Who processes your personal data?

1. The controller of your personal data isAI Touch s.r.o., a company with its registered office at Podolská 401/50, Podolí, 147 00 Praha 4, registered in the Commercial Register maintained by the Municipal Court in Prague under file no. C 404829, ID No. 216 68 736 (“InTouch” or “we”).
2. For all matters related to privacy and the collection, processing, use and storage of your personal data, please contact us at: welcome@intouch.family

What personal data do we collect?

1. Data provided during registration and account administration

   • When you set up an account with us, we may collect your contact information such as your first name, last name, email address, phone number and your address. In addition, we may also collect your log-in credentials (i.e., email and password) and billing information (e.g. your credit card details), where applicable.
   • We may collect your personal data when you communicate with us through email, telephone, chat, our social media or other communication channels, for example when you request customer support.
   • During registration, we may receive your personal data from your relative who has subscribed to our services for your benefit or on your behalf. In such case, we may process personal data about you such as your name, age, telephone number, time zone, preferred language, topics of discussion or timing of calls, and other relevant information. Your relative must ensure that you have read and understood this Privacy Policy and that you have given him or her permission to share your personal data with us for the purposes of providing you our services.

2. Data we collect when you use our services

   • We may collect your personal data when you use our services (incl. free or demo versions of our services), in particular our voice AI solution. You have full control over which personal data you decide to share with us. You are not obliged to provide your personal information during your use of the voice AI solution. However, please note that in such case you may not be able to use our services to the full extent. We will always ask you at the beginning of the first voice AI for your consent to collect and process such personal data.
   • In addition, we may with your consent collect other types of data such as voice-related data to detect e.g. blurriness of speech, clarity, and mood levels. We may also generate transcripts of your calls or collect results of any games or exercises that you have decided to take.
   • Furthermore, our services offer you the possibility to send a message to your elderly relative who communicates with our voice AI solution. We may therefore collect and process any personal data that you choose to disclose in such messages.
     Some of the personal data that we collect during your use of our services may be in limited circumstances data of sensitive character (e.g. health-related data). Please note that we will collect and process such data exclusively to provide you with our services and based on your consent. You may withdraw your consent anytime by contacting us at welcome@intouch.family
     InTouch does not share your sensitive personal data with third parties unless mandated by law or unless you authorize us to do so (this does not include our processors who provide essential services such as IT hosting, and who are bound by contractual obligations to respect your privacy and secure your data).

3. Data we collect from other sources

   • We collect information about your use and interaction with our websites, content and services (such as search history, page visits, IP address, etc.). We use cookies and other tools collect such data. The exact scope of personal data collected will depend on the specific features of the website / application / services then available and used by you and your privacy preferences. If you wish to learn more information about our use of cookies or if you wish to update your cookie preferences, please refer to our Cookie Policy.

How do we use your personal data?

1. To provide and improve our services and to develop new offerings

   • We will use your personal data to deliver our services to you, such as when you access our application, subscribe to our services, or talk to our voice AI solution. We will use your personal data in particular to identify you when you login to your account, to process your payments, and to fulfil your requests.
   • We may use the personal data about you to enhance, optimize, secure, update, market, and analyse our services or develop new services or products. Certain features of the services use third-party generative AI solutions, i.e., automated tools that provide information or generate text based on their programming and training data. InTouch will not use your personal data to train or improve its services’ generative AI features without your explicit consent as per these Privacy Policies or the Terms and Conditions.

2. To communicate with you

   • We may process your personal data to communicate with you, in order to provide you our services and also for example when we assist you with setting up or administering your account, provide customer care, resolve your complaints, and send support messages. Such communication is not affected by your marketing communication preferences.
   • We may in some cases also use our AI voice solution to provide immediate responses to your queries. We will always inform you about the involvement of such an AI voice solution.

3. To inform you about InTouch’s services

   • We may contact you about our news, events, services and their features or special offers that we believe may interest you, provided that we have the requisite permission to do so, either on the basis of your consent, or our legitimate interests where we may do so, within the limits provided by law. You may change your marketing preferences at any time by following the instructions in such communications (e.g. by clicking on the “unsubscribe” link) or by contacting us directly via the contact details provided in the Section 1 of this Privacy Policy.

4. To comply with legal obligations

   • We may also process your personal data to comply with applicable legal obligations.

5. To prevent fraudulent activities and protect our rights

   • We may use the information about you to detect, prevent and address fraud and other illegal activity and to establish, exercise or defend our legal claims and protect our rights.

On what legal basis do we process your personal data?

1. We process, use, and store your data primarily to perform our obligations under the contracts we have concluded with you to provide our services.
2. In certain instances, we may process your personal data based on our legitimate interests. Company’s legitimate interests include offering our services to you, enhancing our services or/and products and customer base, providing you a better user experience, management of the customer relationships, exercising and defending our legal rights, preventing fraud, illegal activity or imminent harm, and ensuring the security and operability of our network and services. Where permissible under applicable law, we may also contact you about our services and products based on our legitimate interests.
3. In specific cases (see for example Section 2.2), we process your data based on your consent, in accordance with the requirements for consent under applicable privacy laws. We may also rely on your consent for direct marketing purposes or personalized advertising.
4. We may process your personal data where such processing is necessary to comply with the laws applicable to our business operations.

For how long do we store your data?

1. We will store your personal data for as long as is necessary to provide you with the services requested by you; for as long as is reasonably required to store such information for our legitimate interests, such as exercising our legal rights, or for as long as we are legally obligated to store such information.
2. If you consent to us collecting, processing, using, and storing your personal data, we will do so for the duration of such consent — in other words, until such consent expires or is withdrawn. You have the right to withdraw your consent at any time. For more details on the withdrawal of your consent, please see Section 8 below.
3. We will delete personal data when it is no longer needed or when you request your data to be deleted, subject to certain exceptions provided by the relevant data protection laws.

Data disclosures and transfers

1. We may share your personal data with non-affiliated third parties such as professional advisors or public authorities when necessary:
   • To comply with legal obligations;
   • To enforce or defend our legal rights, or in connection with corporate restructuring, such as a merger or business acquisition, or in connection with an insolvency situation;
   • To prevent fraud or imminent harm; and/or
   • To ensure the security and operability of our network and services.
2. We share your data with our trusted business partners, who process your data as our vendors and data processors on our behalf and pursuant to our instructions (for the purposes of e.g., IT support, hosting, etc.). We strive to select our vendors carefully and ensure they are able to provide adequate data protection and security safeguards.
3. Your personal data can be shared through third-party cookies and other related technologies that are used by third parties. Please refer to our Cookie Policy for more information.
4. As required by the applicable laws, any transfer of your personal data outside the EU or UK only takes place if the requirements of the applicable privacy laws, in particular as laid down in Art. 44 et seq. GDPR, have been fulfilled, e.g., based on the European Commission’s adequacy decision, or the Standard Contractual Clauses, including the UK SCC Addendum, where applicable.

Data security

1. We have implemented and will maintain appropriate technical and organizational measures, internal controls, and information security routines in accordance with good industry practice while keeping in mind the state of technological development in order to protect your data against accidental loss, destruction, alteration, unauthorized disclosure or access or unlawful destruction. We employ various security measures to protect the information we collect, as appropriate to the type of information, including encryption, firewalls, and access controls. We further ensure that all individuals who have access to your data and are involved in the collection, processing, use, and/or storage thereof are bound by appropriate confidentiality obligations and have appropriate training.

What are your rights?

1. If you have any questions or concerns about the handling of your personal data, and/or you wish to exercise your data subject rights, please contact us at any time via the contact details provided in the Section 1 of this Privacy Policy.
2. As a data subject, you have the following rights:
   • The Right to Access: You have a right to request access to the personal data about you that we process and to receive a copy of that data.You may contact us at any time with a request to receive more information regarding the following:
     • the purposes for which we use your personal data;
     • how we categorize your personal data;
     • the recipients of your personal data;
     • the length of time we store your personal data; and
     • your rights as a data subject.
   • The Right to Portability: You have the right to receive a copy of your personal data from us in a structured and commonly used machine-readable format. You may also request us to transfer such data to another data controller.
   • The Right to Erasure: You may request us to erase your personal data from our records. Please note, that in some cases we may be legally obliged to retain some of your personal data. We may also retain some of your personal data in order to defend our legal rights, avoid sending you unwanted materials in the future, and to keep a record of your request and our response.
   • The Right to Rectification: If you discover that any of the data we possess about you is incorrect or incomplete, you may as us to rectify or supplement your data.
   • The Right to the Restriction of Use: You have a right to request restriction of our use of your personal data, in particular if you believe that such processing is unlawful, or your data are inaccurate.
   • The Right to Object: In cases in which we rely on our legitimate interest to use your personal data, we must consider and acknowledge the interests and rights that you have under data protection law. Your privacy rights are always protected by appropriate safeguards and balanced with your freedoms and other rights. You have the right to submit an objection at any time to our use of your personal data based on our legitimate interest.
   • The Right to Withdraw Consent: You have the right to withdraw your consent at any time to our use of your personal data. Please note that a withdrawal of your consent does not affect the legality of the use of your personal data prior to your consent being withdrawn.
   • Additionally, you have the right to lodge a complaint with the competent Data Protection Authority if you believe your rights regarding our use of your personal data have been violated. The list of EU Data Protection Authorities is available here.

Children’s Privacy

Changes to this Privacy Policy

1. We may periodically modify the provisions of this Privacy Policy and encourage you to review it from time to time in order to stay up to date with the most recent developments in the area of the protection of your personal data. In the event of significant changes, we may also choose to notify you via email should we have your email address in our records.
2. Updated versions of this Privacy Policy will be published on our website.