Wysa Privacy Policy

Welcome to Wysa's Privacy Policy.

Welcome to Wysa, the mobile and online service of Touchkin eServices Private Limited ("Touchkin," "we," "us," or "our"). When you use Touchkin's services, you trust us with your information. This Privacy Policy governs your use of the software application Wysa for mobile devices ("Wysa" or the "Wysa app"), created by Touchkin. It is meant to help you understand what data we collect, why we collect it, and what we do with it. This is important; we hope you will take time to read it carefully.

Introduction

We at Touchkin, believe your privacy is very important.

We will always respect and protect your privacy, and this deeply informs our guiding principles.

a. Your trust means a lot to us. We will always tell you of any personal information that we collect, and will take your permission before asking you to share it with us.

b. We will clearly identify why we need this information.

c. We will collect only the minimum information necessary to provide our services to you. For example, we don't ask for your phone number, email, or your gender, or your age. We don't have to have it, hence we don't ask for it.

d. If we collect it at any time, we will protect your personal information. We respect your privacy and protect it with strong encryption, plus strict policies that govern how all data is stored and handled.

e. We will only use your information for a specific reason, with your consent or as required or permitted by law. We will keep your information only as long as necessary.

f. We will try and help you keep your personal information accurate and complete.

g. We will make our policies and practices in handling personal information transparent.

h. You will have access to your personal information and will be able to correct it.

i. We will be accountable to you. We want to hear your opinion on how we're doing against these principles, this Privacy Policy, and applicable law.

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 don't build a profile based on your content or browsing habits to sell to advertisers.

We don't 'monetize' the information you store with us.

We don't read your messages to get information and then send you unwanted content.

We can only meet our mission if we have earned your trust.

2. The Application (Wysa App)

Wysa, the Wysa app, is a virtual AI chatbot that users can chat with, and through a conversational interface get access to tools and techniques to manage stress and moods. The Wysa app is available in iOS or Android.

3. What this Privacy Policy applies to

This Privacy Policy explains how Touchkin will handle and safeguard your personal information, and the choices you have to access and control your personal information. This Privacy Policy applies to personal information you provide us when you use the Wysa app ("Wysa App"), optional services made available within the Wysa App, and other apps that integrate with or work in conjunction with the Wysa App (collectively "Apps"), personal information you provide us when you visit websites maintained by us relating to our Apps ("Websites") (Apps and Websites are collectively referred to as the "Service"); and personal information about you that is provided by users of the Service.

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 Privacy 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 privacy policy or addendum which applies in addition to, and may modify this Privacy Policy, before you can access the additional service.

3. What information does Touchkin collect and how is it used?

To provide you our Service, Touchkin collects and uses the following types of information:

USER PROVIDED INFORMATION


i. During sign up

When you download and set up Wysa, you don't need to go through a sign up process.

From time to time we may collect some information from you during sign-up for research purposes. This will always be done with your consent, and you will know the purpose for which the information will get used.


ii. During in-app use

All conversations you have with Wysa are private, and are not shared with any third parties at any time. This includes information provided by you such as, personal information, location & time information and any other information shared by you during the conversation.

AUTOMATICALLY COLLECTED INFORMATION


i. Device information and access logs when you use our Service

When you use the Service or visit our Website, we may obtain and maintain certain electronic identification or log data from your mobile device or personal computer such as: OS type, IP address, browser information including type and language settings, device identifier or mobile application identifier.

We use this information to detect and deter unauthorized or fraudulent use of or abuse of the Service, and to optimize your experience eg make sure the Wysa app is displayed correctly on your phone, or your usage settings are applied.


ii. Other (optional) information

To improve your experience, we could provide additional functions, like the ability to access your account from multiple devices, or in general, help you get more out of Touchkin. If you choose to use such functions, we may ask you for some more information:


OPTIONAL: Contact Telephone numbers in your address book

If you want to invite friends or contacts to use the Wysa App, you may send them invitations directly via SMS, Whatsapp or e-mail directly from your mobile device using the address book in your mobile phone. When you use the invitation (under "Settings -> "Share") function in the Wysa App, we will access your address book to identify your friends. After your friend(s) have been identified, you can send invitations directly to individual friends and contact via SMS or e-mail on your mobile device telephone. Touchkin does not send invitations as part of this Service – only you do.

Further, we will only show information from the telephone number fields in your mobile device's address book; we do not collect contact names or any information from other data fields.


OPTIONAL: Location Information

To use the Wysa App, you are not required to provide your location information ("geolocation"). However, we provide features that utilize geolocation for your convenience and to improve your experience. For example, you might need additional support or services when travelling.


In all cases, collection and use of your geolocation is one-time-only (ad hoc), so we delete the geolocation after we use it and do not retain it. Also, we do not aggregate your geolocation to create a history.


In other cases where we collect or use your geolocation data in an additional separate service, we will make sure that we provide notice and/or obtain your consent.


You can turn off location sharing at any time using your phone settings.


v. 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 commuter 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.


vi. 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 (e.g., name, mailing address, 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.


vii. OPTIONAL: Payment Information

If you choose to purchase or use a fee-based service and pay for such service by means other than in-app purchases via iTunes or Google Play, we may need to collect your credit card information. We will use your credit card information only to process your purchase or use our fee-based service. Please note that, we will not retain your credit card information because your credit-card settlement will be handled by appropriate third party payment agencies.



4. How we use and handle your Information


a. How does Touchkin use my information?

To provide the Service, Touchkin, as a data controller or joint data controller, may use your information for the following purposes:

• to provide you the Service via your mobile phone or personal computer and to allow you to transmit your user-generated content to other Touchkin users;

• to verify your identity;

• to allow you to use your Touchkin account on multiple devices and transfer your Touchkin account to another device;

• to help you find people you know that already are Touchkin users so that you can connect using Touchkin; and, upon your request, to allow other Touchkin users to connect with you;

• to enable you to sync other applications offered by Touchkin, Touchkin affiliates, and Touchkin business partners together with your Touchkin account and to share information between the applications you use;

• to respond to requests you may make to use services provided by Touchkin other than the Wysa app service;

• to detect and deter unauthorized or fraudulent use of or abuse of the Service;

• to improve and/or optimize the Service;

• to enable us to provide customer support, and to respond effectively to your inquiries and claims;

• to conduct user satisfaction surveys;

• to provide you with information regarding the Service;

• to measure the effectiveness of advertisements that we may place on the Internet or in other media;

• to notify users of any other important information regarding the Service, if necessary;

• to identify winners of promotional contests, to send gifts to those winners, and to deliver purchased products and the like;

• to aggregate anonymized statistical data regarding the Service; and

• to comply with applicable laws or legal obligations.

• If, however, we provide you with more specific purpose(s) of use either at the time we ask you to provide your personal information or through another means, then such notice will take precedence over the general purposes of use stated in this Section 4.a of this Privacy Policy.


b. How does Touchkin protect my information?

To fulfil our commitment to respecting and protecting your privacy and the confidentiality of your information, Touchkin has implemented industry-standard safeguards to prevent unauthorized access or disclosure, misuse, alternation, or destruction of your information. More specifically, we are working with hosting and data centre partners with certifications like ISO/IEC 27001:2005, in order to assure security, availability, processing integrity, confidentiality and privacy of data. All information between the Wysa app and server is encrypted and transmitted via SSL. We also plan to extend our data security to best-in-class level, especially for health data, by selecting partners who will be compliant under HIPAA (Health Insurance Portability and Accountability Act).


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 personally identifiable information with other people. Also, please notify us in the event you suspect any unauthorized use of your account or any other breach of security via our contact information.


c. Where is my 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 the European Economic Area.


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.


d. How long does Touchkin keep my information?

Touchkin retains any personal information you provide while your account is in existence, for the length of time needed to fulfil any of the applicable purposes of use described in this Privacy Policy, or to comply with applicable laws and regulations.

We may retain your personal information even after your account is closed if retention is reasonably necessary. These could be in situations where we need to comply with applicable laws, regulations 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.


e. 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 personal 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 applicable laws and regulations. We also require that they access your personal information only the extent necessary to perform tasks on our behalf.


f. Does Touchkin give my information to third parties?

Other than as described in this Privacy Policy and, where relevant, other applicable privacy policies or addendums, Touchkin will never provide your information to any third parties without your consent, unless we believe in good faith that we are required or permitted to do so under applicable laws or to protect and defend Touchkin's rights and/or property.


h. 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 Apps. We may also install third-party modules within the Apps in order to deliver the Service and help us understand how the Service is used.


5. Your choices and your rights

It is possible that Touchkin obtains personal information relating to individuals who are currently not users of the Service. Regardless of whether or not you are a user of the Service, you have the choices and rights under this section if we hold your personal information.


a. How do I control my information?

Touchkin has tried to make it as easy as possible for you to have control over your personal information. If we hold your personal information, you can always send us a written request at any time to confirm, correct, block, or delete any other personal information that we hold which cannot be confirmed directly on the Wysa App. Upon verification of your identity, we will respond to your request within a reasonable period of time and in accordance with relevant law. To check, correct, block, or delete your information, please contact us via this Contact Form. If you would like to send us a written request, please refer to Section 6.b for our mailing address.


If you no longer wish to use the Service or if you no longer wish to consent to Touchkin's collection and use of your personal information, you may choose to delete your entire account directly by uninstalling the Wysa App. We will take reasonable measures to delete your information in accordance with Section 4.d.


6. Other important information for you

a. A special note about children in the United States of America

The Wysa App service is intended for a general audience and is not directed to or intended be used by children under the age of 13 ("Children").


We understand the special necessity to protect children's privacy on Touchkin, 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 let us know via this Contact Form. If you would like to send us a written request, please refer to Section 6.b for our mailing address.


If we learn that we have inadvertently collected personal information from Children, we will deactivate the relevant account(s) and will take reasonable measures to promptly delete such personal information from our records.



b. I have questions, comments or concerns

If you have any questions, comments, or concerns about this Privacy Policy or our other privacy policies or practices, please contact us at wysa@touchkin.com or by writing to:

Touchkin eServices Private Limited
Attn: Privacy Policy
First Floor, 'Manjusha',
17th Cross, 2nd Main,
Indira Nagar II Stage, Hoysala Nagar,
Indiranagar,
Bengaluru,
Karnataka - 560038.
OR
Email us : feedback@touchkin.com

c. Changes to this Privacy Policy

We may modify our Privacy 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 law. The last time we updated this Privacy Policy was on 30th of June, 2017.


When we make any material changes to our Privacy Policy, we will provide notice to you on our Service, or by other reasonable means. 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 close your account. Continuing to use our Service after a notice of changes has been communicated to you or published on our Service constitutes your acceptance of changes and consent to the modified Privacy Policy.