Versao em Portugues

Privacy Policy

Last updated: March 1, 2026

1. Introduction

touch irl, LLC ("Touch?", "we", "us") values your privacy. This Policy describes how we collect, use, store, and protect your personal data when you use the Touch? application and related services.

This Policy has been prepared in compliance with the California Consumer Privacy Act (CCPA/CPRA), the Children's Online Privacy Protection Act (COPPA), the General Data Protection Regulation (GDPR), Brazil's General Data Protection Law (LGPD), and other applicable legislation.

2. Data Controller

Company: touch irl, LLC
Jurisdiction: Delaware, United States
Email: privacy@touchirl.com
Website: touch-irl.com

3. Data We Collect

3.1. Data you provide

DataPurposeLegal basis
NicknameAnonymous identificationContract performance
EmailAuthentication, communicationContract performance
Date of birthAge verification (18+), zodiacLegal obligation
Profile photoPersonalization (optional)Consent
Real name, Instagram, phoneReveal feature (optional)Consent

3.2. Data collected automatically

DataPurposeLegal basis
GPS locationProximity and eventsConsent
Ultrasonic audioProximity detection (processed locally)Consent
Device dataCompatibility, securityLegitimate interest
Connection historyApp functionalityContract performance
Chat messagesUser communicationContract performance

3.3. Sensitive data (biometric)

Facial verification (selfie): Used optionally for identity verification. The image is stored securely and you may request its deletion at any time. This data is considered sensitive under GDPR, LGPD, and CCPA/CPRA, and requires specific consent.

4. How We Use Your Data

5. Data Sharing

We do not sell your personal data.

We share data only with:

6. Data Retention

Data typeRetention period
Account dataWhile account is active + 30 days after deletion
Chat messages24 hours (expire automatically with the connection)
Connection historyWhile account is active
Payment data5 years (tax obligation)
Verification selfieUntil deletion request or account termination
Security logs90 days

7. Your Rights (All Users)

Depending on your jurisdiction, you have the following rights:

To exercise any right, email privacy@touchirl.com. We will respond within 15 business days (or as required by applicable law).

8. California Residents (CCPA/CPRA)

If you are a California resident, you have the right to: know what personal information we collect, request deletion of your data, not be discriminated against for exercising your rights, and opt out of the sale of your personal information. We do not sell personal information.

To exercise your rights, email privacy@touchirl.com with the subject "CCPA Request".

9. Protection of Minors

Touch? is intended exclusively for users aged 18 and older. We do not knowingly collect data from anyone under 18. If we identify that a minor is using the service, the account will be terminated and data deleted within 72 hours.

Parents or guardians who believe a minor has provided data to Touch? may contact us at safety@touchirl.com for immediate deletion.

10. Security

We implement technical and organizational measures to protect your data, including:

No system is 100% secure. In case of a security incident, we will notify affected users and competent authorities as required by law.

11. Cookies and Local Storage

Touch? uses browser localStorage to maintain your session and preferences. We do not use third-party tracking cookies. Locally stored data includes: session ID, language preferences, app settings.

12. Changes to This Policy

This Policy may be updated periodically. Significant changes will be communicated within the App. The last update date will always be indicated at the top of this document.

13. Contact

For privacy questions, exercising rights, or complaints:

Touch? -- touch irl, LLC. All rights reserved.