Privacy policy

Working draft pending legal review before public launch. The data flows and sub-processors below are accurate; the legal framing is being confirmed.

Who we are

Toby is operated by Seagull Tech Solutions Ltd, a company registered in England & Wales (company no. 16974447). Contact: support@seagulltech.co.uk. We are registered with the UK Information Commissioner's Office (ICO).

We are the data controller for your account details and how you use Toby. For the customer records, notes and emails you put into Toby, you are the controller of that information and we process it on your behalf, under your instructions, to run the service for you.

What we collect

Account details: your name and email address.
The customer records, jobs and notes you create in Toby.
Voice notes you record, which we transcribe to text.
If you connect a mailbox, the emails Toby reads so it can file them against the right customer. You choose whether to connect Gmail or Outlook, and you can disconnect at any time.
Basic usage and diagnostic data (app version, error reports) so we can keep the app working.

How we use it

Only to provide the service: organising your jobs, transcribing and summarising your own content, filing your emails, generating your briefings, and chasing your follow-ups. We do not sell your data and we do not use it for advertising.

Where your data is stored

Your account and customer data is stored in the United Kingdom, on Google Cloud infrastructure in the London region. Some processing described below involves providers outside the UK; where that happens, the transfer is protected by appropriate safeguards such as Standard Contractual Clauses or a UK adequacy decision.

How we protect your data

We take particular care with sensitive data, including the emails Toby reads from your connected mailbox. We protect it with the following measures:

Encryption in transit. All data moving between the app, our servers and our providers travels over encrypted connections (HTTPS/TLS).
Encryption at rest. Your stored data, including your customer records and the access tokens used to connect your mailbox, is encrypted at rest on Google Cloud infrastructure.
Secure token handling. The credential used to connect your Gmail or Outlook account is held in your device's secure system keystore and, on our servers, in encrypted storage. It is used only to read and file your mail, and you can revoke it at any time.
Least-privilege access. Toby requests only the narrowest mailbox permission it needs (read-only access to your mail) and never requests permission to send, delete or modify your email.
Access controls and monitoring. Access to production systems is restricted to authorised staff, and direct access to stored customer data is logged and auditable. We monitor our systems for errors and security events.

AI processing

Toby uses AI to transcribe your voice notes and to summarise and organise the content you give it. To do this, the relevant content (for example a voice recording, a note, or an email you have asked Toby to file) is sent to our AI provider, OpenAI, for processing and returned to you. This processing happens in the United States.

Your content is not used to train OpenAI's models. It is processed only to produce the result you asked for and is handled under a data processing agreement with that provider.

Improving Toby's answers

Toby answers questions about your own records, and we need to know when those answers are wrong in order to fix them. What we keep depends on the kind of account you have:

Paying customers. While you are on a paid plan we keep no copy of your questions or Toby's answers. We record only anonymous diagnostics: which feature ran, how large the request was, a broad subject label such as "money" or "dates", and whether Toby was able to answer. None of it contains your records or anything about a specific customer of yours.
Testers on a free or comped account. We also keep the question you asked and the answer Toby gave, for 30 days, so we can see where Toby helps and where he falls short. We do not keep the records behind the answer: not your notes, not your emails, not your documents. An answer does sometimes repeat a customer's name, a price or a date back to you, so some of your work appears in what we read. Testers are told this inside the app.
Our own internal accounts. Everything the AI was given and everything it replied, again for 30 days, so a fault can be traced end to end. These are our own accounts, not customers'.

Anything we keep is stored with your account data in the United Kingdom, is deleted automatically after 30 days, is never sold or shared, and is never used to train anyone's AI models. Deleting your account deletes it along with everything else.

If your account moves between these groups — a tester taking out a paid plan, for example — the new rules apply from that moment on. Anything already kept runs out its 30 days and then deletes itself.

Who we share it with

We share data only with the service providers (sub-processors) that make Toby work. Each processes data on our behalf under contract:

Google Cloud / Firebase (United Kingdom): hosting, database and sign-in.
OpenAI (United States): the AI transcription and summarisation described above.
Stripe: payment and subscription processing. Your card details go directly to Stripe; we never see or store them.
Sentry (European Union): error monitoring, so we can fix crashes. Configured not to collect the contents of your records.
PostHog (European Union): product analytics, so we can see which features are used and where people get stuck. We send only anonymous usage events (screens viewed, actions taken), never the contents of your records.
Cloudflare: hosting and privacy-friendly analytics for this website.

Email access

If you connect Gmail or Outlook, Toby requests only the access it needs to read your incoming and sent mail and file it against the right customer, so each record holds both sides of the conversation. We do not send email from your account. You can revoke this access at any time from your email provider's security settings or by disconnecting inside Toby.

Toby's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements. We use Gmail data only to read and file your customer emails inside Toby. We do not transfer it to anyone except the sub-processors listed above that operate Toby on our behalf, we never sell it, we do not use it for advertising or to train AI models, and no human reads it except where you ask us to for support, where strictly needed for security, or — on a tester or internal account, as described in "Improving Toby's answers" above — where you have been told we keep the questions and answers from your account to fix faults.

Support access

A small number of Seagull Tech staff can access your account data when it is needed to help you with a support request or to investigate a fault. Access is limited to what the issue requires, and direct access to stored data is logged.

Legal basis

We process your account and customer data to perform our contract with you (providing the service). Where we process diagnostic data to keep the app secure and reliable, we rely on our legitimate interests in doing so.

Retention

We keep your data while your account is active. When you delete your account, your data is removed from our live systems within 30 days. Short-lived encrypted backups roll off within 7 days after that. Anything kept under "Improving Toby's answers" deletes itself 30 days after it was created, whether or not you delete your account, and rolls out of those backups within 7 days of that. See how to delete your account.

Your rights

You can export all your data or delete your account at any time from within the app. Under UK GDPR you also have rights of access, correction, erasure and portability, and the right to complain to the ICO. To exercise any of these, contact support@seagulltech.co.uk.

Changes

If we change this policy we will update the date above and, for significant changes, let you know in the app or by email.