Privacy Policy

1. Who We Are

HighRoad Software is a brand operated by COBI Management SRL, a private limited liability company registered under Belgian law.

• Company name: COBI Management SRL
• Enterprise number: BE 0676.613.701
• Registered address: Rue Haut Chemin 8, 1370 Jodoigne, Belgium
• Email: privacy@cobimanagement.eu

COBI Management SRL is the data controller for all personal data processed in connection with HighRoad Software apps and this website.

2. What Data We Collect and Why

2.1 Data Stored Locally on Your Device

All content you create within our apps (conversations and presets in Roundtable AI, family trees in FamilyLegacy, wellness entries in PulseWave, wardrobe items in DressGenius) is stored locally on your device. This data does not leave your device unless you explicitly enable iCloud sync (see section 2.2). We do not have access to this data.

2.2 iCloud Sync (Optional)

If you enable iCloud sync in an app, your data is stored in your personal iCloud account managed by Apple Inc. We do not have access to your iCloud data. Apple's Privacy Policy applies to this storage. You can disable iCloud sync at any time in the app settings.

2.3 Roundtable AI — Third-Party AI Providers

When you use cloud-based AI models in Roundtable AI (for example via OpenRouter), your discussion prompts and AI responses are transmitted directly from your device to the AI provider you selected. This communication is necessary for the app to function with cloud models. No conversation content is sent to COBI Management SRL.

Your API keys are stored locally on your device using macOS system encryption (safeStorage). They are sent only to the AI provider during API requests and are never transmitted to us. When using local GGUF models, all inference runs entirely on-device — nothing is sent over the internet.

We encourage you to review the privacy policies of the providers you use, including the OpenRouter Privacy Policy.

2.4 Roundtable AI — Licence Purchases via Paddle

If you purchase a Roundtable AI licence through our website, the transaction is processed by Paddle.com, our Merchant of Record. Paddle collects payment information (name, email, billing address, payment method) to complete the purchase and comply with tax regulations. COBI Management SRL does not receive or store your payment details. See the Paddle Privacy Policy for full details.

2.5 App Store Transactions

Purchases, subscriptions, and in-app purchases are handled exclusively by Apple via the App Store. We do not receive your payment details. Apple may share a reseller receipt with us to verify your purchase, which contains a transaction ID and product identifier — no personal financial data.

2.6 Website Server Logs

When you visit www.highroadsoftware.com, our hosting provider (alwaysdata.com) may record standard server access logs including your IP address, browser type, the page requested, and timestamp. These logs are retained for up to 30 days for security and diagnostic purposes. We do not use these logs for profiling or marketing.

2.7 Email Contact

If you contact us via email at info@cobimanagement.eu, we process your name, email address, and message content solely to respond to your enquiry. We do not add you to any mailing list without explicit consent.

2.8 Cookie Consent Preference

If you interact with our cookie consent banner, we store your preference (accepted or rejected) in your browser's localStorage. This is a functional necessity and contains no personal identifiers. It expires after 180 days.

3. Legal Basis for Processing (GDPR Art. 6)

• Legitimate interests (Art. 6(1)(f)): Server logs for security and abuse prevention.
• Performance of a contract (Art. 6(1)(b)): Processing your email to respond to support requests.
• Consent (Art. 6(1)(a)): Cookie preference storage, iCloud sync.

4. Data We Do Not Collect

We explicitly do not:

• Use advertising trackers, analytics SDKs (Google Analytics, Meta Pixel, etc.)
• Build behavioural or advertising profiles
• Sell, rent, or share your personal data with third parties for their own purposes
• Collect health data, biometric data, or sensitive personal data
• Send marketing emails or newsletters (unless you explicitly sign up)

5. Third-Party Services

Our apps and website interact with the following third-party services:

• Apple App Store: Distribution, payments, and in-app purchases. Apple Privacy Policy applies.
• Apple iCloud: Optional sync feature. Apple Privacy Policy applies.
• OpenRouter: Cloud AI model provider used by Roundtable AI when the user chooses cloud models (see section 2.3). OpenRouter Privacy Policy.
• Paddle.com: Merchant of Record for Roundtable AI licence purchases (see section 2.4). Paddle Privacy Policy.
• Google Fonts: Used on this website to load the Plus Jakarta Sans and Inter typefaces. Google may log the request. We may self-host these fonts in a future update to eliminate this.
• alwaysdata.com: Website hosting. Standard server logs (see section 2.6).

6. Data Transfers Outside the EU

Apple Inc. is a US-based company. When you use the App Store or iCloud, your data may be transferred to the United States under Apple's Standard Contractual Clauses (SCCs) with the European Commission. When you use cloud AI models in Roundtable AI, prompts are sent to the AI provider selected (which may be US-based, depending on the model). Google Fonts requests may also be processed in the US. We have no control over these transfers; they are governed by the respective company's privacy policies and applicable transfer mechanisms.

7. Data Retention

• App data: Retained on your device for as long as the app is installed. Deleted when you delete the app or clear app data.
• iCloud data: Governed by your iCloud account settings.
• Email correspondence: Retained for up to 3 years from the last contact, then deleted.
• Server logs: Retained for up to 30 days.
• Cookie preference: Stored for 180 days in localStorage.

8. Your Rights Under GDPR

As a resident of the European Union (or where applicable law provides), you have the following rights:

• Right of access (Art. 15): Request a copy of personal data we hold about you.
• Right to rectification (Art. 16): Request correction of inaccurate data.
• Right to erasure (Art. 17): Request deletion of your personal data ("right to be forgotten").
• Right to restriction of processing (Art. 18): Request that we limit processing of your data.
• Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.
• Right to object (Art. 21): Object to processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you may withdraw at any time.

To exercise any of these rights, contact us at privacy@cobimanagement.eu. We will respond within 30 days. You also have the right to lodge a complaint with the Belgian Data Protection Authority (dataprotectionauthority.be).

9. Children's Privacy

Our apps and website are not directed at children under the age of 13. We do not knowingly collect personal data from children. If you believe a child has provided us with personal information, please contact us at privacy@cobimanagement.eu and we will delete it.

10. Security

We implement appropriate technical and organisational measures to protect any personal data we process, including TLS encryption for all website traffic and email communications. App data stored on your device is protected by your device's built-in security features (including device encryption where enabled).

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via a notice on our website. The "last updated" date at the top of this page always reflects the most recent version. Continued use of our apps or website after an update constitutes acceptance of the revised policy.

12. Contact

For any privacy-related enquiries or to exercise your rights:

• Email: privacy@cobimanagement.eu
• Post: COBI Management SRL, Rue Haut Chemin 8, 1370 Jodoigne, Belgium