Privacy Policy

1Overview

This Privacy Policy explains how POSITIVE COMMUNICATIONS LLC ("Rowi," "we," "us," or "our") collects, uses, discloses, stores, and protects personal information when users access or use the Rowi mobile application for iOS and Android, the Rowi website, and related services (collectively, the "Services").

By using Rowi, users acknowledge that they have read this Privacy Policy. If a user does not agree with this Privacy Policy, the user should not use the Services.

This draft is designed for a product that is initially free and may later introduce donations, paid features, subscriptions, or other monetization models. The policy should be updated before any material change in the data collected, product features, monetization, analytics, advertising, AI providers, or countries of availability.

2Controller and Contact Information

The entity responsible for the Services is POSITIVE COMMUNICATIONS LLC.

Company mailing address: 2 S Biscayne Boulevard, Suite 3200 #742, Miami, FL 33131.

Privacy contact: support@getrowi.app.

If local law requires a separate privacy representative, data protection officer, or local agent, that information should be added before publication.

3Scope of this Policy

This Privacy Policy applies to the Rowi app, the Rowi landing page and website, account registration flows, support communications, and any related services that link to this Privacy Policy.

This Privacy Policy does not apply to third-party websites, platforms, app stores, payment providers, social networks, or AI providers that may have their own privacy policies.

4Eligibility and Age Restriction

Rowi is intended for users who are 18 years of age or older. Rowi is not intended for children or minors. We do not knowingly collect personal information from users under 18. If we learn that a user under 18 has provided personal information, we may delete the account and associated data.

5Personal Information We Collect

Depending on how a user interacts with Rowi, we may collect the following categories of information:

• Account information: name, email address, login method, account identifiers, authentication data, and optional phone number.
• Profile and personalization information: age, height, weight, preferences, goals, productivity information, tasks, routines, and other information the user chooses to enter.
• Photos and user-provided media: profile images or photos that the user chooses to upload or use in the app. Rowi does not access the user photo library unless the user grants permission or selects photos.
• Location information: approximate or precise location, depending on the feature and device permissions granted by the user. If precise location is not required for a feature, Rowi should use approximate location or user-entered location when possible.
• Device and technical information: device type, operating system, app version, IP address, identifiers, crash logs, diagnostic data, browser information, and similar technical data.
• Usage and behavior data: events inside the app, screens viewed, features used, clicks, interactions, session information, and performance data.
• Support information: communications sent to support, requests, feedback, bug reports, and related metadata.
• Website and cookie data: cookie identifiers, analytics events, campaign source, advertising identifiers where permitted, and similar website tracking data.

6Sensitive or Higher-Risk Information

Some information Rowi may collect, such as height, weight, age, photos, location, and productivity or personal goals, can be sensitive depending on the context and applicable law. Rowi should collect only what is necessary for the specific product feature and should not use body metrics, photos, or precise location for targeted advertising unless expressly reviewed and legally approved.

Rowi is not a medical, health diagnosis, therapy, legal, financial, or emergency service. Information generated by Rowi should not be used as professional advice.

7How We Collect Information

We collect information in the following ways:

• Directly from users when they create an account, complete a profile, enter tasks or goals, upload content, contact support, or use app features.
• Automatically through the app, website, cookies, pixels, SDKs, analytics tools, device identifiers, logs, and similar technologies.
• From authentication providers, such as Google Sign-In and Apple Sign-In, when a user chooses those login methods.
• From third-party service providers that help us operate, analyze, secure, and improve the Services.

8How We Use Personal Information

We may use personal information for the following purposes:

• Create, authenticate, and manage user accounts.
• Provide, personalize, maintain, and improve Rowi features.
• Organize tasks, goals, productivity inputs, and user-provided content.
• Generate AI-assisted suggestions, summaries, recommendations, and productivity support.
• Respond to support requests and communicate with users about the Services.
• Analyze usage, troubleshoot bugs, improve performance, and measure app and website effectiveness.
• Protect the security, integrity, and availability of the Services.
• Prevent fraud, abuse, spam, unauthorized access, and policy violations.
• Operate website analytics and marketing measurement, subject to applicable consent requirements.
• Comply with legal obligations, enforce our Terms of Use, and protect rights and safety.
• Develop aggregated or de-identified insights that cannot reasonably identify a user.

9Artificial Intelligence Processing

Rowi uses artificial intelligence providers to help organize tasks, goals, productivity information, and other content that users choose to enter. Depending on the feature, Rowi may process user content through providers selected by us, which may include OpenAI, Google Gemini, Anthropic, or other equivalent AI providers.

AI-generated outputs may be inaccurate, incomplete, or inappropriate. Users should review outputs before relying on them. Rowi does not provide medical, legal, financial, psychological, or other professional advice.

Unless separately disclosed and agreed, Rowi does not intend to use personal user content to train proprietary public AI models. Third-party AI providers process information according to applicable agreements and their own service terms. Rowi should implement commercially reasonable settings and controls to limit unnecessary retention or training uses where available.

10Third-Party Services and SDKs

Rowi may use third-party services to operate and improve the Services. These may include:

• Authentication providers, including Google and Apple.
• Analytics providers, including Google Analytics and related Google tools.
• Website advertising and measurement tools, including Meta Pixel and TikTok Pixel, subject to consent settings where required.
• AI providers, including OpenAI, Google Gemini, Anthropic, and similar providers.
• Hosting, database, cloud infrastructure, crash reporting, customer support, email, security, and monitoring providers.
• App stores and mobile platform providers, including Apple and Google.

11Cookies, Pixels, and Similar Technologies

The Rowi website may use cookies, pixels, SDKs, local storage, and similar technologies for necessary site operation, analytics, performance measurement, and marketing measurement.

Where required by law, non-essential cookies and similar technologies should be disabled until the user provides consent. Users should be able to accept all, reject non-essential, or manage cookie preferences through a cookie settings interface.

More information should be available in the Rowi Cookie Policy at https://getrowi.app/cookies.

12Advertising and Marketing Measurement

Rowi does not currently include paid in-app purchases. Rowi may use marketing and analytics tools to measure website campaigns, app installs, engagement, and product performance.

We do not sell personal information for money. Some uses of pixels or advertising tools may be considered "sharing" or targeted advertising under certain privacy laws. Where required, users should be given a way to opt out of such sharing or targeted advertising.

13Legal Bases for Processing

Where applicable, Rowi processes personal information based on one or more of the following legal bases: user consent, performance of a contract, legitimate interests, compliance with legal obligations, and protection of rights, safety, and security.

Consent may be required for certain permissions, cookies, precise location, marketing communications, and other higher-risk processing depending on applicable law.

14How We Share Personal Information

We may share personal information with:

• Service providers that process information on our behalf.
• AI providers when necessary to deliver AI-powered features selected or used by the user.
• Analytics, measurement, and advertising partners as described in this Privacy Policy and the Cookie Policy.
• App stores and authentication providers as necessary for login and distribution.
• Professional advisors, such as legal, accounting, security, or compliance providers.
• Authorities, courts, regulators, or third parties where required by law or necessary to protect rights, safety, and security.
• Successors in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction.

15International Transfers

POSITIVE COMMUNICATIONS LLC is a U.S. company, and Rowi may be accessed from LATAM, the United States, and other countries. Personal information may be processed in the United States and other countries where our service providers operate. Privacy laws in those countries may differ from the laws of the user country.

16Data Retention

We retain personal information for as long as necessary to provide the Services, maintain the user account, comply with legal obligations, resolve disputes, prevent fraud and abuse, enforce agreements, and maintain security.

When a user deletes an account, Rowi will delete or de-identify personal information associated with that account, except where retention is necessary for legal, security, fraud prevention, backup, or compliance reasons. Backup deletion may take additional time according to operational cycles.

17Account and Data Deletion

Users may request deletion of their Rowi account and associated personal data from within the app by going to Settings > Account > Delete Account, or through the web resource at https://getrowi.app/delete-account.

Users may also contact support@getrowi.app for privacy or deletion requests. We may need to verify the request before deleting information.

18User Rights and Choices

Depending on location and applicable law, users may have rights to:

• Access, correct, update, or delete personal information.
• Object to or restrict certain processing.
• Withdraw consent where processing is based on consent.
• Request a copy or portability of certain data.
• Opt out of certain targeted advertising, sharing, or marketing communications.
• Lodge a complaint with a data protection authority where applicable.

To exercise these rights, contact support@getrowi.app.

19Mobile Permissions

Rowi may request permissions such as photos, notifications, location, or other device access. Users can manage permissions through device settings. If a permission is not granted, some features may not work or may work with limited functionality.

20Security

We use commercially reasonable administrative, technical, and organizational measures designed to protect personal information. However, no system is completely secure. Users should use strong passwords, protect their devices, and contact us immediately if they suspect unauthorized account access.

21Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If changes are material, we will provide notice through the app, website, email, or other reasonable means. Continued use of Rowi after an update means the user acknowledges the updated Privacy Policy.

22Contact

For privacy questions, requests, or concerns, contact POSITIVE COMMUNICATIONS LLC at support@getrowi.app.

Mailing address: 2 S Biscayne Boulevard, Suite 3200 #742, Miami, FL 33131.