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AskTilly — Privacy Policy

Last Updated: 25 October 2026

1. Introduction

AskTilly is built on the principle that you should understand exactly what happens to your data. This Privacy Policy describes how AskTilly collects, uses, shares, and protects your information when you use our messaging and AI chatbot aggregation services.

2. Data Transparency

AskTilly uses encryption to give you the most control over your data. We want to be very clear about what we store, what we can see, what we cannot see, and what we can or cannot recover for you.

2.1 What We Encrypt (Opaque to AskTilly)

AskTilly cannot read, access, or recover this data. If you lose all your passkeys, encrypted messages, contacts, and chat history are permanently unrecoverable. Wallet access can be restored using your recovery phrase or an exported compatible wallet descriptor, but only if you have backed it up — AskTilly cannot help recover it.

2.2 What We Can See (Visible to AskTilly)

2.3 AI Services and Other Limitations

AI provider data handling: When you send a prompt to a non-confidential AI service, it is protected in transit (TLS) but is not end-to-end encrypted: AskTilly and the provider running your selected model can read it. The iOS app sends AI content to Anthropic (Claude) or OpenAI (GPT) only after you agree on the AI permission screen. We remain responsible for the third-party processors we use for the iOS app and require them to provide protection at least equal to that described in this policy, including confidentiality, security and applicable data-protection obligations. Section 6.2 explains the providers, uses and retention of AI content.

AI output accuracy: AI responses may be inaccurate, biased, or fabricated. AskTilly does not guarantee correctness. See Terms of Service Section 8.4.

Self-hosted or third-party LLMs: If you connect self-hosted or custom AI endpoints, AskTilly is not responsible for their data handling, security, or compliance.

3. PII Categories We Collect

The following table lists every category of personal data we collect, its source, the legal basis for processing, and how long we keep it.

Category Data Elements Source Legal Basis Retention
Identity Phone number, first name, last name, display name User-provided Contract Until account deletion
Contact Email address (optional), recovery email, email verification status, short-lived email verification codes User-provided Contract Email until account deletion; verification codes until expiry or successful use
Authentication PIN hash, passkey public keys, passkey credential IDs, TOTP secrets, backup codes, device-attestation metadata and counters User-created Contract Until account deletion
Wallet Metadata Public wallet descriptors, address derivation state, receive addresses, balances, asset metadata, transaction history, wallet mode, and compliance-country signals used for wallet gating User-created + derived from public blockchain activity and client/device signals Contract + Legitimate interest Until you ask us to delete them. Wallet records, including your encrypted wallet backup, are not deleted automatically when you delete your account; email privacy@asktilly.ai to have them deleted
Profile Profile picture, timezone, language preference User-provided Contract Until account deletion
Messaging Message content (E2E encrypted for confidential rooms, plaintext for open rooms), media attachments User-created Contract 30 days (undelivered); per room policy (delivered)
AI Interactions Prompts sent to AI, AI responses, model selection User-created Contract AskTilly does not retain; see provider policies
Contacts Hashed phone numbers from address book, encrypted contact blobs User-provided (hashed) Contract + Consent Until sync disabled or account deletion
Privacy Preferences Discoverability, presence, read receipts, notification scope User-configured Contract Until account deletion
Device & Technical IP address, user agent, device info, OS version Auto-collected Legitimate interest Up to 90 days (infrastructure logs 30 days)
Legal Consent Terms acceptance records (type, version, timestamp, IP, user agent) Auto-collected Legal obligation 7 years
Billing Plan selection, coupon usage (payment details held by Stripe) User-provided + Stripe Contract 7 years (tax/accounting)
Organization Org name, domain, role, membership dates User/admin-provided Contract Until org deletion
Security Events Failed login attempts, lockout events, password reset requests Auto-collected Legitimate interest 1 year

4. How We Use Data

We use data to:

User-to-user communications in confidential rooms are protected by end-to-end encryption. AskTilly does not access, store, or use the content of your encrypted conversations for any purpose. In open (non-confidential) rooms, content is accessible to AskTilly for service delivery and enforcement of these Terms. AI interactions are processed by third-party providers as described in Section 6.2; AskTilly does not retain or use your AI prompt content for training or service improvement.

5. Legal Bases for Processing

Under GDPR Article 6, we process personal data on the following legal bases:

5.1 Contract Performance (Art. 6(1)(b))

Account creation, messaging, AI service delivery, billing — processing necessary to provide the Services you requested.

5.2 Consent (Art. 6(1)(a))

Marketing emails, functional cookies — withdrawable at any time: marketing emails under Settings → Privacy & Marketing in the app, or for either by emailing privacy@asktilly.ai. Withdrawal does not affect the lawfulness of processing before withdrawal.

5.3 Legitimate Interest (Art. 6(1)(f))

Security monitoring, fraud prevention, abuse detection, aggregated analytics — balanced against your rights with appropriate safeguards.

5.4 Legal Obligation (Art. 6(1)(c))

Tax records, law enforcement responses, legal acceptance audit trail — processing required by applicable law.

6. Sharing of Information

6.1 We share information with:

6.2 AI Provider Data Policies

AI in the iOS app. iOS version 1.0.0 offers Claude models from Anthropic and GPT models from OpenAI. Before your first AI message, the permission screen names these providers and explains the sharing. You can withdraw permission at any time in Settings > Privacy & Marketing. What is sent to the provider of your selected model: your message, earlier messages in the same chat, attachments you add, and the searches the assistant runs for you. Messaging other people does not require this AI permission.

Commercial model providers. We use Anthropic’s and OpenAI’s business APIs. These providers process content to deliver and maintain the service, protect it against abuse, and meet legal obligations. They do not use the prompts and replies we send through these APIs to train their models. Their commercial agreements include confidentiality, security and data-protection obligations; we require protection at least equal to that described in this policy. We remain responsible for our selection and use of these providers.

Provider retention. Retention depends on the provider and API feature. Providers may retain content for security and abuse monitoring, to operate features that store data, or to comply with law. Some features retain content until it is deleted, and documented security or legal exceptions can require longer retention. The links below explain the applicable retention rules. Messages and attachments kept in your AskTilly chat follow the room retention rules in Section 8.

Provider Business Terms and Data Protection
OpenAI Services Agreement; Data Processing Addendum; API Data Controls and Retention
Anthropic Commercial Terms; Data Processing Addendum; Commercial Data Retention

If either provider no longer meets these protections, we stop sharing your data with it until equivalent protection is restored.

Other web AI services. The AskTilly website can also offer Google (Gemini) and TensorCash compute-network models; these are not offered in iOS version 1.0.0. Google processes content under its Gemini API Terms, which distinguish paid and unpaid services and their data-use rules. For standard-mode compute-network models, independent operators can read the prompts and responses they process. This is not confidential or end-to-end-encrypted inference, and the commercial API agreements above do not cover those operators.

6.3 We do NOT:

7. International Data Transfers

Your data may be stored and processed:

We rely on:

Phone numbers may be used to determine geographic region for compliance purposes. For wallet compliance controls, AskTilly may also process approximate country signals such as app storefront, SIM country, and device locale.

8. Data Retention

Data Type Retention Period After Expiry
Account data Until account deletion Anonymized/deleted
User-to-user messages (E2E) Delivery only; undelivered max 30 days Deleted
Open room messages Per room retention policy (default 30d delivered) Deleted by sweeper
AI prompts/responses Copies in your chat follow the room retention policy; provider copies follow Section 6.2 Deleted under the applicable retention rules, subject to security or legal exceptions
Contacts (hashed) Until sync disabled or account deletion Deleted
Wallet records (descriptors, addresses, transaction history, encrypted wallet backup) Kept after account deletion until you ask us to delete them (privacy@asktilly.ai) Deleted on request
Legal acceptance records 7 years (compliance) Deleted
Billing records 7 years (tax/accounting) Deleted
Security event logs 1 year Deleted
Device/technical logs Up to 90 days (infrastructure logs 30 days) Deleted

You may request deletion of your account at any time: in the app under Settings → Danger Zone → Delete account, on the web under Settings → Account → Delete account, or by emailing privacy@asktilly.ai from the address registered to your account. Step-by-step instructions are at asktilly.ai/delete-account.html.

9. Your Rights by Jurisdiction

9.1 GDPR (EU/EEA/UK)

Under the General Data Protection Regulation, you have the right to:

Exercise these rights by emailing privacy@asktilly.ai. You can also delete your account yourself in Settings (see asktilly.ai/delete-account.html) and manage marketing emails under Settings → Privacy & Marketing in the app.

You also have the right to lodge a complaint with your local supervisory authority.

9.2 CCPA/CPRA (California)

California residents have the right to:

Contact: privacy@asktilly.ai

9.3 LGPD (Brazil)

Brazilian residents have similar rights to those described under GDPR, including access, correction, deletion, and data portability. Contact: privacy@asktilly.ai

10. Security

We implement:

No system is perfectly secure; you use AskTilly at your own risk.

11. Children

AskTilly is not for anyone under 16, in any country. Everyone is asked their age group when they sign up, and if the answer is under 16 the account is blocked. We do not knowingly collect data from anyone under 16. If we learn of such collection, we delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy periodically. Major changes will be communicated through the app. Continued use constitutes consent to updates.

13. Contact Information

Data Controller. Ask Tilly AI Ltd, a company incorporated in England and Wales under company number 17020603, having its registered office at 20 Wenlock Road, London, England, N1 7GU, United Kingdom (the operator of AskTilly).

Privacy Office. Email: privacy@asktilly.ai

13.1 EU Representative under Article 27 GDPR

Pursuant to Article 27 of Regulation (EU) 2016/679 (GDPR), Ask Tilly AI Ltd has designated the following representative in the Union for data subjects in the EU/EEA whose personal data it processes:

Camerotto Legal — Avv. Maria Allegra Camerotto
Via Santa Margherita 44, 31100 Treviso (TV), Italy
Email: eu-rep@camerottolegal.it
Telephone: +39 0422 1628816

EU/EEA data subjects may contact Ask Tilly AI Ltd directly at privacy@asktilly.ai or its EU Representative at the address above on all issues related to processing.

13.2 EU Legal Representative under Article 13 DSA (hosting-service tier)

Pursuant to Article 13 of Regulation (EU) 2022/2065 (the Digital Services Act), Ask Tilly AI Ltd has designated the following legal representative in the Union for the hosting-service-provider obligations of Articles 11–18 DSA:

Camerotto Legal — Avv. Maria Allegra Camerotto
Via Santa Margherita 44, 31100 Treviso (TV), Italy
Email: dsa-rep@camerottolegal.it
Telephone: +39 0422 1628816

Ask Tilly AI Ltd is a provider of a hosting service within the meaning of Article 3(g)(iii) DSA and is not an "online platform" within the meaning of Article 3(i) DSA. The designation covers only the hosting-tier obligations of Articles 11–18 DSA.

14. Reporting Illegal Content / Designated Agent

To report content that should be removed under the EU Digital Services Act, the UK Online Safety Act, the US Take It Down Act, or other applicable laws, see the published designated-agent process at asktilly.ai/takedown or email takedown@asktilly.ai. EU/EEA reporters may also file an Article 16 DSA notice via Ask Tilly AI Ltd's EU legal representative at dsa-rep@camerottolegal.it. The published process describes the 1-Business-Day acknowledgement and the 7-calendar-day DSA Article 16 substantive-disposition timelines, the information AskTilly requires in a notice, the counter-notice route, retention, and CSAM-escalation handling.