Legal
Tovael Privacy Policy
Effective: May 6, 2026 · Last updated: June 23, 2026
1. Who We Are
Tovael is operated by TJNAI.ai LLC, a North Carolina limited liability company. TJNAI.ai LLC is the data controller for all personal data collected through Tovael.
Email: support@tjnai.ai
Website: tjnai.ai
2. What We Collect
We collect only what is necessary to provide the app:
- Email address: Account creation and authentication
- Pool configuration: Name, volume, type, strip preference — for accurate chemical recommendations
- Pool chemistry readings: Chlorine, pH, alkalinity, CYA, hardness — your test history
- Device push token: Optional — for weekly pool reminders, requires your permission
- Anonymized purchase identifiers: Verifying your in-app purchase entitlement
- Security audit logs: Detecting and preventing abuse
We do not collect your name, location, or any information unrelated to pool management.
Camera & photos: The app requests camera access to photograph test strips. Images are transmitted to our AI analysis service and permanently deleted immediately after analysis completes. No strip photos are stored.
3. Legal Basis for Processing (GDPR)
For users in the EEA and UK, we process your data under these legal bases:
- Account and pool data: Contract — necessary to provide the service
- Push notification token: Consent — only when you enable reminders; withdrawable in Settings
- Purchase identifiers: Legitimate interest — to verify your purchase entitlement
- Security audit logs: Legitimate interest — protecting service integrity
4. How We Use Your Data
We use your data exclusively to:
- Provide pool chemistry analysis and recommendations
- Store your reading history
- Send weekly pool testing reminders (only if you opt in)
- Verify your in-app purchase
- Detect and prevent abuse
We do not use your data for advertising, profiling, or any purpose unrelated to pool management. We do not sell your data to any third party.
5. Third-Party Processors
We share data with these service providers solely to operate Tovael:
- Supabase: Database, authentication, file storage (US)
- Anthropic: AI analysis of strip photos (US)
- RevenueCat: In-app purchase management (US)
- Apple: App distribution, push delivery (US)
Each provider is bound by a data processing agreement. International transfers: All processors are US-based. For EEA/UK users, transfers to the US are made under Standard Contractual Clauses (SCCs) approved by the European Commission.
6. Data Retention
We retain your data for as long as your account is active. When you delete your account — via Profile → Delete Account in the app or by emailing us — all of your personal data (profile, readings, push token, audit logs, and email address) is permanently and immediately deleted from our systems.
The one exception is a one-way, irreversible hash of your email address, which we retain solely to enforce our free-trial limit — so the free trial cannot be reset by repeatedly deleting and recreating an account. This hash cannot be reversed to recover your email or used to contact you, and is not linked to any other data. We retain it under our legitimate interest in preventing abuse of the service.
7. Your Rights
All users- Access: Request a copy of the data we hold about you
- Correction: Update inaccurate data (most can be updated in the app)
- Deletion: Delete your account and all data instantly via Profile → Delete Account, or by emailing support@tjnai.ai
- Portability: Request your data in a machine-readable format (CSV or JSON)
- Restriction: Pause processing of your data without deleting it
- Object: Object to processing based on legitimate interest
- Withdraw consent: Disable push notifications anytime in iOS Settings or in the app
- Lodge a complaint: Contact your local Data Protection Authority — EU: edpb.europa.eu, UK: ico.org.uk
You have the right to know what personal information we collect, to request deletion, and to opt out of the sale of personal information. We do not sell personal information.
To exercise any of these rights, email support@tjnai.ai. We will respond within 30 days.
8. Automated Decision-Making (GDPR Article 22)
Tovael uses AI to analyze test strip images and generate chemical recommendations. This analysis is a tool to assist you — it is not a binding automated decision and has no legal or similarly significant effect on you. You remain in full control of all pool chemical decisions.
9. EU/UK Representative (GDPR Article 27)
TJNAI.ai LLC is based in the United States. We are not required to appoint an EU or UK representative under Article 27 because our processing is occasional, limited to individuals who voluntarily registered for Tovael, and does not involve large-scale processing of special categories of data.
10. Required vs. Optional Data (Article 13(2)(e))
- Email address: Required — without it you cannot create an account
- Pool configuration: Required — recommendations cannot be generated without it
- Push notification token: Optional — without it you will not receive weekly reminders
11. Children and Age of Consent
Tovael is not directed at children. Under GDPR, the minimum age for digital consent is 16 in most EU member states, though member states may lower it to 13. Under US law (COPPA), the threshold is 13. We apply a minimum age of 13 globally. If you are between 13 and 16 in an EU member state requiring parental consent at your age, please ask a parent or guardian to review and accept these terms on your behalf.
12. Security
We protect your data with:
- Encryption in transit (TLS) and at rest
- Row-level security on our database — your data is only accessible by you
- Secure token storage on your device (iOS Keychain)
- Automatic deletion of strip photos immediately after analysis
13. Changes to This Policy
We may update this policy from time to time. We will notify you of material changes by updating the “Last updated” date above. Continued use after changes constitutes acceptance.
14. Contact
TJNAI.ai LLC
Email: support@tjnai.ai
Web: tjnai.ai/tovael-privacy