Last updated: 7 November 2026
This policy describes which personal data inTouch processes — in the app for iOS and Android, in the browser version inTouch Web and on this website. It applies worldwide. It is based on the EU General Data Protection Regulation (GDPR); section 17 contains additional information for users in the United Kingdom, Switzerland, the USA, Canada, Brazil, Japan, South Korea, Australia and India.
The controller within the meaning of Art. 4(7) GDPR is:
Max VogtYou can reach us at this address for all data protection questions and to exercise your rights. We have not appointed a data protection officer because there is no legal obligation to do so.
inTouch encrypts chat content on your device before it leaves it (key agreement via ECDH on curve P-256, key derivation with HKDF-SHA256, encryption with AES-256-GCM). It is only decrypted on the recipients' devices. We cannot read this content.
This data is transmitted over encrypted connections (TLS), but is stored on our servers in a form we could technically read:
To deliver messages, we process who sent a message of which type (e.g. text, photo) to whom and when, whether it was delivered and read, which message it replies to, and who belongs to which chat. We do not see the content.
Your private key is created on your device and kept there securely (iOS Keychain or Android Keystore). It only leaves the device in two cases that you trigger yourself, and encrypted each time: (1) when pairing inTouch Web, it is handed over to your browser (section 4.12); (2) it is part of your backup in your iCloud or Google Drive (section 4.13).
Legal bases under the GDPR: contract = Art. 6(1)(b) (performance of the terms of use), consent = Art. 6(1)(a), legitimate interests = Art. 6(1)(f), legal obligation = Art. 6(1)(c). How long we keep the data is listed in section 9.
Data: phone number, chosen name, a verification code we send by SMS, an internal user ID and a sign-in token. Purpose: creating your account, recognising you, preventing abuse. The code is sent by our provider Vonage. We also store which version of the terms of use and of this privacy policy you confirmed when signing up, and when. Legal basis: contract; for abuse prevention, our legitimate interest in a secure service; for the record of your confirmation, legitimate interest and legal obligation (Art. 5(2) GDPR).
Protecting sign-in against abuse: so that nobody can guess verification codes or trigger SMS messages in bulk, we limit sign-in. When someone requests a code, we record this for the phone number and for the IP address of the request; when someone checks whether a number is registered with inTouch, we record this for the IP address. A record consists only of the type of event, the time and a check value (a hash computed with a secret key, HMAC-SHA256) of the number or the IP address — for IPv6, only of its /64 network. We do not store the number or the IP address itself for this. Limits: per number, 3 codes in 10 minutes and 10 in 24 hours; per IP address, 20 codes and 30 number checks per hour. When you enter the code, we count the attempts per check value of the number; after 5 wrong entries the code becomes invalid and you request a new one. We delete the records after 24 hours and the attempt counter 15 minutes after the last attempt (in each case at the hourly clean-up), and immediately after a successful entry or with a new code. If you delete your account, we delete the records for your number immediately; those for IP addresses cannot be linked to an account and expire after 24 hours. Because they are so short-lived, this data is not included in the data export. It is kept in our database at Cloudflare (section 7) and goes to no one else. Legal basis: legitimate interests (Art. 6(1)(f) GDPR) in protecting accounts against code guessing and the service against SMS abuse and the costs it causes.
Data: name (required), optionally profile photo, bio, birthday and links. Purpose: presenting you to others; if you enter your birthday, it appears to your contacts in the birthday add-on. Legal basis: contract.
If you allow access to your contacts, the app sends all phone numbers in your address book in a uniform format (E.164) over a TLS-encrypted connection to our server. The numbers are not hashed. Names, email addresses and other contact details stay on your device.
The server compares the numbers with registered accounts and only stores which inTouch users are among your contacts (their user IDs). Numbers without an inTouch account are processed in memory for the comparison only and are not stored. On your first match, those of your contacts who already use inTouch receive a notification that you have joined inTouch.
Your contacts are shown with the names from your address book; these names stay on your device (exception: encrypted to your inTouch Web, section 4.12).
Legal basis: for you, contract; the address book is only accessed with your permission in the system dialog. For the numbers of people in your address book who do not use inTouch, we rely on our and your legitimate interest in finding people you know on the service; we only process these numbers transiently and do not store them. The app keeps working without contact access; you then only see contacts you are already connected with.
Data: encrypted content (section 3), message metadata, chat and group memberships, unencrypted elements such as reactions and GIF addresses. The server keeps undelivered messages, encrypted, until your device fetches them. Encrypted media stay in our storage until the message or chat is deleted. The app stores read content in plain text only on your device. Purpose: delivering messages. Legal basis: contract.
If you delete a chat, the server only remembers from when it is deleted for you, so that it does not come back on your other devices or after signing in again.
Data: group name, description and picture, members, admins, invitations; for events, start and end, responses, photos and expenses; for polls, the votes cast. Purpose: group features. Event photos can only be retrieved by group members via time-limited, signed addresses. Legal basis: contract.
Data: photos and videos, captions, comments, likes, tags and mentions, the audience you choose, who viewed a story. Purpose: sharing content with the audience you choose. Story media can only be retrieved via addresses signed individually for each viewer. Stories disappear after 16 hours unless you add them to a highlight. Legal basis: contract.
Flicks are end-to-end encrypted photos or videos for viewing once. The server knows the sender, recipients, display time and the day it was sent. The encrypted medium is deleted as soon as all recipients have viewed it, after 7 days at the latest. For the “streak” (how many days in a row you have exchanged flicks with each other) we store the days on which you exchanged flicks. Legal basis: contract.
Voice and video calls run via Cloudflare RealtimeKit (preferred region eu-central-1, Frankfurt). For this we transmit your profile name and an internal identifier (“user-<ID>”); the call room's name contains the chat ID. Audio and video are relayed live, not recorded and not stored, but they are not end-to-end encrypted. The calling software reports technical quality data to Cloudflare (e.g. network and connection data including IP addresses, operating system). While a call is running, we store which call is running in which chat. After the call ends, we delete your profile name and identifier at RealtimeKit and close the call room; if a call was not ended normally (e.g. a crash), this happens after 12 hours at the latest. Cloudflare keeps the technical quality data for 6 months. Legal basis: contract.
Data: a push token, a device identifier (iOS: “identifierForVendor”, Android: “ANDROID_ID”), platform and app language. Notifications are delivered via the Apple Push Notification service (iOS) or Google's Firebase Cloud Messaging (Android). They contain the sender's profile name, IDs, the address of their profile photo and, for text, the encrypted content, which only your device decrypts. Some notifications contain readable details: for calls the caller's name and, where applicable, the group's name; for invitations the group name; for likes, comments and mentions the name of the person acting (never the comment text). Where possible, your device replaces the name with the name from your address book. Purpose: informing you about messages, calls and activity. Legal basis: contract; notifications only appear if you allow them in the system dialog. Firebase additionally collects an installation ID.
The server stores whether you are currently connected and — as long as “Show online status” is on — when you were last online. Under Settings → “Account Privacy” you can switch off “Show online status” and “Read receipts”. If you switch off the online status, the server no longer stores a “last seen” time and deletes the one already stored; others then see neither your online status nor when you were last online. If you switch off read receipts, others no longer see that you have read their messages. Whether you are currently connected and which messages were delivered and read is still recorded by the server for delivery purposes. Legal basis: contract.
Legal basis: contract (you actively use the feature); location is only accessed with your permission in the system dialog and only while the app is in use.
inTouch Web lets you use inTouch in a browser. To pair, you scan a QR code with the app (with confirmation by Face ID or biometrics). Your phone then hands over to your browser, encrypted, your private key, your chat keys, your previous history and the names from your address book. The history passes through our storage in encrypted packages for this and is deleted as soon as the browser confirms receipt. Your phone stores the name list encrypted on our server for 30 days so that the browser can pick up changes.
The browser stores messages (decrypted), keys and names locally in its storage (IndexedDB) on that computer; they are deleted when you sign out. inTouch Web sets no cookies. For each pairing we store a session (browser label, last access, valid for 30 days) and, to prevent abuse, the IP address used for pairing for one hour.
inTouch Web can be embedded on other websites. The embedding website has no access to your messages or keys; it only learns whether a browser is paired and the number of unread messages. We learn the address of the embedding website. Legal basis: contract; IP address at pairing: legitimate interests (abuse prevention).
If you switch it on, the app backs up your messages, keys (including your private key), reminders, nicknames, saved messages and settings — on iOS to your iCloud, on Android to the hidden app folder of your Google Drive (the app only gets access to that folder). On Android the backup then runs automatically every 12 hours. We do not receive the backup and have no access to your iCloud or Google account.
The backup is encrypted with AES-256-GCM. The key is derived from your user ID and your phone number, not from a password. Anyone who has the backup file and knows both could therefore decrypt it. Next to the backup there is a small unencrypted file with date, count and size (no content), so that the app can offer a backup before opening it. Apple's and Google's privacy notices apply to iCloud and Google Drive. Legal basis: contract (you switch the feature on).
In the app you can download a copy of your data (Settings → “Your app and media” → “Archive and Download”) and delete your account. We count export requests (at most five per hour). Legal basis: legal obligation (Art. 15, 17, 20 GDPR) and contract.
Every request to our servers creates technical logs at our hosting provider Cloudflare: time, address and function called, error messages and connection data, which may include the IP address. Our log lines contain user, chat and other internal IDs, but no names, no texts of messages, posts or groups, no locations and no contact lists; phone numbers only appear shortened, SMS codes never. Logs are deleted automatically after at most 7 days. Purpose: operation, troubleshooting, defence against attacks and abuse. Legal basis: legitimate interest in a secure, working service.
We store whom you block (blocked people can then no longer deliver direct messages, flicks or calls to you and are not told; this does not apply in shared groups), your privacy and notification settings, your own contact lists and “close friends”. Legal basis: contract.
You can report posts, comments, stories and profiles in the app. Data: your user ID, what you report, the reason you chose and your description (if you give one), and a copy of the reported content at the time of the report: text, references to the photos and videos, and the user ID and profile name of the person who created it. Chat messages cannot be reported this way — they are end-to-end encrypted and we do not receive their content; you can report the person instead and describe what happened. We hide the reported content for you at once. We are notified of each new report by email (sent through our provider Resend); the email contains the reason, the description, the copy of the text and the user ID and profile name of the person who created the content — but not who reported it. After reviewing it, we tell you the outcome by push notification. If we remove content, we tell the person who created it the reason, but not who reported it. For serious or repeated violations we suspend an account: we note the suspension on the account and keep a check value (hash) of the most recently used sign-in token, so that the app can explain the suspension instead of signing you out without a reason. Your own reports are included in your data export. Purpose: removing unlawful content and content that violates our rules, protecting users. Legal basis: legal obligation (Art. 16 and 17 of Regulation (EU) 2022/2065, the “Digital Services Act”) and legitimate interest in a secure service.
If you write to us by email or through the contact form, we process your message, your email address and your name (if given) to handle your request. Our server forwards a message from the form by email to our mailbox via our provider Resend; it is not stored on our servers. We protect the form against mass automated requests with Cloudflare Turnstile (section 16) and limit the number of messages per sender; for this we keep a non-reversible check value (hash) of your IP address with a counter for one hour. Legal basis: contract or legal obligation (for requests concerning your rights); for protecting the form, legitimate interest in a working contact channel.
Decrypted messages, keys, address-book names, nicknames, saved messages, reminders, picture and video caches, and the photos the Memories add-on shows from your library stay on your device — unless you back them up or pair inTouch Web.
The app only accesses these functions after you allow it in the system dialog; you can revoke this at any time in the system settings:
The legal basis for accessing these device functions is Section 25(2) no. 2 of the German TDDDG (strictly necessary for the service you explicitly requested) or, where the operating system asks for permission, your consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR).
We do not sell data and do not pass it on for advertising. Only the following receive data:
| Recipient | Purpose | Data | Role, location |
|---|---|---|---|
| Cloudflare, Inc. | Hosting (servers, database, storage, delivery), logs, calls (RealtimeKit), this website, bot check in the contact form (Turnstile) | all data processed on our servers (section 4), live call audio/video, call quality data, for Turnstile browser and device characteristics and IP address | Processor, USA (global network) |
| Vonage B.V. (Amsterdam), with Vonage companies in the USA | Sending the SMS verification code | phone number, code | Processor, Netherlands/USA |
| Resend (Plus Five Five, Inc.) | Sending us the email notification about a report (section 4.17) and the messages from the contact form | for reports: reason, description, copy of the reported text, user ID and profile name of the person who created the content; for the contact form: name, email address, message | Processor, USA |
| Google (Gmail) | Mailbox in which we receive the notifications about reports and the messages from the contact form | as in the row above | Provider acting on its own responsibility, USA/Ireland |
| Apple (iCloud Mail, Apple Distribution International Ltd.) | Receiving your emails to our @in-touch.cc addresses | your emails to us | Provider acting on its own responsibility, Ireland/USA |
| Google (Firebase Cloud Messaging) | Push notifications on Android | push token, Firebase installation ID, notification content (section 4.9) | Processor, USA/Ireland |
| Apple (Apple Push Notification service) | Push notifications on iOS | push token, notification content (section 4.9) | Processor, USA/Ireland |
| Google (Maps SDK, ML Kit, Geocoder) — Android | Maps in location messages; QR scanner; place names | coordinates of the place shown, IP address, device and diagnostic data, SDK identifiers | Provider acting on its own responsibility, USA/Ireland |
| Apple (Maps, geocoding) — iOS | Maps in location messages; place names | coordinates of the place shown, IP address | Provider acting on its own responsibility, USA/Ireland |
| GIPHY, Inc. | GIF search and display (directly from your device; in inTouch Web via our server) | search terms, IP address, device information | Provider acting on its own responsibility, USA |
| OpenMeteo GmbH | Weather add-on (directly from your device) | coordinates, IP address | Provider acting on its own responsibility, Switzerland |
| Unsplash | Recipe pictures in the recipe add-on | IP address when loading | Provider acting on its own responsibility, Canada |
| Tagesschau (ARD), ESPN | News and sports data | no personal data (fetched by our server) | — |
| Apple iCloud / Google Drive | Your backup | encrypted backup | your own account; we receive nothing |
| Tools you connect with your API key | your own purposes | what you release (section 4.11) | chosen by you |
| Authorities | only where legally required | the requested data we hold (no chat content — we do not have it) | — |
We have agreements under Art. 28 GDPR with our processors. Providers “acting on their own responsibility” process the data under their own privacy notices. The direct connection to GIPHY and Open-Meteo only arises when you use the respective feature; the legal basis is then contract (Art. 6(1)(b) GDPR).
Our database and our file storage (photos, videos, voice messages) are located in Cloudflare data centres in Europe. Cloudflare operates a global network, however: requests are received and processed in the nearest data centre, and the app's real-time connection (delivery, online status) may run in a data centre outside Europe. An exclusively European location has not been contractually fixed with Cloudflare. Data may therefore also be processed in the USA and other countries. We base transfers to the USA on the European Commission's adequacy decision for the EU-US Data Privacy Framework (Art. 45 GDPR) where the recipient is certified under it, and otherwise on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR), which form part of the processing agreements. Certified under the Data Privacy Framework (as of October 2026) are Cloudflare, Inc., Google LLC, Vonage's US companies (Vonage Holdings Corp.) and Resend (Plus Five Five, Inc.); for Apple, the standard contractual clauses Apple uses for transfers from the EEA apply. Switzerland benefits from an adequacy decision of the European Commission. You can obtain a copy of the safeguards on request.
| Data | How long |
|---|---|
| Account, profile, contact matches, settings, blocks | until you change them or delete your account |
| Record of which version of the terms of use and the privacy policy you confirmed | until you delete your account |
| SMS code | 5 minutes |
| Proof of number verification | valid for 1 hour; removed at the next clean-up after that |
| Sign-in protection: records of code requests and number checks (check values of the phone number or IP address) | 24 hours (hourly clean-up); those for your number immediately when you delete your account |
| Sign-in protection: counter of wrong code entries | 15 minutes after the last attempt (hourly clean-up); immediately after a successful entry, with a new code or when you delete your account |
| Message metadata, chat deletion markers | until the message or chat is deleted or you delete your account |
| Undelivered encrypted messages | until delivery, at most 365 days |
| Encrypted chat media | until the message or chat is deleted for everyone or the sender's account is deleted |
| Private notes | not stored; held in memory only until delivery |
| Stories with views and likes | 16 hours (hourly clean-up); as part of a highlight, as long as the highlight exists |
| Flicks | medium until all recipients have viewed it; record 24 hours after viewing; unopened at most 7 days |
| Flick streaks (exchange days) | until the account is deleted |
| Posts, comments, likes, highlights, add-on data, events, expenses | until you delete them or your account; group content until the group is deleted |
| Groups | until the last member leaves (then deleted immediately, at the latest at the hourly clean-up) |
| Push token, device identifier | until you sign out or delete your account |
| Running calls | until the call ends; if a call was not ended normally, at most 12 hours |
| Participant details at Cloudflare RealtimeKit (profile name, identifier) | until the call ends; for calls not ended normally, at most 12 hours |
| Technical quality data of calls at Cloudflare RealtimeKit | 6 months |
| Released reminders (inTouch API) | until you switch the release off |
| inTouch Web: session | valid for 30 days; the session record remains until the account is deleted |
| inTouch Web: history packages / name list / IP at pairing | until the browser confirms receipt / 30 days after the last change / 1 hour |
| Reports (with the copy of the reported content) | until the decision, then 180 days (hourly clean-up); immediately when the reporting or the reported person deletes their account |
| Email notifications about reports | 180 days after the decision on the report |
| Suspension note on an account; check value of the sign-in token of a suspended account | until the account is deleted; 12 months |
| Server logs | at most 7 days |
| Backup in iCloud / Google Drive | until you delete it, switch the backup off or delete your account |
| Check value of the IP address (contact form limit) | 1 hour |
| Emails and contact form messages to us | until your request is resolved; records of GDPR requests up to 3 years |
When you delete your account, we delete the data on our servers immediately (no waiting period), as well as the data on your device and your backup. What remains afterwards is listed on the Delete account page. There are currently no statutory retention obligations for user data.
If an account is suspended for violating the terms of use and then deleted, we keep a keyed hash (a check value computed with a secret key) of the phone number for 12 months — solely to prevent re-registration with that number. No other data is kept for this. The legal basis is Art. 6(1)(f) GDPR (our legitimate interest in preventing a suspension from being evaded).
We protect data through end-to-end encryption of chat content, encrypted connections only (TLS), access checks on every request using a sign-in token, limits on code requests and sign-in attempts (section 4.1), signed, time-limited addresses for story media and event photos, storing keys in the device's Keychain or Keystore, and by minimising the data we store. No system is perfectly secure; we report personal data breaches in accordance with Art. 33 and 34 GDPR.
inTouch shows no advertising, contains no analytics, advertising or crash-reporting tools, does not track you across other apps or websites and uses no advertising ID. We do not make decisions based solely on automated processing that produce legal effects concerning you (Art. 22 GDPR), and we do not create profiles. We do not use your content to train AI models.
We need your phone number and name to create an account; without them the service cannot be used. All other details and permissions are optional; without them some features are unavailable.
Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20), and you can withdraw consent at any time with effect for the future (Art. 7(3)).
Right to object (Art. 21 GDPR): where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you can object at any time on grounds relating to your particular situation. We will then stop processing the data unless we demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defence of legal claims.
Right to lodge a complaint: you can complain to a data protection supervisory authority, in particular in the member state of your habitual residence, place of work or the place of the alleged infringement. The authority competent for us is: the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg (Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg), Lautenschlagerstraße 20, 70173 Stuttgart, Germany (baden-wuerttemberg.datenschutz.de).
We reply within one month (in complex cases this can be extended by two months; we will tell you if so). Exercising your rights is free of charge. For requests by email, we check that the phone number belongs to you before we disclose or delete data.
inTouch is intended for people aged 16 and over (in countries with a higher minimum age for consent, that age applies). We do not ask for your age at registration. If we learn that an account belongs to someone below the minimum age, we delete it. Parents and guardians can reach us at datenschutz@in-touch.cc.
This website sets no cookies, uses no analytics or tracking tools and loads no fonts or other content from third parties. That is why there is no cookie notice here. The only exception is the contact form: only there does the page load Cloudflare Turnstile, a Cloudflare service that checks whether a human is using the form. For this, Turnstile evaluates technical characteristics of your browser and device as well as your IP address; the check is usually invisible. This is strictly necessary for the use of the form you requested (Section 25(2) no. 2 TDDDG); the legal basis is our legitimate interest in protecting the form against abuse (Art. 6(1)(f) GDPR). When you visit it, our hosting provider Cloudflare processes technically necessary data (IP address, time, page requested, browser identifier) to deliver the page and fend off attacks; the logs are deleted after at most 7 days. Legal basis: legitimate interest in providing the website securely.
The UK GDPR and the Data Protection Act 2018 apply, with the rights and legal bases described above. Transfers to the USA rely on the UK Extension to the EU-US Data Privacy Framework or the International Data Transfer Addendum. You can complain to the Information Commissioner's Office (ico.org.uk). UK representative (Art. 27 UK GDPR): none — inTouch is currently offered in the EU only; before offering it in the United Kingdom we will appoint a representative.
The Federal Act on Data Protection (FADP) applies. In particular, you have the right of access, rectification, erasure and data portability. Transfers to the USA rely on the Swiss-US Data Privacy Framework or on standard contractual clauses with the Swiss amendments. The supervisory authority is the Federal Data Protection and Information Commissioner (edoeb.admin.ch). Swiss representative (Art. 14 FADP): none — inTouch is currently offered in the EU only; before offering it in Switzerland we will appoint a representative.
This section supplements the policy for residents of California (CCPA/CPRA) and of states with comparable laws (including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia), to the extent they apply to us.
Categories collected in the past 12 months (sources: you, your device, other users, e.g. when your number is in their address book; purposes: section 4; retention: section 9):
We have not collected commercial, biometric, professional or education information and have not drawn inferences (profiles). We use sensitive personal information only for the purposes permitted under the CCPA (providing the service, security); a right to limit therefore does not apply.
No sale, no “sharing”: we do not sell personal information and do not share it for cross-context behavioural advertising — including that of people under 16 — and have not done so in the past 12 months. We have only disclosed data for business purposes to service providers (section 7). GIF searches and weather requests go directly from your device to GIPHY or Open-Meteo at your direction. We would treat a Global Privacy Control signal as an opt-out of sale/sharing; since neither takes place, it does not change the processing.
Your rights: to know (including categories and specific pieces of data), to delete, to correct, to data portability, and to opt out of sale/sharing and targeted advertising (which do not take place). We will not discriminate against you for exercising your rights. Requests: in the app (section 14) or by email to datenschutz@in-touch.cc; we verify your identity using your account's phone number. An authorised agent can act for you if they provide written authorisation. We respond within 45 days. If we decline a request, you can ask for a review by emailing us with the subject “Appeal”; we will inform you of the outcome within the statutory period. If the decision stands, you can contact your state's Attorney General. We offer no financial incentives for data. “Shine the Light” (Cal. Civ. Code § 1798.83): we do not disclose data to third parties for their direct marketing.
Children (COPPA): inTouch is not directed at children under 13. We do not knowingly collect data from children under 13; if we learn of it, we delete it.
We process data under PIPEDA or the law of your province (including Québec) with your consent, which you give through the app and can withdraw at any time (with the consequence that some features are no longer available). Your data is processed outside Canada (in particular in the USA and the EU) and may be accessible to authorities there. You have the right of access and correction. The person in charge of the protection of personal information (also within the meaning of Québec's Law 25) is Max Vogt, reachable at datenschutz@in-touch.cc. Complaints: Office of the Privacy Commissioner of Canada (priv.gc.ca) or the Commission d'accès à l'information du Québec.
The LGPD (Law 13,709/2018) applies. The legal bases are performance of a contract (Art. 7 V), consent (Art. 7 I), legitimate interests (Art. 7 IX) and legal obligations (Art. 7 II), as set out in section 4. You have the rights under Art. 18 LGPD (confirmation, access, correction, anonymisation, blocking or deletion, portability, information about recipients, withdrawal of consent). International transfers take place under Art. 33 LGPD (standard contractual clauses or for the performance of a contract). Data protection communication channel (“Encarregado”): datenschutz@in-touch.cc. Complaints: Autoridade Nacional de Proteção de Dados (gov.br/anpd).
The business operator under the APPI is Max Vogt, Rorgenwieserstraße 27, 78576 Emmingen-Liptingen, Deutschland. The purposes of use are set out in section 4. Data is provided to recipients in the USA, the EU (Ireland) and Switzerland (section 7). The EU and Switzerland have comprehensive data protection laws (GDPR, FADP); the EU is recognised by Japan's Personal Information Protection Commission as having an equivalent standard. The USA has no comprehensive federal data protection law, but has state laws; our service providers there are contractually bound to measures corresponding to the principles of the APPI. Our security measures are described in section 10. Requests for disclosure, correction, cessation of use or deletion, and complaints, go to datenschutz@in-touch.cc.
Under the Personal Information Protection Act (PIPA):
We handle personal information in accordance with the Australian Privacy Principles. Data is disclosed to recipients in the USA, the EU and Switzerland (section 7). You can request access and correction and complain to us at datenschutz@in-touch.cc; if we have not resolved your complaint to your satisfaction within 30 days, you can contact the Office of the Australian Information Commissioner (oaic.gov.au).
Under the Digital Personal Data Protection Act 2023, we process the data listed in section 4 for the purposes stated there on the basis of your consent, which you give at registration and through the permissions and can withdraw at any time as easily as you gave it (deleting your account, revoking a permission). You have the right to a summary of the data processed, to correction, completion, updating and erasure, to grievance redressal, and to nominate a person to exercise your rights in the event of death or incapacity. Grievance contact: Max Vogt, datenschutz@in-touch.cc; after the grievance procedure you can approach the Data Protection Board of India. In India you may only use inTouch from the age of 18.
If the law of your country grants you further rights, you can exercise them at datenschutz@in-touch.cc.
We update this policy when the app, our service providers or the law change. We will inform you of material changes in the app. This policy is also available in German; both versions are equally authoritative.