InTouch Privacy Policy
At InTouch, we care deeply about the privacy and security of your personal data. We understand that you are entrusting us with delicate information about yourself or your loved ones, who may need assistance and support. That is why we are committed to being transparent about our privacy practices and treating your data with utmost care and respect.
This Privacy Policy (“Privacy Policy”) explains what type of personal data we collect and process about you and the measures we apply to protect such personal data with respect to which we act as a data controller. Personal data refers to any information that identifies your or could be used to identify you. It is used interchangeably with the term ‘personal information’.
We adhere to high ethical standards and comply with applicable laws and regulations when we collect, process, and store your personal data, including the European General Data Protection Regulation (EU 2016/679) (the “GDPR”); European national laws implementing derogations, exceptions or other aspects of the GDPR; the GDPR, as transposed into the United Kingdom national law, and as amended from time to time (the “UK GDPR”), the United Kingdom’s Data Protection Act 2018, and the California Consumer Privacy Act of 2018, as amended from time to time (the “CCPA”).
This Privacy Policy applies to all individuals whose personal data is processed in connection with the InTouch services. This includes: (i) individuals who directly purchase the services for their own use, (ii) individuals who buy the services for their relatives, (ii) the relatives, and (iv) other trusted relatives who have been given access to InTouch services by the users.
1. Who processes your personal data?
1.1 The controller of your personal data is AI 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”).
1.2 For all matters related to privacy and the collection, processing, use and storage of your personal data, please contact us at contact@intouch.family.
2. What personal data do we collect?
Depending on the features of the services you use, InTouch may collect various categories of personal data for different purposes. This includes both data provided directly by you or your family member, and data generated during your use of the services.
2.1 Data that you or your family member provide to us
(a) Account and billing information
When you set up an account with us, we may collect your contact information such as your first name, last name, email address and phone number. In addition, we may also collect your login credentials (email and password) and billing information (e.g. your credit card details), where applicable. If you choose to, you may designate one or more trusted relatives to access the services, in which case we may collect their identification and contact details, such as their name, phone number, and email address.
(b) Customer support and communication
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.
(c) Information provided by a family member on your behalf
If the services were procured on your behalf, typically by your family member, this family member may provide personal data about you during registration. The scope of personal data collected will depend on what the family member elects to share with us, and can include 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 is required to ensure that you have read and understood this Privacy Policy and that you have given your permission to share your personal data with us for the purposes of providing you our services. We encourage you to review this Privacy Policy yourself and to contact us if you have any questions about our use of your data.
(d) Data you share during conversations
We may collect personal data you decide to share with us during your conversations with our AI voice solution (including free or demo versions of our services). 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.
Some of the personal data that you choose to share with us may be in limited circumstances considered as data of sensitive character, such as information related to your health or well-being. Please note that we will only collect and process such data when it is strictly necessary to provide you with our services, and only with your explicit consent. You may withdraw your consent anytime by contacting us at contact@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).
(e) Messages sent by family members
If you are a family member purchasing the services on behalf of your relative, our services offer you the possibility to send a message to the 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.
2.2 Data generated by your use of our services
(a) Transcripts and mood analyses
We will generate transcripts of your calls or collect results of any games or exercises that you have decided to take to analyse your mood levels. These transcripts and mood analyses may include your personal data if you share them with us during your conversations with our AI voice solution.
(b) Summaries of your conversations
In addition, we will generate short summaries of your conversations and share them, along with mood analyses, with the family members who purchased our services for you and trusted relatives designated by them.
2.3 Data we collect from other sources
(a) Cookies and similar technologies
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 to 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.
3. How do we use your personal data?
3.1 To provide and improve our services and to develop new offerings
(a) We may use your personal data to provide and operate the InTouch services. This includes enabling you to access and use our application, process your subscription, and deliver the core functionalities of our services. 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. In particular, we use your personal data to:
- identify and authenticate you when you log in to your account,
- process payments and manage your subscription,
- configure the AI voice assistant based on your language preferences, availability, and chosen topics of interest,
- enable conversations with our AI voice solution and personalize them according to the conversations,
- analyse transcripts of conversations with our AI voice solution to assess mood levels and generate summaries of such conversations,
- shares conversation summaries and mood analyses with designated family members and deliver relevant notifications or messages to and from family members.
(b) We may also use your personal data to enhance, optimize, secure, update, market, and analyse our services or develop new services or products.
3.2 To communicate with you
(a) 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 (including changes to applicable terms and conditions and other communication to fulfil our legal and / or contractual obligations). Such communication is not affected by your marketing communication preferences.
3.3 To inform you about InTouch’s services
(a) 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.
3.4 To comply with legal obligations and protect our rights
(a) We may also process your personal data to comply with applicable legal obligations.
(b) 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.
4. How do we use AI?
4.1 We use a third-party provider which ensures that your personal data is not used to train a third-party large language model (“LLM”).
4.2 Our AI-powered features are supported by LLMs hosted on the Google Cloud Platform, to provide automated assistance, generate responses, and enhance user experience.
4.3 Please note that the answers generated by the LLMs are personalized based on personal data provided during the use of our services (e.g., text input, user preferences, interaction logs, response times, questions asked).
4.4 If you have any questions regarding your data protection rights in relation to our use of AI, if you wish to access your personal data used by the LLMs, to delete such personal data or to rectify inaccurate or incomplete data, please contact us at: contact@intouch.family.
5. On what legal basis do we process your personal data?
5.1 We process, use, and store your data primarily to perform our obligations under the contracts we have concluded with you to provide our services.
5.2 In certain instances, we may process your personal data based on our legitimate interests. InTouch’s legitimate interests include enhancing our services or/and products and customer base, providing you a better user experience, management of 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.
5.3 In specific cases, 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.
5.4 We may process your personal data where such processing is necessary to comply with the laws applicable to our business operations.
6. For how long do we store your data?
6.1 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.
6.2 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 9 below.
6.3 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.
7. Data disclosures and transfers
We may disclose your personal data to third parties in the following circumstances:
7.1 We may share your personal data with non-affiliated third parties such as professional advisors or public authorities when necessary:
(a) to comply with legal obligations;
(b) 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;
(c) to prevent fraud or imminent harm; and/or
(d) to ensure the security and operability of our network and services.
7.2 We may 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 to ensure they are able to provide adequate data protection and security safeguards.
7.3 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.
7.4As 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.
8. Data security
8.1 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.
9. What are your rights?
9.1 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.
9.2 As a data subject, you have the following rights:
(a) 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.
(b) The Right to Receive Information: 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.
(c) 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.
(d) 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.
(e) 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.
(f) 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.
(g) 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.
(h) 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.
9.3 To exercise any of the above-mentioned rights, please contact us through the contact information provided in Section 1 of this Privacy Policy.
9.4 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.
9.5 If you are a Californian consumer, you have the following rights under CCPA, which you (or an authorized agent on your behalf) may exercise by contacting us at contact@intouch.family:
(a) Right to know: You have the right to request that we disclose to you the categories and specific pieces of personal information that we have collected about consumers. These may include the categories of sources of personal information, of the business or commercial purposes for collecting personal information, and of the third parties with whom InTouch shares personal information. They can be generally found in this Privacy Policy.
(b) Right to correct: You have the right to request that we correct your personal information that is inaccurate upon your request.
(c) Right to delete: You have the right to request that we delete any personal information about you we have collected. Upon your request, InTouch will delete your personal information, and you will not receive any InTouch content or services, unless you subsequently provide your personal information in connection with a new registration, or it is otherwise lawfully provided to InTouch. Please note that your request may be denied if we need your personal information to fulfil our legal obligations and exercise or defend our legal claims.
(d) Right to opt out of sale or sharing: InTouch does not sell personal information, as defined in the CCPA. We may, however, share your personal information collected by cookies with third parties for the purpose of personalized advertising. You can opt out of such sharing in our cookie banner by disabling all optional cookies when you first visit the InTouch website. If you want to update your cookie preferences, please see our Cookie Policy.
(e)Right to limit use and disclosure of sensitive personal information: You have the right to request that we limit the use and disclosure of sensitive personal information (such as your financial account information and health-related information).
(i) Right to non-discrimination: You have the right to not be discriminated against if you choose to exercise any of the above-mentioned rights. We do not offer financial incentives or price or service differences to consumers in exchange for the retention of their personal information.
10. Children’s Privacy
Our services or content are not directed, or intended for use by, children under the age of 18 years. Therefore, we do not knowingly collect personal data from children under the age of 18 years. If we become aware that personal data of a child under 18 have been collected, we will take appropriate steps to delete such data.
11. Changes to this Privacy Policy
11.1 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.
11.2 Updated versions of this Privacy Policy will be published on our website.
11.3 This Privacy Policy shall become valid and effective on [04/07/2025].