Privacy Policy

1. Data Controller

2. Data We Collect

2.1 Data Stored Locally on Your Device

The following data is stored only on your device and is never transmitted to our servers:

• Email/Chat Credentials: Your IMAP passwords, API tokens for Slack, Discord, Chatwork, Jira, Trello, and Redmine are stored in encrypted secure storage (iOS Keychain / Android KeyStore)
• AI API Keys: Your Google Gemini API key is stored in encrypted secure storage
• Profile Configurations: Connection settings, schedules, filters, and preferences
• Analysis Results: AI-generated summaries, extracted tasks, and thread data
• Message Content: Fetched emails and chat messages for local processing

2.2 Data Transmitted to Third-Party Services

When you use TL;2DO, the app connects directly to third-party services using your own credentials:

• Email Providers: Your email content is fetched via IMAP directly from your email server
• Chat Platforms: Messages are fetched directly from Slack, Discord, Chatwork, etc. using their APIs
• Google Gemini API: Message content is sent to Google's AI service for analysis using your personal API key

Important: These transmissions occur directly between your device and the third-party service. Original Device LLC does not receive, store, or have access to this data.

2.3 Data We Do NOT Collect

• We do not collect your email content or chat messages
• We do not collect your credentials or API keys
• We do not collect analytics or usage telemetry (unless you opt in)
• We do not collect device identifiers for tracking purposes
• We do not collect location data

3. Purpose and Legal Basis for Processing

4. Data Retention

• Local App Data: Retained on your device until you delete it or uninstall the app
• Analysis History: Free tier: 3 days; Premium: 30 days (configurable, stored locally)
• Support Correspondence: Retained for up to 2 years for quality assurance
• Subscription Records: Managed by Apple App Store / Google Play per their policies

You can delete all local data at any time by clearing app data or uninstalling the app.

5. Your Rights Under GDPR

As a data subject, you have the following rights:

To exercise any of these rights, please contact us at tl2do@tl2do.com. We will respond within 30 days.

6. Third-Party Services

TL;2DO integrates with the following third-party services. When you connect these services, their respective privacy policies apply:

• Google Gemini API: Google Privacy Policy
• Apple App Store: Apple Privacy Policy (for iOS subscriptions)
• Google Play: Google Privacy Policy (for Android subscriptions)

For chat and email platforms (Slack, Discord, Gmail, etc.), you connect using your own credentials. We do not have access to your accounts or data on these platforms.

7. International Data Transfers

When you use the Google Gemini API, your message content may be transferred to Google's servers, which may be located outside your country of residence, including in the United States.

Google provides appropriate safeguards for international transfers, including Standard Contractual Clauses (SCCs) where required. For more information, see Google's data transfer frameworks.

Note: Original Device LLC does not transfer your personal data internationally, as we do not collect or store your personal data on our servers.

8. Data Security

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

• Encrypted Storage: Credentials and API keys are stored using iOS Keychain (AES-256) and Android KeyStore (hardware-backed encryption)
• Secure Connections: All network communications use TLS/HTTPS encryption
• Local Processing: Sensitive data processing occurs on your device, not on external servers
• No Plain Text Storage: Passwords and tokens are never stored in plain text
• Autofill Protection: Sensitive input fields are protected from autofill services on Android

9. Children's Privacy

TL;2DO is not intended for use by children under the age of 16. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected such data, please contact us immediately at tl2do@tl2do.com, and we will take steps to delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

• Posting the updated policy on this page with a new "Last Updated" date
• Displaying an in-app notification when significant changes occur

We encourage you to review this policy periodically. Continued use of the app after changes constitutes acceptance of the updated policy.

11. Contact Us

If you have any questions about this Privacy Policy, your personal data, or wish to exercise your rights, please contact us:

For EU residents, you also have the right to lodge a complaint with your local Data Protection Authority.