Privacy Policy

Last updated: October 17, 2026 · Version 1.0

Plain-Language Summary

What this actually means for you:

ApplyOwl runs on your own computer. Your resume, your job-site logins, the applications you send, and everything ApplyOwl does in your browser stay on your device — they are never uploaded to us. We literally cannot see them.

ApplyOwl uses your own AI — your OpenAI/Anthropic API key, or your own ChatGPT/Claude subscription. Those AI requests go directly from your computer to your provider, on your credentials. They never pass through us. We don't proxy them, store them, or train on them (we operate no AI training of any kind).

The only things we hold on our servers are what we need to run your account: your email, your subscription status, and basic operational data like error reports and license checks. The app also has optional usage analytics — which screens and features you use, never your resume, your applications, your logins, or anything you type. It's off unless you switch it on if your account is in Canada or we don't know your country, and you can change it anytime in Settings (see Tier 2).

You can export your account data, and delete your account yourself at any time from Settings — it takes effect immediately. Uninstalling the app removes the local data from your machine.

Questions? legal@applyowl.app. No lawyers needed — just ask.

1. Introduction

This Privacy Policy describes how Zoey OS, LLC ("Zoey OS," "we," "us," or "our") collects, uses, stores, and protects your personal information when you use ApplyOwl, our local-first job-application automation application, our website, and related services (the "Services"). ApplyOwl is a product owned and operated by Zoey OS, LLC.

Local-first by design. ApplyOwl is a desktop application that runs on your own computer and acts in your own browser. The core of what ApplyOwl does — reading job listings, filling applications, attaching your resume, and using AI to draft answers — happens locally on your device. The information involved in that work does not reach our servers (see Section 2).

Global availability. ApplyOwl is offered internationally. Our account and website infrastructure is operated from and hosted in the United States; where we process personal information, it is processed in the United States regardless of where you are located (see Section 11.4). The Services are not available in countries or territories subject to comprehensive U.S. or other applicable export sanctions, and we may block access from such regions.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. It should be read together with our Terms of Service and Acceptable Use Policy.

Contact Information:

2. What Stays on Your Device (and Never Reaches Us)

Because ApplyOwl is local-first, the most sensitive information involved in using it never leaves your computer and is never transmitted to, or stored by, Zoey OS:

Uninstalling the app, or using its in-app controls, removes this local data from your machine. We cannot delete it for you because we never have it.

3. Our Data Collection Tiers (What We Do Collect)

What we collect is limited to what's needed to run your account and keep the app working and secure.

Tier 1: Operational Telemetry (Always-On, Service-Required)

What it is: Data required to run and secure the Services and validate your entitlement. No access to your resume, applications, or AI content.

Examples:

Legal basis: Contractual necessity (required to provide the Services).

Retention: 90 days for performance data; up to 7 years for billing-related records (legal requirement).

Your control: Included in data export; deleted with account deletion.

Tier 2: Usage Analytics (Settings Toggle; Off by Default in Canada)

What it is: A record of which screens and features of the app you use, and key account events, so we can see what works and where people get stuck. It's tied to your account by a random internal identifier — not anonymous — but it never contains the content of your work with ApplyOwl.

What is collected when it's on:

What is never collected for analytics: your resume or its contents, the jobs you apply to or the answers you submit, your AI prompts or responses, your job-site logins, your API keys or subscription tokens, your name, email, or phone number, your precise location, or anything you type into a free-text field. We do not record your screen or replay your sessions.

Who processes it: PostHog, Inc., our analytics provider, on our behalf, in the United States (see our Subprocessor List). We do not sell this data or use it for advertising, and we configure PostHog to discard your IP address once it has been used to determine your country.

Default:

Legal basis: Consent where off by default; legitimate interest (with notice and opt-out) where on by default.

Retention: Up to seven (7) years; deleted when you delete your account.

Your control: Switch on or off anytime in Settings > Privacy > Usage analytics, or on the first-run notice. Your choice follows your account across devices. Turning on "Do Not Sell or Share My Personal Information" also switches usage analytics off.

Tier 3: Training Data — We Do Not Train On Your Data, and We Don't Run AI At All

Zoey OS does not operate any AI training, and does not run AI inference on your data. ApplyOwl's AI work is performed by your own AI provider, using your own API key or subscription, in a request that goes directly from your device to that provider. We never receive, store, proxy, or train on your prompts, your AI's responses, your resume, or your applications.

Your AI provider's terms govern those AI calls, not ours. This matters especially for the bring-your-own-subscription option:

4. Categories of Personal Data We Collect

4.1 Account Information

4.2 Operational and Billing Metering

4.3 Device and Technical Data

4.4 Consent and Compliance Records

We do not collect the categories described in Section 2 — they stay on your device.

5. How We Use Your Information

PurposeData UsedLegal Basis
Provide and secure the Services; validate your licenseAccount info, operational telemetryContractual necessity
Understand how the app is used so we can improve it (usage analytics, only where on — Tier 2)Usage events and basic account details; never your resume, applications, or AI contentConsent where off by default; legitimate interest (with notice and opt-out) where on by default
Process payments and calculate taxBilling info (via our payment processor)Contractual necessity; legal obligation
Respond to support requestsAccount infoContractual necessity
Detect abuse and prevent fraudOperational and security signals, IP, device infoLegitimate interest
Determine legal availability (sanctions/export screening)Edge country from IPLegal obligation
Send transactional communicationsEmail addressContractual necessity
Send marketing communicationsEmail addressConsent (opt-in only)

6. What We Do Not Do

7. How We Share Your Information

7.1 Subprocessors (Required for Service Delivery)

We use a small number of third-party providers to run our account service, payments, website analytics, email, and error monitoring. Each operates under contractual obligations limiting their use of your data to service provision only. A complete, current list is maintained at applyowl.app/legal/subprocessors. We will notify you at least 30 days before adding a new subprocessor. Note: your AI provider is not our subprocessor — you contract with them directly under your own credentials.

7.2 Legal Requirements

We may disclose information if required by law, subpoena, court order, or government request, and will notify you unless legally prohibited.

7.3 Business Transfers

If Zoey OS is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

7.4 With Your Consent

We may share information for other purposes with your explicit consent.

8. Data Retention and Deletion

8.1 Active Accounts

Data TypeRetention
Operational telemetry90 days
Usage analytics (Tier 2, where on)Up to 7 years; deleted with account deletion
Account informationFor the life of your account
Billing records7 years (legal requirement)
Your resume, applications, AI content, loginsStored only on your device; never held by us

8.2 Account Deletion

You can delete your account yourself at any time through Settings > Account > Delete Account. Deletion takes effect immediately. Afterwards: your access ends immediately; all account data is wiped from production within 30 days and from backups within 1 year; a confirmation email is sent; billing records may be retained for 7 years per law (anonymized). To remove the local data on your device, use the app's controls or uninstall it.

8.3 Subscription Cancellation (Without Account Deletion)

Cancelling a subscription does not delete your account or your data. Your account reverts to the free version. If you don't use the Services for 12 consecutive months, we will email you at least 30 days beforehand and then close the account; any use during that window resets the clock.

9. Your Rights

10. Children's Privacy

You must be at least 13 to create an account or use the Services. We do not knowingly collect personal information from anyone under 13, and the Services are not directed to children under 13. If we discover we have collected information from a minor, we will delete it promptly (within 48 hours of discovery). Contact legal@applyowl.app.

11. United States — State Privacy Rights (CCPA/CPRA and Similar)

If you reside in California or another U.S. state with a comprehensive consumer privacy law (e.g., Virginia, Colorado, Connecticut, Utah, Texas, and others), you have the rights below.

To exercise these, use Settings or contact legal@applyowl.app.

12. EU, EEA, UK & Switzerland (GDPR / UK GDPR / revFADP)

12.1 Roles

For personal information you provide as a consumer, Zoey OS acts as a controller.

12.2 Legal Bases

Processing ActivityLegal Basis
Providing the ServicesPerformance of contract
Billing, payments and taxPerformance of contract; legal obligation
Usage analyticsConsent (off-by-default regions); legitimate interest with notice/opt-out (on-by-default regions)
Security and fraud preventionLegitimate interest
Sanctions/export screeningLegal obligation
Marketing communicationsConsent

12.3 Your Rights

In addition to Section 9, you may lodge a complaint with your local supervisory authority (UK: ICO; Switzerland: FDPIC), object to processing based on legitimate interest, restrict processing, and receive your data in a portable format. We do not carry out solely-automated decision-making producing legal or similarly significant effects.

12.4 International Data Transfers

Our account and website infrastructure is hosted in the United States. Where you are outside the U.S., relevant personal data is transferred to and processed in the U.S. under Standard Contractual Clauses (SCCs) (EU Modules; for the UK, the IDTA; for Switzerland, FDPIC-recognized clauses) with our subprocessors, plus supplementary measures.

12.5 Data Subject Requests

We respond to verified requests within 30 days (extendable as permitted). Contact legal@applyowl.app.

13. Cookies and Tracking

13.1 Desktop Application

The app does not use third-party advertising cookies, cross-site tracking, pixels, or fingerprinting (beyond the hashed hardware identifier for device limits disclosed in our Terms). In-app usage analytics (Tier 2) do not use cookies and do not record or replay sessions.

13.2 Website

Our website uses essential cookies (login/session, CSRF, preferences) and, under the consent rules below, PostHog privacy-focused analytics and any advertising/affiliate tools we run. For visitors in the EU, EEA, and UK, no non-essential analytics or advertising tools load until you explicitly accept. For visitors elsewhere, anonymous cookieless analytics load on page load, with persistent cookies set only if you accept. We honor the Global Privacy Control (GPC) signal and do not respond to legacy Do Not Track headers.

If you create an ApplyOwl account on the website, the analytics events from that browsing session are associated with the email address you provide, so we can understand which content and pages lead people to sign up. This association lives only inside our analytics provider under the same restrictions as Tier 2 above, is never used for advertising, and is deleted with your account. In-app usage analytics are never linked to your email — the app uses a random identifier.

14. Data Security

Breach notification: In the event of a breach affecting your personal information, we will notify affected users without undue delay and, where required, within 72 hours of becoming aware, describe what was affected and our response, and notify regulators as required.

15. Changes to This Privacy Policy

We may update this Policy. We will notify you of material changes by email (at least 30 days before they take effect), by prominent in-Service notice, and by posting the updated policy with a new date and version. Where changes materially reduce your privacy rights, we will obtain your explicit consent first.

16. Contact Us

Zoey OS, LLC (operator of ApplyOwl)

Privacy: legal@applyowl.app

Abuse / Support: support@applyowl.app

Address: 7901 4th St N, STE 300, St. Petersburg, FL 33702, United States

We aim to respond to privacy inquiries within 5 business days.

17. Additional Regional Privacy Rights (Addenda)

Where an addendum grants a right greater than the body of this Policy, the addendum controls for residents of that jurisdiction.

17.1 Canada (PIPEDA & Quebec Law 25)

We collect, use, and disclose personal information with your knowledge and consent, except where permitted or required by law. Access/correction via the in-app tools or legal@applyowl.app. For accounts in Canada, usage analytics are off unless you switch them on. Quebec residents have rights to portability and to be informed of automated decision-making (we do none); our Privacy Officer is reachable at legal@applyowl.app. Complaints: OPC or, in Quebec, the CAI.

17.2 Brazil (LGPD)

Rights: confirmation, access, correction, anonymization/blocking/deletion, portability, information about sharing, and withdrawal of consent. DPO (Encarregado): legal@applyowl.app. Authority: ANPD. U.S. processing occurs under safeguards consistent with LGPD Art. 33.

17.3 Australia (Privacy Act & APPs)

We handle personal information per the Australian Privacy Principles. Access/correction via in-app tools or legal@applyowl.app. Cross-border disclosure (APP 8) to the U.S. under contractual safeguards. We comply with the Notifiable Data Breaches scheme.

17.4 United Kingdom

Covered by Section 12 (UK GDPR). Complaints: ICO. Transfers rely on the UK IDTA.

17.5 Switzerland

Covered by Section 12 (revFADP). Contact the FDPIC. Transfers rely on FDPIC-recognized clauses.

17.6 Other Jurisdictions

Residents of other countries with data-protection laws may exercise the universal rights in Section 9 and contact legal@applyowl.app for any additional local rights.

Last updated: October 17, 2026 · Version 1.0

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