Privacy Policy for Reply Lab: AI Texting Keyboard

Privacy Policy

Last updated: July 9, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  • Application refers to Reply Lab: AI Texting Keyboard, the software program provided by the Company.

  • Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

  • CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Application Of Technology, LLC, 17451 N 101st Way.

    For the purposes of the GDPR, the Company is the Data Controller.

  • Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

  • Country refers to: United States

  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

  • Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

  • Device Identifier means a randomly generated identifier created and stored on Your Device by the Application. It is not linked to Your real-world identity.

  • Advertising Identifier means the resettable identifier provided by Your Device's operating system for advertising purposes (on iOS, the Identifier for Advertisers, or "IDFA"). It is accessible to the Application only if You grant permission through Apple's App Tracking Transparency prompt.

  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

  • GDPR refers to EU General Data Protection Regulation.

  • Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual.

    For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

    For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

    We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.

  • Service refers to the Application.

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

    Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Reply Lab does not require You to create an account, and We do not ask for Your name, email address, phone number, or location in order to use the Application.

Device Identifier

When You use Reply Lab, the Application generates a random Device Identifier stored on Your Device. This identifier is not linked to Your real-world identity. It is used to apply usage limits, to let You manage community modes You have published, and to help prevent abuse of the Service.

Message Text You Submit for a Reply

When You ask Reply Lab to generate a reply, the text You provide for that request is transmitted through Our secure proxy to Our AI provider solely to generate the reply. We do not store this text on Our servers after the reply is generated, and We do not use it to build a profile of You or for advertising.

Screenshots You Choose to Attach

If You choose to attach a screenshot for analysis, the image is transmitted through Our secure proxy to Our AI provider solely to generate replies for that request. We do not retain the image after processing. Reply Lab does not request access to Your photo library; You select what to share each time.

Community Modes You Publish

If You choose to publish a custom "mode" to the community marketplace, the mode's content (its name, prompt, and any preview text You provide) is stored in Our database so other users can browse and download it. It is associated with Your Device Identifier so that You can edit or delete it later. Your Device Identifier is not displayed to other users.

Crash and Diagnostic Data

To keep the Application stable and reliable, We collect technical crash and diagnostic data when the Application encounters an error or crash. This may include the Device model, operating system version, Application version, and technical details about the error. This data is processed by Our crash-reporting Service Provider and is used solely to identify, diagnose, and fix problems. We configure this data collection to exclude the content of Your messages and replies.

Advertising Data (Only With Your Permission)

We use the TikTok Business SDK to measure the effectiveness of Our advertising — for example, whether a TikTok ad led to an app install, free trial, or subscription. If, and only if, You grant permission through Apple's App Tracking Transparency prompt, this involves sharing the following with TikTok:

  • Your Device's Advertising Identifier (IDFA)
  • App events, such as app installs, app launches, trial starts, and purchases (including the product and price)

We never share Your messages, conversations, screenshots, or generated replies with TikTok or any advertising partner. Advertising data is used solely to measure and improve Our advertising campaigns.

If You decline the tracking prompt, no Advertising Identifier is shared, and attribution is limited to Apple's privacy-preserving SKAdNetwork framework, which does not identify You or Your Device. You can change Your choice at any time in iOS Settings → Privacy & Security → Tracking.

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include Your Device's Internet Protocol (IP) address, request timestamps, the Device Identifier described above, and basic diagnostic data. We use this data only to enforce rate limits, monitor for and prevent abuse, and keep the Service reliable and secure. These short-term operational logs are retained briefly and then automatically deleted.

Payments

Subscriptions are processed by Apple through in-app purchase. We never receive or store Your payment card details. We receive only the subscription status needed to provide Pro features.

Use of Your Personal Data

The Company uses the limited information described above only to:

  • Provide and maintain the Service, including generating the AI replies and screenshot-based replies You request.
  • Enforce free and Pro usage limits.
  • Operate the community marketplace and let You manage modes You publish.
  • Measure the effectiveness of Our advertising, using only the advertising data described in "Advertising Data (Only With Your Permission)" and only if You grant tracking permission.
  • Maintain the security, reliability, and integrity of the Service, including detecting and preventing abuse and monitoring crash and diagnostic reports to keep the Application stable.
  • Provide customer support when You contact Us.
  • Comply with legal obligations.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, in which information held by Us about Service users is among the assets transferred.

We do not use Your message content for advertising, and We do not build advertising or behavioral profiles from Your conversations. Advertising measurement uses only the technical advertising data described above, and only with Your permission.

We may share Your information in the following limited situations:

  • With Service Providers: We share information with the Service Providers described in the "Detailed Information on the Processing of Your Personal Data" section, who process it on Our behalf and under contract solely to provide the Service.
  • With advertising partners: If You grant tracking permission, We share the advertising data described in "Advertising Data (Only With Your Permission)" with TikTok to measure and improve Our advertising campaigns.
  • For business transfers: We may share or transfer information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With other users: Content You choose to publish to the community marketplace (such as a mode's name, prompt, and preview text) is publicly visible to other users by design. Your Device Identifier is not shown.
  • For legal reasons: As described in the "Disclosure of Your Personal Data" section.
  • With Your consent: We may disclose information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations, resolve disputes, and enforce Our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose.

  • Message text and screenshots submitted for replies: not stored after the reply is generated.
  • Operational and security logs (IP address, request timestamps, Device Identifier): retained for a short period for security and abuse-prevention purposes, then automatically deleted.
  • Crash and diagnostic data: retained by Our crash-reporting Service Provider for a limited period to diagnose and fix issues, then deleted in accordance with their retention practices.
  • Advertising data: shared with TikTok only if You grant tracking permission, and retained by TikTok in accordance with its own privacy policy. We do not store this data on Our servers.
  • Community modes You publish: retained until You delete them or request deletion.
  • Subscription status: Payment card details are not stored on Our servers; they are processed by Apple. We retain limited subscription status information for as long as needed to provide and manage Pro features and to comply with applicable legal, tax, and accounting obligations.

We may retain Personal Data beyond the periods stated above where required by law, to establish, exercise, or defend legal claims, at Your explicit request, or where residual copies exist in backup systems scheduled for routine deletion.

You may request information about how long We will retain Your Personal Data by contacting Us.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

The Application gives You the ability to delete community modes You have published directly within the Service. You may also contact Us to request access to, correction of, or deletion of any Personal Data associated with Your Device Identifier.

You can stop the sharing of advertising data at any time by withdrawing tracking permission in iOS Settings → Privacy & Security → Tracking.

Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data only as needed to perform their functions on Our behalf, and are contractually required to process it solely to provide the Service. Our primary Service Providers are:

  • Anthropic — processes the text and screenshots You submit in order to generate replies.
  • Cloudflare — operates the secure proxy that routes requests and enforces rate limits.
  • Supabase — hosts the database used for the community marketplace.
  • Sentry — processes crash and diagnostic data to help Us monitor, diagnose, and improve the stability of the Service.
  • Apple — processes subscription payments and provides app distribution.

In addition, if You grant tracking permission:

  • TikTok — receives the Advertising Identifier and app events described in "Advertising Data (Only With Your Permission)" to measure the effectiveness of Our advertising. TikTok's use of this data is also governed by its own privacy policy, available at https://www.tiktok.com/legal/privacy-policy.

Payments

We may provide paid products and/or services within the Service. Subscriptions are processed by Apple.

We will not store or collect Your payment card details. That information is provided directly to Apple, whose use of Your personal information is governed by their Privacy Policy.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes. For example, advertising measurement occurs only if You grant permission through Apple's App Tracking Transparency prompt, and You may withdraw that permission at any time.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company, such as keeping the Service secure and preventing abuse.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

International Transfer of Personal Data

We may transfer, store, and process Personal Data in countries other than the country in which You are located, including countries outside the European Economic Area ("EEA") and the United Kingdom ("UK"), where data protection laws may differ.

Where we transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, We rely on appropriate safeguards, such as:

  • The European Commission's Standard Contractual Clauses ("SCCs") and/or the UK International Data Transfer Agreement ("IDTA") or the UK Addendum to the SCCs (as applicable)
  • Supplementary measures where appropriate, such as encryption in transit and at rest, access controls, data minimisation, and vendor security reviews.

We transfer Personal Data internationally only as needed to provide the Service and to work with Our Service Providers. You may contact Us using the details in the "Contact Us" section to request further information about the safeguards We use for international transfers.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. This enables You to receive a copy of the Personal Data We hold about You. Because We identify data by Device Identifier rather than account, We may ask You to provide information that lets Us locate the relevant data.
  • Request restriction of processing. You have the right to ask Us to restrict processing of Your Personal Data in certain circumstances.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format.
  • Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data, where consent is the legal basis for processing. For advertising measurement, You can withdraw consent at any time in iOS Settings → Privacy & Security → Tracking.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights by contacting Us. Please note that We may ask You to verify Your identity or provide information that lets Us locate the relevant data before responding to such requests. We generally respond within one month, and may extend by two further months where necessary, in accordance with applicable law.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information defined in the CCPA/CPRA, and what We actually collect.

  • Category A: Identifiers.

    Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

    Collected: Limited. We collect a randomly generated Device Identifier and Your IP address. With Your permission (via Apple's App Tracking Transparency prompt), We also collect Your Device's Advertising Identifier (IDFA) for advertising measurement. We do not collect Your real name, email address, or account name through the Application.

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

    Examples: A name, signature, physical characteristics, address, telephone number, identification card number, insurance policy number, education, employment, bank account number, credit card number, or other financial information, medical information, or health insurance information.

    Collected: No.

  • Category C: Protected classification characteristics under California or federal law.

    Collected: No.

  • Category D: Commercial information.

    Examples: Records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies.

    Collected: Limited. We receive Your subscription status from Apple. We do not receive Your payment details. With Your permission, purchase events (product and price) are shared with TikTok for advertising measurement.

  • Category E: Biometric information.

    Collected: No.

  • Category F: Internet or other similar network activity.

    Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

    Collected: Limited. We log request timestamps, crash and diagnostic data, and similar technical data for rate limiting, stability, and security. With Your permission, app events (such as installs, launches, trial starts, and purchases) are shared with TikTok for advertising measurement.

  • Category G: Geolocation data.

    Collected: No.

  • Category H: Sensory data.

    Collected: No.

  • Category I: Professional or employment-related information.

    Collected: No.

  • Category J: Non-public education information.

    Collected: No.

  • Category K: Inferences drawn from other personal information.

    Collected: No.

  • Category L: Sensitive personal information.

    Collected: No.

Under CCPA/CPRA, Personal Information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the CCPA/CPRA's scope.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, the text or screenshots You submit for a reply, or the modes You publish.
  • Automatically from You. For example, Your Device Identifier, IP address, Advertising Identifier (with Your permission), and crash or diagnostic data as You use the Application.
  • From Service Providers. For example, subscription status from Apple.

Use of Personal Information

We may use or disclose the personal information We collect for "business purposes" as defined under the CCPA/CPRA, including to:

  • Operate the Service and provide You with Our Service.
  • Provide support and respond to Your inquiries.
  • Measure the effectiveness of Our advertising (only with Your permission).
  • Detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Comply with applicable law.

Disclosure of Personal Information

We may disclose the following categories of personal information to Service Providers for business purposes:

  • Category A: Identifiers (Device Identifier and IP address)
  • Category D: Commercial information (subscription status)
  • Category F: Internet or other similar network activity (technical logs and crash or diagnostic data)

When We disclose Personal Information for a business purpose, We enter a contract that requires the recipient to keep that personal information confidential and not use it for any purpose except performing the contract.

In addition, if You grant tracking permission, We disclose the following categories to TikTok for advertising measurement, as described below under "Sale or Sharing of Personal Information":

  • Category A: Identifiers (Advertising Identifier)
  • Category D: Commercial information (purchase events)
  • Category F: Internet or other similar network activity (app events)

Sale or Sharing of Personal Information

We do not sell Your personal information for money. If, and only if, You grant tracking permission through Apple's App Tracking Transparency prompt, We disclose Your Advertising Identifier and app events (such as installs, trial starts, and purchases) to TikTok for advertising measurement and optimization. This disclosure may constitute "sharing" for cross-context behavioral advertising purposes as defined by the CCPA/CPRA.

You can opt out of this sharing at any time — and prevent it entirely — by declining or withdrawing tracking permission in iOS Settings → Privacy & Security → Tracking. The Application honors this choice automatically: if permission is not granted, no Advertising Identifier is shared. We do not otherwise sell or share personal information, and Our remaining disclosures are to Service Providers who process information on Our behalf and under contract, which is not a "sale" or "share" under applicable law.

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell personal information, and We do not knowingly share the personal information of any consumer We know to be under 16 years of age.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which they are used.
  • The right to know/access. You have the right to request that We disclose information about Our collection and use of personal information. Because We identify data by Device Identifier rather than account, We may ask You to provide information that lets Us locate the relevant data.
  • The right to opt out of sale or sharing. We do not sell personal information. Sharing for advertising measurement happens only with Your permission, and You may opt out at any time by declining or withdrawing tracking permission in iOS Settings → Privacy & Security → Tracking.
  • The right to correct Personal Information. You have the right to correct inaccurate personal information We collected.
  • The right to limit use and disclosure of sensitive Personal Information. We do not collect sensitive personal information.
  • The right to delete Personal Information. You have the right to request deletion of Your Personal Information, subject to certain legal exceptions.
  • The right not to be discriminated against for exercising any of Your rights.

Exercising Your CCPA/CPRA Data Protection Rights

To exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

Only You, or a person authorized to act on Your behalf, may make a verifiable request related to Your personal information. Your request must provide sufficient information to allow Us to reasonably verify You (or Your authorized representative) and describe Your request with sufficient detail for Us to evaluate and respond to it.

We will respond to a verifiable request free of charge within 45 days of receipt. The time period may be extended once by an additional 45 days when reasonably necessary and with prior notice.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals. However, You can control app tracking on iOS at any time in Settings → Privacy & Security → Tracking.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such content, please contact Us using the contact information below and provide enough detail (such as the relevant Device Identifier or mode) to let Us locate it.

Be aware that Your request does not guarantee complete or comprehensive removal of content and that the law may not permit or require removal in certain circumstances.

Children's Privacy

Reply Lab is not directed to children under 13, and We do not knowingly collect personal information from children under 13. If You are a parent or guardian and believe Your child has provided Us with personal information, please contact Us and We will take steps to delete it.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: