Camino Accountability LLC

Privacy Policy

Last updated July 29, 2026

This Privacy Policy (“Policy”) describes how Camino Accountability LLC (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with the Camino website, mobile applications, and related services (collectively, the “Services”). This Policy is incorporated into, and should be read together with, our Terms of Service and EULA provided in connection with an app store.

By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you may not use the Services.

1. Scope of This Policy

This Policy applies to information collected through the Services, including our website, mobile applications, and related communications.
This Policy does not apply to information collected by third parties, including any third-party licensed content providers, payment processors, or app store platforms, which are governed by their own privacy policies.

2. Information We Collect

We may collect the following types of information set forth in this Section 2.

2.1 Information You Provide to Us

Account and registration information, such as your name, email address, and password.
Onboarding and assessment responses, including self-reported information about your goals, habits, and program preferences, used to personalize your program and to power the Matching Algorithm described in our Terms of Service.
Profile and display information you choose to provide, such as a display name or avatar.
Voice demo recordings you affirmatively choose to provide to improve transcription accuracy, as described in Section 2.3 below.
Payment information, which is collected and processed by our third-party payment processor or the applicable app store; we do not store full payment card numbers or other information protected by the Payment Card Industry Data Security Standard (PCI DSS) on our own servers.
Communications you send us directly, such as customer support requests or feedback.

2.2 Information Collected Automatically

Generalized app interaction and engagement data, such as which program days you complete, feature usage, session length, and general navigation patterns within the Service. This interaction data is collected and analyzed by us in anonymized and/or aggregated form, as described in Section 4.
Device and technical data, such as device type, operating system, unique device or app identifiers, app version, and crash or diagnostic logs, used to operate, secure, and improve the Service.
Log data such as access times and general error/performance information.

2.3 On-Device AI Data

As described in our Terms of Service, the Service may include on-device artificial intelligence features that generate transcripts of voice recordings or journal entries you provide, and that may use a voice demo recording you provide to improve transcription accuracy and correction for your account.
Any personalized recognition or interaction model built from this data is created and stored locally on your device. We do not, by default, receive or store the underlying voice recordings, raw transcripts, or on-device model on our servers, except where you affirmatively submit such content to us (for example, as part of a support request or a report of a Terms of Service violation), or as reflected in anonymized, de-identified, or aggregated form as described in Section 4.

2.4 Voice Calls Are Ephemeral

If the Service offers a live voice call feature (for example, between matched users), those calls are ephemeral: we do not record or transcribe live voice calls made through the Service, and no audio or transcript of a live call is retained by us or stored on our servers.
This is distinct from the voice demo recordings described in Section 2.3, which you separately and affirmatively choose to provide for transcription-improvement purposes.

2.5 Location Data

We do not currently collect precise geolocation data from your device. We may collect general, approximate location information (such as country or region inferred from an IP address) for purposes such as security, localization, and legal compliance.
We may add features that collect more precise device location data in the future. If we do, we will update this Policy and, where required by applicable law, provide additional notice and/or obtain your consent before beginning such collection.

3. How We Use Information

We may use the information we collect from and about you in the following ways:

To provide, operate, personalize, and maintain the Service, including delivering day-by-day program content and generating Partner Matches and Cohort assignments through the Matching Algorithm described in our Terms of Service;
To operate on-device AI features, including transcription and transcript-accuracy improvement, as described in Section 2.3;
To support safety, moderation, and enforcement of our Terms of Service, including on-device detection of potential policy violations in messaging, as described in our Terms of Service;
To process payments and manage subscriptions;
To communicate with you, including sending service-related notices, updates, and, where permitted, marketing communications (which you may opt out of);
To analyze, maintain, and improve the Service, including through anonymized, de-identified, and aggregated analysis as described in Section 4;
To share with our partners, where we deem appropriate business value (but we will not sell your raw data), as described in Section 5;
To detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms of Service; and
To comply with applicable law, legal process, and enforceable governmental requests.

4. Anonymized, De-Identified, and Aggregated Data; Metadata

We may convert information we collect into anonymized, de-identified, and/or aggregated form (“Anonymized Data”) that does not identify you, and metadata that describes usage patterns without exposing underlying content.
We use Anonymized Data and metadata to operate, secure, analyze, and improve the Service, to understand generalized app interaction patterns, to support research and product development, and for any other business purpose, without further restriction under this Policy, because such data no longer constitutes your personal information.
We maintain technical and administrative safeguards designed to prevent Anonymized Data from being re-identified, and we do not attempt to re-identify Anonymized Data except as necessary to verify the effectiveness of such safeguards.

5. How We Share Information

We do not sell your personal information, and we do not share your raw (non-anonymized) personal information with third parties for their own independent marketing or advertising purposes.

We may share information as follows:

Anonymized Data and Metadata: We may share Anonymized Data, de-identified data, aggregated data, and metadata with third parties, including analytics providers, research partners, and other business partners, for the purposes described in Section 4.
Service Providers: We share information with vendors and service providers who perform services on our behalf (for example, cloud hosting, payment processing, customer support, and analytics), under contractual obligations to protect that information and use it only to provide services to us.
Third-Party Content Licensors: Providers of licensed third-party program content generally do not receive your personal information; they provide content to us for delivery through the Service and do not, as a general matter, receive raw user data in connection with that licensing relationship.
Other Users (Limited): As described in our Terms of Service, matched users and Cohort members may see limited information you or the Company elect to share (such as a display name and program-relevant, non-identifying information); we do not disclose your full account information to other users beyond what is described in the Terms of Service.
Legal and Safety: We may disclose information where we believe in good faith that disclosure is necessary or advisable to comply with applicable law or legal process, to protect the rights, property, or safety of Company, our users, or others, or to enforce our Terms of Service.
Business Transfers: We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of some or all of our assets, subject to standard confidentiality arrangements.
With Your Consent: We may share information for any other purpose disclosed to you and with your consent.

6. Accountability Partner, Mentor, and Cohort Data Sharing

Partner Matches and Cohort assignments are generated by the Matching Algorithm, which runs on our servers and processes your onboarding and usage information solely to compute matches and assignments, consistent with our Terms of Service.
We limit the information visible to a Partner Match or Cohort member to what is reasonably necessary to support the peer feature, as described in our Terms of Service. Any additional information you choose to share directly with another user is shared at your own discretion and is not controlled by us.

7. Private Messaging and Group Boards

Private messages and group board communications are end-to-end encrypted between users. We do not read the plaintext content of your private communications in transit, except through on-device moderation as described in our Terms of Service, or where content is reported to us.
On-device moderation may generate limited flags or metadata regarding a potential Terms of Service violation, which may be shared with us for safety and enforcement purposes, without necessarily transmitting the full plaintext content of your messages, as described in our Terms of Service.

8. Cookies and Similar Technologies

We and our service providers may use cookies, SDKs, and similar technologies on our website and applications to operate the Service, remember preferences, and collect generalized app interaction and analytics data as described in Section 2.2.
Depending on your device and jurisdiction, you may be able to manage cookies and similar technologies through your browser or device settings.

9. Data Retention

We retain personal information for as long as reasonably necessary or advisable to provide the Company, protect the Services, comply with legal obligations, resolve disputes, and enforce our agreements, after which it is deleted, anonymized, or aggregated in accordance with our internal retention practices.
Because live voice calls are ephemeral and are not recorded or transcribed, no retention period applies to their content. Voice demo recordings and related transcripts, where you provide them, are processed on-device as described in Section 2.3.

10. Data Security

We use administrative, technical, and physical safeguards designed to protect information from unauthorized access, use, or disclosure, including end-to-end encryption for private messaging and group boards and on-device processing for certain AI features.
No method of transmission or storage is completely secure. We cannot guarantee the absolute security of your information.

11. Your Privacy Choices and Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or receive a copy of certain personal information we hold about you, and to opt out of certain processing.
Because we do not sell personal information and do not share raw personal information for cross-context behavioral advertising, no “Do Not Sell or Share My Personal Information” opt-out is generally required to give effect to those preferences; where applicable law nonetheless requires that we provide such a mechanism, we will do so.
You may update certain account information directly in the Services, and may request deletion of your account and associated personal information by contacting us using the information in Section 15, subject to legal retention requirements.
Depending on your jurisdiction, you may have the right to appeal a denial of a privacy request, and the right not to receive discriminatory treatment for exercising your privacy rights.

12. Sensitive Personal Information

Information related to your use of a recovery and technology-wellness program may be considered sensitive personal information under certain state and international privacy laws. We limit our use of such information to providing, securing, and improving the Service, personalizing your program, and other purposes described in this Policy, and we do not sell such information.
Where required by applicable law, we will provide additional notice or obtain consent before collecting or using sensitive personal information for purposes beyond those necessary to provide the Service.

13. Children's Privacy

The Service is intended for use by individuals who are at least 18 years old, consistent with our Terms of Service. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from someone under 18, we will take steps to delete it.

14. International Users and Data Transfers

We are based in the United States, and information we collect may be stored and processed in the United States or other countries where we or our service providers operate. You may not access the Services from outside the United States, and if you do, we will remove you from the Services and delete your information. If you do provide such information from outside the United States, you understand that your information may be transferred to, stored, and processed in a country with data protection laws that may differ from those of your home jurisdiction.

15. Contact Us

If you have questions about this Policy or wish to exercise a privacy right described above, please contact us at:

Camino Accountability LLC

785 N. Maple Rd., Apt. 2
Ann Arbor, MI 48103

hello@thecaminoapp.com

16. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will provide notice through the Services, by email, or by other reasonable means prior to the changes taking effect. Your continued use of the Services after the effective date of a revised Policy constitutes your acceptance of the changes.