

Waiver

Our failure to enforce any provision of this Privacy Policy does not constitute a waiver of that provision.

Governing Law

This Privacy Policy is governed by the laws of the State of Hawaii, without regard to conflict of law principles.


ACKNOWLEDGMENT

By using Grug Notes, you acknowledge that you have read, understood, and agree to this Privacy Policy.

If you do not agree with this Privacy Policy, please discontinue use of the Service.

Thank you for trusting Grug Notes with your information.