Neverhold Privacy Policy

1. Introduction

Neverhold is committed to protecting your privacy. This Privacy Policy describes our practices for Neverhold (the dialer, com.neverhold.dialer) and neverhold.co. The standalone TAP app (com.neverhold.tap) has a separate TAP Privacy Policy. TAP features inside Neverhold (cards, exchange, Medical ID) and the shared signed-in account (loyalty, Business Account / Remove Ads, emergency Message Center copies) are described here. By using Neverhold, you agree to this policy.

This Privacy Policy complies with:

• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) - United States
• Personal Information Protection and Electronic Documents Act (PIPEDA) - Canada
• Ley Federal de Protección de Datos Personales (LFPD) - Mexico
• General Data Protection Regulation (GDPR) - where applicable
• Google Play Store Data Safety requirements
• Android privacy and security best practices

2. Information We Collect

2.1 Information You Provide to Us

We collect information that you provide directly to us, including:

• Account Information: Name, email address, phone number, username, and password when you create an account with email. You may also sign in with Google or Microsoft (Azure / Microsoft Entra ID / Microsoft 365). Those providers send us an identifier, display name, and email; we do not receive your Google or Microsoft password;
• Profile Information: Profile photo, preferences, and settings you configure in the App;
• Verification Information: Phone numbers you verify with a one-time code (SMS or voice via Twilio). Signing in with Google or Microsoft does not verify a phone number. A number shown on a Microsoft or Google profile may be offered as a prefill only; TAP still requires the SMS/voice code. A Google or Microsoft email is treated as an email-verified sign-in for account purposes;
• Cloud backup (optional): If you use account cloud backup (Business Account), we store a JSON backup of your Æther / TAP contacts and your TAP cards (personal and business, including photos and custom designs) in our storage (Supabase) under your user id. TAP Medical ID is never included in cloud or file backups;
• File backup (optional): You may also back up to Google Drive, Files, iCloud, or a folder you choose. Those backups include your TAP cards and contacts in one JSON file. Medical ID is never included;
• On-device vault: Your TAP cards and Medical ID are stored encrypted on your device, scoped to your signed-in account, and survive sign-out on the same phone. They are cleared when you uninstall the app or delete your account on that device;
• Business Account connected mailboxes (optional): If you purchase or redeem Business Account and connect Gmail, Exchange / Microsoft 365, or iCloud, we use tokens you authorize to sync contacts you choose (Google People API, Microsoft Graph Contacts, or iCloud CardDAV). You can disconnect a mailbox in the App;
• Payment Information: Billing address and payment method information (processed by third-party payment processors, not stored by us);
• Communications: Information you provide when contacting us for support or feedback;
• User-Generated Content: Custom voicemail messages, call recordings (if enabled), and spam reports you submit;
• Referrals and Loyalty: Referral codes you use or share, and loyalty/rewards data associated with your account;
• Æther / TAP card: The contact fields you choose to put on your digital card (name, photo, phone, email, socials, company, and similar);
• TAP photos and camera (Android): When you add a picture to a TAP card or profile, TAP uses the Android system Photo Picker, or the camera if you take a new photo. TAP does not request access to your photo library. TAP no longer scans TAP-card QR codes for exchange. Medical ID may still display an emergency QR for a first responder;
• TAP Medical ID (optional): Health and safety information you enter yourself, such as medical conditions, medications, allergies, blood type, language, and emergency-contact names, relationships, and phone numbers. We do not require Medical ID to use TAP card exchange;
• Emergency lock-screen messages (optional): If you enable TAP Medical ID on the lock screen, a first responder can open TAP’s emergency ID without unlocking (the system notification does not show your conditions, medications, or allergies). If they use lock-screen Send, the app builds a message from fields they enter (injured person’s listed name/phone, status such as conscious / unconscious / critical / fatal, destination/hospital, notes) and from your Medical ID emergency contacts. That message is sent as SMS to those contacts only. TAP does not read your SMS inbox. If a contact has a TAP or Neverhold account with a verified phone that matches, a copy of the same message is delivered to their in-app Message Center as an emergency item.

2.2 Information We Collect Automatically

When you use the Services, we automatically collect certain information, including:

• Device Information: Device type, operating system, unique device identifiers, mobile network information, and device settings;
• Usage Information: How you interact with the App, features you use, time spent in the App, and crash reports;
• Call Information: Call logs, call duration, phone numbers called/received, call timestamps, and call status (connected, missed, etc.);
• Contact Information: Contacts stored on your device that you grant us access to, used locally for caller identification, call management, and saving Æther / TAP cards you receive. Device address-book data is processed on your device unless you choose to save or sync a TAP card to your Neverhold/TAP account;
• Location Information: TAP (and TAP inside Neverhold) may request nearby Bluetooth / Wi‑Fi permissions and, on some Android versions, location, solely so TAP card exchange can discover a nearby phone. We do not use that access for advertising, mapping, or background tracking. Approximate location may also be inferred from IP address for fraud prevention when you connect to our servers;
• NFC: If you arm TAP Medical ID NFC, the device can share a short-lived emergency Medical ID payload with a nearby NFC reader or phone. TAP cannot turn NFC on without you enabling it in system settings;
• Network Information: IP address, internet service provider, and network connection type;
• Log Information: App logs, error logs, and diagnostic information.

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Sign-in providers: Google and Microsoft (Azure / Entra ID) when you tap Continue with Google or Continue with Microsoft. We receive the OAuth tokens needed to create or resume your Neverhold/TAP session. If the same verified email is already on a Neverhold/TAP account, sign-in may attach to that existing account rather than creating a duplicate;
• Microsoft Graph: If you connect Exchange / Microsoft 365 under Business Account, we read and write contacts you authorize (Contacts.ReadWrite). Graph may also return a mobile phone on /me used only to prefill TAP’s phone-verify screen — never as a verified number;
• Google (People API / account): If you connect Gmail under Business Account, we sync contacts you authorize. Google Sign-In for login is separate from that optional Gmail connect;
• Apple / iCloud: If you connect iCloud contacts under Business Account, you provide an Apple ID email and an app-specific password for CardDAV. We do not use that password for Apple Sign-In on TAP Android;
• Service Providers: Information from VoIP and SMS providers (e.g., Twilio) regarding call status, verification codes, and billing;
• Firebase: Analytics data (app interactions), crash reports (Firebase Crashlytics), and diagnostics (Firebase Performance) to improve the App;
• AdMob: When ads are displayed, Google AdMob may collect device identifiers and ad interaction data for advertising purposes;
• Google Play Billing: Purchase verification data (product ID, purchase token, order ID) when you make in-app purchases;
• App Stores: Basic account information from Google Play Store if you download the App through an app store.

2.4 Website Data

When you use our website (neverhold.co), we collect:

• Email addresses: If you subscribe to launch notifications via our "Notify Me" or similar form, we store your email to send updates. This data is retained until you unsubscribe or request deletion.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Providing and Improving the Services

• Deliver, maintain, and improve the Services;
• Process and complete transactions, including VoIP calls and subscription payments;
• Provide customer support and respond to your inquiries;
• Customize your experience and personalize content;
• Develop new features and services;
• Let you build and exchange Æther / TAP contact cards;
• Create and maintain your account when you sign in with email, Google, or Microsoft;
• Store optional cloud backups of TAP / Æther contacts you choose to back up;
• Sync contacts from Gmail, Exchange / Microsoft 365, or iCloud when you connect those accounts under Business Account;
• Operate a shared loyalty balance and entitlements (including Business Account, extra business cards, and Remove Ads) across TAP and Neverhold for the same signed-in user;
• Store TAP Medical ID you enter, and (if you enable it) send owner-designated emergency SMS and in-app emergency messages;
• Share a short-lived Medical ID payload over NFC when you arm that feature.

3.3 Communication

• Send you service-related communications (account updates, security alerts, etc.);
• Send you marketing communications (with your consent, which you can opt-out of at any time);
• Notify you about changes to our Services, Terms of Service, or Privacy Policy;
• Respond to your comments, questions, and requests.

3.4 Security and Fraud Prevention

• Detect, prevent, and address fraud, security threats, and abuse;
• Verify your identity and prevent unauthorized access;
• Monitor for suspicious activity and violations of our Terms of Service;
• Protect the rights, property, and safety of Neverhold, our users, and others.

3.5 Legal Compliance

• Comply with applicable laws, regulations, and legal processes;
• Respond to government requests and court orders;
• Enforce our Terms of Service and other agreements;
• Protect our legal rights and interests.

3.6 Analytics and Research

• Analyze usage patterns and trends to improve the Services;
• Conduct research and development;
• Generate aggregated, anonymized data for business intelligence.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• VoIP / SMS Service Providers: Twilio and other providers for VoIP calling and phone-number verification SMS/voice (not for TAP Medical ID emergency SMS, which is sent by the device);
• Identity providers: Google and Microsoft for optional social login;
• Mailbox / contact APIs: Google People API, Microsoft Graph, and iCloud CardDAV when you connect those accounts;
• Cloud Storage Providers: For storing your data securely (e.g., Supabase, Firebase), including optional TAP contact backups;
• Payment Processors: Google Play Billing (and other app stores when available) for in-app purchases such as Business Account and Remove Ads;
• Analytics Providers: Firebase Analytics, Google Analytics for usage analytics;
• Customer Support: Service providers that assist with customer support operations.

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.2 Legal Requirements

We may disclose your information if required by law or in response to:

• Valid legal process (subpoenas, court orders, search warrants);
• Government requests and regulatory inquiries;
• Legal obligations to protect rights, property, or safety;
• Emergency situations involving immediate danger to life or physical safety.

4.3 Business Transfers

If Neverhold is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your information.

4.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing. You (or a first responder using lock-screen Send after you enabled TAP Medical ID on the lock screen) may also initiate sharing with people you choose:

• TAP / Æther cards: Fields you select are sent to the nearby or remote recipient who accepts the card;
• Medical ID .tapcard / NFC: Medical fields you entered are shared only when you (or lock-screen Send / NFC arm) start a medical share from the Emergency / Medical ID hub — not as part of ordinary TAP card exchange;
• Emergency SMS: The lock-screen message is sent by SMS to the emergency-contact numbers on your Medical ID. TAP does not send SMS to your general inbox, marketing lists, or people you did not designate;
• TAP / Neverhold Message Center: If a designated contact has a TAP or Neverhold account whose verified phone matches, we deliver a copy of that emergency message to their in-app Message Center. We do not insert a copy for the sender.

4.5 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for research, analytics, or business purposes.

5. TAP Medical ID, emergency SMS, NFC, and .tapcard

This section applies to TAP and to TAP Medical ID features inside Neverhold. It is optional and is not required to exchange ordinary TAP cards.

5.1 What you enter

TAP Medical ID is information you type yourself (conditions, medications, allergies, blood type, language, and emergency contacts). We treat it as sensitive health and safety information. We do not sell it, use it for advertising, or include it on a TAP card unless you start a medical share from the Emergency / Medical ID hub.

5.2 Lock screen and emergency SMS (Android)

If you enable TAP Medical ID on the lock screen, TAP can show a lock-screen entry so a first responder can view fields you entered, show a QR, arm NFC, and send an alert. The Android notification used to reach that screen does not include your medical conditions, medications, or allergies.

TAP requests the Android SMS permission so a first responder can send one emergency message to your designated Medical ID contacts only without TAP becoming the default SMS app. TAP does not request READ_SMS or RECEIVE_SMS and does not read your message inbox. We do not send marketing, bulk, or account-verification SMS through this permission. Inviting someone to install TAP uses the system Share sheet, not SEND_SMS. On devices without a cellular radio (for example many Wi‑Fi tablets), TAP may open the system Messages composer instead of sending silently.

The same message may also be delivered in-app to TAP / Neverhold users whose verified phone number matches a designated contact. Recipients see it in Message Center as an emergency, not as a dump of their device SMS inbox.

5.3 NFC

You must arm NFC from the Emergency hub. TAP cannot turn the NFC radio on for you; if it is off, we open Android NFC settings and retry when you return. Armed NFC shares a short-lived Medical ID payload (typically a few minutes) with a nearby reader or phone.

5.4 Sharing and receiving a medical .tapcard

A medical .tapcard can be shared in person (TAP / NFC) or as a file. Recipients can view or delete a received Medical ID; they cannot edit the origin copy. Saving a later ordinary TAP card from the same person does not wipe Medical ID already stored. If the owner sends a new medical .tapcard, saving it replaces the stored Medical ID for that origin card.

5.5 Retention and deletion

On-device Medical ID stays until you edit or delete it or delete your account. Emergency Message Center copies follow the same retention as other in-app messages until the recipient deletes them or the account is deleted. SMS that left the device lives with the mobile carrier of each recipient, not in a TAP SMS archive.

6. Call Recording

If you enable call recording features:

• We store recorded calls securely on our servers or your device (depending on your settings);
• Recorded calls are encrypted and accessible only to you (unless you share them);
• You are responsible for complying with applicable call recording laws and obtaining consent from all parties where required;
• You can delete recorded calls at any time through the App;
• We retain recorded calls according to your settings or until you delete them.

7. Data Security

We implement reasonable technical and organizational measures to protect your information, including:

• Encryption: Data in transit is encrypted using TLS/SSL, and sensitive data at rest is encrypted;
• Access Controls: Limited access to personal information on a need-to-know basis;
• Secure Storage: Information stored on secure servers with appropriate access controls;
• Regular Security Audits: Periodic security assessments and vulnerability testing;
• Incident Response: Procedures to detect, respond to, and mitigate security incidents.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

8. Your Rights and Choices

8.1 Access and Correction

You have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Update your account information through the App settings.

8.2 Deletion

You can request deletion of your personal information by:

• Deleting your account through the App settings;
• Contacting us at support@neverhold.co with a deletion request.

We will delete your information subject to legal retention requirements and our need to maintain certain records for legitimate business purposes.

8.3 Data Portability / Request my data

In Neverhold Lite (com.neverhold.dialer): Settings → About → Request my data exports a free PDF and/or JSON package (local-first). Categories and third parties in that package match this policy’s Neverhold Lite lists below. Under CCPA/CPRA § 1798.130(b), we are not obligated to regenerate more than twice in 12 months; re-sharing the last local package is unlimited. You may also email support@neverhold.co.

8.3a Neverhold Lite — CCPA categories (aligned with Request my data)

App: Neverhold Lite dialer (com.neverhold.dialer). TAP has a separate policy.

Categories collected:

• Identifiers (account id, email, phone, username)
• Customer records / profile
• Call information (call logs, numbers, duration, timestamps) for dialer features
• Contacts on device (caller ID / Æther People)
• Internet / network activity
• Geolocation (Nearby/TAP exchange on some Android versions; IP for fraud)
• Professional / employment-related (card fields)
• Inferences (loyalty tier)
• Sensitive personal information — Medical ID you enter (optional)
• Commercial information (purchases, entitlements, loyalty)

Sources: you; your device (call log, contacts, app state); auth providers (Supabase Auth + Twilio); Google Play Billing; optional Google/Microsoft/iCloud Business Account connects; app stores.

Purposes: dialer and call management; TAP/Æther cards and exchange; account auth; loyalty; purchases; Medical ID / emergency SMS you enable; support and security; ads unless ad-free; backups you choose.

Third parties / processors: Supabase; Twilio; Google Play Billing; Google AdMob (unless ad-free); Firebase Crashlytics / Analytics / Performance as enabled; Google / Microsoft / Apple when you use those sign-in or Business Account sync; OS share targets you choose; carriers for SMS you send.

We do not sell personal information.

8.4 Opt-Out Rights

You can opt-out of:

• Marketing Communications: Unsubscribe from marketing emails through the unsubscribe link or App settings;
• Firebase Analytics: Analytics collection is enabled in production. To limit analytics, you can use your device settings (e.g., opt out of personalized ads) or contact us to disable Analytics for your account;
• Advertising (AdMob): Use your device settings to opt out of personalized ads (Settings → Google → Ads → Opt out of Ads Personalization) or use AdChoices where available;
• Location / Nearby: TAP may request Nearby, Bluetooth, Wi‑Fi, and (on some Android versions) location for card exchange only. You can deny those permissions in system settings; exchange may then fail. Approximate location inferred from IP cannot be opted out of at the device level;
• Google / Microsoft sign-in: You can use email instead, or disconnect a connected mailbox under Business Account in the App;
• Cloud backup: You can skip backup, or delete stored backups by deleting your account;
• TAP Medical ID / emergency SMS: You can leave Medical ID blank, turn off lock-screen Medical ID, revoke SMS permission, and delete received Medical ID cards. Emergency SMS still depends on the carrier once a message is sent.

8.5 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of categories and specific pieces of personal information we collect, use, and share;
• Right to Delete: Request deletion of your personal information (subject to exceptions);
• Right to Opt-Out: Opt-out of the sale of personal information (we do not sell your information);
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights;
• Right to Correct: Request correction of inaccurate personal information;
• Right to Limit Use of Sensitive Information: Request limits on the use of sensitive personal information.

To exercise these rights, use Request my data in Neverhold Settings (or TAP About), or contact us at support@neverhold.co.

Privacy Policy last updated: August 29, 2026 (CCPA category alignment with in-app export).

8.6 Canadian Privacy Rights (PIPEDA)

If you are a Canadian resident, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA):

• Right to Access: Request access to your personal information;
• Right to Correction: Request correction of inaccurate information;
• Right to Withdraw Consent: Withdraw consent for collection, use, or disclosure of your information (subject to legal and contractual restrictions);
• Right to File a Complaint: File a complaint with the Privacy Commissioner of Canada if you believe we have violated your privacy rights.

8.7 Mexican Privacy Rights (LFPD)

If you are a resident of Mexico, you have rights under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPD), including ARCO rights:

• Access (Acceso): Request access to your personal information we hold;
• Rectification (Rectificación): Request correction of inaccurate or incomplete information;
• Cancellation (Cancelación): Request deletion of your personal information when you consider it is not being used properly. Our account deletion process implements this right—see our Account Deletion page;
• Opposition (Oposición): Object to the processing of your personal information for specific purposes;
• Revocation of Consent: Revoke consent you have given for the processing of your data (subject to legal and contractual restrictions);
• Right to File a Complaint: File a complaint with the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI) at www.inai.org.mx if you believe we have violated your privacy rights.

To exercise these rights, contact us at support@neverhold.co or privacy@neverhold.co.

9. Data Retention

We retain your personal information for as long as necessary to:

• Provide the Services to you;
• Comply with legal obligations;
• Resolve disputes and enforce our agreements;
• Maintain security and prevent fraud.

When you delete your account, we will delete or anonymize your personal information within a reasonable timeframe, except where we are required to retain it for legal or legitimate business purposes. That includes OAuth sessions, Gmail / Exchange / iCloud tokens you connected, TAP cloud backups, loyalty balance, and entitlements tied to the account. Emergency SMS already delivered to carriers cannot be recalled.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, where data protection laws may differ. We ensure that such transfers comply with applicable data protection laws by:

• Using standard contractual clauses approved by relevant data protection authorities;
• Implementing appropriate safeguards to protect your information;
• Complying with applicable data protection laws, including GDPR where applicable.

11. Children's Privacy

The Services are not intended for children under 13 years of age (or 16 in the European Economic Area). We do not knowingly collect personal information from children under 13 (or 16 in the EEA). If you believe we have collected information from a child, please contact us immediately, and we will delete such information.

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Remember your preferences and settings;
• Analyze usage patterns and improve the Services;
• Provide personalized content and advertisements (with your consent).

You can control cookies through your device or browser settings, though this may affect some features of the Services.

13. Third-Party Links and Services

The Services may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you access.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated Privacy Policy on our website and in the App;
• Updating the "Last Updated" date;
• Sending you an email notification (if you have provided an email address);
• Displaying an in-app notification requiring you to review and accept the updated policy.

Your continued use of the Services after changes become effective constitutes your acceptance of the updated Privacy Policy.

15. Contact Us

16. Data Safety Information (Google Play)

In compliance with Google Play Store Data Safety requirements, we disclose the following. Play Console forms for TAP vs Neverhold differ slightly (TAP does not collect voicemail / call recordings). User-initiated Medical ID / TAP-card / emergency-SMS sharing is described in this Privacy Policy; it is not sold and is not used for advertising. Health information and emergency SMS are never used for ads. AdMob uses device identifiers on the free tier unless you have Remove Ads or Business Account.

Data Type	Collected	Shared (third party)	Purposes	Required/Optional
Name	Yes	No	App functionality, Account management	Required
Email address	Yes (including from Google or Microsoft sign-in)	No	Account management, App functionality, Developer communications	Required
Phone number	Yes	No	App functionality, Account management, Call management, emergency contacts. Verified only after SMS/voice OTP — not from Google/Microsoft profile	Required for account; emergency contacts optional
User IDs	Yes	No	App functionality, Account management	Required
Photos (profile / TAP card)	Yes	No	App functionality, Personalization	Optional
Health info (TAP Medical ID)	Yes (user-entered)	No (third parties); user-initiated share only	App functionality (emergency Medical ID)	Optional
SMS messages (send / emergency copy)	TAP sends SMS; in-app copy if recipient is a TAP/Neverhold user	No advertising partners	App functionality (emergency alerts to designated contacts)	Optional (lock-screen Medical ID)
Approximate location	TAP Nearby / some Android versions	No	App functionality (TAP discovery only — not Medical ID GPS tracking)	Optional
Other user content (contact backup / mailbox sync)	Yes if you enable backup or Business Account sync	No advertising partners	App functionality	Optional
Voice or sound recordings	Yes (Neverhold only)	No	App functionality (voicemail, call recording)	Optional
Contacts	Yes (with permission)	No	App functionality (caller ID, TAP cards, optional Gmail/Exchange/iCloud sync)	Optional
App interactions	Yes	Yes (Google)	Analytics	Optional
Crash logs	Yes	Yes (Google)	Analytics, App functionality	Optional
Diagnostics	Yes	Yes (Google)	Analytics	Optional
Device or other IDs	Yes	Yes (Google/AdMob)	Analytics, Advertising or marketing	Optional
Purchase history	Yes	No	App functionality	Required (for subscription users)

Security practices:

• Data is encrypted in transit (TLS). TAP Medical ID on device is stored with the app; emergency Message Center copies on our servers are access-controlled (row-level security). Cloud contact backups are stored under your user id in our storage bucket.
• Users can request deletion of their data via account deletion or by contacting support@neverhold.co.

By using Neverhold, you acknowledge that you have read and understood this Privacy Policy.