**Last Updated: June 17, 2025**
## Introduction
ThinkTotem ("we," "our," or "us"), operated by Tugulab Ltd., is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://thinktotem.com or use our app that helps people learn any content faster.
## Information We Collect
### Personal Data
We collect the following personal information:
- Name
- Email address
- Payment information
### Usage & Technical Data
We automatically collect certain non-personal information when you interact with the Service, including:
- Device and browser information
- IP address and approximate location
- Usage statistics (pages visited, features used)
- Cookies and similar tracking technologies
This data helps us improve performance, analyze trends, and personalize your experience.
### Conversation and Voice Data
When you engage with the AI tutor, we store conversation transcripts and, if voice mode is enabled, audio recordings and their transcriptions. This information is used to provide the Service, ensure quality, and improve our AI models.
## How We Use Your Information
We process your information to:
- Provide, operate, and maintain the Service (including AI tutoring and voice features)
- Process and manage subscriptions and payments
- Personalize learning plans and content
- Improve, monitor, and train our AI models (conversation data is anonymized when used for model improvement)
- Communicate with you about your account, updates, and promotional offers
- Detect, prevent, and address technical issues, abuse, or fraudulent activities
## Data Sharing and Disclosure
We share information only with trusted service providers who perform services on our behalf and under our instructions, including:
- Hosting, authentication, database
- LLM providers (AI content generation)
- Speech-to-text vendors (voice transcription)
- Payment processors
- Analytics providers (usage analytics and error tracking)
These partners are bound by confidentiality and security obligations. We may also disclose information to comply with legal obligations or protect our rights and users.
## Data Retention
We keep personal data only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required by law.
## Security
We use industry-standard technical and organizational measures—including encryption in transit and at rest, access controls, and regular audits—to protect your data.
## International Transfers
Your information may be transferred to and processed in countries other than your own. We rely on appropriate safeguards, such as Standard Contractual Clauses, to protect such transfers.
## Your Rights
Depending on your jurisdiction, you may have rights to access, correct, delete, or restrict processing of your personal data, as well as the right to data portability and to withdraw consent.
## Cookies
We use first- and third-party cookies for authentication, preferences, and analytics. You can control cookies through your browser settings, but disabling them may affect functionality.
## Children's Privacy
Our services are not directed to children under 13 years of age, and we do not knowingly collect personal information from children.
## Updates to This Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by sending an email to the address you have provided.
## Contact Us
If you have questions or concerns about this Privacy Policy, please contact us at:
Email: claudio@thinktotem.com
Company: Tugulab Ltd.
Address: United Kingdom
By using ThinkTotem, you consent to this Privacy Policy.
