Who we are
This Privacy Policy explains how Oriono Digital Limited, trading as Chocho Journal ("Chocho", "we", "us", "our"), collects and uses your personal data when you use the Service.
We are the data controller for your personal data. Oriono Digital Limited is registered in England and Wales with company number 14864124. Our registered office is at 186a Cowley Road, Oxford, OX4 4UE.
We are registered with the UK Information Commissioner's Office (ICO) as a data controller.
If you have any questions about this policy or your data, email hello@chochojournal.com for general and privacy enquiries, or legal@chochojournal.com for formal data protection and legal notices.
Scope and what you record
This policy covers our website, your Dashboard, and the iMessage journalling service.
Chocho is a journal, so what you record is the information you choose to log, such as short notes and symptom scores. We treat this as your ordinary personal data, and we explain in section 5 the legal basis we rely on to process it.
Chocho is for adults only. It is not intended for anyone under 18, and we do not knowingly collect data from children. See section 12.
The personal data we collect
- Account data. When you sign up, our sign-in provider collects your name and email address and the credentials you use to log in. We use this to create and secure your Account.
- Payment data. When you buy a Subscription, our Payment Provider (DodoPayments) collects and processes your payment details as merchant of record. We do not receive or store your full card details. We receive confirmation of your purchase, your plan, and limited billing information needed to manage your Subscription and provide support.
- Your journal content. This is the heart of the Service. It includes the messages you send to Chocho, the symptoms and details it records, the scores you give, your notes, and the journal, summaries, analytics, and reports built from them.
- Delivery data. To deliver the Service over iMessage, we and our delivery provider process the number provisioned for you and the messages exchanged, so that your texts reach the journal.
- Support and feedback data. If you contact support or use in-product feedback or live chat, we process what you send us so we can help you.
- Website and analytics data. When you visit our website, we and our analytics provider may collect technical information such as your device type, browser, approximate location derived from your IP address, and how you use the site. We use analytics cookies for this only where you have given consent (see section 6).
- Technical and security data. We process technical logs needed to run the Service securely, such as request metadata and error logs.
Where your data comes from
Most data comes directly from you, when you sign up, subscribe, and text Chocho.
Some data comes from our providers acting on our behalf, for example purchase confirmations from the Payment Provider and delivery information from the iMessage delivery provider.
How we use your data, and our legal bases
We use your personal data for the purposes below. For each, we set out the lawful basis under the UK GDPR.
| Purpose | What this involves | Lawful basis |
|---|---|---|
| Providing the Service | Running your account, delivering Chocho over iMessage, building your journal, scores, analytics, and reports | Performance of our contract with you (Article 6(1)(b)) |
| Processing your journal entries | Organising and analysing the information you choose to log | Performance of our contract with you (Article 6(1)(b)) |
| Taking payment | Managing your Subscription, renewals, refunds, and invoices through our Payment Provider | Performance of our contract, and our legal obligations for tax and accounting |
| Support and communication | Answering your questions, sending service emails such as provisioning and account confirmations | Performance of our contract, and our legitimate interests in supporting users |
| Security and running the business | Keeping the Service secure, preventing abuse, fixing faults, and improving reliability | Our legitimate interests in a secure, working service |
| Website analytics | Understanding how our website is used so we can improve it | Your consent, given through cookies (section 6) |
| Meeting legal duties | Keeping records we are legally required to keep, and responding to lawful requests | Compliance with a legal obligation |
You stay in control of what you log. You decide what to record with Chocho, and you can stop and ask us to delete your data at any time (see sections 9 and 11). Where we rely on your consent for any processing, you can withdraw it at any time, and withdrawing it does not affect processing we carried out beforehand.
We do not sell your personal data, and we do not use your journal content for advertising.
Cookies and similar technologies
We use a small number of cookies and similar technologies:
- Essential cookies. Set by our sign-in provider so you can log in and stay logged in, and to keep the site secure. These are required for the site to work and do not need consent.
- Analytics cookies. Set by Google Analytics to help us understand website usage. These are optional and are only used if you accept them through our cookie banner. You can decline or change your choice at any time, and if you decline, Google Analytics is not loaded.
- Support and feedback tools. Our in-product support and feedback tool may set cookies needed for it to function when you use it.
We do not use advertising cookies or sell data collected through cookies. You can also control cookies through your browser settings. Blocking essential cookies may stop parts of the site from working.
Who we share your data with
We share personal data only with providers who help us run the Service, and only as needed. Each acts under a contract that requires them to protect your data and to use it only for the purposes we set. Nobody accesses your journal by default. Where access is needed to troubleshoot, only our UK-based team can access it, with your permission and only for as long as needed.
Our main providers (subprocessors) are:
| Provider | What they do | Location |
|---|---|---|
| Clerk | Accounts and sign-in | United States |
| DodoPayments | Payments and invoicing, as merchant of record | United States |
| Supabase | Database and storage for your journal | United States (US East) |
| Photon | iMessage delivery and number provisioning (fully managed third-party service) | United States |
| Third-party LLM providers | Process your messages to organise them into a structured journal | Outside the UK (see section 8) |
| Featurebase | In-product live chat and feedback | United States |
| Cloudflare | Hosting and delivery of the Service | United States and global edge network |
| Google Analytics | Website usage analytics, only with your consent | United States |
Third-party LLM providers. To turn your messages into a structured journal, we send them to be processed by third-party large language model (LLM) providers. We use more than one provider and may change providers as the Service develops. See section 8 for where this processing takes place.
We may also share data where we are legally required to, for example to comply with a court order or a lawful request from an authority, or to protect our rights, safety, or the safety of others.
If our business is reorganised, sold, or merged, personal data may be transferred as part of that, and your rights under this policy will continue to apply.
International data transfers
Some of our providers, including some of our LLM providers, are based in the United States and in other countries, so running the Service involves transferring your personal data outside the United Kingdom.
Where we transfer your data internationally, we make sure it is protected by appropriate safeguards recognised under UK data protection law. Depending on the provider, this means the UK International Data Transfer Agreement, the UK Addendum to the European Commission's Standard Contractual Clauses, or the provider's certification under the UK Extension to the EU-US Data Privacy Framework. We also assess the protections in place before transferring.
You can ask us for more information about the safeguards we use by emailing legal@chochojournal.com.
How long we keep your data
We keep your journal and account data for as long as your Subscription is active, so you can use the Service.
After your Subscription ends, you keep access to your Dashboard for 90 days, so you can review, export, and download your data. After that 90-day period, your journal and account data are deleted automatically. If you would like your data deleted sooner, contact hello@chochojournal.com and we will arrange it.
We do not keep separate long-term backups of your journal, so deletion is final.
We keep limited payment and invoice records for about six years, because tax and accounting law requires it. These records are held by our Payment Provider as merchant of record and contain billing information rather than your journal content.
We may keep minimal records for longer where the law requires it, or to handle a legal claim.
How we protect your data
We take security seriously. Measures include:
- Your iMessages are end-to-end encrypted in transit by Apple's iMessage.
- Your journal is stored with encryption and strict access controls.
- Access to journal data is restricted, is off by default, and is only carried out by our UK-based team with your permission when needed for support.
- We use reputable providers and hold them to contractual security and confidentiality obligations.
No online service can be guaranteed to be completely secure, but we work to protect your data and to review our safeguards as we grow.
If a data breach happens that is likely to risk your rights, we will notify the ICO, and you where required, in line with our legal duties.
Your rights
Under UK data protection law you have the right to:
- be informed about how we use your data, which this policy explains;
- access the personal data we hold about you;
- rectify data that is inaccurate or incomplete;
- erase your data ("right to be forgotten") in certain circumstances;
- restrict or object to certain processing;
- data portability, to receive your data in a portable format or have it transferred, where this applies. Your Dashboard already lets you export your journal; and
- withdraw consent at any time, where we rely on your consent for processing.
To exercise any of these rights, email hello@chochojournal.com or legal@chochojournal.com. We will respond within one month, as the law requires. We may need to confirm your identity first.
You also have the right to complain to the ICO if you are unhappy with how we handle your data. You can contact the ICO at ico.org.uk. We would appreciate the chance to resolve your concern first, so please consider contacting us before you approach the ICO.
Children
Chocho is for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we learn that we hold data about someone under 18, we will delete it and close the Account.
If you are in the United States
We welcome users from the United States, and some US state privacy laws, such as the California Consumer Privacy Act as amended by the California Privacy Rights Act, give residents specific rights.
If you are a US resident with these rights, you may have the right to know what personal information we collect and how we use it, to request access to or deletion of your personal information, and to not be discriminated against for exercising your rights.
We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We do not use your journal content for advertising of any kind.
To exercise any of these rights, contact us at hello@chochojournal.com. We will verify your request and respond as required by the applicable law.
Changes to this policy
We may update this policy from time to time, for example when we change providers or add features. If we make a significant change, we will give you reasonable notice, for example by email or through the Dashboard.
The "last updated" date at the top shows when this policy last changed.
Contact us
If you have any questions, requests, or complaints about your data, contact us at hello@chochojournal.com, or for formal notices at legal@chochojournal.com.