Effective date: July 4, 2026
Applies to: Talking Tags (iOS app) and cometassociates.com
Summary
Comet Associates does not collect, store, sell, or share personal data about you. Talking Tags has no servers, no user accounts with us, and no analytics or tracking. Your tag library is stored on your device and synced privately through your own iCloud account using Apple's CloudKit and SwiftData frameworks. We never see it.
The rest of this document explains exactly what that means under U.S., California, European, and other privacy laws.
1. Who we are
Comet Associates ("we," "us," "our") is the developer and publisher of the Talking Tags iOS app and the website cometassociates.com (together, the "Services"). You can reach us at privacy@cometassociates.com.
2. Information we collect
2.1 Information collected by the app
Talking Tags does not collect any personal information from you. When you use the app:
- The names, descriptions, audio recordings, and other details (such as notes, links, and custom fields) you assign to your NFC tags are stored on your device using Apple's SwiftData framework.
- If you have iCloud sync enabled, that data is synced to your private iCloud account using Apple's CloudKit framework. It is encrypted in transit and at rest under Apple's standard CloudKit security model. We do not have access to it.
- The app reads NFC tag identifiers locally on your device. We do not transmit tag data anywhere.
- We do not use third-party analytics, advertising SDKs, crash-reporting services that collect personal data, or any tracking technologies.
- If you tap Subscribe to Newsletter (in Settings, or on the final onboarding screen), the app simply opens our newsletter sign-up page in your browser. The app itself collects no email address and sends us nothing; any sign-up happens on the website, as described in Section 2.2.
2.2 Information collected by the website
The cometassociates.com website does not use cookies, set tracking pixels, or run analytics. If you email us using one of the addresses on this site, or submit the contact form, we receive your message and email address through our email provider and use them only to respond to you.
Newsletter sign-up. If you choose to subscribe to the Talking Tags newsletter, we collect the email address you enter on our sign-up page and provide it to our email service provider, Kit (formerly ConvertKit), which stores it and sends you the newsletter on our behalf. Sign-up uses double opt-in: you must confirm your address by clicking a link in a confirmation email before you receive anything, so no one can add you without access to your inbox. We use your address only to send Talking Tags news and updates — we do not sell it, share it beyond Kit, or use it for any other purpose. You can unsubscribe at any time using the link at the bottom of any newsletter email, which removes you from the list. Subscribing is entirely optional and separate from using the app.
2.3 Information Apple may collect
Distribution of Talking Tags through the Apple App Store and use of CloudKit and SwiftData are governed by Apple's own privacy practices. Apple may collect information related to your App Store account, downloads, and usage of iCloud features. That collection is between you and Apple. See Apple's Privacy Policy.
3. How we use information
Because we do not collect personal data through the app, there is no personal data for us to use, profile, sell, or analyze. If you contact us by email, we use your message and email address solely to respond to your inquiry, and we delete the conversation when it is no longer needed.
4. Sharing and disclosure
We do not sell, rent, or trade any personal information, and we have no ad partners or data brokers. Apart from the opt-in newsletter described in Section 2.2, we do not maintain a marketing list. The only third parties involved in the operation of the Services are:
- Apple Inc. — for app distribution, CloudKit/SwiftData sync, and standard iOS frameworks.
- Our hosting and email providers — for serving the website and receiving emails you send to us. These providers process technical data (such as IP addresses) only as needed to deliver their services and do not receive your tag library.
- Kit (formerly ConvertKit) — our email service provider, used only if you subscribe to our newsletter. It stores the email address you provide and sends you the newsletter on our behalf; it does not receive your tag library. See Kit's Privacy Policy.
We may disclose information if required to do so by law, valid legal process, or to protect against fraud or harm — but as a practical matter, we have very little information to disclose.
5. Children's privacy
Talking Tags is a general-audience accessibility utility. It is not directed at children under 13, and we do not knowingly collect personal information from children. If a parent or guardian believes a child has provided us with personal information, please email privacy@cometassociates.com and we will delete it.
6. Your rights
6.1 California (CCPA / CPRA)
California residents have the right to request access to, deletion of, and correction of personal information we hold; to opt out of "sale" or "sharing" of personal information; and not to be discriminated against for exercising those rights. Because we collect little personal information — only an email address if you contact us or opt into our newsletter, which we never sell or share beyond the service providers who deliver it — in practice there is very little for us to disclose, delete, or correct, but you may still send a verifiable request to privacy@cometassociates.com and we will respond.
6.2 European Economic Area, U.K., and Switzerland (GDPR / UK GDPR)
If you are in the EEA, U.K., or Switzerland, you have rights of access, rectification, erasure, restriction, portability, and objection regarding personal data we control about you, and you may withdraw consent at any time. Since we do not collect personal data from app users, in practice these rights apply only to email correspondence you initiate with us and to a newsletter subscription you opt into. Our legal basis for processing such email is your consent (for the newsletter, which you may withdraw at any time by unsubscribing) and/or our legitimate interest in responding to your inquiry. You may also lodge a complaint with your local data protection authority.
6.3 Other jurisdictions
Residents of other U.S. states with privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas, and others) have analogous rights. Send any request to privacy@cometassociates.com.
7. Data deletion and account closure
Talking Tags has no Comet Associates account to delete — there is no sign-up and no server-side profile. You can clear your tag library at any time:
- From the app: Settings → Reset & Delete All Data.
- From iCloud: Settings app → [your name] → iCloud → Manage Account Storage → Talking Tags → Delete Data.
- By email: Send a deletion request to privacy@cometassociates.com and we will delete any email correspondence we have with you.
- Newsletter: If you subscribed to the newsletter, unsubscribe using the link at the bottom of any newsletter email — or email us — to be removed from our email service provider.
See Manage Your Data for step-by-step instructions.
8. Security
Tag data on your device is protected by iOS's standard data protection. Data synced through CloudKit is encrypted in transit and at rest under Apple's standard CloudKit security model. Because we never receive your data, our security obligations are limited to protecting our own email systems and website infrastructure.
9. International data transfers
If you contact us by email and you are located outside the United States, your message will be transferred to and processed in the United States, where our email provider operates. By emailing us, you consent to that transfer.
10. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the effective date above and, if the changes are material, post a notice on this page and on the Talking Tags App Store listing. Your continued use of the Services after a change indicates your acceptance of the updated policy.
11. Contact
If you have questions about this Privacy Policy or how Talking Tags handles your information, please contact us:
- Email: privacy@cometassociates.com
- Mail: Comet Associates, [Mailing address — to be added before launch], USA