Privacy Policy

Effective Date: September 30, 2026 | GDPR, CCPA/CPRA, and Mobile App Store Compliant

1. Our Commitment to Your Privacy

Frogly ("Company," "we," "our," or "us") respects your personal privacy. This Privacy Policy describes how we collect, store, process, and protect your information across our web platform, iOS mobile application, and Android mobile application. We operate in strict compliance with Apple App Store Review Guidelines (Guideline 5.1.1), Google Play Developer Data Safety requirements, the European Union General Data Protection Regulation (GDPR), United Kingdom GDPR, and the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA).

2. Information We Collect and Legal Bases for Processing

Under GDPR Article 6, we process your information based on contract performance (to deliver the Service), legitimate interests (system security and reliability), and explicit consent (for microphone access).

Account and Identity Information:

When creating an account, our authentication provider (Clerk) collects your email address, full name, and authenticated profile identifier. If you use OAuth (Google or Apple), we receive a secure authentication token. We never store raw passwords.

Productivity Tasks and Metadata:

Your daily frogs, ABCDE priority tags, weekly objectives, quarterly goals, and consequence logs are stored in an encrypted PostgreSQL database protected by cryptographic Row-Level Security (RLS) keyed to your individual user identifier.

Diagnostic and Telemetry Logs:

We capture anonymized crash diagnostics and latency metrics via Sentry to resolve software faults. Personal identifiers and sensitive payload fields are scrubbed before transmission.

3. Voice Coaching and Microphone Data Guarantees

When you activate the Executive Voice Coach in our applications, Frogly requests microphone permission. We provide the following strict legal and technical guarantees:

Active Activation Only: The microphone is opened strictly while a voice session is active and is immediately closed when the session ends.
Zero Retention for Training: Audio streams are processed ephemerally for real-time inference. We do not retain audio files, and your voice is never used to train machine learning models.
No Biometric Voiceprints: We do not extract biometric identifiers, voiceprints, or vocal geometry from your speech.
No Sale of Audio Data: Audio data is never shared with advertisers, brokers, or unaffiliated third parties.

4. Subprocessors and Cross-Border Transfers

We partner exclusively with certified, enterprise infrastructure providers under executed Data Processing Addenda incorporating standard contractual clauses (SCCs):

Clerk Inc. (United States): Identity and session security (SOC 2 Type II).
Amazon Web Services / Supabase (United States): Encrypted PostgreSQL database hosting.
Private Cloud AI Provider: Real-time task breakdown inference with zero data retention.
Stripe Inc. (United States / EU): PCI-DSS Level 1 payment processing.
Sentry / Functional Software (United States): Anonymized application crash reporting.

For full geographic residency details and transfer safeguards, visit our dedicated Data Residency Page.

5. California Privacy Rights (CCPA / CPRA Notice)

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

No Sale or Sharing of Personal Data: Frogly does not sell your personal information, nor do we share your personal information for cross-context behavioral advertising.
Right to Know and Access: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you over the past 12 months.
Right to Delete: You have the right to request deletion of your personal information, subject to legal exceptions such as statutory tax retention.
Non-Discrimination: We will not discriminate against you for exercising any of your statutory privacy rights.

6. European Union and United Kingdom (GDPR) Rights

If you are located in the EEA or UK, you possess specific data rights under GDPR Chapter III:

Right of access to your data (Article 15).
Right to rectification of inaccurate records (Article 16).
Right to erasure / "Right to be Forgotten" (Article 17).
Right to restriction of processing (Article 18).
Right to data portability in structured JSON format (Article 20).
Right to lodge a complaint with your local Data Protection Supervisory Authority.

7. Account Deletion and Self-Service Data Purge

In full accordance with Apple App Store Guideline 5.1.1(v) and Google Play policy, you can delete your account and all associated data at any time:

In-App Deletion: In Settings, scroll to Danger Zone and select Delete Account.

Public Web Request: If you uninstalled the app, visit our public Account Deletion Page or email privacy@frogly.app with subject line "Account Deletion Request" for processing within 48 hours.

8. Children's Privacy

Frogly is an executive productivity application and is not directed to individuals under 13 years of age (or under 16 in the European Union). We do not knowingly collect personal information from children.

9. Contact Our Data Protection Officer

If you have questions regarding this Privacy Policy or your data subject rights, contact our Data Protection Officer at:

privacy@frogly.app | dpo@frogly.app