Privacy policy‍ ‍

Last updated: 25 August 2026

Introduction

EMBO is a brand operated by UNCIA HOLDINGS LLC, a Wyoming limited liability company (“UNCIA”, “we”, “us”, “our”). This Privacy Policy explains how we collect, use, disclose and protect personal information in connection with:

• the website and online store at www.embonow.com, which is powered by Squarespace;

• the EMBO handheld device (the "Device"); and

• the EMBO application for Apple iOS (the "App").

We refer to these together as the “Services”. Capitalised terms used in this Privacy Policy and not defined in it have the meaning given to them in our Terms of Service.

If there is a conflict between our Terms of Service and this Privacy Policy, this Privacy Policy governs the collection, processing and disclosure of personal information.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

Summary

The most important things to know are these.

• The website and store collect the information you would expect an online store to collect: your name, contact details, delivery address, order history, and technical information about your visit.

• The App works differently. It is designed so that information about which applications you choose to shield, how you configure them, and what you do when a shield appears, stays on your iPhone. We do not collect it, and we cannot see it.

• We do not sell your personal information for money, and we do not share anything obtained through Apple’s Screen Time technologies with anyone, for any purpose. The advertising tools on our website may amount to “sharing” for advertising under some state privacy laws, and you can opt out of that at any time (see Section 18.3).

Part A of this policy covers the website and store. Part B covers the App. Part C covers matters that apply to both.

1. Who we are and how to contact us

UNCIA HOLDINGS LLC, a Wyoming limited liability company trading as EMBO, is the controller of the personal information described in this policy.

UNCIA HOLDINGS LLC (trading as EMBO)

1032 E Brandon Blvd #7181

Brandon, FL 33511

United States

Email: procurement@unciaholdings.com

Telephone: +34 699 025 773

Business Registration Number (EIN): 32-0835976

Part A: The website and online store

2. Personal information we collect through the website

"Personal information" means information that identifies, relates to, describes, or can reasonably be linked to you. It does not include information that is anonymised or de-identified so that it cannot reasonably be linked to you.

Depending on how you interact with the website, we may collect or process the following categories of personal information:

• Contact information, including your name, email address, telephone number, billing address and shipping address.

• Transaction and order information, including products viewed, added to cart, purchased, returned, exchanged or cancelled, order history and timestamps.

• Payment information, including payment method type, transaction confirmations, and tokens generated by our payment processors. We do not store full payment card numbers.

• Account information, including preferences, saved items and settings, if you create an account.

• Activation Code records, including which code was issued against which order, so that we can support you and detect misuse.

• Communications, including messages, emails, reviews, survey responses and support enquiries.

• Device and technical information, including IP address, device identifiers, browser type, operating system, network information, and approximate location derived from IP address.

• Usage and interaction data, including pages viewed, time spent on pages, links clicked, referring and exit pages, and interactions with site features.

• Marketing and advertising data, including engagement with our advertisements and marketing communications, and attribution data, where permitted by law.

3. Health-related information

We do not ask for health information, and we do not want to receive it. Please do not send us information about your health.

If you choose to tell us something about your health, for example when asking a support question about whether the Device is suitable for you, we will use that information only to answer your enquiry, we will retain it with your support correspondence, and we will not use it for marketing, profiling, advertising or any other purpose.

4. Sources of personal information

• Directly from you, when you browse the site, place an order, create an account, contact support, subscribe to marketing communications, or otherwise interact with us.

• Automatically, through cookies, pixels, tags and similar technologies, when you access or use the website.

• From service providers that support our business operations, such as payment processors, hosting providers, analytics providers, fulfilment partners, fraud prevention services, customer support platforms and marketing tools.

• From advertising and analytics partners, where permitted by law.

5. How we use personal information

• To provide and operate the Services, including processing payments, fulfilling orders, shipping products, issuing and validating Activation Codes, managing accounts and providing customer support.

• To communicate with you, including order confirmations, shipping updates, customer service responses, product safety or recall notices, and administrative messages.

• To market our products and Services, including sending promotional messages where permitted, personalising content, and measuring advertising performance. You may opt out at any time.

• To analyse and improve our business, including understanding how customers use the website, measuring performance, and troubleshooting issues.

• To protect the security and integrity of the Services, including detecting and preventing fraud, Activation Code misuse and unauthorised access.

• To comply with legal obligations, enforce our Terms of Service, respond to lawful requests, and protect the rights, property and safety of our customers, of third parties and of our business.

6. Cookies, tracking technologies and advertising

6.1 We and our partners use cookies, pixels, tags and similar technologies on the website to operate it, analyse performance, personalise content and measure the effectiveness of advertising.

6.2 These may include Squarespace analytics and reporting tools; advertising and analytics services provided by Meta Platforms and by Google; and email and messaging platforms used to send transactional and marketing communications and to measure engagement.

6.3 These providers may collect or receive information about your interactions with the website, including device and usage data, subject to their own privacy policies.

6.4 You can control cookies through your browser settings and, where available, through our cookie preference tool. Disabling cookies may affect how parts of the site work.

6.5 If your browser or device sends a Global Privacy Control signal, we will treat it as a request to opt out of any sale or sharing of personal information for cross-context behavioural advertising, where required by applicable law.

6.6 The App does not use cookies, advertising software, attribution software or third-party analytics. See Part B.

7. How we disclose personal information

We may disclose personal information in the following circumstances:

• To Squarespace, which hosts our store and provides core e-commerce infrastructure and related services.

• To service providers that perform services on our behalf, such as payment processing, order fulfilment, shipping, customer support, analytics, marketing, fraud prevention, cloud storage and communications.

• To advertising and marketing partners, for the purpose of delivering and measuring advertising, subject to applicable law and to your choices.

• To professional advisers, such as lawyers, accountants, auditors and insurers, where necessary.

• To comply with legal obligations, to respond to lawful requests, to enforce our Terms of Service, or to protect the rights, property or safety of any person.

We do not sell personal information for money. Some of the advertising activity described in Section 6 may constitute “sharing” for cross-context behavioural advertising under certain state privacy laws, and you can opt out as described in Section 18.3. We do not disclose to any third party any information obtained through Apple’s Screen Time technologies. See Section 12.

8. Relationship with Squarespace

The website and store are hosted by Squarespace. Squarespace processes personal information relating to your access to and use of the store in order to provide and improve its services and may act as an independent controller for certain processing activities relating to its platform features. Information you submit may be transmitted to and processed by Squarespace in countries other than your country of residence.

Part B: The EMBO app

9. The App is designed to keep your information on your device

9.1 The App is free to download. It does not require you to create an account, provide an email address, or set a password.

9.2 The App does not contain any third-party advertising, attribution or analytics software.

9.3 The App does not send your app selections, block settings, shield activity or usage statistics to us or to anyone else. That information is stored on your iPhone.

10. Apple Screen Time, and how app selection works

10.1 The App uses Apple's Screen Time technologies, including the Family Controls, ManagedSettings and DeviceActivity frameworks, so that you can choose applications to limit and so that iOS can display a system shield when you open them.

10.2 We request Screen Time access for your own device only, using individual authorization. We do not request or use authorization to supervise or manage another person's device.

10.3 When you choose which applications to flag, you do so through a selection interface provided by Apple. Apple does not give us the names or identities of the applications you choose. Instead, each selection is represented by an opaque token generated by Apple. That token cannot be used by us, or by any third party, to determine which application it refers to, and it has no meaning outside your device. This is a deliberate privacy protection built into Apple's technology, and it means that we do not know, and cannot find out, which applications you have chosen to shield.

10.4 The App may display usage-style statistics, such as screen time or pickups, using Apple's on-device reporting technology. Where it does so, that information is rendered on your screen by Apple's software. It is displayed to you; it is not stored by us and it is not transmitted off your device.

10.5 You can revoke Screen Time authorization at any time in iOS Settings. If you do, shielding and the features that depend on it will stop working.

11. Information the App stores on your device

The following is stored locally on your iPhone, in the App's own storage, in a shared app group used by the App and its Screen Time extensions, and in some cases in the device keychain. None of it is transmitted to us:

• Activation status, including whether the App has been activated and when.

• The Activation Code you enter, which is checked against a list included in the App itself. No code is sent to a server for validation.

• Onboarding and permission status, such as whether you have completed onboarding and granted Screen Time authorization.

• Your application selections, represented as the opaque Apple tokens described in Section 10.

• Your block configuration, including whether a block is total or partial, schedules, wait times and unlock durations.

• Shield activity, such as how many times a shield was shown and whether you chose to pause or to open the application anyway.

• Temporary state, such as wait timers and temporary unlock windows.

• Any goals you set.

• Summary statistics used to draw your dashboard.

Educational articles shown in the App are content that we supply. They are not information about you.

12. Our commitment regarding Screen Time data

We do not sell, rent, license, trade or otherwise disclose to any third party any data obtained through Apple's Family Controls, ManagedSettings or DeviceActivity frameworks, for any purpose. We do not use that data for advertising, marketing, profiling, audience building, or sale to data brokers, and we do not permit any third party to do so. This commitment applies notwithstanding any other provision of this Privacy Policy.

13. Notifications

If the App sends you reminders or summaries, these are local notifications generated on your device. iOS will ask for your permission before any notification is shown, and you can turn notifications off at any time in iOS Settings.

14. If this changes

Part B describes how the App works today. If a future version of the App sends any of this information off your device, for example to provide backup, synchronisation or an account, we will update this Privacy Policy, describe clearly what is being sent and why, and, where required by law or by Apple, ask for your consent before doing so.

Part C: General

15. Retention

15.1 We keep order and transaction records for as long as necessary to fulfil the order and provide support, and thereafter for as long as required for tax, accounting, warranty, product safety and legal purposes.

15.2 We keep support correspondence for as long as necessary to resolve your enquiry and to maintain a record of it.

15.3 We keep marketing contact details until you unsubscribe, and we then keep a suppression record so that we do not contact you again.

15.4 Information stored by the App on your device remains there until you clear it within the App or delete the App. Deleting the App removes its local data. Revoking Screen Time authorization in iOS Settings removes the shields.

16. Security

16.1 We implement administrative, technical and physical safeguards designed to protect personal information, and we require our service providers to do the same.

16.2 Information held by the App is protected by the security of your iPhone, including the application sandbox, the app group shared by the App and its extensions, and the device keychain. Keeping your device locked, updated and physically secure is an important part of protecting that information.

16.3 No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

16.4 We will never ask you for your Apple Account password or your Screen Time passcode. If you receive a message that appears to come from us asking for either, it is not from us.

17. Children

17.1 The Services are not directed to children. You must be 18 or over to purchase from us or to agree to our Terms of Service. The Device and the App are intended for people aged 16 or over.

17.2 We do not knowingly collect personal information from children under 13. If you believe that a child under 13 has provided us with personal information, please contact us and we will delete it.

17.3 The App is not a parental control product and is not designed for supervising another person's device.

18. Your choices and rights

18.1 Marketing. You can unsubscribe from marketing emails using the link in any message, or by contacting us. We will still send you transactional and service messages relating to your orders, your warranty and product safety.

18.2 Access, correction and deletion. You may ask us for a copy of the personal information we hold about you, ask us to correct it if it is inaccurate, or ask us to delete it. We may need to verify your identity before we act on a request, and we may need to retain some information where the law requires it.

18.3 United States state privacy rights. Several US states give residents rights over their personal information. Whether or not those laws currently apply to us, as a matter of policy we will honour requests to access, correct, delete or obtain a copy of personal information, and requests to opt out of any sale or sharing of personal information, from residents of any US state. We do not sell personal information for money. Some of the advertising activity described in Section 6 may constitute “sharing” for cross-context behavioural advertising under certain state privacy laws, and you may opt out by contacting us or by sending a Global Privacy Control signal as described in Section 6.5. We do not knowingly sell or share the personal information of anyone under 16. We will not discriminate against you for exercising your rights.

18.4 Opt-out preference signals. Where required by applicable law, we honour the Global Privacy Control signal as described in Section 6.5.

18.5 Cookies. You can manage cookies through your browser settings and, where available, through our cookie preference tool.

18.6 The App. You control the App's information directly. You can clear it within the App, revoke Screen Time authorization in iOS Settings, or delete the App from your device.

18.7 How to make a request. Contact us using the details in Section 1. We will respond within 45 days, and will tell you if we need more time.

19. International users

19.1 The Services are directed to customers in the United States. We do not sell to, or offer the Services to, customers outside the United States, including residents of Canada, the European Economic Area and the United Kingdom.

19.2 We are based in the United States, and any information we collect is stored and processed in the United States. If you access the Services from another country, you do so on your own initiative.

20. Third-party links

The Services may contain links to third-party websites and platforms, including the Apple App Store. We are not responsible for the privacy practices or the content of those third parties. Please review their privacy policies before providing personal information to them.

21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any change will be posted on this page with an updated "Last updated" date. Where a change is material, we will make reasonable efforts to notify you in advance, for example by email or by a notice on the website or in the App.

22. Contact

If you have questions about this Privacy Policy or our privacy practices, or wish to exercise your rights, contact us at:

UNCIA HOLDINGS LLC (trading as EMBO)

1032 E Brandon Blvd #7181

Brandon, FL 33511

United States

Email: procurement@unciaholdings.com

Business Registration Number (EIN): 32-0835976