Privacy Policy

Toto Ventures Inc. (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile applications (collectively, the “Apps”). Please read this Privacy Policy carefully.

By using our Apps, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our Apps.

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## 1. Information We Collect

We collect different types of information depending on which App you use and how you use it.

### 1.1 Information We Do NOT Collect

**We do not collect personal identifying information such as:**
– Names
– Email addresses
– Phone numbers
– Physical addresses
– Payment or credit card information

**We do not require account creation.** All payment processing for in-app purchases and subscriptions is handled directly by Apple through the App Store. We do not have access to any account or payment information.

### 1.2 Health and Fitness Data (HealthKit)

Some of our Apps integrate with Apple HealthKit to provide health and fitness features. If you grant permission, we may access:
– Steps and activity data
– Workout information
– Heart rate data
– Calories burned
– Distance traveled
– Other health metrics you authorize

**Important commitments regarding HealthKit data:**
– **We will never use HealthKit data for advertising or marketing purposes**
– **We will never sell HealthKit data to third parties, data brokers, or information resellers**
– HealthKit data is only used to provide health and fitness features within the App
– HealthKit data is stored locally on your device and may sync via iCloud (controlled by your Apple settings)
– In some Apps, we may store minimal health data (such as workout summaries or statistics) using Firebase Cloud Storage to enable features like syncing across devices or displaying historical trends
– You can revoke HealthKit permissions at any time in your iOS Settings under Privacy → Health

### 1.3 Usage and Analytics Data

We automatically collect information about how you use our Apps, including:
– **App usage data** – Features you use, screens viewed, time spent in the App, button clicks
– **Device information** – Device model, operating system version, language settings, timezone
– **Unique identifiers** – Anonymous device IDs (not linked to your personal identity)
– **Log data** – Crash reports, error logs, performance data
– **Analytics data** – Aggregated statistics about App usage, session duration, and user engagement

This data helps us understand how people use our Apps so we can improve performance, fix bugs, and develop new features.

### 1.4 Location Data

Some Apps may request access to your approximate or precise location for features like:
– Fitness tracking (e.g., mapping runs or walks)
– Weather information
– Location-based App functionality

**We do not:**
– Share your location with third parties for advertising
– Track your location when the App is not in use (unless you explicitly enable background location for fitness tracking)
– Store location history beyond what’s necessary for App functionality

You can control location permissions at any time in your iOS Settings.

### 1.5 User-Generated Content

If you create or upload content within our Apps (such as notes, photos, workout logs, or other data), we store that content to provide App functionality.

– Most user content is stored locally on your device or in your personal iCloud account
– Some Apps may use Firebase Cloud Storage to sync your content across devices or provide cloud backup features
– Some Apps may send user-uploaded videos to third-party processing services (such as HeyGen) to provide translation and lip-sync features. These videos are associated with anonymous user IDs and are not linked to your personal identity.
– This content is associated with an anonymous user ID or your device, not with personally identifiable information like your name or email

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## 2. How We Use Your Information

We use the information we collect for the following purposes:

### 2.1 To Provide and Improve Our Services
– Deliver core App features and functionality
– Display your personal data (workouts, statistics, etc.) within the App
– Sync your data across your devices using iCloud or Firebase Cloud Storage
– Analyze usage patterns to improve App performance and user experience
– Identify and fix bugs, crashes, and technical issues
– Develop new features based on how users interact with the Apps

### 2.2 To Ensure Security and Prevent Fraud
– Detect and prevent fraudulent activity, abuse, or security issues
– Monitor for violations of our Terms of Use
– Protect the rights, property, and safety of Toto Ventures Inc., our users, and the public

### 2.3 To Comply with Legal Obligations
– Respond to legal requests from law enforcement or government authorities
– Enforce our Terms of Use and other agreements
– Protect against legal liability

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## 3. How We Share Your Information

**We do not sell, rent, or trade your personal data to anyone.**

We may share your information only in the following limited circumstances:

### 3.1 With Third-Party Service Providers

We use trusted third-party services to help us operate our Apps and analyze usage. These providers have access to your information only to perform specific tasks on our behalf and are obligated to protect your data.

**Third-party services we use:**

**Firebase (Google LLC)**
– Purpose: Analytics, crash reporting, performance monitoring, and may include cloud storage for app data syncing
– Data shared: Device identifiers, usage statistics, crash logs, App events, and in some Apps, user-generated content (workout data, notes, settings) stored anonymously
– Privacy Policy: https://firebase.google.com/support/privacy

**RevenueCat**
– Purpose: Subscription and in-app purchase management
– Data shared: Anonymous device IDs, purchase events, subscription status
– Privacy Policy: https://www.revenuecat.com/privacy

**HeyGen (HeyGen Inc.)**
– Purpose: Video translation and lip-sync processing
– Data shared: Videos you submit for translation are sent to HeyGen’s servers for processing. Videos are associated with an anonymous user ID, not your personal identity.
– Videos are used solely to perform the requested translation and are not used for advertising or marketing purposes
– Video data is retained by HeyGen in accordance with their privacy policy
– Privacy Policy: https://www.heygen.com/privacy

**Other Analytics Services**
– We may use additional analytics tools to understand App usage and improve user experience
– These services receive only anonymized, aggregated data
– No personally identifiable information is shared

### 3.2 For Legal Reasons

We may disclose your information if required to do so by law or if we believe in good faith that such action is necessary to:
– Comply with legal obligations, court orders, or government requests
– Enforce our Terms of Use or investigate potential violations
– Protect the rights, property, or safety of Toto Ventures Inc., our users, or the public
– Detect, prevent, or address fraud, security, or technical issues

### 3.3 Business Transfers

If Toto Ventures Inc. is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be transferred as part of that transaction. We will notify you via a prominent notice in the App or via other means if your information becomes subject to a different privacy policy.

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## 4. In-App Purchases and Subscriptions

Some of our Apps offer in-app purchases and subscription services (collectively, “Paid Features”). By purchasing Paid Features, you agree to the following:

### 4.1 Payment and Billing
– All purchases are processed through the Apple App Store
– Prices are displayed in your local currency and may include applicable taxes
– Payment will be charged to your Apple ID account at confirmation of purchase
– We do not have access to your payment information; all transactions are handled by Apple

### 4.2 Subscriptions
– Subscriptions automatically renew unless auto-renew is turned off at least 24 hours before the end of the current period
– Your account will be charged for renewal within 24 hours prior to the end of the current period
– You can manage your subscriptions and turn off auto-renewal in your Apple ID Account Settings
– The subscription price may be subject to change with notice; changes will apply to subsequent subscription periods

### 4.3 Free Trials
– Some subscriptions may offer a free trial period
– If you do not cancel before the trial period ends, you will be automatically charged for the subscription
– You can cancel your free trial at any time through your Apple ID Account Settings

### 4.4 Refunds and Cancellations
– Refund policies are governed by Apple’s App Store refund policies
– To request a refund, contact Apple Support directly
– Canceling a subscription will stop future billing but will not refund the current billing period
– You will retain access to Paid Features until the end of your current billing period

### 4.5 Changes to Pricing
– We reserve the right to modify subscription prices at any time
– Price changes for existing subscribers will take effect at the start of the next subscription period after notice is provided
– Continued use of the subscription after a price change constitutes acceptance of the new price

### 4.6 Subscription Terms
By subscribing to any Paid Features, you acknowledge that:
– Content, features, and availability of Paid Features may change over time
– We may modify, discontinue, or add features to subscriptions at our discretion
– Access to Paid Features is contingent on maintaining an active subscription
– Sharing subscription access with others is prohibited unless explicitly allowed

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## 5. Data Retention

We retain minimal data. The majority of your information is stored locally on your device or in your personal iCloud account. In some Apps, we may use Firebase Cloud Storage to enable syncing and backup features.

– **Usage and analytics data**: Anonymous analytics are retained for up to 24 months for improving App performance, then deleted or anonymized
– **HealthKit data**: Stored locally on your device and synced via your personal iCloud (if enabled). Some Apps may store workout summaries or statistics in Firebase Cloud Storage for syncing across devices.
– **User-generated content**: Primarily stored locally on your device or in your personal iCloud. Some Apps may use Firebase Cloud Storage to enable cloud syncing and backup.
– **Video content**: Videos submitted for translation or lip-sync processing are sent to third-party services (such as HeyGen) and retained by those services in accordance with their respective privacy policies.
– **Log and crash data**: Anonymous crash reports and error logs are retained for up to 12 months for debugging purposes, then deleted

**Important:** When data is stored via Firebase Cloud Storage, it is associated with an anonymous user ID, not your name or email. Since the data is anonymized and not linked to personally identifiable information, it cannot be individually identified or deleted upon request. Deleting the App from your device will prevent any further data collection.

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## 6. Your Privacy Rights and Choices

You have control over your information and how it’s used.

### 6.1 Your Data Storage
– Most of your data (HealthKit, settings) is stored on your device or in your personal iCloud account
– Some Apps may use Firebase Cloud Storage to enable syncing across devices or cloud backup
– Data stored via Firebase is associated with an anonymous user ID, not your personal identity

### 6.2 Delete Your Data
– Deleting the App from your device removes all locally stored App data
– To delete data stored in your iCloud, go to iOS Settings → Your Name → iCloud → Manage Storage → [App Name] → Delete Data
– For Apps that use Firebase Cloud Storage, data is stored with anonymous device IDs that cannot be linked back to you personally. Deleting the App will stop any further data collection.
– Anonymous analytics data cannot be traced back to you and will be automatically deleted after the retention period

### 6.3 HealthKit Permissions
– Revoke HealthKit access anytime in iOS Settings → Privacy → Health
– Revoking access prevents the App from reading or writing health data
– Existing health data remains in your Health app unless you delete it manually

### 6.4 Location Permissions
– Control location access in iOS Settings → Privacy → Location Services
– You can choose “Never,” “While Using the App,” or “Always”

### 6.5 Analytics Opt-Out
– You can limit analytics tracking in iOS Settings → Privacy → Analytics & Improvements → Share iPhone Analytics (turn off)
– Note: This is a device-level setting that affects all apps

### 6.6 Manage Subscriptions
– Subscriptions are managed through your Apple ID Account Settings
– We do not have access to your subscription or billing information

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## 7. Data Security

We take reasonable measures to protect your information from unauthorized access, loss, misuse, or alteration. However, no method of transmission over the internet or electronic storage is 100% secure.

**Security measures we implement:**
– Encryption of data in transit using industry-standard protocols (HTTPS/TLS)
– Secure cloud storage with access controls (when using Firebase)
– Regular security audits and updates
– Limited employee access to user data

**Please note:** While we strive to protect your information, we cannot guarantee absolute security. You use our Apps at your own risk.

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## 8. Third-Party Services and Links

Our Apps may contain links to third-party websites or services that are not owned or controlled by Toto Ventures Inc. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

**Third-Party Payment Processing:** All payment transactions for in-app purchases and subscriptions are processed by Apple through the App Store. We do not collect, store, or have access to your payment information. Your use of Apple’s payment services is subject to Apple’s Terms of Service and Privacy Policy.

You acknowledge and agree that we shall not be liable for any damage or loss caused by your use of any third-party content, goods, or services.

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## 9. Children’s Privacy

Our Apps are appropriate for children under the age of 13. We are committed to protecting children’s privacy and comply with the Children’s Online Privacy Protection Act (COPPA).

**What We Collect from Children:**
– We do not knowingly collect personal information from children, including names, email addresses, or any other personally identifiable information
– We only collect anonymous usage data and analytics (as described in Section 1.3) that cannot be used to identify individual children
– If an App uses HealthKit, parents/guardians must grant permission through iOS settings

**Parental Controls:**
– Parents and guardians can control App permissions (HealthKit, Location, etc.) through iOS Settings
– Parents can delete all App data by deleting the App from the device
– Parents can manage in-app purchases through Screen Time restrictions in iOS Settings

We recommend that parents and guardians monitor their children’s use of mobile applications and educate them about online safety.

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## 10. International Users

Our Apps are available worldwide. If you are using our Apps from outside Canada, please be aware that your information may be transferred to, stored, and processed in Canada or other countries where our service providers (such as Google/Firebase) operate.

By using our Apps, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection laws.

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## 11. California Privacy Rights (CCPA)

If you are a California resident, you have certain rights regarding your personal information under the California Consumer Privacy Act (CCPA):
– Right to know what personal information we collect, use, and share
– Right to request deletion of your personal information
– Right to opt-out of the sale of personal information (note: we do not sell personal information)

**Important:** Because we do not collect personally identifiable information and all data is associated with anonymous device IDs, we cannot identify or delete specific user data upon request. Most of your data is stored locally on your device or in your personal iCloud account, which you control directly. Deleting the App removes all local data and stops further data collection.

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## 12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:
– Update the “Last Updated” date at the top of this policy
– Notify you of significant changes through the App or other appropriate means
– For material changes, we may require you to accept the updated policy to continue using the App

Your continued use of our Apps after changes to this Privacy Policy constitutes your acceptance of the updated policy.

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## 13. Contact Us

If you have questions or concerns regarding this Privacy Policy, you may contact us at contact @ totoventures.com.

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## Summary

**Quick Overview:**
– We collect minimal personal data (no names, emails, or payment info)
– Most data is stored locally on your device or in your personal iCloud
– Some Apps may use Firebase Cloud Storage for syncing and backup (associated with anonymous IDs only)
– HealthKit data is never used for ads or sold to third parties
– We only collect anonymous analytics (Firebase, RevenueCat) to improve the Apps
– You can delete your data by deleting the App and managing your iCloud settings
– We do not sell your information to anyone