Last updated: 10/12/2025
Welcome to Simone, the AI-assisted coaching service provided by Tigo Labs SAS (“we”, “us”, “our”).
Protecting your data is central to our mission. This Privacy Policy explains what data we collect, how we use it to provide your coaching via Simone, and your rights regarding this information.
1) Data Controller
The controller responsible for your personal data is:
Tigo Labs SAS
13 rue du Delta, 75009 Paris, France.
RCS: 940 227 2343.
For any privacy-related questions: contact@tigo-labs.com.
2) The Data We Collect
We process the following categories of data strictly necessary for the Service:
A. Data You Provide Directly
- Account Identifiers: Your email address is required to create an account. You may optionally provide your name and profile preferences.
- Interaction Content (User Content): This includes everything you share with Simone: your messages, goals, tracks, notes, and other inputs, as well as the AI Outputs generated for you.
Important Note: We do not require special-category data (e.g., health data). If you choose to provide such information in your conversations, it will be processed as part of your Interaction Content based on your explicit consent (by submitting it).
- Feedback: If you provide ideas, suggestions, or contact support.
B. Data Collected Automatically
- Technical & Usage Data: To ensure security and performance, we collect device identifiers, IP addresses, timestamps, session metrics, crash/diagnostic logs, and feature usage data.
- Payment Data: If you subscribe to a paid plan, transactions are processed by third-party payment processors. Tigo Labs does not store your full credit card details.
3) Why We Use Your Data & Lawful Bases
We process your data for the following purposes:
| Purpose | Lawful Basis (GDPR) |
|---|---|
| Providing the Service: Account creation, AI conversations, maintaining context/memory for coaching. | Performance of Contract (Art. 6(1)(b)) |
| Personalization: Tailoring Simone’s responses to your style and past goals. | Performance of Contract (Art. 6(1)(b)) |
| Security & Maintenance: Fraud prevention, abuse detection, debugging, and technical operations. | Legitimate Interests (Art. 6(1)(f)) |
| Service Improvement: Measuring functionality and user experience (without profiling for third-party ads). | Legitimate Interests (Art. 6(1)(f)) |
| Legal Compliance: Accounting, handling GDPR rights requests. | Legal Obligation (Art. 6(1)(c)) |
Note: We do not sell personal data. We do not share personal data with third parties for their own marketing or analytics purposes.
4) AI & Data Processing
Simone relies on various AI technologies.
- Processing: When you send a message, the text is securely transmitted to our AI partners (processors) to generate a response.
- Training: Your data is used to provide the Service (e.g., memory functions). We use User Content to improve the Service, but we ensure your personal data is not used to train the public models of our third-party providers unless explicitly stated otherwise.
5) Data Sharing (Recipients)
We do not disclose personal data to third parties except:
- Authorized Personnel: Tigo Labs staff on a strict need-to-know basis.
- Service Providers (Processors): Vetted vendors acting on our instructions under written data-processing agreements. This includes:
- Hosting and Cloud infrastructure.
- AI runtime providers.
- Payment processors.
- Analytics tools.
- Legal Requirements: If required by law or to protect rights and safety.
6) International Transfers
Where data are transferred outside the EEA/UK (e.g., to US-based AI providers), we implement appropriate safeguards such as European Commission Standard Contractual Clauses (SCCs) and additional technical measures.
7) Retention
We retain personal data only as long as necessary:
- Account & Interaction Data (Memory): Retained until you delete specific items or close your account.
- Session Logs: Up to 12 months.
- Backups: Encrypted backups retained up to 30 days for disaster recovery.
Upon termination, data is handled in accordance with applicable retention schedules.
8) Your Rights (GDPR)
You have the following rights:
- Access & Portability: Request a copy of your data.
- Rectification: Correct inaccurate information.
- Erasure: Request deletion of your account or specific memory items.
- Restriction & Objection: Limit how we use your data.
To exercise these rights, contact us at: contact@tigo-labs.com.
You also have the right to lodge a complaint with your supervisory authority (e.g., CNIL in France).
9) Security & Account
You are responsible for maintaining the confidentiality of your credentials. We implement technical measures (including abuse detection) to protect the Service and your data.
10) Children
The Service is intended for persons 18 years of age or older. We do not knowingly collect data from minors.
11) Changes to this Policy
We may update this Privacy Policy. Material changes will be notified by reasonable means. Continued use of the Service constitutes acceptance of the updated policy.