SRW GROWTH MANAGEMENT
Privacy, explained.
Updated September 21, 2026
SRW Growth Management operates this company website and is developing Paloma. For a privacy question or request, contact seanryan@wolfingtons.com.
This website and your inquiries
This website presents our consulting, web development, and product work. We have not added advertising trackers, analytics scripts, signup forms, or account registration. The website does not collect your conversation answers or connect to Paloma’s app services.
Our hosting service may process technical information, such as IP addresses and request details, to deliver the pages and protect the website. We do not promise that the hosting provider keeps no logs.
Our hosting platform uses Cloudflare security technologies, including the __cf_bm cookie, to help distinguish automated traffic from normal visits. This is a hosting security cookie, not a Paloma sign-in session. The platform manages its settings and lifetime.
If you email us, we receive your email address, message, and any attachments you choose to send. We use that information to respond to your inquiry, provide requested support, and discuss or carry out work with you. Correspondence may be handled by our email provider and the people responsible for responding. Please avoid sending sensitive personal or financial information.
We keep correspondence for the time needed to handle the inquiry and related work, resolve issues, or meet applicable recordkeeping obligations. You may ask us to delete information you sent; we will explain any information that needs to be retained. No automatic deletion deadline for email is promised.
The Paloma link leads to a separate website with its own waitlist and privacy information. Information submitted there is covered by that website’s notice.
Paloma: pre-release privacy information
Paloma has not been publicly released. The following describes its development design, including optional services that may be unavailable in a particular preview. The release privacy notice will be updated to match the services, provider settings, and regions actually enabled before external distribution.
Conversations and on-device information
Paloma does not provide a place to enter your answers or record what you say. Its core card experience does not require a named Paloma account. Saved questions, named sets, progress, conversation history, preferences, and reminders are stored on your iPhone. There is no Paloma account-based synchronization of this content. Device backup settings may still apply.
When you deliberately share a card, the app or destination you choose receives that content. Its own privacy practices apply. Deleting Paloma data cannot remove copies already exported or sent elsewhere.
Optional fresh questions and OpenAI
The app is designed to ask for separate permission before requesting fresh AI questions. If you allow a request, Paloma’s service sends your chosen collection and mood, an approved topic brief, and writing instructions to OpenAI. Generated questions are also processed for quality and safety checks. To reduce repetition, a continuing session may include up to ten earlier generated questions.
Your spoken answers, private messages, saved-question library, and raw viewing history are not included in those OpenAI requests. Collection and topic choices can still reveal interests, so these requests should not be treated as automatically anonymous. OpenAI’s processing is subject to its API data controls and the account configuration used for the released service. Provider retention is not yet verified for that release.
Purchases and service access
If subscriptions are enabled, Apple handles the purchase and RevenueCat helps confirm access and restore purchases. Paloma’s backend uses a random service identity and purchase-related information to manage entitlements and usage allowances. Those identifiers are pseudonymous, not anonymous. Actual Apple purchasing is not available through this website.
Optional feedback and learning
Personal topic learning, shared learning, and deliberate rating sharing have separate permission choices in the development design. They do not follow automatically from permission to use AI. Depending on the enabled feature, data can include broad topics, bounded interaction signals, or a rating tied to a fingerprint of the question. A question fingerprint may identify a known question; this feedback is not described as anonymous.
Personal topic summaries stay on the device, except limited topic weights that may be sent to Paloma’s service when requesting fresh questions. Shared feedback uses credentials separate from purchase identity. Intimacy is excluded from passive learning, but a rating deliberately shared on an Intimacy card can still identify that question. Reports include question text only when you separately choose to include it. WhatsApp importing is not available in the current release scope.
Service providers and protection
The app’s planned online services use Cloudflare hosting, OpenAI for question generation and checks, and Apple and RevenueCat for purchasing and subscription access. Each receives only the information relevant to that service; for example, Paloma’s AI request does not contain its purchase identity or your conversation answers.
The development system uses authenticated requests and access restrictions, and encrypts temporary question-recovery results. The final provider configuration, processing locations, log and backup retention, and related agreements still need verification before online features are distributed. No claim of zero provider retention is made.
Retention and deletion design
| Information | Current development design |
|---|---|
| Saved cards, sets, and history | Stay on the iPhone until removed or included in an app-data deletion. |
| Temporary AI recovery | Becomes inaccessible after ten minutes; stored results are removed by successful scheduled cleanup. |
| Feedback, learning events, reports, and routine receipts | Generally expire after thirty days, followed by cleanup. The applicable clock depends on the feature and when information reaches the service. |
| Limited anti-abuse records | Certain hashed allowance, purchase-continuity, and revocation records may remain for thirty-one days to prevent replay or an allowance reset. |
These periods describe the development system, not verified production retention. Provider records, backups, unresolved deletion retries, and legally required records may have different periods. Those details and actual cleanup operation will be confirmed for the enabled release.
Your choices and requests
In supported builds, Settings → Privacy lets you change the available AI, feedback, and learning choices. Stopping future sharing does not recall requests that have already been processed. Settings → Delete my data clears local records and requests applicable service and provider deletion. An unfinished deletion remains pending and can retry; an acknowledgement from one service does not mean every provider or backup copy is immediately erased.
App-data deletion does not cancel an Apple subscription or restore previously deleted history. Purchase management remains separate.
For access, correction, deletion, or a privacy concern, email seanryan@wolfingtons.com. We may need enough information to verify that a request relates to you. Please do not send passwords, identity documents, or app credentials in your first message.
Paloma is intended for adults 18 and older. Age and regional access requirements will depend on the configuration approved for the release. Changes to this notice will be reflected in the date above.