Privacy Policy
Effective date: 16 June 2026 · Version 1.0
This Privacy Policy ("Policy") describes how Tuga Capital LLC ("Tuga Capital", "PaperNote", "we", "us", or "our") collects, uses, discloses, and safeguards information in connection with the PaperNote applications for iOS, iPadOS, and macOS (the "App"), the website at papernote.ink (the "Site"), and related services (collectively, the "Services"). PaperNote is engineered for data minimization: the Services are designed so that we hold as little information about you as is technically possible.
Summary (non-binding). This summary is provided for convenience and does not replace the full text below. We do not receive or store your notes; they are end-to-end encrypted on your device with keys only you control. Use of the free tier requires no account. Paid plans are identified by an anonymous license key, not by your name or email. We do not sell or share your personal information, serve advertising, or profile you. Cloud-based artificial intelligence ("AI") features are strictly opt-in and operate on a per-action basis.
1. Definitions
In this Policy, capitalized terms have the meanings given below:
- "Personal Data" means any information relating to an identified or identifiable natural person.
- "License Key" means the anonymous alphanumeric credential issued upon purchase of a paid subscription that activates paid features and synchronization.
- "Vault" means the encrypted store of your notes and associated content (text, handwriting, images, PDFs, audio, transcripts, and AI-generated results).
- "Account Identifier" means the irreversible, salted cryptographic hash derived from a License Key that serves as the sole identifier of a paid account on our systems.
- "Processor" and "Sub-processor" mean a third party that processes data on our behalf.
2. Controller and contact information
2.1. The data controller responsible for processing under this Policy is Tuga Capital LLC, a limited liability company organized under the laws of the State of New Mexico, United States.
2.2. Questions, requests, or complaints regarding this Policy or our data practices may be directed to privacy@papernote.ink.
3. Information we collect
3.1. Account information. We do not collect your name, email address, telephone number, or other direct identifiers. When you purchase a paid subscription, we derive and store only the Account Identifier. The License Key is not stored on our servers in readable form; it resides solely within your device Keychain and with our payment Processor.
3.2. Vault content. We receive Vault content exclusively as ciphertext (see Section 5). We do not have access to the plaintext of your notes or any decryption key.
3.3. Payment information. Payment card details and any email address you provide at checkout are collected and processed by our payment Processor (Section 7) and are not transmitted to or stored on our servers.
3.4. Technical data. Like most internet services, our infrastructure provider processes limited technical information (such as IP address and request metadata) transiently for security, fraud-prevention, and service-delivery purposes. We do not use this data to identify you or build profiles.
3.5. Information we do not collect. We do not collect precise geolocation, contacts, advertising identifiers, or biometric identifiers, and we do not employ third-party advertising or cross-site tracking technologies.
4. Purposes and legal bases for processing
4.1. We process the limited information described above to: (a) authenticate paid accounts and deliver entitlements; (b) operate, maintain, and secure the Services; (c) process transactions through our payment Processor; (d) comply with legal obligations; and (e) detect, prevent, and address fraud, abuse, or technical issues.
4.2. Where the EU General Data Protection Regulation ("GDPR") or the UK GDPR applies, our legal bases are the performance of a contract (Art. 6(1)(b)), our legitimate interests in operating and securing the Services (Art. 6(1)(f)), and compliance with legal obligations (Art. 6(1)(c)).
5. End-to-end encryption of the Vault
5.1. All Vault content is encrypted on your device prior to transmission. Each object is sealed with a unique object key, which is wrapped by a master key that is generated on, and never leaves, your device except through Apple's iCloud Keychain to your own devices. Our servers store only ciphertext.
5.2. We do not possess, escrow, or have any means to obtain your master key, and accordingly we are technically incapable of decrypting, reading, or producing the plaintext of your Vault content.
Material limitation on data recovery. Because decryption keys are held solely by you, loss of access to all of your devices and your iCloud Keychain will render your Vault permanently unrecoverable by any party, including us. You are solely responsible for maintaining access to your devices and Keychain backups.
6. Artificial intelligence features
6.1. On-device processing. By default, AI transformations (including handwriting recognition, transcription, structuring, and document question-answering) are performed locally on your device. No content is transmitted to us for these operations.
6.2. Optional cloud processing. Certain features may, at your explicit and per-action election, transmit only the specific content you select to our AI gateway operated on Cloudflare Workers AI. Your full Vault and unrelated notes are never transmitted. Content submitted for cloud processing is used solely to generate and return the requested output and is not used to train any model.
7. Payment processing
7.1. Subscriptions and credit purchases are processed by Stripe, Inc. ("Stripe"). Any email address, billing details, and payment instrument you provide are collected and retained by Stripe as a data controller and/or processor for billing, receipts, tax, and anti-fraud purposes, and are governed by Stripe's privacy policy.
7.2. We receive from Stripe only a billing reference sufficient to associate a successful payment with an Account Identifier and to determine entitlements. We do not receive your payment card number.
8. Disclosure of information; Sub-processors
8.1. We do not sell, rent, or share your Personal Data for monetary or other valuable consideration, and we do not disclose it for cross-context behavioral advertising.
8.2. We engage the following categories of Sub-processors to provide the Services: (a) cloud infrastructure, storage, and AI gateway (Cloudflare, Inc.); and (b) payment processing (Stripe, Inc.). Sub-processors are bound by contractual obligations to protect data and to process it only as instructed.
8.3. We may disclose information where required to do so by law, regulation, legal process, or governmental request, or where necessary to protect the rights, property, or safety of PaperNote, our users, or the public. Owing to end-to-end encryption, we are unable to produce the plaintext of Vault content in response to any such request.
9. International transfers and data location
9.1. The Services are operated from, and account records and encrypted Vault objects are stored on infrastructure located in, the United States. If you access the Services from outside the United States, you understand that your information may be processed in the United States.
9.2. Where required, transfers of Personal Data from the European Economic Area, the United Kingdom, or Switzerland are made pursuant to appropriate safeguards, including the European Commission's Standard Contractual Clauses. Because Vault content is end-to-end encrypted, its storage location does not enable access to its contents.
10. Data retention and deletion
10.1. Encrypted Vault objects are retained until you delete them or delete your account, at which point the corresponding ciphertext and account record are removed from our storage within a commercially reasonable period, subject to routine backup cycles.
10.2. Records held by Stripe are retained by Stripe in accordance with its policies and applicable legal, accounting, and tax obligations.
11. Security
We implement administrative, technical, and organizational measures designed to protect information, including end-to-end encryption of Vault content and encryption in transit. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
12. Your rights
12.1. EEA/UK data subjects. Subject to applicable law, you may have the rights of access, rectification, erasure, restriction, portability, and objection, and the right to lodge a complaint with a supervisory authority. Because we do not hold information that identifies you, we may be unable to associate a request with an individual without additional information that we do not possess; in such cases we may be unable to action the request (GDPR Art. 11).
12.2. U.S. state privacy rights. Residents of California (CCPA/CPRA) and other states with comprehensive privacy laws may have rights to know, access, delete, correct, and opt out of sale or sharing of personal information. We do not sell or share personal information, and we do not process sensitive personal information for purposes requiring an opt-out. You may exercise applicable rights by contacting us; we will not discriminate against you for doing so.
12.3. To exercise any right, contact privacy@papernote.ink. We will respond within the timeframes required by applicable law.
13. Children's privacy
The Services are not directed to children under the age of 13 (or the minimum age of digital consent in your jurisdiction), and we do not knowingly collect Personal Data from such children. If you believe a child has provided us with Personal Data, contact us and we will take appropriate steps.
14. Cookies and the website
The Site does not use advertising or cross-site tracking cookies. The Site is served through Cloudflare and loads fonts from Google Fonts, which may process technical request data as described in their respective policies. Strictly necessary technical processing may occur for security and delivery of the Site.
15. Changes to this Policy
We may amend this Policy from time to time. The "Effective date" above indicates when this Policy was last revised. Material changes will be made available through the Site and, where appropriate, within the App. Your continued use of the Services after an amendment takes effect constitutes acceptance of the revised Policy.
16. Contact
Tuga Capital LLC — New Mexico, United States · privacy@papernote.ink