Buddy Privacy Notice

Our Role in Processing Personal Data

Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller’s instructions. This Privacy Notice describes our privacy practices where we are acting as the controller of personal data.

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and the Buddy application. For example, you may provide us your personal data directly when you create an account, use the AI browsing features, submit feedback, or otherwise contact us or interact with us.

We also collect personal data automatically when you interact with our application and may also collect personal data from other sources and third parties.

Personal Data Provided by Individuals

We collect the following categories of personal data that individuals provide to us:

• Account Information, including email address, usernames, passwords and a randomly generated unique device identifier that is stored securely on your device’s iOS keychain. We use this information primarily to create and maintain your account, authenticate your identity, save information on your behalf when using Buddy’s built-in password manager feauture, and communicate with you regarding the application and your account. If you choose to sign in with your Apple ID, we may also associate your Apple ID with your device identifier for authentication purposes.
• AI Browsing Inputs, including text prompts, commands, and messages you submit to the AI assistant while browsing. Buddy stores ordinary browser data such as history, bookmarks, downloads, and up to 50 AI chat sessions both locally on your device and on our servers. An AI request may also include a limited amount of prior conversation and device time zone and location. We transmit this information to our third-party AI service providers — currently Anthropic and SpaceXAI (formerly xAI, the provider of the Grok models) — via their application programming interfaces (APIs) to generate responses and perform actions on your behalf. Which provider handles a given request depends on the model selected for that feature, and we may add or change providers over time. See Anthropic’s commercial API retention documentation and SpaceXAI’s API security and retention documentation for reference; both state that API inputs and outputs are generally deleted within 30 days, subject to exceptions.
• Webpage Content, including limited page metadata, page content, screenshots, and information about actions you ask Buddy to perform. Outside Private Browsing, limited metadata such as the page URL, title, and open-tab information may be sent to us even when Use Page Context is off. When Use Page Context is on, Buddy may also send page text, structured information about visible controls and forms, and screenshots. If Suggested Actions is enabled, Buddy may send a page observation, recent conversation context, and a screenshot to generate a suggestion without a new message from you. Buddy can read, summarize, and interpret webpage content and navigate on your behalf, but it cannot bypass a website’s authentication or security controls, and it will not submit forms or complete transactions without your express confirmation, as further described below.
• Shared Report Content, including a report title, rendered report content, and eligible report images that you choose to publish. A published report is available to anyone who has its capability link until you revoke it or it expires. Buddy configures these pages not to be indexed by search engines, but recipients and messaging services may fetch them to display the existing rich link preview. Do not publish information you do not want link recipients to see.
• Form and Transaction Data, including personal information (such as name, address, payment details, and other data fields) that you direct the AI assistant to input into forms or use to complete transactions on third-party websites. The AI assistant will only submit forms or complete purchases after receiving your express confirmation. We do not independently store this information; it is processed solely to fulfill your directed action on the applicable third-party website.
• Assistant Memory, including durable facts or preferences you have expressed or signaled through your use of the services or predictions or characteristics we may infer about you based on the other personal data we collect and your interactions with the Buddy application, (for example, a preference to always book business class flights, or other specific preferences you share) which we use to personalize and improve your experience. The facts or preferences stored within Assistant Memory may be used as part of Buddy’s AI features. You can review, edit, or delete Assistant Memory in the application by using the methods described in the Your Privacy Choices section below.
• Payment Information, including payment card information, billing address, and other financial account information.. Please note that we use third-party payment providers, including Apple In-App Purchase (IAP) to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number, you provide these third-party payment providers in connection with payments. Rather, all such information is provided directly by you to our third-party payment providers. The payment provider’s use of your personal data is governed by their privacy notice
• Feedback, Inquiries and Support Information, including the contents of messages sent through our support channels, feedback forms, or email. We use this information primarily to investigate and respond to your inquiries and to improve our products and services.

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our products and services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s mobile device and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:

• Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
• Meta App Install Attribution Data, including device and app metadata plus install and activation events sent through Meta’s iOS SDK. We use this limited data to measure and optimize advertisements for Buddy on Meta services, including Instagram. Buddy disables Meta’s automatic App Events mode and does not send StoreKit purchases, AI messages, webpage content, browsing history, contacts, photos, or precise location through this integration.
• Information About the Way Individuals Use Our Services and Interact With Us, including the sites you visit through the services, how frequently you access our services, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, videos you watch, the communications you have through our services, and the content, links and ads you interact with), while using the AI features, timestamps, and general metadata logs about your use of our services (but not the substantive content of webpages, which is processed only in real time as described above). The technologies we deploy are designed to allow us and our third-party providers to collect detailed information about browsing behavior and actions that you take on our services, crash and error diagnostics, and other usage data which may record your scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our products or services, or engage in chat features or other communication platforms we provide.
• Information About Usage and Token Metadata, including the number and frequency of AI queries, token consumption, session duration, latency, response status, and feature usage patterns. We use this information to improve AI performance, identify and resolve errors, and enhance the browsing experience. Buddy records limited first-party product analytics under a random Buddy ID outside Private Browsing. This collection is separate from the optional Help us improve setting.
• Proposed TikTok Advertising Measurement Data, including the automatic app events InstallApp, LaunchAPP, and day-two retention, together with a TikTok SDK anonymous identifier, Apple’s Identifier for Vendor (IDFV), local IP address, user agent, locale, device model and operating-system version, Buddy version and build, session data, ATT status, and event timestamp. TikTok would use this information to measure and optimize campaigns that promote Buddy and would be Buddy’s only SKAdNetwork conversion-value updater. Buddy does not request App Tracking Transparency authorization; when authorization is unavailable, the SDK’s IDFA field is the all-zero value rather than a usable advertising identifier, and Buddy disables the integration if authorization is somehow already present. Buddy’s code disables enhanced-data postback, automatic purchase capture, and SDK logging and never calls TikTok identity or custom-event APIs. The reviewed TikTok 1.5.1 SDK preserves the local purchase opt-out after remote configuration. It can nevertheless accept server-side configuration that changes its network domain or enables diagnostics, crash collection, and debug screen capture. Because those upstream behaviors could expose additional data, the protected production gate remains off. That gate selects the ordinary Buddy target, which does not link the SDK, embed its credentials, or contain its load-time hooks. The isolated TikTok-enabled target will not ship until enforceable vendor controls, required-reason API declarations, tracking domains, and ATT treatment have been approved.
• Shared Report Interaction Data, including when a public report link is successfully fetched and whether the request appears to be a human browser visit or an automated preview, crawler, or prefetch. The retained traffic row contains the report’s internal share identifier, the report owner’s pseudonymous Buddy ID, the coarse request category, and timestamps. It does not contain the public capability or URL, visitor IP address, User-Agent, request headers, report title or content, or a visitor identifier. Human browser visits increment the lifetime view count shown to the report owner; automated fetches are counted separately and excluded from that number. This server-side public-link measurement is not controlled by the in-app Help us improve setting.
• Crash and Error Diagnostics, including anonymous native crash reports, app-hang or watchdog reports, and selected handled failures sent to Sentry after you select the optional Help us improve choice while turning on Buddy’s AI or enable it later in Settings, and while Private Browsing is off. Buddy configures Sentry not to attach a user profile, webpage content, screenshots, view hierarchy, URLs, AI messages or responses, request or response bodies, raw backend error messages, network breadcrumbs, session replay, or performance traces. Turning off Help us improve or entering Private Browsing stops future Sentry collection through Buddy.
• Search Suggestion Information, including normalized text entered into the address bar when it appears to be a search rather than a URL. Search Suggestions are enabled by default outside Private Browsing. When enabled, Google Suggest receives the query and processes it in accordance with its own privacy practices. Buddy does not forward your Buddy device ID or session token to Google. If you proceed to view search results on Google, your interaction with Google’s search results page is likewise governed by Google’s Privacy Policy. To view Google’s Privacy Policy, please click here.
• Suggestion Chips, may be presented to you automatically based on your browsing input and the Webpage Content, and may include selectable quick-action options (such as “highlight” or “summarize”) that Buddy may present to help you interact with the AI assistant more efficiently.
• Information About Your Location, including general geographic location that we or our third-party providers may derive from your IP address, as well as more precise geolocation when you grant us access through your device settings.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services and to improve the effectiveness of our products, services, offers, advertising, communications and customer service. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site (b) identify you across multiple devices; (c) provide and monitor the effectiveness of our services; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our products and services.

Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties:

• Single Sign-On: We may provide you the ability to log in to our services using Sign in with Apple. When you use this feature, we do not receive your Apple ID login credentials. Instead, we receive a token from Apple to help identify you in our system and confirm you successfully authenticated through your Apple ID. This information allows us to more easily provide you access to our products and services.
• Mobile Authentication: For our Password Manager feature, to access your passwords we may ask you to authenticate using a biometric authentication system used by your operating system (e.g., FaceID). We do not process or have access to any biometric information (such as facial or fingerprint data) you may use to authenticate on your device. All biometric processing occurs solely on your device through Apple’s iOS operating system; we only receive confirmation of whether the authentication was successful, and only if and when this feature is made available.
• Voice input. If you use dictation, Buddy uses Apple's Speech framework, which will send us the text content of your dictation. It prefers on-device transcription, but Apple may process audio on its servers when on-device recognition is unavailable for your language or device; in that case, Apple’s handling of your voice data is governed by Apple’s Privacy Policy. Microphone and speech-recognition access require iOS permission, which you can revoke in iOS Settings.
• Service Providers: Our service providers (e.g., Google) that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.
• AI Model Providers: We use third-party AI model providers (such as large language model providers through their APIs) to power the AI features of our application. These providers may return processed outputs based on your inputs, which we use to deliver the AI browsing experience to you.
• Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
• Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

Additional Uses of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

• Provide, operate, personalize and maintain the AI browsing features of the Buddy application, including reading and interpreting webpage content, navigating webpages, filling out forms, and completing transactions at your direction and with your express confirmation;
• Process and transmit your AI prompts and browsing inputs to third-party AI service providers to generate responses and carry out actions on your behalf;
• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our products and services, or to deliver the services requested
• Manage our organization and its day-to-day operations;
• Communicate with you, including via email and in-app notifications;
• Request you provide us feedback about our product and service offerings;
• Create and maintain your user account and verify your identity;
• Verify your identity and entitlement to our products and services;
• Address inquiries or complaints made by or about an individual in connection with the application;
• Develop, operate, improve, maintain, protect, and provide the features and functionality of the application, including by training or fine-tuning artificial intelligence and machine learning models used in connection with our services;
• Conduct research and analytics to understand usage patterns and improve our products and services;
• Measure and optimize advertising campaigns that promote Buddy using Meta install and activation events and, if approved, TikTok app-lifecycle events and Apple’s SKAdNetwork;
• Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
• Store and autofill your saved credentials through the Password Manager feature;
• Generate inferences about your preferences and interests to personalize and improve your experience;
• Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice;
• Help maintain and enhance the safety, security, and integrity of our application, technology, assets, and business;
• Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, carry out our obligations, and protect our business interests and the interests and rights of third parties;
• Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Whim and others;
• Comply with contractual and legal obligations and requirements;
• Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

As noted above, we may use your personal data to improve our services and train or fine-tune the artificial intelligence and machine learning models that power our platform and services.

Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways:

• To AI Providers: We transmit your AI browsing inputs (including prompts, commands, relevant webpage content and any other input you choose to provide) to third-party AI model providers — currently Anthropic and SpaceXAI (formerly xAI, the provider of the Grok models) — via their APIs to assess requests, website content, generate responses and perform actions on your behalf. Which provider handles a given request depends on the model selected for that feature, and we may add or change providers over time. Under our agreements with these providers, they will not process your personal data to further train or refine their AI technologies. To view Anthropic’s privacy policy, please click here. To view SpaceXAI’s privacy policy, please click here.
• To Service Providers: We engage third parties to perform certain services on our behalf, such as hosting, analytics, and customer support. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf.
• To Meta for Advertising Measurement: Meta’s iOS SDK sends limited device/app metadata and install or activation events so we can attribute installs and measure campaigns promoting Buddy on Meta services, including Instagram. Meta’s processing is governed by its terms and privacy policy.
• To TikTok for Advertising Measurement: The proposed App Events SDK flow would send the app-lifecycle and device/app context described above so that we can attribute installs and measure campaigns promoting Buddy. Buddy does not intentionally supply TikTok with email, phone number, external user ID, custom events, URLs, browsing history, webpage or AI content, or purchase events. The pinned SDK preserves Buddy’s local purchase opt-out, but production remains disabled because TikTok’s remotely controlled diagnostic/debug behavior does not yet let us guarantee the other exclusions.
• To Third-Party Websites You Interact With: When you access websites through the Buddy browser or direct the AI assistant to take actions on your behalf (e.g., fill out forms or complete transactions), the personal information you have provided to the third-party websites will be provided directly to those websites. Where the AI assistant is asked to complete transactions, the information will be submitted to those third-party websites at your express direction and, where ordering or buying on your behalf, with your confirmation. We are not responsible for the privacy practices of those third-party websites.
• To Third-Party Integrated Services: When you use certain features that require a third-party integration (e.g., Google Search, Apple iOS FaceID) we will share information about your requests and usage of those services to the relevant provider. We are not responsible for the privacy practices of those third-party services. For more information on Google’s Privacy Policy, please click here. For more information on Apple’s Privacy Policy, please click here.
• In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.
• To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
  • to detect, suppress, or prevent fraud;
  • to reduce credit risk and collect debts owed to us;
  • to protect the health and safety of us, our customers, or any person; or
  • as otherwise required by applicable law.
• With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction.

Your Privacy Choices

The following privacy choices are made available to all individuals with whom we interact.

Communication Preferences

• Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as account verification or service update emails).
• Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the application settings. Please note we do not have any control over your device’s notification settings and are not responsible if they do not function as intended.

Other Privacy Choices

• Private Browsing: Buddy offers a Private Browsing mode that you can activate at any time. When Private Browsing is enabled, Buddy does not store your browsing history, save chat sessions, create or update Assistant Memory, or collect certain metadata (such as crash diagnostics) that would otherwise be collected outside of Private Browsing, as described in the Information Stored on Your Device and Private Browsing section above.

Buddy does not display third-party advertising inside the app. Meta’s iOS SDK measures installs and activations from campaigns advertising Buddy on Meta services, including Instagram. A separate proposed TikTok integration would measure campaigns that advertise Buddy. It does not ask for ATT permission or use a usable IDFA, but its direct app-event postbacks would include the other persistent device-level and technical information listed above in addition to Apple’s SKAdNetwork postbacks. Its production gate is off and selects the ordinary Buddy target, which does not contain the TikTok SDK, configuration, or tracking manifest. We will not ship the isolated TikTok-enabled target until the vendor, required-reason API, tracking-domain, and legal/ATT blockers described above are resolved. We do not sell personal data.

Withdrawing Your Consent

Where we have your consent for the processing of your personal data, you may withdraw your consent at any time by adjusting your preferences in the application settings or by contacting us as set forth in the Contact Us section below.

Modifying or Deleting Your Personal Data

If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us directly at privacy@whim.run, or use the Delete My Data option in Settings > Advanced. Delete My Data deletes account-linked information from our backend but does not clear local chats, Assistant Memory, browsing history, bookmarks, or downloads stored on your device. To clear this information, please use the relevant in-app controls or remove the application from your device. Please note that removing the application may not remove your device’s Keychain identifier, so we recommend using Delete My Data before removing the application where possible. Deleting your data will not cancel your Buddy subscription; to manage or cancel your subscription, please visit your Apple ID account settings. We may not be able to modify or delete your personal data in all circumstances.

Device-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide:

• Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as you mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

Children’s Personal Data

Our application is not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 16. If an individual is under the age of 16, they should not use our application or otherwise provide us with any personal data either directly or by other means. If a child under the age of 16 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 16, we will promptly delete that personal data.

Security of Personal Data

We have implemented reasonable physical, technical, and organizational safeguards that are designed to protect your personal data. However, despite these controls, we cannot completely ensure or warrant the security of your personal data.

Retention of Personal Data

We will usually retain the personal data we collect about you for no longer than reasonably necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.

Third-Party Websites and Services

Our application enables you to browse and interact with third-party websites. Third-party websites and other services may also reference or link to our websites and services. This Privacy Notice does not apply to any personal data practices of third parties. This Privacy Notice does not apply to any personal data practices of these third-party websites, plug-ins, applications, or other services. To learn about the personal data practices of third parties, please visit their respective privacy notices.

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by prominent posting on the application or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

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