1. Introduction

Rhumb, LLC (“Rhumb,” “we,” “us,” or “our”) operates the Rhumb mobile application (“App”).

This Privacy Policy explains what information Rhumb collects and processes, why we use it, when it may be shared with service providers, how long it may be retained, and the choices available to you.

Rhumb is designed to help users make meaningful progress through planning, action, observation, and reflection. The information you choose to enter into Rhumb is used to provide these features and maintain your experience across use of the App.

We do not sell your personal information or use your information for targeted advertising.

2. Information We Collect

   
   

   1. Account Information

      
      

      When you create a Rhumb account, we collect information necessary to create and maintain that account, including:

      
      

      • Email address, which is used to create and identify your account and support account functions such as authentication and password recovery.

      • Account identifier, which is generated to associate your account with your Rhumb data.

      • Profile information you choose to provide, such as profile preferences and a profile photo.

        
        

      Your password is handled through our authentication provider. Rhumb does not store your password in readable form.

      
      

   2. Information You Add to Rhumb

      
      

      Rhumb stores information you choose to create or record while using the App. Depending on the features you use, this may include:

      
      

      • Focuses and related planning information;

      • Systems and activities;

      • Activity schedules, completion information, and timing information;

      • Needs

      • Notes and observations;

      • Reflections;

      • Momentum and other progress information;

      • Reminder preferences; and

      • Feedback or support information you choose to submit.

        
        

      This information is associated with your account so Rhumb can provide the App’s core functionality and preserve your information between sessions and devices where supported.

      
      

   3. Profile Photos and Photo Library Access

      
      

      If you choose to add a profile photo, Rhumb may request access to your device’s photo library so you can select an image.

      
      

      Rhumb does not require access to your camera or microphone for this purpose. Rhumb does not delete or modify the original photo in your device’s photo library.

      
      

      A selected image may be temporarily stored on your device and uploaded to Rhumb’s storage provider so it can be used as your profile photo.

      
      

   4. Information Stored on Your Device

      
      

      Rhumb stores some information locally on your device to operate the App, maintain your session, improve reliability, and support features such as reminders.

      
      

      This may include:

      
      

      • Authentication session information;

      • Locally cached copies of Rhumb data;

      • App preferences;

      • Reminder information;

      • Temporary files related to profile photos; and

      • Limited technical information used to support data migration, recovery, or prevent deleted account data from being unintentionally restored.

        
        

      Some local information may remain temporarily after it is no longer needed because of operating-system or application caching behavior.

      
      

   5. Analytics and Diagnostic Information

      
      

      Rhumb uses analytics and diagnostic tools to understand how the App is used, identify technical problems, and improve the product.

      
      

      When analytics are enabled, the information collected may include:

      
      

      • An account-associated identifier;

      • Limited information about interactions with Rhumb features;

      • App and device context needed to understand technical behavior; and

      • Sanitized diagnostic or error information.

        
        

      Rhumb is designed not to send the contents of your Notes, Needs, Reflections, Focuses, or other private user-created content to our analytics provider as analytics data.

      
      

      Rhumb also configures its analytics implementation to avoid collecting precise location information through the App and to disable analytics-based geographic enrichment where supported.

      
      

      We do not use analytics information for targeted advertising.

      
      

   6. Notifications

      
      

      If you enable notifications, Rhumb may use your notification preferences and schedule information to provide reminders on your device.

      
      

      Rhumb does not require access to your contacts, calendars, or location to provide these reminders.

      
      

      Rhumb may schedule notifications related to activities, schedules, and other Rhumb features for which you have enabled reminders. These notifications are currently scheduled locally on your device rather than sent through a Rhumb-operated remote push-notification service.

      
      

      You can manage or disable notifications at any time through your device's notification settings (Settings > Notifications > Rhumb on iOS). Disabling notifications will not affect your ability to use Rhumb's other features.

      
      

   7. Feedback and Communications

      
      

      If you contact us or submit feedback through Rhumb, we may receive the information you provide, including the contents of your message and information necessary to respond to or understand your request.

3. How We Use Information

We use personal information as reasonably necessary to:

• Create, authenticate, maintain, and secure your account;

• Provide Rhumb’s planning, activity, observation, reflection, reminder, and related features;

• Save and synchronize your information;

• Maintain your profile and profile photo;

• Provide password recovery and other account services;

• Respond to feedback, questions, and support requests;

• Understand use of the App and improve its functionality;

• Diagnose errors and maintain the reliability and security of the App;

• Prevent deleted or outdated information from being unintentionally restored;

• Enforce our Terms of Use and protect Rhumb, our users, and others; and

• Comply with applicable legal obligations.

We do not use the private content you create in Rhumb for advertising.

4. Service Providers and Disclosure of Information

We use third-party service providers to operate portions of Rhumb. These providers may process information on our behalf only as necessary to provide their services.

Supabase

Rhumb uses Supabase for services including account authentication, database infrastructure, and file storage. Information stored through these services may include your account information, Rhumb product data, and profile photo.

PostHog

Rhumb uses PostHog for limited product analytics and diagnostics. Rhumb limits the information sent to PostHog and does not intentionally send the contents of your private Notes, Needs, Reflections, Focuses, Systems, or similar user-created content as analytics data.

Apple

Rhumb is distributed through Apple’s App Store and uses features of the Apple platform. Apple may process information independently in connection with the App Store, your Apple account, device services, or purchases. Apple’s handling of that information is governed by Apple’s own terms and privacy practices.

Other Disclosures

We may also disclose information:

• When required by applicable law, legal process, or a valid governmental request;

• When reasonably necessary to protect the rights, safety, security, or integrity of Rhumb, our users, or others;

• In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction; or

• At your direction or with your consent.

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Rhumb does not sell your personal information.

We do not share your personal information with third parties for their own targeted advertising or direct marketing purposes.

5. Purchases and Subscriptions

Rhumb may offer paid features or subscriptions.

Purchases made through Apple’s App Store are processed through Apple’s payment system. When Apple processes a purchase, Rhumb does not receive or store your full payment-card information. We may receive information from Apple necessary to determine the status of a purchase or subscription and provide the features you purchased.

If Rhumb uses another payment provider in the future, this Privacy Policy will be updated as appropriate to describe that processing.

6. Data Retention

We retain personal information for as long as reasonably necessary to provide Rhumb, maintain your account, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and protect the security and integrity of the App. The following specific retention periods apply:

• Account information and account-linked Rhumb data are generally retained for the duration of your active Rhumb account. When you successfully delete your account, Rhumb deletes account-linked server data designated for deletion as described in Section 7. Limited information may be retained where required by law or reasonably necessary for security, fraud prevention, technical integrity, dispute resolution, or other legitimate purposes described in this Privacy Policy.

• Analytics and diagnostic information may be retained for a limited period consistent with the purposes described in this Privacy Policy and the retention practices of the service providers we use. We may delete or de-identify this information when it is no longer reasonably necessary for those purposes, subject to applicable legal, security, and technical requirements.

• Transaction records, when applicable, are retained as required by applicable tax and financial regulations.

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When information is no longer reasonably necessary for these purposes, we may delete or de-identify it in accordance with our systems and applicable legal requirements.

7. Account and Data Deletion

You may delete your Rhumb account from within the App.

When account deletion is successfully completed, Rhumb deletes account-linked server data that is designated for deletion, including your Rhumb product data and associated profile-photo files, subject to limited exceptions required by law or necessary for security, fraud prevention, or other legitimate purposes.

Rhumb also attempts to remove account-related information controlled by Rhumb that is stored locally on your device. Some temporary or cached information may persist for a limited period because of device, operating-system, backup, or caching behavior outside Rhumb’s direct control.

Limited technical information may also be retained where necessary to prevent information associated with a deleted account from being unintentionally restored.

Analytics or diagnostic information previously collected may not be deleted at the same time as your account and may remain for the limited retention period applicable to that information.

Deleting the Rhumb App from your device does not delete your Rhumb account. Account deletion must be performed through the account-deletion feature in the App.

8. Security

We use reasonable technical and organizational safeguards designed to protect personal information from unauthorized access, alteration, disclosure, or destruction.

These measures include encrypted network communications and access controls for systems that process Rhumb data. Authentication credentials and sessions are handled using security mechanisms appropriate to the platform and services we use.

No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Your Privacy Choices and Rights

You can manage certain information directly within Rhumb and can delete your account through the App.

Depending on where you live, applicable law may also give you rights concerning your personal information, which may include rights to:

• Request access to personal information we maintain about you;

• Request correction of inaccurate personal information;

• Request deletion of personal information;

• Obtain a portable copy of certain personal information; or

• Appeal or otherwise exercise additional rights provided by applicable privacy law.

Rhumb does not sell personal information or process personal information for targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects.

To make a privacy request, contact us using the information in Section 16.

We may need to verify your identity before fulfilling certain requests. Some rights may be subject to exceptions under applicable law.

We will not discriminate against you for exercising privacy rights provided by applicable law.

We do not sell your personal information or use your information for targeted advertising.

1. Rights of Texas Residents (TDPSA)

   
   

   If you are a Texas resident, the Texas Data Privacy and Security Act (“TDPSA”) may provide you with additional rights regarding your personal data. Subject to applicable exceptions, Texas residents may have the right to:

   
   

   • Access the personal data we have collected about you;

   • Correct inaccuracies in your personal data;

   • Delete personal data we have collected from or about you;

   • Obtain a portable copy of your personal data in a readily usable format; and

   • Opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

     
     

   Rhumb does not sell personal data, engage in targeted advertising, or profile users in furtherance of decisions that produce legal or similarly significant effects.

   
   

   To exercise your rights under the TDPSA, contact us at privacy@tryrhumb.com. We will respond to verified requests within forty-five (45) days. If we need additional time, we will notify you of the extension and the reason. If we decline to take action on a request, you may appeal by contacting us at the same address.

   
   

2. Rights of California Residents (CCPA)

   
   

   If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), may provide you with additional rights. Subject to applicable exceptions, California residents may have the right to:

   
   

   • Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purpose for collecting the information, and the categories of third parties with whom we share it.

   • Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions.

   • Right to Opt-Out of Sale: Rhumb does not sell personal information as defined under the CCPA.

   • Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

     
     

   To exercise your rights under the CCPA, contact us at privacy@tryrhumb.com.

   
   

3. Universal Opt-Out Mechanism / Global Privacy Control

   
   

   Rhumb does not sell personal information or process personal information for targeted advertising. Accordingly, Rhumb does not currently engage in the types of processing for which universal opt-out mechanisms such as Global Privacy Control (“GPC”) are generally used to communicate an opt-out preference.

10. App Tracking and Advertising

    
    

    1. App Tracking Transparency

       
       

       Rhumb does not track users across apps or websites owned by other companies as defined by Apple’s App Tracking Transparency (“ATT”) framework. Rhumb does not request access to the Identifier for Advertisers (“IDFA”) and does not display the ATT prompt.

       
       

    2. Privacy Nutrition Label

       
       

       Rhumb’s App Store privacy labels (the “Privacy Nutrition Label”) are designed to be consistent with the data practices described in this Privacy Policy. If you believe there is a discrepancy between the App Store privacy labels and this Privacy Policy, please contact us at privacy@tryrhumb.com so we can investigate and correct any inconsistency.

       
       

11. Data Breach Notification

    
    

In the event of a data breach involving personal information, Rhumb will notify affected users in accordance with applicable law, including the Texas breach-notification statute (Tex. Bus. & Com. Code Section 521.053), which requires notification without unreasonable delay and no later than sixty (60) days after discovery of the breach. Notification will also be provided in accordance with other applicable federal and state breach-notification laws. Notifications may be sent via email, in-app notice, or other methods permitted by law.

12. Children’s Privacy

Rhumb is intended for users who are at least 13 years old and is not directed to children under 13.

We do not knowingly collect personal information from children under 13. If we learn that personal information has been collected from a child under 13 in circumstances requiring its deletion, we will take reasonable steps to delete it.

If you are a parent or guardian and believe a child under 13 has provided personal information to Rhumb, please contact us using the information below.

13. International Use and Data Processing

Rhumb and its service providers may process and store information in the United States and other locations where they operate.

If you access Rhumb from outside the United States, your information may be transferred to and processed in a country with data-protection laws that differ from those in your jurisdiction.

Where required by applicable law, we will use appropriate measures for international transfers of personal information.

14. Governing Law

This Privacy Policy is governed by the laws of the State of Texas, without regard to its conflict-of-law principles, except where applicable law requires otherwise. This governing-law provision is consistent with the governing-law provision in Rhumb’s Terms of Use.

15. Changes to This Privacy Policy

We may update this Privacy Policy as Rhumb changes or as legal or regulatory requirements evolve.

When we make changes, we will update the Effective Date above. If a change materially affects how we handle personal information, we will provide additional notice when required by applicable law.

We encourage you to review the current Privacy Policy periodically.

16. Contact Us

If you have questions about this Privacy Policy, want to exercise a privacy right, or have a concern about Rhumb’s handling of personal information, contact:

Rhumb, LLC

Attn: Privacy Inquiries

1919 Wipprecht St

Houston, TX 77020

privacy@tryrhumb.com