Privacy Policy

Version: 1.0
Effective Date: July 26, 2026
Last Updated: July 26, 2026

1. Scope and Operator

This Website Privacy Policy explains how TodoGroup Apps, a DBA of AION Technologies LLC ("TodoGroup Apps," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information through https://www.todogroupapps.com and its English- and Spanish-language pages (the "Website"). AION Technologies LLC is the legal operating entity. 107 Holdings LLC owns AION Technologies LLC, but is not the Website operator. We may disclose information to 107 Holdings LLC where legally relevant, as described below.

This Policy applies to Website visitors, people who contact us, and people who register interest in early-access, tester, waitlist, promotional, or similar Website programs. It does not govern data processed through TodoClean, TodoMow, TodoBuild, or another application or paid service. Those products are product names under TodoGroup Apps, not separate legal entities, and separate application privacy notices and agreements may apply.

If a translated version of this Policy conflicts with the English version, the English version controls, except where applicable local law requires otherwise.

2. Definitions

For this Policy:

• Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual or household. It includes "personal data" under applicable data-protection law.
• Processing means any operation performed on personal information, such as collecting, storing, using, disclosing, or deleting it.
• Service provider means a vendor that processes information for us under an agreement and for a defined business purpose. Depending on the law, the same entity may be called a processor or contractor.
• Sale, sharing, and targeted advertising have the meanings assigned by applicable U.S. state privacy laws. "Sharing" under California law includes certain disclosures for cross-context behavioral advertising, even if no money changes hands.
• Sensitive personal information means information designated as sensitive under applicable law. The Website forms currently in use are not designed to request government identifiers, payment-card details, account passwords, health information, or precise geolocation.

3. Personal Information We Collect

3.1 Information you provide directly

We may collect:

1. Identity and contact information, including name, email address, telephone number, WhatsApp number, preferred language, and the content of your inquiry.
2. Business-interest information, including business type, product interest, early-access or tester interest, waitlist selection, and whether you are interested in TodoClean, TodoMow, TodoBuild, or a future product.
3. Communications, including messages sent by email, telephone, Website form, WhatsApp, or social media, together with attachments and related correspondence.
4. Feedback and submissions, including suggestions, survey responses, testimonials submitted for consideration, support questions, and information you choose to provide.
5. Marketing preferences, if you indicate interest in receiving future updates through a Website form. TodoGroup Apps does not currently operate a separate email newsletter or marketing list; any marketing preference we hold today comes from the contact, early-access, tester, or waitlist forms described in Section 3.2.

Please do not submit payment-card data, government identification numbers, passwords, health information, or other unnecessary sensitive information through Website forms.

3.2 Contact, early-access, tester, and waitlist forms

The Website includes early-access and waitlist forms that request name, phone or WhatsApp number, email address, preferred language, business type or product interest, page language, and submission time. Form data is submitted through a Website endpoint and delivered by email using Microsoft Graph to TodoGroup Apps' designated inbox (currently info@todogroupapps.com).

We use this information to respond, evaluate interest, administer the requested program, communicate about availability, prevent abuse, and maintain appropriate records. Applying does not guarantee acceptance, product access, availability, or any commercial relationship.

3.3 Email Signup

TodoGroup Apps does not currently offer a general email marketing newsletter separate from the contact, early-access, tester, and waitlist forms described in Section 3.2. If we introduce a newsletter or marketing list in the future, we will update this Policy before it launches, identify the platform used, and put appropriate consent and opt-out mechanics in place.

3.4 WhatsApp and social-media interactions

The Website links to WhatsApp and social-media services. If you follow a link or communicate through one of those services, the service receives information under its own terms and privacy notice. We may receive your profile name, account identifier, contact details, message content, and other information you choose to share. WhatsApp messages may be processed outside the United States. Do not send sensitive information through these channels.

3.5 Automatically collected information

When you use the Website, our hosting, security, network, and technical systems may process:

• Internet Protocol address and approximate location derived from it;
• device type, operating system, browser type and version, language, screen characteristics, and identifiers;
• requested URL, referring URL, date and time, response status, and diagnostic or security logs;
• navigation, interactions, and usage events, if a properly configured and permitted analytics tool is enabled;
• cookie and local-storage choices, including a consent version and preference timestamp; and
• information needed to detect malicious, automated, or fraudulent activity.

TodoGroup Apps hosts the Website using Cloudflare Pages and related Cloudflare services for hosting, network, and security functions. As of the Effective Date, the Website does not use third-party analytics tags or advertising pixels. Our cookie-consent script includes inactive placeholder hooks for potential future analytics or marketing tools. If we activate analytics, tag managers, or advertising technologies in the future, we will update this Policy and our consent tools before doing so.

3.6 Cookies and similar technologies

The Website uses browser local storage for a consent record named todogroupapps_cookie_consent and uses local storage for a lang preference on certain pages. Cookies or similar technologies may also be set by hosting, security, embedded content, or future tools. Details appear in our Cookie Policy.

4. Sources of Personal Information

We may receive personal information:

1. directly from you;
2. automatically from your browser, device, and interaction with the Website;
3. from service providers supporting hosting, security, communications, forms, or analytics;
4. from WhatsApp, social networks, app stores, payment providers, or other third parties when you interact with us through them;
5. from referrals, public business profiles, or business partners where lawful; and
6. from AION Technologies LLC systems and, where relevant, its parent 107 Holdings LLC, subject to appropriate purpose and access controls.

5. How and Why We Use Personal Information

We use personal information to:

• operate, secure, troubleshoot, and improve the Website;
• provide requested content and respond to inquiries;
• administer early-access, tester, waitlist, and promotional programs;
• communicate product availability, next steps, and service information;
• manage language and consent preferences;
• understand demand and Website performance;
• protect our rights, users, systems, and the public;
• detect fraud, abuse, spam, malware, and security incidents;
• comply with law, lawful process, and recordkeeping obligations;
• establish, exercise, or defend legal claims;
• evaluate or complete a financing, reorganization, sale, merger, or other business transaction; and
• send marketing where permitted and consistent with your choices.

We do not use Website-form submissions to make decisions producing legal or similarly significant effects solely by automated means.

6. Legal Bases for EEA and UK Processing

Where the GDPR or UK GDPR applies, our legal basis depends on the activity:

Where we rely on legitimate interests, we consider the purpose, necessity, and impact on individuals. You may object to such processing. Where we rely on consent, you may withdraw it without affecting processing completed before withdrawal.

7. How We Disclose Personal Information

We may disclose relevant information to:

1. Hosting, network, and security providers. We use Cloudflare Pages and related Cloudflare services for hosting, content delivery, and security functions.
2. Business communications providers. The form code uses Microsoft identity endpoints and Microsoft Graph to send form submissions through our configured Microsoft 365 email account.
3. Professional advisers. Lawyers, accountants, auditors, insurers, and consultants may receive information where necessary and subject to professional or contractual duties.
4. Communication and social platforms. WhatsApp and linked social networks process information when you choose to use them.
5. Payment and app-store providers. Some Website pages link to Stripe, the Apple App Store, or Google Play in connection with individual applications (such as TodoClean, TodoMow, or TodoBuild). Those providers process information under their own privacy notices. The Website itself does not operate a general checkout that collects payment-card details.
6. Affiliates. We may provide limited information to 107 Holdings LLC, the owner of AION Technologies LLC, or other controlled affiliates for governance, security, legal, accounting, or shared operational purposes, subject to applicable law. This does not make 107 Holdings LLC the Website operator.
7. Authorities and other persons for legal and safety reasons. We may disclose information to comply with law or valid process; protect rights, safety, and systems; investigate fraud or security events; or enforce agreements.
8. Transaction participants. Information may be reviewed or transferred in connection with diligence, financing, merger, acquisition, reorganization, bankruptcy, or sale of assets, subject to appropriate restrictions.
9. At your direction. We may disclose information with your request or permission.

We require our service providers to process personal information only for authorized purposes, under contractual confidentiality and data-protection obligations appropriate to the service.

8. Sale, Sharing, and Targeted Advertising

TodoGroup Apps does not sell personal information, does not share personal information for cross-context behavioral advertising, and does not process personal information for targeted advertising, as those terms are defined under applicable law. We do not currently use advertising pixels, ad-tech tags, or data brokers on the Website.

If this changes in the future, we will provide the notices and opt-out methods required by law, honor recognized opt-out preference signals (such as Global Privacy Control) where legally required, and update this Policy and our consent tools before the new activity begins.

We do not knowingly sell or share personal information of people under 16.

9. Retention

We retain personal information only for as long as reasonably necessary for the purpose collected, including to provide requested communications, administer programs, comply with law, resolve disputes, protect security, and enforce agreements. Criteria include the relationship and communication history, sensitivity, risk of harm, operational need, legal limitation periods, tax or accounting duties, and whether deletion or de-identification is feasible.

We may retain de-identified or aggregated information where it cannot reasonably be linked to you and we maintain it in de-identified form as required by law.

10. Security

We use administrative, technical, and organizational safeguards designed to protect personal information in light of its nature and risks, including access controls, encrypted connections (HTTPS/TLS), and the hosting and security services provided by Cloudflare. No Website, transmission, or storage system is completely secure, and we cannot guarantee absolute security. Visitors should avoid sending sensitive information through general forms, email, WhatsApp, or social media.

11. International Data Transfers

Our operator is based in the United States. If you access the Website from another country, your information may be transferred to and processed in the United States and other countries where we or our providers operate. Their laws may differ from those in your location.

Where the GDPR or UK GDPR applies to a specific transfer, we will use an approved transfer mechanism, such as an adequacy decision, the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum or Agreement, or another lawful safeguard, and implement supplementary measures where appropriate.

12. Children's Privacy

The Website is directed to independent service professionals and small businesses, not children. It is not intended for children under 13, and we do not knowingly request personal information from children under 13 through Website forms. If you believe a child submitted personal information, contact us so we can investigate and take appropriate action.

13. Privacy Rights

Depending on your residence and applicable law, you may have rights to:

• know or access personal information and information about its processing;
• correct inaccurate personal information;
• delete personal information, subject to exceptions;
• obtain a portable copy of certain information;
• restrict or object to processing;
• opt out of sale, sharing, targeted advertising, or certain profiling;
• limit certain uses of sensitive personal information;
• withdraw consent;
• appeal a denied request where required; and
• receive equal service and not be unlawfully discriminated against for exercising a right.

These rights are not absolute. We may deny or limit a request where permitted, including when we cannot verify it, an exception applies, or fulfilling it would adversely affect another person's rights.

13.1 Additional U.S. state considerations

Privacy laws in several U.S. states provide overlapping but not identical rights, definitions, thresholds, exceptions, deadlines, and appeal procedures. If a law applies to TodoGroup Apps and to your information, we will apply the rights and response rules required by that law. For example, a covered resident may be able to obtain a list of categories of third parties or specific third parties to which information was disclosed, opt out of processing for targeted advertising or certain profiling, or appeal a refusal. Some laws require consent before processing sensitive data or impose special duties for known children or teenagers.

The Website does not currently offer a financial incentive or loyalty program in exchange for personal information. If that changes, we will provide the required terms and value analysis before enrollment.

We will maintain a request process proportionate to the information we hold. We will not require you to create an account solely to make a request. We may retain a record of a request, our verification steps, decision, and communications to demonstrate compliance and prevent fraud. If a request concerns information controlled by an independent third party, we may direct you to that party; if the party acts as our processor, we will address the request as required.

13.2 Submitting a request

Submit requests to legal@todogroupapps.com with the subject "Privacy Request." Describe the request, your jurisdiction, and the email or phone number associated with your interaction. Do not email identity documents unless requested through an approved secure method.

13.3 Verification

We will use information reasonably necessary to match the request to our records and assess the risk of disclosure or deletion. We may ask you to confirm control of an email address or phone number or provide details about a recent interaction. We use verification information only for verification, fraud prevention, security, and legal compliance.

13.4 Authorized agents

Where permitted, an authorized agent may act for you. We may request proof of signed authorization, verify the agent's identity and authority, and ask you to confirm the request directly, unless a valid power of attorney or applicable law provides otherwise.

13.5 Appeals

If applicable state law provides an appeal right, reply to our decision or email legal@todogroupapps.com with the subject "Privacy Appeal" within 45 days of our decision. State why you believe the decision should be reconsidered. We will respond within the period required by applicable law and provide any required regulator complaint information.

14. California Disclosures

If the CCPA applies to us, California residents may exercise rights to know, delete, correct, opt out of sale or sharing, limit certain uses of sensitive personal information, and receive nondiscriminatory treatment.

For the preceding 12 months, we have collected the following statutory categories of personal information, as described in Sections 3–7 of this Policy: identifiers and contact details; internet or other electronic-network activity; approximate geolocation derived from IP address; professional or employment-related information inferred from business type; and inferences about product interest. We have disclosed these categories to the service providers described in Section 7 for the business purposes described in this Policy. We have not sold or shared personal information, as those terms are defined under the CCPA.

The Website is not designed to collect sensitive personal information for purposes that trigger a right to limit, but phone messages or submissions could contain information a visitor voluntarily supplies. Do not submit unnecessary sensitive information.

If we become subject to the CCPA in a manner that changes these disclosures, we will provide the methods and response procedures the law requires. We will not use personal information collected solely to verify a request for unrelated purposes. We will not disclose highly sensitive account credentials or other information that law prohibits us from producing in response to a request. We may deny a request in whole or part when a statutory exception applies and will explain the basis as required.

14.1 Do Not Track and Global Privacy Control

Browsers may transmit Do Not Track (DNT) or Global Privacy Control (GPC) signals. No uniform legal standard requires a response to DNT in all jurisdictions, and the Website does not contain DNT-specific logic. The current consent script does not detect or apply GPC because the Website does not engage in the sale or sharing of personal information or targeted advertising. If that changes, we will implement and test GPC detection, and honor it where legally required, before the new activity begins.

15. EEA and UK Rights

If the GDPR or UK GDPR applies, you may request access, correction, erasure, restriction, portability, or objection; withdraw consent; and complain to the supervisory authority where you live or work or where an alleged infringement occurred. You may object at any time to direct marketing and to related profiling. Where processing is based on legitimate interests, you may object based on your particular situation.

TodoGroup Apps has not appointed an EU or UK representative or a Data Protection Officer, because we do not believe our current activities trigger that requirement under the GDPR or UK GDPR. We will appoint one if our processing activities change in a way that requires it.

If we receive a qualifying request, we will respond without undue delay and within the applicable statutory period, subject to any lawful extension. We may ask for information needed to confirm identity, clarify scope, or locate records. Ordinarily, no fee applies, but a reasonable fee or refusal may be permitted for manifestly unfounded or excessive requests. If we decline to act, we will give the required reasons and complaint information.

You may lodge a complaint with a competent EEA data-protection authority or the UK Information Commissioner's Office, as applicable. We encourage you to contact us first so we can try to resolve the concern, but doing so does not waive a complaint right.

16. Marketing Preferences

You may opt out of promotional email using the unsubscribe method in the message or by contacting us. You may ask us to stop promotional WhatsApp or text messages by replying STOP or using the platform's controls, as applicable. We may retain limited suppression information so we can honor the request. Opting out of marketing does not prevent necessary replies, transaction-related notices, security messages, or other nonmarketing communications.

17. Third-Party Links and Embedded Content

The Website may link to or embed content from WhatsApp, Apple, Google, Stripe, Instagram, Facebook, TikTok, LinkedIn, and other services. Embedded content (such as a social-media post or video displayed directly on our page) may cause the third-party service to receive certain information automatically when the page loads, even if you do not click on it. We do not control these third parties' privacy practices. A link or embed does not mean the third party acts as our processor or that we endorse all of its practices. Review each third party's own notice before providing information.

18. Changes to This Policy

We may update this Policy as practices, technology, products, or law change. We will post the updated version with a revised Last Updated date and provide additional notice where required. Material changes will not be applied retroactively where prohibited.

19. Contact Us

Website operator: TodoGroup Apps, a DBA of AION Technologies LLC
Privacy and legal email: legal@todogroupapps.com
General email: info@todogroupapps.com
Telephone: +1 786-600-5400
Postal address: 4030 Wake Forest Rd, Raleigh, NC 27609 (Wake County)

Questions about cookies may also be addressed under the Cookie Policy.