· Legal
Effective Date: June 27, 2026 · Last Updated: September 28, 2026
The App is designed for personal note capture. When you use the App, you may provide:
Speech is transcribed by Apple's speech recognition in iOS, which may process audio on your device or on Apple's servers. This is separate from note structuring, described in Section 3.
You are in full control of what you provide. The App does not require you to create an account, provide your name, or share any personal identifiers to use its core functionality.
We do not collect device identifiers (see Section 12 for version 2.0), usage analytics, crash reports, or behavioural data. The App contains no analytics software, no advertising SDKs, and no third-party tracking tools of any kind. Our hosting providers process IP addresses transiently, as is standard for delivering and securing any website or server, but we do not collect or retain them ourselves. Our server keeps a temporary in-memory counter per IP address and per anonymous install ID to limit abuse. It resets daily and is never written to storage.
The only automated process that occurs is the temporary transmission of certain content to our processing server for the purposes described in Section 3.
If you choose to purchase a paid subscription (Toru Smart) or the one-time Toru Forever purchase, the transaction is processed entirely by Apple through the App Store. We do not receive, store, or have access to your payment card details, billing address, or any financial information. Apple's privacy policy governs the handling of your payment data.
Toru Smart subscribers may choose to enable the optional voice recording storage feature. When enabled, the original audio recording of a voice-captured note is stored locally on your device alongside the structured note. This feature is disabled by default and must be explicitly activated by the user.
Voice recordings are never sent to our servers or to any third party; they are included only in backups you choose to make. They are deleted automatically when you delete the associated note.
Your notes, lists, transcriptions, and voice recordings are stored on this device. This data does not leave your device except as described in Section 3 (processing) and Section 2.2 (iCloud backup).
If you have enabled iCloud backup on your device and the App's iCloud backup feature is turned on, your notes and lists may be included in your iCloud backup. This is governed by Apple's iCloud terms and privacy policy. We do not control, access, or interact with your iCloud data.
We do not maintain a user database. We do not store your notes, transcriptions, account information, or any personally identifiable information on our servers. Our server infrastructure is used solely as a processing relay as described in Section 3.
When you choose to structure a note, our server forwards the relevant content to Anthropic PBC, our processing provider, which structures and returns it. The structured result is then returned to your device. Beyond note text, this can include photos you've captured for structuring, in-app support chats, recipe suggestions, task breakdowns, and, on Toru Smart, an automatic check after a note is saved that looks for commitments you may want to follow up on.
Anthropic's API deletes inputs and outputs within 30 days. Content flagged for a violation of Anthropic's usage policies may be retained for up to two years. Your content is never used to train Anthropic's models.
In accordance with applicable transparency requirements, including Article 50 of the EU AI Act, we disclose that intelligent automation is used to process and structure the content described above. This automation assists in organising your thoughts. It does not make decisions about you, assess your behaviour, profile you, or infer sensitive characteristics from your content.
The Bridge looks for meaningful connections between two of your notes captured at least seven days apart. Short excerpts, up to 400 characters each, are checked through our processing provider to judge whether the connection is meaningful and to write the message you see. At most one Bridge card is surfaced per day. If you act on a card, you may choose to create a "Thread" note linking the two.
We work with a small number of third parties to operate the App and this website. Each is listed below with its role:
Anthropic's processing is governed by their API usage policies and privacy documentation, available at anthropic.com.
Our relay server is hosted in the European Union (Frankfurt, Germany). It forwards content to Anthropic PBC for processing, which takes place in the United States. All data involved is transient and not retained on our own servers; retention by Anthropic is described in Section 3.1.
Transfers of personal data from the EU/UK to the United States are protected by our processing provider's data processing terms, which include the European Commission's Standard Contractual Clauses.
For users in the European Economic Area, the United Kingdom, and Switzerland, we rely on the following legal bases under the General Data Protection Regulation (GDPR) and applicable national law:
Because all of your data is stored locally on your device, you exercise full control over it at all times. You may:
If you are located in the European Economic Area, United Kingdom, or Switzerland, you have additional rights under the GDPR, including the right to access, rectification, erasure, restriction of processing, data portability, and the right to object to processing. You also have the right to lodge a complaint with your local data protection supervisory authority.
Given the architecture of the App — where all data is stored on your device and our servers retain no user data — most of these rights are exercised directly through your device. For any requests that cannot be addressed through the App itself, please contact us using the details in Section 13.
We respect the privacy rights of California residents. While Hey Toru! at its current scale does not meet the thresholds that trigger mandatory compliance with the California Consumer Privacy Act (CCPA), we voluntarily apply the following principles to all California users:
As Hey Toru! grows, we will review our CCPA obligations and update this policy accordingly.
Some browsers and devices allow users to transmit a "Do Not Track" signal to indicate that they do not wish to be tracked across websites and applications. The App does not track users across third-party websites or applications, does not use cross-context advertising, and contains no behavioural tracking technology of any kind. Accordingly, Do Not Track signals do not alter the App's behaviour, as no tracking of this nature occurs in the first place.
Your notes, lists, and transcriptions are retained on your device for as long as you choose to keep them. You may delete individual items or all data at any time through the App.
Optional voice recordings (Toru Smart) are retained on your device for as long as the associated note exists. When you delete a note, the associated voice recording is deleted with it.
Our processing server retains no user content. All transmitted content is discarded immediately upon completion of the processing request (retention by our processing provider is described in Section 3.1).
Subscription and purchase transaction records are retained by Apple in accordance with their policies. We do not maintain independent records of your transactions beyond what Apple provides to us.
We take the security of your information seriously. The following measures are in place:
No method of transmission over the internet or method of electronic storage is completely secure. While we use commercially reasonable means to protect your information, we cannot guarantee absolute security.
In the event of a security breach that compromises your personal information, we will notify affected users without undue delay and in accordance with applicable law. For users in the European Economic Area, notification will be made within 72 hours of our becoming aware of the breach where required by GDPR. For users in other jurisdictions, we will comply with applicable state and national breach notification requirements.
Given that the App stores all user data locally on-device and our servers retain no user content, the scope of any potential server-side breach is inherently limited. In the event that a breach of our server infrastructure occurs, we will assess the impact and notify users if their information has been or is reasonably likely to have been affected.
Breach notifications will be delivered via a notice posted on heytoru.com and, where possible, within the App.
The App is not directed to children under the age of 13 in the United States, or under the applicable minimum age in other jurisdictions (13 in most countries, 16 in certain EU member states). We do not knowingly collect personal information from children below the applicable minimum age.
If you believe a child has provided personal information through the App, please contact us at [email protected] and we will take appropriate steps to address the situation promptly.
We may update this Privacy Policy from time to time to reflect changes in our practices, the App's features, or applicable law. When we make material changes, we will update the effective date at the top of this policy and, where appropriate, notify users through the App.
This policy is written by data category and processing purpose, not by specific feature. This means that as the App evolves — including the addition or removal of features — this policy remains accurate provided the categories of data collected and the purposes of processing remain consistent. Where new categories of data or new processing purposes are introduced, this policy will be updated accordingly.
Your continued use of the App after any changes constitutes your acceptance of the updated policy.
This section covers heytoru.com itself, separately from the App described elsewhere in this policy.
The items below describe App behaviour that is not yet live. They apply only once you are running Hey Toru! version 2.0 or later, and are included here in advance for transparency.
If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your information, please contact us:
Hey Toru!, operated by Pembroke Labs, LLC
Pembroke Labs, LLC
500 N. Brand Blvd, Suite 890
Glendale, CA 91203
United States
Use our support form to get in touch — we respond to all legitimate requests within 30 days as required by applicable law.
Hey Toru! · heytoru.com · ™ HEY TORU!