Wysa Voice Assistant Privacy Policy

Wysa Voice Assistant Privacy Policy

Initial Effective Date: : Nov 11, 2019 (GMT)
Latest Revised Date: : Nov 11, 2019 (GMT)

THIS POLICY DESCRIBES OUR POLICIES AND PROCEDURES FOR COLLECTION, USE, STORAGE, PROCESSING, DISCLOSURE AND PROTECTION OF ANY INFORMATION, INCLUDING, BUT NOT LIMITED TO, PERSONAL INFORMATION PROVIDED BY YOU AS A USER WHILE USING THE SERVICE. USER SHALL MEAN ANY PERSON/ PERSONS, WHO VISITS, USES, DEALS WITH AND/ OR TRANSACTS THROUGH WYSA VOICE ASSISTANT (“Assistant Policy”). PLEASE READ OUR ASSISTANT TERMS OF SERVICE AND THIS POLICY (TOGETHER, THE “ASSISTANT AGREEMENT”) CAREFULLY, AS YOU MUST AGREE TO BOTH DOCUMENTS IN ORDER TO HAVE PERMISSION TO USE OUR SERVICE.

IMPORTANT NOTE:

  1. If You are thinking about or committing suicide or if You feel that You may be a danger to yourself or to others or if You otherwise have any medical or mental health emergency or if You are in a crisis or trauma or abuse, please discontinue use of the service immediately and call the relevant emergency number in Your country and notify the police or emergency medical services. For example, You can find Your country-specific suicide emergency number at: Suicide.org - Suicide Prevention, Awareness, and Support

  2. When You use Voice Assistant, You are also using the Google Assistant, and the Google Privacy Policy describes how Google collects and uses data about Your use of the Voice Assistant. You may wish to consult Google’s documentation regarding what Information is shared with Your Google Assistant or how to delete Your Google Assistant activity or how to choose which services remember You.

  3. Google Assistant converts Your voice messages to text-based messages. Only Your text-based message is collected and processed to provide Our Service. Your original voice messages are never collected nor stored with Us at any time.

  4. Keep Your conversations private and device secure by following the best practices outlined in section 7.d.

  5. Always lock Your device and exit the Voice Assistant to ensure Your conversations remain private and secure.

PLEASE TAKE TIME TO REVIEW THE FOLLOWING INFORMATION CAREFULLY.

Table of Contents

Introduction
Definitions
What is Voice Assistant?
Who can Use the Service?
What Information do we collect and how do we use it?
What Information will be processed by Us for purposes of legitimate interests?
How does Touchkin protect Your Information?
Where is Your Information transmitted and stored?
How long does Touchkin keep Your Information?
Does Touchkin use outside service providers or agents?
Does Touchkin give Your information to third parties?
Does Touchkin use third-party modules?
What are Your data protection rights?
Can children under 13 use Voice Assistant?
Who can You contact for additional questions, comments or concerns?
Can Non-English speaking users use the Voice Assistant?
What are some Best Practices to follow to keep Your devices secure?
Changes to this Assistant Policy
Severability and Exclusion
Governing Law and Dispute Resolution

1. Introduction

Welcome to Wysa Voice Assistant, the Google Assistant assisted Service of Touchkin eServices Private Limited (hereinafter “Touchkin”, “Wysa”, “We”, “Us”, or “Our”). When You as a user (“You/r”) use Touchkin’s services, You trust Us with Your Information. This Assistant Policy governs Your use of the Google Assistant integrated Wysa Service (hereinafter the “Wysa Voice Assistant” or “Voice Assistant”) created by Touchkin. This Assistant Policy constitutes a legal agreement between You and Touchkin.

This Assistant Policy applies to Information You provide Us when You use the Voice Assistant, Information You provide Us when You visit websites maintained by Us relating to our Voice Assistant (“Websites”). Our Voice Assistant, Websites, or any of Our online services, and software provided on or in connection with the services are collectively referred to as the "Service(s)").

What does this Privacy Policy apply to?

This Assistant Policy (“Assistant Policy” or “Wysa Voice Assistant Privacy Policy”) has been drafted in accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or Information) Rules, 2011, including (but not limited to) requirements within HIPAA (Health Insurance Portability and Accountability Act) and General Data Protection Regulation (GDPR) (EU) 2016/679 regulation (collectively referred to as “Data Protection Law”).

This Assistant Policy describes the steps that We will take to comply with the Data Protection Law to ensure the processing of Your Personal Information. For the purposes of Data Protection Law, the Data Processor for Voice Assistant is Touchkin eServices Private Limited, a private limited company, incorporated and existing under the laws of India and having its registered office at No. 532, "Manjusha", First Floor, 2nd main, 16th Cross, II stage, Indiranagar, Bangalore KA 560038 IN).

This Assistant Policy is meant to help You understand what data We collect, why We collect it, what We do with it how You can manage and control the use of Your Information and the rights You have to access and control Your Personal Information. Please read the definitions in the next section to understand the terminology used in this Privacy Policy.

Our mission is very simple. We want to help You care for yourself better, and help You access tools that can help build healthier behaviour, both physically and mentally.

We will always respect and protect Your privacy, and this forms a part of Our guiding principles. We have policies and procedures in place to protect the privacy and security of Your Information. Your trust means a lot to Us. Wysa does not request for Your Personal Information. Please do not share any Personal Information at any time in Your Use of Our Service such as while in conversation with the Voice Assistant Service. We will always tell You of any Personal Information that We may collect, and will take Your permission before asking You to share it with Us. We will clearly identify why We need this Personal Information. We will collect only the minimum Personal Information necessary to provide Our services to You. For example, We don’t ask for Your full name, phone number, email address, country specific social security number, Your gender, Your date of birth or Your address. We don’t have to have it, hence We don’t ask for it. If We collect it at any time, We will use and protect Your Personal Information in accordance with the terms of this Assistant Policy. We respect Your privacy and will protect it with strong encryption during transmission, plus strict policies that govern how all data is stored and handled. We will keep Your Information only as long as necessary.

Your use of the Voice Assistant will be governed by this Assistant Policy as applicable to the Voice Assistant together with all policies, notices, guidelines, disclaimers that are published and shared with You from time to time which are incorporated herein by way of reference including but not limited to Assistant Terms of Service. This Assistant Policy shall be enforceable against You in the same manner as any other written agreement.

Users may request additional services from Touchkin or Touchkin affiliates.  Because the needs and choices of each user may vary, We may provide separate privacy policies or addendums to this Assistant Policy for certain additional services.  Any applicable separate privacy policies and addendums will explain the types of Information We collect, their purposes of use and other policies that may apply to that service.  When You choose to use an additional service, You may be informed of the applicable Assistant Policy or addendum which applies in addition to, and may modify this Assistant Policy, before You can access the additional service.

Touchkin reserves the right to make changes to this Assistant Policy and to make such changes effective for all Information We may already have collected from You. You must periodically review the policy for the latest Information on our privacy practices.

2. Definitions

Personal Information or personal data or personal identifiable Information (PII) means Information relating to an identified or identifiable natural person who can be directly or indirectly identified by reference to an identifier such as full name, identification numbers, location address, online identifier and other identifiers within the definitions of The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 and General Data Protection Regulation (GDPR) (EU) 2016/679 regulation.

Non-Personal Information means any Information that does not reveal Your specific identity either directly or indirectly. This includes Information that is anonymized so that it does not allow easy identification of a specific individual.

Information under this Assistant Policy means both Personal and Non-Personal Information.

A Cookie is a small amount of data generated by a website and saved by Your web browser. Cookies are used to store user preferences for a specific site. Use of cookies makes web-surfing easier. You may refuse to accept Cookies by activating the setting on Your browser which allows You to refuse the setting of Cookies.

Encryption is the process of transforming Information into unreadable text so that it is only legible to those possessing an encryption key. The process of making encrypted Information readable again is referred to as decryption.

Web browser is a software program that allows user to access, retrieve and view Information on the World Wide Web. Examples of browsers include Internet Explorer, Firefox, Google Chrome and Safari.

3. What is Voice Assistant?

The Voice Assistant is a voice-assisted service of Wysa AI chatbot (“Bot”), that You can chat with using the Google Assistant conversational platform, to get access to tools and techniques to manage Your emotional wellness and to encourage You in building resilience. Your interaction with the Bot using Google Assistant is with an AI chatbot and not a human. The Bot is restricted in the means of response and the intended usage of Voice Assistant is as an early intervention tool. The Bot cannot and will not offer advice on issues it does not recognize. Voice Assistant and Service is not intended for use in crisis such as abuse or complex or severe mental health conditions that causes ideation of suicide, harm to self and others, and any medical emergencies. Voice Assistant and Service cannot and will not offer medical or clinical advice. It can only suggest that user seeks advanced (medical) help.

4. Who can Use the Service?

You may use the Service only if You are a natural/legal person and can form a binding contract with Wysa, and only in compliance with this Assistant Agreement and all applicable local, state, national, and international laws, rules and regulations. If You are between 13 and 18 years of age, please read through this Assistant Agrement with Your parent or legal guardian, and in such a case this Assistant Agreement shall be deemed to be a contract between Touchkin and Your legal guardian or parent and to the extent permissible under applicable laws, enforceable against You. Anyone under 13 is strictly prohibited from creating an account and/or using the Service.

5. What Information do We collect and how do We Use it?

To provide You Our Service, Touchkin will collect, store and use the following Information provided by You:

  1. USER PROVIDED PERSONAL INFORMATION

    Wysa does not request nor collect Your Personal Information. Please do not share any Personal Information at any time in Your Use of Our Service such as while in conversation with the Voice Assistant Service or when You contact Us with inquiries or send Us feedback. By voluntarily providing Us with Your Personal Information, You are consenting to Our use of it in accordance with this Assistant Policy. If You provide Personal Information, You acknowledge and agree that such Personal Information may be transferred from Your current location to the globally-located secure cloud servers of Our authorized third party data processor namely Amazon Web Services (AWS) or to Our own secure server locations.

    If You accidently provided Personal Information and/or submitted media files containing Personal Information (such as videos, images, etc.) during Your conversation with the Voice Assistant and want to rectify or delete that Information, kindly write to Us at the contact provided in section 7.b. at the earliest.

    At present, You do not need to go through a registration or sign-up process or share Personal Information before using the Service.

    The Data Protection Law sets out a number of different reasons for collecting and processing Your Personal Information. The lawful basis for processing all Your Personal Information is for the performance of this Assistant Agreement and as agreed by You.

  2. USER PROVIDED NON-PERSONAL INFORMATION

    To provide You Our Service, Touchkin will collect, store and use the following Non-Personal Information provided by You:

    1. How do We handle Your conversation messages?

      When You use the Service, all the voice-based conversation messages You have with the Voice Assistant is converted to text by Google Assistant platform and only the Voice-converted text-based message is collected and processed by Us. Your original Voice-based message is never collected by Us. You provide Your messages by way of choosing pre-formatted responses or by way of free-speech. Each voice converted text message that is collected by Us get processed in real-time by the Voice Assistant’s proprietary algorithms, and directed appropriately to subsequent context-based conversational text-based message based on a proprietary rule-based content management process. At no point during Your conversation with the Voice Assistant does another natural person have access to, or gets to monitor or respond to, Your messages. Our proprietary algorithms also process all Your messages for positive and negative sentiments and for any self-harm or suicidal tendencies. This is done to enable the Voice Assistant to empathetically converse with You, and personalize Your conversation. There is no solely automated processing done by the Voice Assistant to determine what You should do - You are always asked to verify whether the Voice Assistant has understood Your conversation or sentiment or emotions or feelings correctly, before proceeding down a conversational path.

      Your messages are not processed to send You unwanted content. Your submitted messages or app usage habits or Website browsing habits are not used to sell to advertisers. We do not ‘monetize’ the messages or the Information You submit to Us. The messages You send and receive are encrypted and stored securely. You can read more about the security provided in section 6 of this Assistant Policy.

      PLEASE NOTE THAT WHEN YOU CLOSE YOUR WEB BROWSER OR THE VOICE ASSISTANT, YOUR EXISTING SESSION WILL END AND YOU WILL NOT BE ABLE TO ACCESS YOUR PAST INFORMATION OR SESSION CONVERSATION. YOUR NEXT START OF THE VOICE ASSISTANT WILL BE CONSIDERED AS A NEW SESSION.

      A limited set of Your Voice-converted text-based conversation message gets anonymized before being processed for internal operations and for research purposes. This is done only to improve Your future experience when using Our Service. YOUR CONVERSATION IS NEVER SHARED WITH A THIRD PARTY WITHOUT YOUR EXPLICIT CONSENT.

    2. Do We need to know Your full name?

      When You use the Service, We will not ask for and will not require Your full name at any point of time during the conversation. After sign up, We may take You through a one time on-boarding process. Here We ask for only Your nickname to help personalize Our conversation with You. Please do not share Your full name to maintain complete anonymity.

    3. Why do We ask about Your thoughts, feelings (emotions), mood, major event or life changes, goals and energy levels?

      When You use the Service, We may periodically ask You about Your thoughts, feelings or emotions, mood, major event / changes in life, Your resilience goals and Your energy levels. Your response is processed by Wysa solely to provide You access to tools and techniques to manage Your emotional wellness and to encourage You in building resilience.

      Your Information is encrypted during transmission and is securely stored. YOUR INFORMATION IS NEVER SHARED WITH A THIRD PARTY WITHOUT YOUR EXPLICIT CONSENT.

    4. How do We handle Your responses to health related questions?

      When You use the Service, You may be asked to respond to health related questions. Response is voluntary and You can opt to not report to any of these questions. You will also be asked to share how You cope with day to day activities as part of the health questions. Health related questions are a proven way to baseline and track progress of Your symptoms. Your response is used solely for the purpose of providing You with feedback on Your well-being and to provide You access to validated and curated tools and techniques to manage Your emotional wellness and to encourage You in building resilience.

      Your response is encrypted during transmission and is securely stored. YOUR INFORMATION IS NEVER SHARED WITH A THIRD PARTY WITHOUT YOUR EXPLICIT CONSENT.

  3. AUTOMATICALLY COLLECTED NON-PERSONAL INFORMATION

    To provide You Our Service, Voice Assistant will automatically collect, store and use the following Non-Personal Information:

    1. Why do We collect Device Information and access logs when You Use Our Service?

      When You use the Service, We may also collect Non-Personal Information through the use of commonly-used Information-gathering tools such as cookies, fingerprint, log files and web beacons. Such Information may include standard Information collected from Your device (such as device application identifier, operating system, OS version, time zone, manufacturer, model and brand name) or from Our Website (such as browser type, browser language, Operating System, browser Information including type and language settings) along with the actions You take on Our Website (such as the web pages viewed and the links clicked).

      We use this Information to detect and deter unauthorized or fraudulent use of or abuse of the Service, and to optimize Your experience.

    2. Do We collect Passive Sensing Information from Your device?

      When You use the Service, the Voice Assistant does not passively collect nor process any Information from Your device sensors, such as accelerometer, ambient light readings and screen on/off readings, including location (GPS) and call logs.

    3. How do We Use any Third Party Software?

      When You use Voice Assistant, You are also using the Google Assistant and governed as per Google Terms of Service. The Google Privacy Policy describes how Google collects and uses data about Your use of the Voice Assistant. You may wish to consult Google’s documentation regarding what Information is shared with Your Google Assistant or how to delete Your Google Assistant activity or how to choose which services remember You. Our Voice Assistant integrates with the Google Assistant Platform using the App Actions SDK provided by the Google platform. Our service, uses a unique Non-Personal identifier to connect with You and collects only the Voice converted text provided by Google Assistant via secure API.

      Our website is hosted on Strikingly, a third party web management and analytics platform. Strikingly helps Us collect Your website visit and Usage Information for the purposes of analytics and improve Your experience on our website. The use of Strikingly is governed by Strikingly’s Terms of Service, Privacy and Cookie Policy and GDPR Compliance Statement.

      NO PERSONAL INFORMATION OR IDENTIFIERS ARE PUSHED BY THE VOICE ASSISTANT TO THESE THIRD PARTY SOFTWARE.

  4. OTHER OPTIONAL INFORMATION

    To improve Your experience, We provide optional features in the Voice Assistant.  If You choose to use such features, We may ask You for additional Information:

    1. OPTIONAL: Your feedback and ratings

      When You use the Service, We may ask You for Your feedback and Your rating of Voice Assistant. This feedback and rating is used by Us to improve the product and Your product experience.

      AS A BEST PRACTICE, IT IS ADVISED THAT YOU TAKE ADEQUATE PRECAUTIONS TO NOT SHARE YOUR HEALTH OR PERSONAL INFORMATION WHILE GIVING FEEDBACK OVER EMAIL NETWORKS.

    2. OPTIONAL: Location Information


      To use the Voice Assistant, You are not required to provide Your location Information (“geolocation”). Voice Assistant does not collect Your Geolocation Information. We do however check Your device clock and collect Your date-time settings to help Us offer a safe and improved experience.

      If We collect or use Your geolocation data as an additional separate service, We will make sure that We provide notice and/or obtain Your consent. You can always turn off location sharing at any time using Your device settings.

    3. OPTIONAL: Contact Information for customer support

      There may be occasions where You wish to contact Us to seek support.  If You contact Us via Our website or by other means, We may need some Information from You, which You may choose to provide. This includes Your name, contact info such as Your email address, phone number, as well as Information about Your mobile device or personal computer such as device type, and OS type.  We will use this Information to address and investigate the issues You have forwarded to Us, to provide You support and to improve Our customer support service.

    4. OPTIONAL: Contact Information for promotional events and customer surveys

      If You choose to participate in promotional events or surveys that Touchkin may offer from time to time, We might ask Your contact details (such as name, phone number, email address, gender and date of birth) to administer the event, such as to confirm participation eligibility for the event, to enable You to fill out a questionnaire, to conduct to deliver the prizes to You. NO PROMOTIONAL EVENT NOTIFICATIONS WILL BE SENT WITHOUT YOUR EXPLICIT PERMISSION TO RECEIVE MARKETING NOTIFICATIONS.

6. Other Important Information for You

  1. What Information will be processed by Us for purposes of legitimate interests?

    To provide the Service, We may use Your Information based on Our legitimate interests for the following purposes. We Use legitimate interest basis to process Your Information in a way which might reasonably be expected as part of running Our business and which does not materially impact Your rights, freedom or interest.

    • To detect and deter unauthorized or fraudulent use of or abuse of the Service;
    • For transmission, use and disclosure to business associates or third party based on a business associate agreement. The business associate will not use or disclose Personal Information in any way that would violate the contract.
    • For uses and disclosures required by law;
    • For disclosures for judicial and administrative proceedings;
    • For disclosures for law enforcement purposes;
    • For uses and disclosures for public health reporting, and other public health activities;
    • For uses and disclosures to avert a serious threat to health or safety to You, Us, or others;
    • For using minimal de-identified data to improve and/or optimize the Service;
    • To enable Us to provide customer support, and to respond effectively to Your inquiries and claims;
    • For uses and disclosures for oversight activities such as audits, investigations, and inspections;
    • For uses and disclosures for research purposes (subject to qualifications and exceptions);
    • For any direct marketing purposes;

    By using the Service, You hereby agree to the use of Your Information for the above mentioned purposes.

  2. How does Touchkin protect Your information?

    To fulfil Our commitment to respecting and protecting Your privacy and the confidentiality of Your Personal Information, Touchkin has implemented industry-standard safeguards to prevent unauthorized access or disclosure, misuse, alteration or destruction of Your Information.  More specifically, We will comply with all applicable data protection and security laws in order to assure security, availability, processing integrity, confidentiality and privacy of data. All Information between the Voice Assistant and server is encrypted and transmitted via SSL.

    Because no method of electronic transmission or method of data storage is perfect or impenetrable, We cannot guarantee that Your Information will be absolutely safe from intrusion during transmission or while stored in Our systems.

    To help protect Your privacy and confidentiality of Your Information, We also need to ask for Your cooperation regarding the following:  Please do not copy and transmit Your chat conversations, health data and/or Personal Information with other people.  Also, please notify at the contact Information provided in Section 7.b, in the event You suspect any unauthorized use of Your account or any other breach of security via Our contact Information.

  3. Where is Your Information transmitted and stored?

    To provide the Service in a reliable and responsible manner, Touchkin processes and stores Your Information on secure servers which may be physically located in different countries around the world, including countries outside India.

    By continuing to use the Service, You agree that Your Information may be internationally transferred and that Touchkin can process and store Your Information in a country other than where You submitted it.

    Jurisdiction and Cross Border Transfer of Information

    Our Services are global and Your Information (including any voluntarily provided Personal Information) may be stored and processed in any country where We have operations or where We engage with partner/s, and We may transfer Information to countries outside of Your country of residence, to countries which may have Data Protection Law that are different from those of Your country. However, We will take adequate safeguards and steps reasonably necessary to ensure that any such transfers protect Your privacy, fundamental rights and freedoms, and the exercise of Your rights, in accordance with the this Assistant Policy and in compliance with Data Protection Law.

  4. How long does Touchkin keep Your Information?

    Touchkin retains any Information You provide or automatically collected while Your account is in existence, for the length of time needed to fulfil any of the applicable purposes of use described in this Assistant Policy, or to comply with applicable Data Protection Law.

    We may retain Your Information even after Your account is closed if retention is reasonably necessary. These could be in situations where We need to comply with applicable Data Protection Law or legal obligations, provide and complete customer support service, resolve disputes between or with Touchkin users, or to detect and deter unauthorized or fraudulent use of or abuse of the Service.

  5. Does Touchkin use outside service providers or agents?

    To facilitate and provide You with the Service, it sometimes is necessary for Touchkin to request third party partner service providers or agents to help Us process and/or store Your Information. We strictly evaluate the partner service providers and agents, and We make every effort to ensure that they have established appropriate and secure Information administration and organizational control systems, and We strictly require that they comply with confidentiality obligations and applicable laws and regulations including Data Protection Law as relevant.  We also require that they access Your Information only to the extent necessary to perform tasks on Our behalf.

  6. Does Touchkin give Your Information to third parties?

    Other than as described in this Assistant Policy and, where relevant, other applicable privacy policies or addendums, Touchkin will never provide Your Information to any third parties without Your explicit consent, unless We believe in good faith that We are required or permitted to do so under applicable contracts and laws, or to protect and defend Touchkin’s rights and/or property.

    As required by Data Protection Law and as per the agreements executed with business associates, third-party health coaches and partners must protect the privacy of data Wysa will share with them and they are required to keep Your Information private and secure.

    We may be involved in the transaction of a merger, acquisition, sale of assets, business re-organization, bankruptcy etc. During such a process, We may sell, transfer or otherwise share some or all of Our assets which may include Your Information. However, in such an event of sale or transfer, We shall reasonably ensure that Your Information collected and stored by the Us is stored and used by the transferee in a manner that is consistent with this Assistant Policy. Any such third party to whom We transfer or sell shall have the right to continue to use the Information that You provide to Us or collected by Us immediately prior to such transfer or sale. On completion of the sale or transfer, the Assistant Policy of the third party shall apply with respect to Your Information. To stay updated about such business transactions, please read this Assistant Policy from time to time.

  7. Does Touchkin use third-party modules?

    Touchkin uses third party advertising agencies to place advertisements on the internet or in other media. To measure the effectiveness of the advertisements to determine how much to pay to the advertising agencies, We may install third-party modules within the Voice Assistant.  We may also install other third-party modules within the Voice Assistant in order to deliver the Service and help Us understand how the Service is used.

  8. What are Your data protection rights?

    You have certain rights under the Data Protection Law in relation to the Personal Information that You share with Us. We have tried to make it as easy as possible for You to have control over Your Personal Information. To exercise any of Your rights, please email a request at the contact Information provided in section 7.b. Please note that We will require You to verify Your identity before responding to any requests to exercise Your rights. We may also limit Your individual rights requests (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other's privacy; (c) to protect our rights and properties; or (d) where the request is unjustified or excessive.

    If You have provided and We process Your Personal Information based on this contract, You can always send Us a written email request at the contact Information provided in section 7.b at any time to check, rectify, erase or restrict processing of Your Personal Information.

    Upon verification of Your identity, We will respond to Your request within one month and in accordance with relevant Data Protection Law. Touchkin will provide You with a request form that You will need to fill and submit back to Us via email. We will verify and erase only the specific identifiable Information as requested by You, within 72 hours of receiving the filled request form.

    You have the right to object to processing of Your Personal Information that is based on legitimate interests for the purposes explicitly mentioned in section 6.a by sending Us a written email request at the contact Information provided in section 7.b.

    PLEASE NOTE THAT WHEN YOU CLOSE YOUR WEB BROWSER OR THE VOICE ASSISTANT, YOUR EXISTING SESSION WILL END AND YOU WILL NOT BE ABLE TO ACCESS YOUR PAST INFORMATION OR SESSION CONVERSATION. You have the right of data portability to receive digital copy of Your Personal Information in a machine readable format. You can send Us a written email request at the contact Information provided in section 7.b. Upon verification of Your identity, We will respond to Your request within one month and in accordance with relevant Data Protection Law. We may charge You a small fee for this service. We do not ask any Personal Information during Your use of Service. We may at times be unable to address Your request, if We are unable to correctly identify You.

    If You are not happy about any aspect of the way We collect, share or Use Your Personal Information, please let Us know at the contact Information provided in section 7.b. You have the right to complain to a Data Protection supervisory authority in Your state of residence.

7. Additional information for You

  1. Can children under 13 use Voice Assistant?

    The Voice Assistant is intended for a general audience and is not directed to or intended to be used by children under the age of thirteen (13) years.

    We understand the special necessity to protect children's privacy on Voice Assistant, and We do not knowingly collect any Personal Information from children.

    If, however, You believe We have collected any Personal Information from children, then please send Us a written request. Refer to Section 7.b for Our contact details.

    If We learn that We have inadvertently collected Personal Information from children, We will deactivate the relevant account(s) upon identification and will take reasonable measures to promptly delete such Personal Information from Our records.

  2. Who can You contact for additional questions, comments or concerns?

    If You have any questions, comments, concerns, grievance about this Assistant Policy or our other privacy policies or practices, please contact our grievance officer Mr. Ramakant Vempati at [email protected] or by writing to:

    Touchkin eServices Private Limited
    Attn: Assistant Policy
    1st Floor, Manjusha, No 532
    16th Cross, 2nd Main Road, 2nd Stage
    Indiranagar, Bangalore, 560038
    Karnataka - INDIA

    For any technical issues, please contact us at [email protected] with Your questions

  3. Can Non-English speaking users use the Voice Assistant?

    The Voice Assistant has been built and is currently provided only for English language users.

    To ensure wider reach, Touchkin will, in the near future, launch Apps in other international languages. We will keep You updated of this development.

  4. What are some Best Practices to follow to keep Your devices secure?

    You are also responsible for helping to protect the security of Your Personal Information. You are responsible for maintaining the security of any personal computing device on which You utilize the Services.

    US Federal Trade Commission (FTC) publishes Information for Users on how to secure Your Personal Information and devices. These can be found at the following public link.

    FTC - How to Keep Your Personal Information Secure

    Touchkin strongly believes in security and safety of Information in Your device. As a responsible service provider, We therefore like to share important device based security Information for Your attention. These have been sourced from US FTC best practices and guidelines. Always refer back to the US FTC link provided above for more details and future security updates.

    • Always lock Your device screen by setting a password. Use strong passwords and keep passwords private. Never leave Your device unattended.
    • Always keep Your device operating system up-to-date.
    • Enable remote access of Your devices to enable You to locate and control Your devices remotely in the event Your device gets stolen.
    • Install anti-virus software to protect against virus attacks and infections
    • Avoid phishing emails. Do not open files, click on links or download programs sent by strangers
    • Be wise about Using Wi-Fi. Before You send Personal Information over Your laptop or mobile device on a public wireless network in a coffee shop, library, airport, hotel, or other public place, see if Your Information will be protected.

8. Changes to this Assistant Policy

We may modify Our Assistant Policy from time to time for various reasons including to improve Our privacy practices, to reflect changes to Our Service, and to comply with relevant laws.

If and when this Assistant Policy is changed, We will post this Information on our Website and provide You with a copy of the revised notice upon Your request or as otherwise required by relevant law. It is Your responsibility to check Our Website and the apps periodically for updates or changes to Our Assistant Policy. We encourage You to review changes carefully. If You agree to the changes, then please continue to use Our Service. If You, however, do not agree to any of the changes and You no longer wish to use Our service, You may choose to unsubscribe service or close Your account. Continuing to use Our Service after a notice of change has been communicated to You or published on Our Service constitutes Your acceptance of changes and consent to the modified Assistant Policy.

9. Severability and Exclusion

We have taken every effort to ensure that this Assistant Policy adheres with the applicable laws, including the Data Protection Law. The invalidity or unenforceability of any part of this Assistant Policy shall not prejudice or affect the validity or enforceability of the remainder of this Assistant Policy. This Assistant Policy does not apply to any Information other than the Information collected by Touchkin while providing the Services.

10. Governing Law and Dispute Resolution

This Assistant Policy shall be governed by and construed in accordance with the laws of the India. The courts at Bangalore, India shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Assistant Policy.

Touchkin is a company based in India. By browsing/using the Services, You hereby acknowledge that Touchkin is not responsible or liable in any manner to comply with any local laws of Your territory except India.