Privacy Policy

Effective Date: 31 August 2026 · Last Updated: 31 August 2026 · New Roads International Ltd

This Privacy Policy describes how New Roads International Ltd ("Company", "we", "us", or "our") handles personal information in connection with the ToneShift AI: Keyboard & Reply mobile application ("ToneShift AI" or "App"), available on iOS and Android. We are committed to full transparency regarding our data practices and to protecting your privacy in accordance with global privacy laws including UK GDPR, EU GDPR, and CCPA.

1. Introduction & Core Privacy Commitment

ToneShift AI is a keyboard extension and AI communication assistant developed and operated by New Roads International Ltd, registered in Scotland, United Kingdom (SC614092). ToneShift AI is built around a strict privacy-by-design architecture:

• We never keylog or record your general background typing
• We never sell, rent, or trade your personal conversations or text inputs
• We process text drafts and copied messages ephemerally, solely to return your requested AI suggestions

2. Information We Process and How It Is Used

To deliver in-line tone rewrites and Smart Replies, ToneShift AI processes specific text inputs strictly on an on-demand, transient basis.

A. User-Initiated Text Drafts (Tone Rewrite)

• What We Process: The specific text you type into your draft field and submit by tapping a tone button (e.g. Professional, Casual, Assertive, Flirty)
• How It Is Used: Transmitted via secure TLS/HTTPS encryption to our backend API endpoints exclusively to generate your chosen text variants
• Retention: Text is processed in-memory and discarded immediately after suggestions are delivered to your screen — typically within 2 seconds. It is never stored on our servers or logged into persistent databases

B. User-Triggered Clipboard Data (Smart Reply)

• What We Process: Snippets of text currently held on your device's clipboard
• How It Is Used: Read only when you explicitly tap the "Smart Reply" button inside the custom keyboard interface
• Protection: ToneShift AI never reads, monitors, or collects background clipboard contents automatically. Clipboard data is processed in memory and immediately discarded once reply options are returned

C. Technical & Subscription Identifiers

• Anonymous device identifiers — system OS version, app version, and device model used to ensure compatibility and app stability
• Subscription status — managed via Apple App Store in-app purchase tokens or Google Play Billing to verify active premium access and enforce rate limits
• Crash logs and analytics — anonymised and aggregated, not linked to your personal texting activities

This data is never linked to your personal text inputs or used to identify you as an individual.

3. Purpose of "Full Access" (iOS Open Access Permission)

To enable AI processing, custom iOS keyboard extensions require the "Allow Full Access" system setting to be enabled.

• Why It Is Required: "Full Access" expands the keyboard sandbox to permit outbound network requests over HTTPS. Network access is strictly required to route your requested text snippets to our secure AI processing servers
• What It Does NOT Give Us: Granting "Full Access" does not give us access to your personal device files, passcodes, contacts, location data, or typing history across other keyboards or apps
• Our Guarantee: We do not transmit or record any keystrokes typed outside of explicit user actions within ToneShift AI

You can revoke Full Access at any time: Settings → General → Keyboard → Keyboards → ToneShift AI → Disable "Allow Full Access". Note that disabling Full Access will prevent AI text generation features from operating.

4. Third-Party AI Service Providers (Guideline 5.1.2 Disclosure)

ToneShift AI integrates with third-party Large Language Model (LLM) API providers to generate tone adjustments, text rewrites, and Smart Reply suggestions. In compliance with Apple App Store Guideline 5.1.2, we disclose the following:

AI Providers Used

Text submitted by the user may be processed by one or more of the following enterprise-grade AI API providers:

• OpenAI (openai.com) — provider of GPT-series language models
• Anthropic (anthropic.com) — provider of Claude-series language models

How Third-Party AI Data Is Handled

• Ephemeral processing only — data sent to AI API endpoints is processed solely to fulfil your requested output and is not retained beyond the duration of the API call
• Zero Training Policy — under our commercial API terms, data sent to these processing endpoints is processed ephemerally. It is not stored, retained, or used to train global AI models
• Confidentiality agreements — all providers are bound by data processing agreements prohibiting unauthorised use, retention, or disclosure of user data
• Encrypted transmission — all data is transmitted over HTTPS/TLS encrypted connections
• No data brokering — user text data is never sold to or shared with any third party for commercial purposes

5. Data Minimisation & Retention

In compliance with Apple App Store Guideline 5.1.1(iii) and UK GDPR data minimisation principles:

Data Type	Retention Period	Notes
Text inputs & clipboard snippets	0 days (ephemeral)	Exists in memory only during API call (~2 seconds), then destroyed
Subscription tokens	Duration of subscription	Anonymised — no financial data stored by us
Device identifiers & analytics	Up to 12 months	Anonymised and aggregated — cannot identify an individual
Crash logs	Up to 90 days	No personal identifiers attached

No account creation is required. We do not collect your name, email address, phone number, or social credentials to use ToneShift AI.

6. Data Deletion & User Rights

Because ToneShift AI operates without user account registration, we do not maintain personal profiles or historical logs of your text inputs.

How to Request Data Deletion (Google Play & Apple App Store)

Local Data Reset

You may clear all local app cache and preferences at any time by deleting ToneShift AI from your device. This immediately removes all locally stored preferences and settings.

Additional Rights

Depending on your location, you may also have the right to:

• Request information about what data we hold in connection with your device
• Request correction of any inaccurate data
• Object to or restrict processing of your data
• Lodge a complaint with your relevant data protection authority
• Withdraw consent at any time by uninstalling the app and contacting us to delete associated data

UK users may contact the Information Commissioner's Office (ICO) at ico.org.uk or 0303 123 1113.

7. Security Protocols

All communications between the ToneShift AI extension, our server environment, and third-party AI endpoints are secured using TLS/HTTPS encryption protocols (256-bit encryption in transit). We enforce strict access controls and conduct regular reviews of our data processing activities.

8. Children's Privacy

ToneShift AI is rated 13+ on both the Apple App Store and Google Play Store. The app is not intended for use by children under the age of 13 (or 16 in certain EU jurisdictions). We do not knowingly collect personal information from children under 13. If you believe a child under 13 has used the app and provided information, please contact us immediately at tech@newroads.scot.

9. International Users

ToneShift AI is available globally. We comply with applicable data protection laws in all territories, including UK GDPR, EU GDPR, CCPA (California), COPPA (US), and applicable Asia-Pacific data protection legislation.

10. Contact & Data Controller

11. Updates to This Policy

We may update this Privacy Policy periodically to reflect technical or legal changes. Any updates will be posted to this URL with a revised "Last Updated" date. The current version is always available at newroads.scot/toneshift-privacy. Last updated: 31 August 2026.