Privacy Policy

1. Who We Are (Data Controller)

Amble is provided by KeyToTech LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ (“Amble,” “we,” “us”). For privacy questions, contact [email protected].

2. The Short Version

• Everything that matters happens on your device. Your voice recordings, transcripts, text dumps, tasks, and notes are processed locally by an on-device AI model and Apple’s speech recognition. They are not sent to us or to any third party.
• We have no user accounts. You don’t create a login, and we don’t hold a profile of you.
• We don’t store your content on our servers. There is no cloud copy of your dumps for us to access, lose, or hand over.
• We collect anonymous usage analytics — events like “dump created” or “task completed” — to understand how the App is used and improve it. These events do not contain the text of your dumps.
• We never sell your information, and your content is never used to train AI models.
• The App works offline. Core features can run without an internet connection.

3. Information We Collect

3.1 Content that stays on your device (we do not collect this)

The following is created and stored only on your device. We do not receive, store, or have access to it:

• Voice recordings and their transcripts;
• Text brain dumps;
• Tasks, notes, feelings, time estimates, and plans generated from your dumps;
• Your edits, settings, soundscape and companion choices, and history.

Speech recognition is performed using Apple’s on-device speech recognition, and your dumps are structured by a local AI model (Gemma) running on your device. Apple Speech may fall back to Apple’s servers for certain languages/devices. Apple’s own privacy terms would then also apply.

3.2 Anonymous analytics we do collect

To understand how Amble is used and to improve it, the App sends anonymous behavioral events to our analytics providers (Firebase / Google Analytics and Mixpanel). These events describe actions in the App, not the content of your dumps. Examples:

Because the analytics SDKs assign device or install identifiers and may infer approximate location from your IP address, this analytics data can constitute personal data under some laws even though it never includes your dump content.

3.3 Subscriptions

Paid subscriptions are processed by the app store on your device (Apple App Store / Google Play) and the RevenueCat platform. Purchases are tied to your app store account, not to an App account. We receive subscription status (for example, whether you have an active subscription) but not your payment card details.

4. Why We Use This Information (and Legal Bases)

• Run the App on your device — all core processing of your dumps happens locally to provide the service (legal basis: performance of our contract with you);
• Understand and improve the App — anonymous analytics and diagnostics (legal basis: our legitimate interest in improving the product, and/or your consent where required by law);
• Manage subscriptions — confirm entitlements via the app store (legal basis: performance of contract);
• Comply with the law and prevent abuse (legal basis: legal obligation / legitimate interest).

Where your local law requires consent for analytics (for example, in the EEA/UK), we will ask for it and you can decline or withdraw it.

5. On-Device AI and the “No Training” Promise

• Your dumps are processed by an AI model that runs locally on your device. The text of your dumps is not transmitted to us or to a third-party AI service for processing.
• We do not use your content to train any AI model, and because your content never reaches us, there is nothing for us to train on.
• AI output can be inaccurate. You can always review, edit, or delete anything the App produces.

6. Sensitive Content and Distress Detection

Brain dumps are open-ended, so you may include emotionally sensitive content. Amble is a productivity tool, not a counseling, crisis, or medical service.

• Any detection of content that may suggest distress is performed on your device, so that the App can show a brief, kind prompt encouraging you to seek professional or crisis support. This processing does not send your content to us, and the App does not counsel you, monitor you, alert anyone, or contact emergency services.

7. How We Share Information

We do not sell your personal information, and we do not share your dump content with anyone — it stays on your device. We share the limited analytics and subscription data described above only with the providers that make the App work, under contracts limiting them to processing on our instructions:

We may also disclose information if required by law or to enforce our Terms. A current list of providers is available on request.

8. International Data Transfers

Your dump content does not leave your device, so it is not transferred internationally by us. The analytics providers above may process the anonymous event and device data in other countries, including the United States. Where required, those transfers rely on appropriate safeguards such as Standard Contractual Clauses.

9. How Long Is Data Kept

• On your device: your dumps, tasks, and history remain until you delete them or uninstall the App. Uninstalling removes the App’s local data from your device.
• Analytics: our analytics providers retain event data for 14 months, after which it is deleted or aggregated.

10. Your Rights and Choices

• Your content: you control it directly — edit or delete any item, or uninstall the App, at any time. No request to us is needed because we don’t hold it.
• Analytics opt-out: you can opt out of analytics collection in the App’s settings, and/or via your device’s privacy controls. [Confirm the in-app toggle exists.]
• Where applicable law grants them, you may have rights to access, correct, delete, port, or object to processing of the limited analytics data we hold, and to complain to your local data protection authority.

To exercise rights over analytics data, contact [email protected]. Note that because analytics events are anonymous, we may be unable to link them to you specifically, and may ask for information to help locate them or may be unable to fulfil a request we cannot tie to an individual.

11. Children’s Privacy

Amble is for adults (18+, rated 17+ on the app stores). We do not knowingly collect personal information from anyone under that age. If you believe a minor has used the App, contact us.

12. How Data Is Protected

Because your content stays on your device, its security depends largely on your device’s own protections (passcode, biometrics, OS-level encryption). For the analytics data in transit, we and our providers use encryption and access controls. No system is perfectly secure, but we work to protect the limited data we handle.

13. Changes to This Policy

We may update this policy as the App evolves — for example, if we ever introduce accounts or cloud sync, we will update it and tell you before that change affects you. Material changes will be notified in-app, and the “Last updated” date will change.

14. Contact Us

Questions or requests? Reach us at [email protected].