Privacy Policy

Last updated: September 12, 2025

This Privacy Policy explains how I handle information in connection with the TouchGround mobile application (“App”).

The App is operated by:

1. No Collection of Personal Data

I do not collect, store, or share any personal data directly from users of TouchGround.

• The App does not require account registration.
• The App does not request or store names, email addresses, contact details, health data, or location data.

2. Third-Party Services

The App relies on third-party providers to function:

• Apple App Store (for downloads, subscription management, and payments).
• OpenAI (for speech recognition and text/voice generation).
• Conversations with the chatbot are transmitted directly to OpenAI for processing. I do not access, store, or control this data myself.

Any data transmitted through these services is handled by the provider under their own privacy policies:

• Apple: https://www.apple.com/legal/privacy
• OpenAI: https://openai.com/policies/privacy-policy

I do not control and am not responsible for how these providers process data. Depending on your location, data may be transferred outside the EU.

3. Conversation Transcripts & Insights

When you use the AI Life Coach, your voice is transcribed into text for the purpose of generating a reply. These transcripts are also briefly analyzed to highlight key points you mentioned, which are displayed back to you in the Insights section of the App.

• I do not store or access these transcripts myself.
• Transcription and analysis are handled by OpenAI as described above.
• Insights are generated only for your use within the App and are not shared with me or with other parties.
• Your conversations and insights are stored only on your device. If iCloud Backup is turned on, they may also be included in your device backups. Please note these backups only restore if you set up your iPhone again from an iCloud backup — they do not reappear if the app is deleted and reinstalled.

4. Legal Basis under GDPR

Because I do not process personal data myself, GDPR obligations are limited. If third-party services process your data, the legal basis is their legitimate interests or the performance of a contract.

5. Your Rights under GDPR

If personal data is processed by third-party providers, you may have the following rights:

• Access, rectification, or deletion
• Restriction or objection to processing
• Data portability
• Right to lodge a complaint with your data protection authority

5a. U.S. Privacy Rights (California)

The App does not collect, sell, or share any personal information as defined under the California Consumer Privacy Act (CCPA) or the California Privacy Rights Act (CPRA).

To exercise these rights, please contact the relevant provider directly.

6. Children’s Privacy

The App is not directed to children under 18, and I do not knowingly collect information from children.

7. Changes to This Policy

I may update this Privacy Policy from time to time. Updates will be published within the App.

8. Contact