Privacy Policy

Last updated: October 2025

Tuulis Labs LLC (“Tuulis,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy describes how Tuulis collects, uses, discloses, and safeguards information in connection with your use of the Tuulis mobile application, website, and related features and services (collectively, the “Services”). By using the Services, you consent to the practices described below. If you do not agree, please discontinue use of the Services.

1. Information We Collect

 

a. Information You Provide Directly

We collect the following information that you voluntarily submit:

    • Account Information – Name, email address, authentication credentials, and account preferences.
    • Payment Information – Handled by secure third-party processors (e.g., Apple, Stripe). Tuulis does not store payment information.
    • Communications and Support – Messages you send to us, customer-support requests, and any other details you choose to provide.
    • User Content – Text, prompts, affirmations, reflections, or other material you input through the Services (“User Content”).

b. Information Collected Automatically

When you use Tuulis, we automatically collect:

    • Device and System Data – IP address, device type, operating system, app version, and performance logs.
    • Usage Data – Feature interactions, session times, crash reports, and diagnostic events.
    • Cookies / SDKs – Small data files or software tools that help deliver functionality, security, and analytics.

c. Information from Other Sources

We may receive limited data from our service providers (for example, analytics or payment partners) to verify payments, improve performance, or detect fraud.

2. How We Use Your Information

We process information to:

  1. Provide, maintain, and improve the Services.
  2. Personalize your in-app experience and recommendations.
  3. Process payments and manage subscriptions.
  4. Communicate with you regarding updates, support, and important notices.
  5. Detect, prevent, and respond to misuse, fraud, or security incidents.
  6. Comply with legal obligations and enforce our Terms of Service.
  7. Generate aggregated or de-identified data for analytics, research, and product development.

International Users and Legal Basis for Processing
If you are located outside the United States, including within the European Union, the European Economic Area, or the United Kingdom, your information may be processed in accordance with applicable data protection laws. Tuulis relies on lawful bases such as consent, the performance of a contract, and legitimate interests (including providing and improving the Services and maintaining security) as required by your local regulations.

3. Anonymized Analytics and Security Logs

We maintain two categories of data processing:

  • Anonymized Analytics
    • Data stripped of personal identifiers and combined with other user data to analyze trends and improve Tuulis. These datasets cannot reasonably identify you.
  • Security and Audit Logs
    • Limited identifiable logs (such as account ID, IP address, device identifier, and timestamps) retained for detecting and investigating abuse, enforcing Terms, and complying with legal requirements. Access to such logs is restricted to authorized personnel. Identifiable logs are retained for 90 days by default unless extended for an active investigation or legal hold.

4. How We Share Information

We do not sell or rent your personal information. We may disclose information only:

  • To Service Providers – Vendors under written contracts who process data solely to provide hosting, analytics, customer support, or payment services.
  • For Legal and Safety Reasons – When required by law, subpoena, court order, or to protect the rights, property, or safety of Tuulis, our users, or others.
  • In Business Transactions – In the event of a merger, acquisition, reorganization, or sale of assets, subject to equivalent confidentiality and security safeguards.
  • With Your Consent – When you direct us to share or connect your account with another service.

5. Data Retention

We retain personal information only as long as reasonably necessary to fulfill the purposes above or as required by law. When data is no longer needed, we securely delete or anonymize it.

6. Your Rights

Depending on where you live, you may have the following rights:

  • Access & Portability
    Request a copy of the personal data we hold about you.
  • Correction & Deletion
    Request correction or deletion of your personal data.
  • Restriction & Objection
    Limit or object to certain processing activities.
  • Opt-Out of Sale/Sharing
    Tuulis does not sell or share personal information as those terms are defined under applicable privacy laws. You may still contact us to confirm that no such sale or sharing occurs.

To exercise these rights, email support@tuulis.app. We may verify your identity before processing a request.

7. Security

We use technical, administrative, and physical safeguards, including encryption, access controls, and network security measures, to protect your information. However, no system is completely secure; you use the Services at your own risk.

8. Children’s Privacy

The Services are not directed to children under 13. We do not knowingly collect personal information from anyone under 13. If we learn that such data has been collected, we will delete it promptly. If you believe that we may have collected information from a child under 13, please contact us at support@tuulis.app

9. International Data Transfers

Tuulis operates in the United States. If you access the Services from outside the U.S., you consent to the transfer and processing of your information in the U.S. where privacy laws may differ. We implement appropriate safeguards, such as Standard Contractual Clauses, for international transfers where required.

10. Enforcement and Accountability

For investigating or enforcing our Terms of Service, Tuulis may retain and review account and system logs containing limited identifiers (including account IDs, IP addresses, device identifiers, and timestamps). Authorized personnel may re-identify pseudonymous data when necessary to investigate abuse, fraud, or legal requests. All such access is logged and limited to legitimate purposes.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other operational reasons. When we make material updates, we will:

  • Revise the “Last Updated” date at the top of this Policy;
  • Post the updated version within the Tuulis App and on our website; and
  • Where required by law or deemed appropriate, notify you by email or through in-app notice prior to the change taking effect.

Your continued use of the Services after the effective date of any revised Policy constitutes your acknowledgment and acceptance of those changes.

12. Contact Us

If you have questions, concerns, or requests regarding this Policy:

Email: support@tuulis.app
Company: Tuulis Labs LLC