Tillybom Privacy Policy

1. Introduction

This Privacy Policy sets out how we, Tillybom Messenger Inc. (“Tillybom”), use and protect your personal data that you provide to us, or that is otherwise obtained or generated by us, in connection with your use of our cloud-based messaging services (the “Services”). For the purposes of this Privacy Policy, ‘we’, ‘us’ and ‘our’ refers to Tillybom, and ‘you’ refers to you, the user of the Services.

1.1 Privacy Principles

Tillybom has two fundamental principles when it comes to collecting and processing private data:

  • We don't use your data to show you ads.
  • We only store the data that Tillybom needs to function as a secure and feature-rich messaging service.

1.2. Terms of Service

This Privacy Policy forms part of our Terms of Service, which describes the terms under which you use our Services and which are available at https://tillybom.com/tos. This Privacy Policy should therefore be read in conjunction with those terms.

1.3. Table of Contents

This Privacy Policy explains the following:

1.4. EEA Representative

If you live in a country in the European Economic Area (EEA), the Services are provided by Tillybom, which for the purposes of applicable data protection legislation is the data controller responsible for your personal data when you use our Services.

2. Legal Ground for Processing Your Personal Data

We process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (1) providing effective and innovative Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.

3. What Personal Data We Use

3.1. Basic Account Data

Tillybom is a communication service. You provide your mobile number and basic account data (which may include profile name, profile picture and about information) to create a Tillybom account.

To make it easier for your contacts and other people to reach you and recognize who you are, the screen name you choose, your profile pictures, and your username (should you choose to set one) on Tillybom are always public. We don't want to know your real name.

We do not require your screen name to be your real name. Note that users who have you in their contacts will see you by the name they saved and not by your screen name. This way your mother can have the public name 'Johnny Depp' while appearing as 'Mom' to you and as 'Boss' to her underlings at work (or the other way around, depending on how these relationships are structured).

3.2. Your Messages

3.2.1. Cloud Chats

Tillybom is a cloud service. We store messages, photos, videos and documents from your cloud chats on our servers so that you can access your data from any of your devices anytime without having to rely on third-party backups. All data is stored heavily encrypted and the encryption keys in each case are stored in several other data centers in different jurisdictions. This way local engineers or physical intruders cannot get access to user data.

3.2.2. Public Chats

In addition to private messages, Tillybom also supports public channels and public groups. All public chats are cloud chats (see section 3.2.1 above). Like everything on Tillybom, the data you post in public communities is encrypted, both in storage and in transit — but everything you post in public will be accessible to everyone.

3.3. Phone Number and Contacts

Tillybom uses phone numbers as unique identifiers so that it is easy for you to switch from SMS and other messaging apps and retain your social graph. We ask your permission before syncing your contacts.

We store your up-to-date contacts in order to notify you as soon as one of your contacts signs up for Tillybom and to properly display names in notifications. We only need the number and name (first and last) for this to work and store no other data about your contacts.

Our automatic algorithms can also use anonymized sets of phone numbers to calculate the average number of potential contacts an unregistered phone number may have on Tillybom. When you open the 'Invite friends' interface, we display the resulting statistics next to your contacts to give you an idea of who could benefit most from joining Tillybom.

You can always stop syncing contacts or delete them from our servers in Settings > Privacy > Data Settings.

If you are using Android, Tillybom will ask you for permission to access your phone call logs (READ_CALL_LOG). If you grant this permission, Tillybom will be able verify your account by transmitting a phone call instead of asking you to enter a code. Tillybom uses this permission only to confirm receipt of the confirmation call by verifying the number in the call log.

3.4. Location Data

If you share a location in a chat, this location data is treated like other messages in cloud respectively.

Tillybom will use your data to display your location to other users, even when the app is closed.

3.5. Cookies

The only cookies we use are those to operate and provide our Services on the web. We do not use cookies for profiling or advertising. The cookies we use are small text files that allow us to provide and customize our Services, and in doing so provide you with an enhanced user experience. Your browser should allow you to control these cookies, including whether or not to accept them and how to remove them. You may choose to block cookies with your web browser, however, if you do disable these cookies you will not be able to log in to Tillybom Web.

4. Keeping Your Personal Data Safe

4.1. Storing Data

If you signed up for Tillybom from the UK or the EEA, your data is stored in data centers in the Netherlands. These are third-party provided data centers in which Tillybom rents a designated space. However, the servers and networks that sit inside these data centers and on which your personal data is stored are owned by Tillybom. As such, we do not share your personal data with such data centers. All data is stored heavily encrypted so that local Tillybom engineers or physical intruders cannot get access.

4.2. Retention

Unless stated otherwise in this Privacy Policy, the personal data that you provide us will only be stored for as long as it is necessary for us to fulfill our obligations in respect of the provision of the Services.

5. Processing Your Personal Data

5.1. Our Services

Tillybom is a cloud service. We will process your data to deliver your cloud chat history, including messages, media and files, to any devices of your choosing without a need for you to use third-party backups or cloud storage.

5.2. Safety and Security

Tillybom supports massive communities which we have to police against abuse and Terms of Service violations. Tillybom also have much users which makes it a lucrative target for spammers. To improve the security of your account, as well as to prevent spam, abuse, and other violations of our Terms of Service, we may collect metadata such as your IP address, devices and Tillybom apps you've used, history of username changes, etc. If collected, this metadata can be kept for 12 months maximum.

5.3. Spam and Abuse

To prevent phishing, spam and other kinds of abuse and violations of Tillybom’s Terms of Service, our moderators may check messages that were reported to them by their recipients. If a spam report on a message you sent is confirmed by our moderators, your account may be limited from contacting strangers – temporarily or permanently. In case of more serious violations, your account may be banned. We may also use automated algorithms to analyze messages in cloud chats to stop spam and phishing.

5.4. Cross-Device Functionality

We may also store some aggregated metadata to create Tillybom features (see section 5.5 below) that work across all your devices.

5.5. Advanced features

We may use some aggregated data about how you use Tillybom to build useful features. For example, when you open the Search menu, Tillybom displays the people you are more likely to message in a box at the top of the screen. To do this, we calculate a rating that shows which people you message frequently. A similar rating is calculated for inline bots so that the app can suggest the bots you are most likely to use in the attachment menu (or when you start a new message with “@”).

5.6. No Ads

Unlike other services, we don't use your data for ad targeting or other commercial purposes. Tillybom only stores the information it needs to function as a secure and feature-rich cloud service.

6. Who Your Personal Data May Be Shared With

6.1. Other Tillybom Users

Other users of our Services with whom you choose to communicate with and share certain information, who may be located outside the EEA. Note that by entering into the Terms of Service and choosing to communicate with such other users of Tillybom, you are instructing us to transfer your personal data, on your behalf, to those users in accordance with this Privacy Policy. We employ all appropriate technical and organizational measures (including encryption of your personal data) to ensure a level of security for your personal data that is appropriate to the risk.

6.2. Law Enforcement Authorities

If Tillybom receives a court order that confirms you're a terror suspect, we may disclose your IP address and phone number to the relevant authorities. So far, this has never happened.

7. Your Rights Regarding the Personal Data You Provide to Us

7.1. Your Rights

Under applicable data protection legislation, in certain circumstances, you have rights concerning your personal data. You have a right to: (1) request a copy of all your personal data that we store and to transmit that copy to another data controller; (2) delete (see section 8 below) or amend your personal data; (3) restrict, or object to, the processing of your personal data; (4) correct any inaccurate or incomplete personal data we hold on you; and (5) lodge a complaint with national data protection authorities regarding our processing of your personal data.

7.2. Exercising Your Rights

If you wish to exercise any of these rights, kindly contact us using the details in section 10 below.

7.3. Data Settings

You can control how your data is used (e.g., delete synced contacts) in Settings > Privacy > Data Settings (using one of our mobile apps).

Sadly, if you're generally not OK with Tillybom's modest requirements, it won't be possible for us to provide you with our Services. You can delete your Tillybom account by writing to [email protected].

8. Deleting data

8.1. Accounts

If you would like to delete your account, you can do this by writing to [email protected]. Deleting your account removes all messages, media, contacts and every other piece of data you store in the Tillybom cloud. This action must be confirmed via your Tillybom account and cannot be undone.

8.2. Messages

  • In cloud chats, you can choose to delete a message for all participants within at least 48 hours after sending. Otherwise, deleting a message will delete it from your message history. This means that a copy will stay on the server as part of your partner's message history. As soon as your partner deletes it too, it's gone forever.
  • Any party can choose to delete any messages in one-on-one chats, both sent and received, for both sides. There is no time limit. Any party can also opt to clear the entire chat history for both parties, in which case the apps will be instructed to remove all messages in that chat, however many of them are still retained by either of the participants.

8.3. Account Self-Destruction

By default, if you stop using Tillybom and do not come online for at least 6 months, your account will be deleted along with all messages, media, contacts and every other piece of data you store in the Tillybom cloud. You can go to Settings to change the exact period after which your inactive account will self-destruct.

9. Changes to this Privacy Policy

We will review and may update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on this page https://tillybom.com/privacy. Please check our website frequently to see any updates or changes to our Privacy Policy, a summary of which we will set out below.

10. Questions and concerns

If you have any questions about privacy and our data policies, please contact with [email protected].