Tonic Notes

TONIC NOTES PRIVACY POLICY

Date of Last Revision: October 26, 2026

When you use the Tonic Notes services of Pocket Conservatory Inc. ("Tonic,” “we," “us," or “our”), you’re trusting us to handle your personal data. We take that trust seriously. This Privacy Policy describes how we collect, use, and disclose personal information through and in connection with our websites, including tonicnotes.com, our Tonic Notes applications, and any other website or service that we own or control and that links to this Privacy Policy (collectively, the “Service” or “Services”). This Privacy Policy applies to our website visitors, users of our applications, and other individuals who interact with us.

Personal Information We Collect

We collect the following categories of personal information about you:

Information you provide to us:

Where you provide us with the personal information of third parties, such as your friends or other contacts, it is your responsibility to inform them about the processing of their personal information in accordance with this Privacy Policy, and to confirm that they have given their permission.

Automatic data collection. We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interactions over time with the Services, online resources, and our communications.

We use the following tools for automatic data collection:

Information we obtain from other sources:

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:

To provide our Services. This includes:

For research, development, benchmarking, and improving our Services. We may use personal information to analyze and improve the Services, identify trends, and operate and expand our business activities. We may also create aggregated, anonymized, or other de-identified statistics, which we may use for lawful business purposes, including for analytics, forecasting, and strategic planning.

For marketing and advertising. We and our advertising partners may collect and use personal information for marketing and advertising purposes. We do not serve interest-based advertising to children through our application for children.

For compliance and protection. We may use personal information to comply with legal obligations, including to enforce any applicable terms and conditions, defend against legal claims or disputes, protect the security and integrity of our Services, and identify and investigate fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Disclose Personal Information

We may disclose personal information to the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Other users. If you link your account to another user's account, use our communications or collaboration features, or otherwise interact with other users through the Services, certain information associated with your account may be visible to or shared with those users. This may include your name, profile information, and any content you choose to share or make available through such features. Please exercise caution when disclosing personal information to other users.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business, including providers of hosting and cloud infrastructure, artificial intelligence and content generation, information technology and security, error monitoring, customer support, SMS delivery, payment processing, data analytics, fraud detection, and professional services. We do not allow third-party service providers to develop or train models using your personal information. We also take steps to minimize the personal information shared with our service providers. The types and extent of information transmitted will depend on the content you provide through the Services.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, our business (including, in connection with a bankruptcy or similar proceedings).

Your Privacy Rights and Choices

Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related communications – both emails and texts – by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You may continue to receive Services-related and other non-marketing communications.

Opt out of online tracking. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services. Please review the privacy policies and terms of all third-party services carefully.

Security

We use reasonable organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

Retention of Personal Information

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Children’s Privacy

This section serves as our direct notice to parents and guardians and describes our practices with respect to personal information collected from children under 13 years of age.

Parental Consent. We require advance parental consent before collecting personal information from children under 13. Before collecting personal information from a child under 13, we seek verifiable parental consent. During the registration process, we determine your age and eligibility for the Service. Where parental consent is required, we use an “email plus” method to obtain parental consent where we are permitted to do so. We send a notice to the parent or legal guardian at the email address provided during registration describing our information practices and requesting consent. The parent or legal guardian must affirmatively respond to or otherwise confirm the consent request, and we take an additional confirmatory step to help ensure that consent was provided by the parent or legal guardian.

By providing consent, you represent that you are the parent or legal guardian of the child for whom you are registering an account and consent to our collection, use, and disclosure of the child’s personal information as described in this Privacy Policy. A parent or legal guardian may modify or revoke consent at any time by contacting us as described in the “How to Contact Us” section below.

Information We Collect from Children. We may collect the following categories of personal information from children under 13: basic identifiers, vocal information, identifiers contained in photographs, video and audio recordings processed through the Services, device information, and limited automatically collected information used solely for internal operations.

Parental Rights. Parents and legal guardians have the right to review the personal information we have collected from their child, request deletion of their child's personal information, and refuse further collection or use of their child's personal information. To exercise these rights, parents may contact us as described in the "How to Contact Us" section below and we will respond to such requests within a reasonable time. If you close an account, we will mark the account in our database as “Closed,” but may retain personal information from the account to deactivate the account with our service providers, allow you to reactivate the account for some period in the future, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce our terms, or take other actions as required or permitted by law. If you request that we delete your child’s personal information, we will delete as much information as we are legally permitted. Due to regulatory recordkeeping obligations, we may be required by law to retain some information associated with a closed account. If we learn that we have inadvertently collected the information of a child without parental consent, as required by law, we will delete this information.

How We Use Children's Information. We use children's personal information solely to provide and support the internal operations of our child-directed Services, including generating AI-enhanced music lessons and insights. We do not use children's personal information for model training, research or development. We do not serve behavioral or targeted advertising to children under 13 through our child-directed Services, and we do not direct third parties to do so on our behalf.

Disclosure of Children's Information. We may disclose children's personal information only to service providers that support the internal operations of our child-directed Services, such as hosting, AI assisted processing, and security providers. Our service providers may operate or support certain functions of the Service. Below is an illustrative list of functions for which we may use third party service providers and the names of the providers we may use to perform these functions:

We do not sell or otherwise disclose children's personal information to third parties for their own commercial purposes. We do not share children's personal information with advertising partners.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Where we do so, we will update the date of this Privacy Policy and post it on the Services. If we make material changes to this Privacy Policy, we will let you know.

How to Contact Us

Contact us. If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please email us at privacy@tonicnotes.com.