Privacy Policy

1. Data Controller and How to Contact Us

TEMPO ("we," "us," or "our") operates the TEMPO mobile application and related services (collectively, the "Service").

For the purpose of the General Data Protection Regulation and applicable privacy laws, TEMPO is the data controller responsible for any personal data processed in connection with the Service.

If you have any questions or concerns about this Privacy Policy, or wish to exercise any of your rights, please contact us:

This Privacy Policy should be read together with our Terms of Service. By using the Service, you acknowledge that you have read and understood this Privacy Policy.

2. What Personal Data We Collect and Why

A. Sources of Personal Data

We obtain your personal data from the following sources:

1. directly from you, when you submit questions, sign in with Google, contact support, or otherwise interact with the Service;
2. automatically from your device when you use the Service;
3. from third-party service providers that support the Service, including Google (when you sign in with your Google account or purchase a subscription through Google Play), our advertising partner, and our cloud hosting providers.

B. Categories of Personal Data

We collect and process the following categories of personal data:

1. Device profile — when you first open TEMPO, we generate a random identifier for your installation and create a guest profile tied to it. No registration is required.
2. Google account information — if you choose to sign in with Google, we receive your email address, display name, profile picture, and Google account identifier from Google, and use them to link your progress to your account.
3. Questions and inputs — the content of questions or prompts you submit to AI-powered features of the Service (see Section 2.D);
4. In-app activity — your Gem balance and usage, reading sessions, subscription status, and features you have used;
5. Device and technical data — device type, operating system, IP address, and basic log data;
6. Advertising data — if you use the free, ad-supported tier, our advertising partner processes your device's advertising identifier and related device information to serve ads (see Section 2.F);
7. Purchase confirmations — transaction identifiers received from Google Play when you purchase a subscription (we do not receive your full payment card details);
8. Communications — the content of any message you send to our support team.

C. Purposes and Lawful Bases

Contract. We process your personal data on the basis of contract to:

• provide the Service, including maintaining your guest or linked account, delivering content, managing your Gem wallet, and processing your subscription;
• generate AI responses to questions and prompts you submit (see Section 2.D); and
• restore your progress when you sign in with your Google account on a device.

Legitimate Interest. We process your personal data on the basis of our legitimate interests as follows:

Consent. Where required by law (for example, in the European Economic Area and the United Kingdom), we rely on your consent for personalised advertising, collected through a consent prompt in the app. You can decline or withdraw consent, in which case ads may be non-personalised.

Legal Obligation. We process your personal data to comply with legal obligations and respond to lawful requests.

D. AI Processing of Your Questions

When you use AI-powered features of the Service that accept a question or prompt, the content of your submission is transmitted to a third-party AI provider to generate a response.

• The AI provider processes this content in accordance with its own terms and privacy policy.
• We do not authorise our AI providers to use your questions or our API traffic to train their AI models.
• Our retention rules (Section 2.E) apply to the copy of the question we hold. The AI provider's retention rules apply independently to any copy held on their systems.

To protect your privacy, you should not include sensitive personal information in questions (such as government ID numbers, financial account details, or health information). This is also required by our Terms of Service.

E. Retention

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of the Service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise, or defence of legal claims. Reading sessions expire and are removed automatically after a limited period.

Account deletion. You may request deletion of your account and associated personal data at any time by following the instructions on the Delete Account page. Deletion requests are processed within 30 days, after which your account and the personal data tied to it are permanently removed, subject to data we are required to retain by law.

F. Advertising

The free tier of TEMPO is supported by advertising served by Google AdMob, including optional rewarded ads you can choose to watch in exchange for Gems. To serve and measure ads, Google may process your device's advertising identifier, IP address, and device information in accordance with its own privacy policy. You can learn how Google uses this data at policies.google.com/technologies/ads, and you can reset or delete your advertising identifier in your device's settings. TEMPO Premium subscribers are not shown ads.

3. Who We Share Your Personal Data With

Our Partner Organisations and Service Providers

We may disclose information about you to organisations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and to comply with applicable data protection laws.

We may share your information with the following types of service providers:

1. technical and infrastructure providers that assist with our hosting and IT systems;
2. AI providers that generate responses to the questions you submit (Section 2.D);
3. our advertising partner, Google AdMob, which processes limited device data to serve ads (Section 2.F);
4. Google Play, which processes subscription purchases on our behalf;
5. professional advisers such as solicitors, accountants, tax advisors, and auditors; and/or
6. service providers that assist us in providing the Service.

Law Enforcement or Government Bodies

We may disclose your personal data as permitted by law in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms of Service or other agreements, or as required by law.

Business Transfers

If TEMPO is involved in a merger, acquisition, reorganisation, sale of assets, or insolvency, your personal data may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your personal data.

No Sale of Personal Data

We do not sell your personal data. We do not share your personal data with data brokers. Our advertising partner processes limited device data solely to serve ads within the app, as described in Section 2.F.

4. International Data Transfers

TEMPO is made available globally. Your personal data may be transferred to, stored in, or processed in countries outside your country of residence, including by our service providers.

Where the destination country is not recognised as providing an adequate level of protection under the laws of your country of residence, we rely on lawful safeguards to protect your personal data. In the case of transfers from the European Economic Area, this includes the European Commission's Standard Contractual Clauses adopted under Article 46 of the GDPR, together with any supplementary safeguards that may be required.

You may contact us at tempo-support@zodiazz.com for more information about the safeguards we apply to international data transfers.

5. Your Rights

You are entitled to obtain information from us on how we handle your personal data, to request a copy of the personal data we hold about you, and to ask that it be corrected or deleted. You may also, in certain circumstances, restrict or object to our processing of your personal data.

If you gave us your consent to use your personal data for a particular purpose, you can withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

You can object to our use of your personal data where we rely on legitimate interests, as described in Section 2.C.

We do not carry out any decision-making based solely on automated processing, including profiling, that produces legal or similarly significant effects.

You also have the right to lodge a complaint with the data-protection supervisory authority in your country of residence.

To exercise any of these rights, contact us at tempo-support@zodiazz.com. We may need to verify your identity before acting on your request.

Nothing in this Privacy Policy limits any mandatory right you have under the privacy or data-protection law of your country of residence.

6. Children's Privacy

The Service is not intended for use by children under the age of 13, and we do not knowingly collect personal data from children under 13. If you believe we have done so, please contact us at tempo-support@zodiazz.com.

7. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make a material change, we will provide reasonable notice through the app or by updating the "Last Updated" date at the top of this Privacy Policy.

Your continued use of the Service after changes take effect constitutes your acceptance of the updated Privacy Policy.

By using TEMPO, you acknowledge that you have read and understood this Privacy Policy.