Privacy Policy

This privacy policy applies to the Eos app (hereby referred to as "Application") for mobile devices that was created by Tortuga Labs, LLC (hereby referred to as "Service Provider"). This Application is a consumer-facing service that allows users to take action against their daily affirmations to turn intention into results. It is a commercial product, meaning it may offer in-app purchases and subscriptions. Users are permitted to use the app for personal purposes but may not redistribute.

Information We Collect

Birthday: Eos collects your birthday, which is used for age verification to ensure compliance with age restrictions and to provide personalized horoscope content when applicable. This information is stored securely and is not shared with third parties.

Phone Number: The Application may collect your phone number for account verification, authentication purposes, and to enable app functionality. Your phone number is stored securely and is not used for marketing purposes or shared with third parties without your explicit consent.

Location Data: The Application may request access to your device's location to provide you with local weather information and to enable the "Karma" feature, which allows you to send anonymous positive messages to nearby users if you choose to participate. Location data is used only for these purposes and is not sold to third parties or used for tracking your movements.

Contacts Access: To help you easily invite friends to use the Application, Eos may request access to your device's Contacts list. This information is used only to suggest contacts for invitations and to facilitate the sharing process. We do not store your entire contacts list on our servers, and we do not share this information with third parties.

How We Use Your Information

The Application collects information when you download and use it. This information may include:

• Your device's Internet Protocol address (e.g. IP address)
• The pages of the Application that you visit, the time and date of your visit, the time spent on those pages
• The time spent on the Application
• The operating system you use on your mobile device

Birthday Usage: Your birthday is used exclusively for age verification purposes and to generate personalized horoscope content within the Application. This information is never published publicly or sold to third parties.

Phone Number Usage: Your phone number is used for account authentication and verification purposes only. We do not use your phone number for unsolicited marketing communications.

Location Usage: If you grant access to your location, this information is used to display relevant local weather information and to enable the optional "Karma" feature. The Karma feature allows you to send anonymous positive messages to other users in your general vicinity who have also opted into this feature. Your precise location is not stored long-term or shared with other users—only general proximity is used for the Karma feature. You can revoke location access at any time through your device's settings.

Contacts Usage: If you grant access to your Contacts list, this information is used only to help you invite friends to the Application. We do not use your contacts data for marketing purposes or share it with third parties.

The Service Provider may use the information you provide to contact you from time to time to provide you with important information, required notices, and marketing promotions.

For a better experience while using the Application, the Service Provider may require you to provide certain personally identifiable information. The information that the Service Provider requests will be retained by them and used as described in this privacy policy.

Data Disclosure

The Service Provider may disclose User Provided and Automatically Collected Information:

• As required by law, such as to comply with a subpoena or similar legal process.
• When they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• With their trusted service providers who work on their behalf, do not have an independent use of the information disclosed to them, and have agreed to adhere to the rules set forth in this privacy statement.

Opt-Out Rights

You can stop all collection of information by the Application easily by uninstalling it. You may use the standard uninstall processes available on your mobile device or via the mobile application marketplace or network.

If you have granted access to your location or Contacts list, you may revoke these permissions at any time through your device's settings.

Data Retention Policy

The Service Provider will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. If you'd like them to delete User Provided Data that you have provided via the Application, please contact them at eosapp@bytortuga.com, and they will respond in a reasonable time.

Children

The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13.

The Application does not address anyone under the age of 13, and the Service Provider does not knowingly collect personally identifiable information from children under 13 years of age. If the Service Provider discovers that a child under 13 has provided personal information, they will immediately delete it from their servers.

If you are a parent or guardian and are aware that your child has provided personal information, please contact the Service Provider at eosapp@bytortuga.com so they can take the necessary actions.

Security

The Service Provider is concerned about safeguarding the confidentiality of your information. They provide physical, electronic, and procedural safeguards to protect the information they process and maintain. Your personal information, including your birthday, phone number, and location data, is stored securely and is protected using industry-standard security measures. Your data remains private and is only used for the purposes described in this policy.

Changes

This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes by updating this page with the new Privacy Policy.

You are advised to review this Privacy Policy regularly for any updates, as continued use of the Application is deemed approval of all changes.

This Privacy Policy is effective as of 2025-11-14.

Your Consent

By using the Application, you consent to the processing of your information as set forth in this Privacy Policy, now and as amended in the future.

Contact Us

If you have any questions regarding privacy while using the Application or have concerns about data practices, please contact the Service Provider via email at eosapp@bytortuga.com.

For more information about Tortuga Labs, LLC, please visit www.bytortuga.com.