Effective Date: June 20, 2023
- Services we provide to Site visitors (“Website Users”) and services we provide directly to individuals (“Users”) – we are a “data controller” for this information; and
- Services we provide to employees (“Employees”) of our business customers –we are a “data processor” for this information.
Click on the links below to jump to each section:
1. INFORMATION WE COLLECT
The categories of information we collect from Website Users, Employees, and Users may include:
Identification Information you provide to us directly. We may collect personal information, such as your name, phone number, location, and email address when you use or register for our Service.
Creating Accounts. When you create an account through our StayTouch service, you need to provide us with your name, mobile number, email, and a password.
- Third Party Account Information: If you choose to connect third party accounts to the Services (e.g. Google) to sign-up for an account with StayTouch, we may collect information associated with your third party account such as the name, email address, and profile information you provided to the relevant third party. If you sign-up for the StayTouch Service using a third-party platform, we will collect information about your authentication directly from that platform. Please note that your use of the third-party platform’s sign-in tool will be subject to the applicable third-party’s terms.
If you subscribe to our StayTouch Premium Service, you will need to provide us with your subscription preferences and payment information such as your credit card number, billing address, and other authentication details. Payments will be processed by the mobile platform provider (e.g., Apple, Google), and we will receive information about the transactions from the provider. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers. Your account information is not visible to your contacts.
Creating Profiles. When you create a profile, you have full control over the information included in the profile such as your photo, education, work experience, skills, or contact information (e.g. email, phone number, or mailing address) or links to social media accounts. If you upload a photo, we may request access to the camera roll and camera on your mobile device. You may withdraw this permission to access your device’s camera roll and camera at any time through the ‘Settings’ in your mobile device’s app. Your profile information is different from your StayTouch account information, and is only visible to people who have added you as a contact through StayTouch (unless you declined their request to share your contact info) or who you shared your profile information through email or your phone’s native SMS text messaging app.
If you subscribe to the StayTouch Premium Service, you are able to create multiple profiles with the same or different information. You are the master of your contact information and can choose what information to include in each profile.
Please note that we do not require you to include sensitive information in your profile such as date of birth, race, ethnicity, biometrics, medical information, financial information or social security number. Please do not include sensitive information in your profile. If you choose to include such information, it will be visible to those with whom you have shared your profile as described above.
Communications With Us. We receive your personal information such as name, email address, or phone number when you sign up for our mailing list, fill out a survey, or otherwise communicate with us. We may also collect any communications between you and us, and any other information you provide to us.
Marketing Information. We may collect your preferences for receiving our marketing communications, and details about your engagement with them.
Voice Notes. With your permission, we collect voice notes and request access to the microphone on your mobile device in order to facilitate collecting the voice notes. You may withdraw this permission to access your device’s microphone at any time through the “Settings” in your mobile device’s app. Voice notes are intended for your own individual use so you can record information about your contacts. Voice notes should not be used to record others. We are not responsible for the recording of any third parties through the use of voice notes. Therefore, if you will use voice notes, you agree to comply with all applicable laws, whether federal, state, local or international, relating to the privacy of communications, including advising all participants in a recorded conversation that the conversation is being recorded and obtaining their consent, as required. We may also send voice notes to our sub-processor for transcription.
Address Book and Calendar Information. With your permission, we may request access to your contacts or calendar information available on your mobile device or through your email accounts and import or sync contact and calendar information with StayTouch. To help you connect with people you know, we may also receive your personal information when others authorize importing or syncing their contacts or calendar with StayTouch. You can turn off syncing at any time or choose to manually add contacts or calendar information.
You choose who to invite or send your Virtual Contact File (“vCard”). If you choose to send invitations via text message, the standard rates may apply. When inviting your contacts to connect via StayTouch, we use third-party service providers to facilitate sending your emails or texts. Please note that you are the sender of these messages. Only send invitations to contacts you know personally that are interested in using the Service.
Communications with Others. When you use the chat to communicate with other users, we transmit the messages, photos and videos that you upload to your intended recipients. Please note that we are not responsible for any recipient’s use of the information you send. We do not have access to the contents of the chat communications.
Social Media Information. We have pages on social media sites like Facebook, Instagram, and YouTube (“Social Media Pages”). When you interact with our Social Media Pages, we will collect personal information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Information from Other Sources. We may receive information about you from third parties and combine this information with other information we collect from or about you. For example, we may receive your information when someone uploads to StayTouch your contact information that is stored on their phone or address book. We may also receive your information from third parties such as distribution partners, data services, and marketing firms.
For more information about your communication preferences, see “Control Over Your Information” below.
We Process Employees’ Professional Information on Behalf of Our Customers. In order to provide easy connections between contacts, we collect photos, chat communications, voice notes, address book information, calendar information, and other data from Employees. We process that data, including any personal information contained within it, pursuant to our agreements with our business customers. We have no direct relationship with the Employees whose personal information we process in the course of providing our contact information tool to our customers. If you are such an individual and have questions about the processing of your information, please contact the business customer that you interact with directly.
Where an Employee is also a User (i.e., one individual has both professional and personal accounts), the relevant customer may permit that Employee to keep certain information collected through the Employee’s professional account after the Employee’s employment relationship with the customer ends.
Usage Information. We, and our third-party partners, automatically collect certain types of usage information when you visit our Sites, use or Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”).
We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:
Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, computer, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
Information about the way you access and use our Service, for example, the site from which you came and the site to which you are going when you leave our Service, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, whether you accepted a contact, how long you spent on a page or screen, information about your activity on a page or screen, access times, and duration of access, and whether or you have opened our marketing emails or clicked links within them, and other actions you take on the Service.
Analytics. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
Cookies Opt Out. Cookies are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe’s website. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.
For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.
2. HOW WE USE YOUR INFORMATION
We may use your information for the following purposes:
To update your in-app contacts with the latest profile information, enable you to send your vCard and invite others to join the Service and connect with you, and take advantage of StayTouch features such as chat, connection analytics (e.g. how many times you’ve met with a person, extent of meetings), or meeting reminders.
To complete your transactions and requests, and to operate, maintain, improve, and provide to you the features and functionality of the Service, including the StayTouch Premium Service.
To communicate directly with you, such as to send you Service-related emails and push notifications (e.g., account verification, updates to features of the Service, technical and security notices). We may also send you promotional messages, including email messages and push notifications, from us and from our partners. You may change your communications preferences at any time, see the Control Over Your Information section below. Please note that you are not able to opt-out of receiving service messages from us, including security and legal notices.
To remember your information so you will not have to re-enter it during a subsequent visit; help you efficiently access your information after you sign in; provide, improve, test, update and monitor the Service; or diagnose or fix technology problems.
To identify potential customers who are using our services for marketing purposes.
To enable you to participate in the interactive features of the Service (such as engaging in surveys or promotions).
To comply and fulfill our legal duties and obligations such as tax and accounting purposes.
To ensure the security of our products and services and preventing abuse.
To ensure the security of our IT environments and protection of data.
To respond to your emails, comments, questions or requests for customer service.
For any other purpose we may describe when you provide the information.
4. CONTROL OVER YOUR INFORMATION
Profile and Data Sharing Settings. You may update your profile information, such as your company name, job title, and profile photo etc. by editing information on your user profile(s) screen(s) and may change some of your data sharing preferences on your Settings page or by emailing us at firstname.lastname@example.org.
Access to Your Device Information. You may control the App’s access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the App to access your address book, location, photo stream, and camera.
How to Control Your Email/Marketing Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
How to Control Push Notifications. You can stop receiving push notifications from us by changing your preferences on your Settings page, by clicking on send notifications tabs on screens such as favorites in your StayTouch contact book, or by emailing us at email@example.com.
Modifying or Deleting Information. Users with questions about reviewing, modifying, or deleting your information, or who want to remove their name or comments from our Service or publicly displayed content, can contact us directly at firstname.lastname@example.org. We may not be able to modify or delete your information in all circumstances. For example, if you are an Employee, we modify or delete information in accordance with the terms of our agreement with the relevant customer.
5. THIRD-PARTY TRACKING AND ONLINE ADVERTISING
Interest-Based Advertising. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our website over time so that they may play or display ads on our Service, on other devices you may use, and on other websites, apps, or services, including on Facebook. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
Social Media Advertising. We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
Cross-Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-party partners who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.
Interest-Based Advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices and/or the DAA’s resources at www.aboutads.info/choices .
Cross-Device Linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
Mobile Advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some—but not all—interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps”. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/ .
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/lireferences , or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
6. DATA RETENTION
We may retain your information as long as appropriate for business purposes, unless we are required by law or regulation or for litigation and regulatory investigations to keep it for longer periods of time. Any personal information that we have acquired, either directly or from third parties, and that is no longer needed for any business or record-keeping purposes, is disposed of securely and in compliance with established best practices for secure data destruction and/or deidentification.
7. CONFIDENTIALITY AND SECURITY
We maintain commercially reasonable physical, electronic, and procedural safeguards designed to protect the information. These safeguards include storing your information on our secure servers behind firewalls. Despite the actions and precautions, we take, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of the information and you acknowledge and agree that you transmit it to us at your own risk. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose personal information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
8. CHILDREN’S PRIVACY
We do not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information. If you believe that we might have any information from a child under 13, please contact us at email@example.com.
10. CALIFORNIA PRIVACY RIGHTS
Where provided for by law and subject to any applicable exceptions, California residents may have the right:
- To know the categories of personal information that StayTouch has collected about you, the business purpose for collecting your personal information, and the categories of sources from which the personal information was collected;
- To access the specific pieces of personal information that StayTouch has collected about you;
- To know whether StayTouch has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information;
- To have StayTouch, under certain circumstances, delete your personal information;
- To instruct businesses that sell personal information to stop doing so – StayTouch, however, does not sell personal information; and
- To be free from discrimination related to the exercise of these rights.
Users who would like to exercise any or all of these rights may do so by filling out the form here or contacting us as set forth below. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request. Employees should direct their requests to the relevant customer.
11. EU USERS
Scope. This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway, the United Kingdom, and, to the extent applicable, Switzerland).
Legal Bases for Processing. We process Employees’ information pursuant to our contracts with our customers. The specific purposes for which we process Users’ personal information and the legal bases we rely on for the processing are listed below.
|Category of information||How we use it||Legal basis for processing|
|We use this information to send you Service-related emails and messages (for example, account verification, updates to features of the Service, technical and security notices).||This processing is necessary for our legitimate interests, namely, administering the Service and communicating with you in connection with the Service.|
|We use this information to send you promotional messages, including email messages and push notifications, from us and from our partners.||We will only process your personal information in this way to the extent you have given us consent to do so.|
|We use this information to provide to you the features and functionality of the Service.|
|Information collected from or via your device. Such as voice recordings and information contained in your address book and calendar information.||
With your permission, we:
||We will only process your personal information in this way to the extent you have given us consent to do so.|
|Information collected from other sources. We may receive information about you from third parties and other users.||We may combine this information with the information we collect from you directly. We use this information to enhance or supplement our existing user information, to send you advertising or promotional materials or to personalize the Service, and to better understand the demographics of our users.||The processing is necessary for our legitimate interests, namely to tailor the Service to the user and to improve the Service generally.|
|Information received from social networks. If you interact with the Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social networks.||We use this information to authenticate you and allow you to access the Service, as well as to populate your profile with your contact information (such as your name and email address).|
|Subscription information. Such as whether you have subscribed for any premium features on our Services..||We use this information to give you access to the premium features you have subscribed for within the Service.|
|Comments, and opinions. When you contact us directly, for example, by email, phone, mail or by completing an online form, we will record your comments and opinions..||To address your questions, issues and concerns and resolve your customer service issues.||The processing is necessary for our legitimate interests, namely communicating with you effectively for the purposes of resolving your issues.|
|Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier , IDFA or Google AdID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modelling tools, which permit us to recognize and contact you across multiple devices.||We use this information to present the Service to you on your device and to enhance and personalize your experience using the Service.||The processing is necessary for our legitimate interests, namely to tailor the Service to you.|
|We use this information to monitor and improve the Service, assess the effectiveness of our advertising and/or referral campaigns, and for other internal purposes||The processing is necessary for our legitimate interests, namely to improve the Service generally, to monitor and resolve issues, to monitor our advertising campaigns and for other internal purposes.|
|Information about the way you access and use the Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take when using the Service.||We use this information to present the Service to you on your device and to enhance and personalize your experience using the Service.||The processing is necessary for our legitimate interests, namely to tailor the Service to you.|
|We use this information to determine news, alerts and other products and services that may be of interest to you for marketing purposes.||The processing is necessary for our legitimate interests, namely to inform our direct marketing.|
|We use this information to monitor and improve the Service, assess the effectiveness of our advertising and/or referral campaigns and for other internal purposes||The processing is necessary for our legitimate interests, namely to improve the Service generally, to monitor and resolve issues, to monitor our advertising campaigns and for other internal purposes.|
|Information about your location, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address.||We use this information to present the Service to you on your device and to enhance and personalize your experience using the Service.||The processing is necessary for our legitimate interests, namely to tailor the Service to you.|
|We use this information to determine news, alerts and other products and services that may be of interest to you for marketing purposes.||The processing is necessary for our legitimate interests, namely to inform our direct marketing.|
|We use this information to monitor and improve the Service, and for other internal purposes||The processing is necessary for our legitimate interests, namely to improve the Service generally, to monitor and resolve issues and for other internal purposes.|
Your Rights. Pursuant to the European Union General Data Protection Regulation (or “GDPR”), you have the following rights in relation to your personal information, under certain circumstances and subject to any applicable exceptions:
- Right of access: If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your personal information is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal information with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal information so you can contact them directly.
- Right to erasure: You may ask us to delete or remove your personal information, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal information with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or “block” the processing of your personal information in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your personal information with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal information so you can contact them directly.
- Right to data portability: You have the right to obtain your personal information from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your personal information in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to object: You may ask us at any time to stop processing your personal information, and we will do so:
- If we are relying on a legitimate interest to process your personal information -- unless we demonstrate compelling legitimate grounds for the processing or we need to process your data in order to establish, exercise, or defend legal claims;
- If we are processing your personal information for direct marketing. We may keep minimum information about you in a suppression list in order to ensure your choices are respected in the future and to comply with data protection laws (such processing is necessary for our and your legitimate interest in pursuing the purposes described above);
- Right to withdraw consent: If we rely on your consent to process your personal information, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the data protection authority that is authorized to hear those concerns (in the UK, the Information Commissioner’s Office (ICO), who can be contacted at https://ico.org.uk/concerns, and in other EU countries the data protection authority of the country in which you are located).
Please see the “Contact Us” section below for information on how to exercise your rights.
StayTouch is headquartered in the U.S. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the EU and UK. Transfers of your personal information to StayTouch in the U.S. are necessary to perform the agreement we have entered into, or are about to enter into, with you.
12. HOW TO CONTACT US