Niello Privacy Policy ✦

Last updated: July 8, 2026

This Privacy Policy explains how the Niello application (provided by TacticSpace Tech, "we", "our", "us") collects, uses, shares, and protects your personal information, and the rights available to you under the applicable law in your jurisdiction.

We follow these basic principles: we collect only the minimum information needed to provide the Service; you can use the Service — including purchases and AI features — without creating an account or signing in; the journals, stickers, and photos you create are stored on your own device (and, if you subscribe to Niello Pro and turn on iCloud sync, in your own iCloud private database); we do not sell your personal information; we do not share your information with any third party for targeted advertising; we do not use your content to train artificial intelligence models.

1. Information We Collect

Information you provide:

  • If you choose to sign in with Apple — sign-in is optional and is never required to make a purchase or to use AI features — the opaque user identifier returned by Sign in with Apple, used to link your subscription and quota across your devices;
  • The email address and name you choose to share when signing in (controlled by Apple at the time of sign-in);
  • Journals, stickers, and photos you create in the Service. This content is stored on your device; if you are a Niello Pro subscriber with iCloud sync turned on, it is also stored in your own iCloud private database and synced across your devices. In either case, we do not retain a copy on our servers;
  • Messages you send to Mochi — such information exists only briefly in the request path needed to generate a response, and is not persisted.

Information collected automatically:

  • An anonymous device identifier: a random identifier generated on your device the first time you launch the app and stored in the device Keychain. It contains no personal details and is not used to track you across other apps or websites. We use it to meter AI usage and to associate your subscription with your device, so that no account is needed;
  • Your monthly AI usage counts, associated with that identifier (for quota management);
  • Anonymized application crash and basic performance data;
  • Subscription transaction receipts provided by the Apple App Store.

On sensitive personal information

Under the laws of certain jurisdictions (such as China's Personal Information Protection Law), photos may be classified as sensitive personal information. We only process photos that you actively add to the Service, and store them in the manner described above (on your device, and in your private iCloud if you have turned on Pro iCloud sync).

Information we do not collect

We do not collect your precise location, contacts, web browsing history, or any identifier used for cross-app or cross-site behavioral advertising.

Anonymous product analytics

To understand which features are useful and where the Service breaks, we use PostHog (EU Cloud, hosted in Frankfurt) to collect anonymized product-improvement events:

  • On the website: page views, CTA clicks, locale switches, scroll-section reach, 404 hits, and aggregated device/locale info.
  • In the app: app launches, screen views, key actions (e.g. journal entry created, AI feature invoked, subscription paywall viewed), and aggregated performance / error data.

We have configured PostHog so that no person profile is created for anonymous users. We do not use this data to build behavioral profiles, target advertising, or share it with any third party for advertising purposes. You can opt out via your browser's Do Not Track setting on the website, and via Settings → Help improve Niello in the app.

2. How We Use Information

We use the information collected only for:

  • Providing the core functionality of the Service;
  • Preventing misuse, fraud, and security incidents;
  • Communicating service-related matters with you (such as material policy changes or subscription issues);
  • Conducting aggregated, de-identified analysis to improve the product.

3. Legal Bases for Processing

Depending on the applicable law in your jurisdiction, the legal bases on which we process your personal information may include:

  • Contractual necessity: to perform our contractual obligations in providing the Service;
  • Legitimate interests: to operate, improve, and protect the Service, provided such interests do not override your fundamental rights and freedoms;
  • Your consent: for specific types of processing (such as optional personalization);
  • Legal obligation: to comply with laws and regulations applicable to us.

4. Who We Share Information With

To operate the Service, we work with carefully evaluated third-party service providers. These providers, grouped by the function they provide, include:

  • Platform and sign-in services: Apple (optional Sign in with Apple, iCloud, App Store subscriptions);
  • Infrastructure and database services: Google LLC (Google Cloud, including the Firestore database, United States) hosts our API service and stores your subscription state and AI usage counts;
  • Artificial intelligence services: Google LLC (Gemini API, United States) processes the text and images you send to Mochi in order to generate AI replies, governed by Google's API terms and Data Processing Addendum; in some regions we may use alternative model providers (see regional variations below);
  • Product analytics: PostHog (EU Cloud, Frankfurt) — anonymized usage events, used only to improve the Service;
  • Crash and performance reporting: processing only anonymized, aggregated data.

We only share information with these providers as strictly necessary to operate the Service. None of these third parties can access the private content stored on your device or in your iCloud. Such providers handle your information under their own privacy policies and applicable laws.

On regional variations: To comply with the laws and regulations of different jurisdictions (including but not limited to data protection, content-generation regulation, cross-border transfer, and data localization rules), the AI service providers and other infrastructure providers we work with may differ depending on where you are. We evaluate local compliance requirements and choose providers that meet them; certain AI features or service capabilities may therefore vary or be limited in some regions.

We do not sell your personal information, and we do not share your personal information with any third party for the purpose of targeted advertising or cross-context behavioral advertising (under California's CCPA/CPRA and similar laws).

5. Automated Decision-Making

Mochi's content generation involves automated processing. Such automated processing does not produce decisions with legal or similarly significant effects on you. You may stop using AI features at any time without affecting other parts of the Service.

6. Security

  • All client ↔ us ↔ third-party traffic is encrypted with TLS;
  • Identity credentials are stored in the iOS Keychain (system-level hardware-backed encryption);
  • Your core content is stored on your own device; if you turn on Pro iCloud sync, it is also stored in your own iCloud private database, accessible only by your Apple ID.

Although we use industry-standard security measures, no system is absolutely secure. To the extent permitted by applicable law, we are not responsible beyond the statutory limit for security incidents outside our reasonable control.

7. Data Retention

Type Retention
Anonymous device identifier Until you delete your data (in-app deletion or a request via the email below)
AI usage counts Rolling 12 months, auto-deleted after expiry
Subscription state Subscription period plus a reasonable audit window
Email, name Cleared upon sign-out or deletion request
Journal content Stored on your device until you delete it; iCloud copies (Pro sync) are governed by Apple and your iCloud settings

8. Your Rights

Subject to the applicable law in your jurisdiction (including but not limited to the GDPR, CCPA/CPRA, and PIPL), you may have all or some of the following rights:

  • Access and obtain a copy: know how we process your information and receive a copy;
  • Correction: request correction of inaccurate or incomplete information;
  • Deletion: request the deletion of your personal information;
  • Restrict processing: request that we restrict certain processing of your information;
  • Data portability: receive your information in a machine-readable format;
  • Withdraw consent: withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
  • Object: object to our processing of your information in specified circumstances;
  • Non-discrimination: exercising the above rights will not result in differential treatment in the Service.

To exercise these rights, contact us via the email below; if you have signed in with Apple, you can also delete your account and the associated server-side data directly in the app's Settings. We will respond within the timeframe required by applicable law. If you believe our processing infringes applicable law, you may also lodge a complaint with the competent supervisory authority in your jurisdiction.

9. Children

The Service is not directed to children under 13. In some jurisdictions (such as in EU member states and China) the corresponding minimum age may be 14 or 16; local law prevails. We do not knowingly collect personal information from children below the applicable minimum age. If you are a parent or legal guardian and believe that a child in your care provided us with personal information without your consent, contact us so we can address it.

10. Cross-Border Transfers

The Service is offered globally. In providing it, your information may be processed on servers outside your country or region.

Where applicable law requires it, we use appropriate contractual and technical safeguards (including but not limited to the EU Standard Contractual Clauses or other recognized transfer mechanisms) to keep such transfers lawful. In certain jurisdictions, if local law requires localized processing of, or restricts the export of, certain categories of personal information, we will accordingly use local service providers, or not offer the affected feature in that region.

11. Policy Changes

We may update this Policy from time to time. Material changes will be communicated through in-app notice and by updating the "Last updated" date above. Your continued use after changes take effect constitutes acceptance.

12. Contact

For questions about this Policy, our data practices, or to exercise your rights:

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