Privacy Policy

1. Introduction

Staten Holdings LLC dba Trembli is committed to protecting the privacy of every person who uses our service. This Privacy Policy explains what information we collect, why we collect it, how we protect it, and your rights under applicable law — including the Maryland Online Data Privacy Act, effective October 1, 2025.

This policy applies to seniors who text with our AI companion "Tremi," to the family members and caregivers who use our dashboards, and to visitors of trembli.com.

2. Information We Collect

We collect only the categories of information listed below. We do not collect location data, browsing history, or device identifiers beyond what is necessary to operate the service.

• Contact information — phone numbers and email addresses.
• Identity information — first and last names of seniors and family members.
• Health-adjacent information — medication names, dosages, and schedules that seniors provide voluntarily during conversations with Tremi.
• Conversation history — messages exchanged with Tremi. Conversations are private to the senior only and are not visible to family members.
• Family information — names and relationships of family members shared by the senior.
• Wellness indicators — activity and engagement data (e.g., last contact time, message frequency) used to generate wellness signals for family dashboards.
• Payment information — billing data processed securely by Stripe. We do not store full card numbers on our servers.
• Technical information — IP addresses and basic usage data captured in server logs.

3. Why We Collect This Information

We use the information above for the following purposes:

• To provide the Tremi companion service and maintain natural, personalized conversations.
• To send reminders and check-ins requested by the senior.
• To give family members wellness updates through the family dashboard.
• To detect distress in conversations and alert caregivers when appropriate.
• To process payments and manage subscriptions.
• To improve the reliability and quality of the service over time.
• To comply with legal obligations and enforce our Terms of Service.

We do not use your information for advertising, profiling, or sale to third parties.

4. Sensitive Data

Sensitive data is never shared with family members without the senior's explicit consent, except in Level 3 and Level 4 distress situations, where a real-time safety alert may include enough detail to allow caregivers to respond appropriately.

Seniors may revoke consent at any time by texting Tremi or by submitting a request at trembli.com/data-request.

5. Who We Share Information With

We share the minimum data necessary with the following service providers, each governed by a Data Processing Agreement:

• Twilio — SMS delivery. Transmits messages between seniors and our service.
• Anthropic — AI processing. The Claude model powers Tremi's conversations.
• Stripe — payment processing. Handles billing for subscription plans.
• Railway — cloud hosting and database infrastructure.

We may disclose information if required by valid legal process (e.g., a subpoena or court order) or to prevent imminent harm to a person's safety.

6. How Long We Keep Your Information

We retain different categories of data for different periods based on their operational purpose:

• Conversation history — 12 months.
• Account information — until deletion is requested.
• Payment records — 7 years (required for tax and financial compliance).
• Wellness indicators — 24 months.
• Data request records — 3 years (required to demonstrate compliance).

When retention periods expire, records are deleted automatically or anonymized.

7. Your Privacy Rights under the Maryland Online Data Privacy Act

If you are a Maryland resident, you have the following rights with respect to your personal information:

• Right to Know — request confirmation of whether we process your personal data and a copy of that data.
• Right to Delete — request that we delete personal data we hold about you.
• Right to Correct — request that we correct inaccurate information.
• Right to Opt Out — opt out of the processing of your data for targeted advertising, sale, or profiling (we do not engage in any of these, but you may still opt out of general processing).
• Right to Non-Discrimination — we will never penalize you for exercising any of these rights.

To exercise these rights, visit trembli.com/data-request or email ahmad@trembli.com. We will respond to verified requests within 30 days as required by Maryland law.

8. Data Security

We use industry-standard safeguards to protect your information:

• HTTPS transmission — all web traffic uses TLS 1.2 or higher.
• Encrypted storage — the database is encrypted at rest.
• Access controls — dashboards are password-protected and role-based. Only authorized staff can access personal data.
• Anonymous Trembli IDs — every senior is assigned a private identifier (e.g., TR-ABCD-EFGH) so our systems can operate without exposing names.
• Regular reviews — we review our security controls and provider agreements on a regular cadence.

No method of transmission or storage over the internet is 100% secure, but we take meaningful steps to minimize risk.

9. Children

Trembli is not intended for use by persons under the age of 18. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal data, please contact us immediately and we will delete it.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will update the "Last updated" date at the top of this page and notify active users via SMS.

Continued use of Trembli after changes are posted constitutes acceptance of the updated policy.

11. Contact Us

Trembli is operated by Staten Holdings LLC (doing business as Trembli), based in Bowie, Maryland.

• Email: ahmad@trembli.com
• Privacy requests: trembli.com/data-request
• Mail: Staten Holdings LLC, Bowie, Maryland

We respond to all privacy inquiries within 30 days.