Back to touchly

Privacy Policy

Last updated: October 17, 2026

This policy describes the website, including the contact form and survey, and local storage of the Halloween unlock and survey invitation in the app.

Controller

Sven Petersen
Moltkestraße 4
24937 Flensburg
Germany
Email: contact@touchly.net

Who this website is for

This website is intended for parents and caregivers. The contact form is not intended for children. Please do not send children's names, photos, health information, location details, or other personal information about a child through the form.

Data we process

Purposes and legal bases

For EU/EEA users, the legal bases are legitimate interests in operating and securing the website, pre-contractual or contractual communication when responding to requests, and compliance with legal duties where applicable.

Touchly survey and Halloween unlock

Participation, data and purpose

The voluntary survey is for adult parents and caregivers who have already tried Touchly. We ask about the main child's age range, how you heard about Touchly, usage frequency and situations, experiences with the app and Guided Access, pricing and improvement suggestions. Fields marked optional may be left blank. No name, email address, exact date of birth or participant account is required. Please do not include information that could identify a child, especially names, health information or location details.

The survey function transmits your answers and selected language only when you submit. The server adds the receipt time. Transmission to the website uses HTTPS. Answers are emailed to survey@touchly.net to evaluate feedback and improve Touchly. The controller has access; STRATO provides hosting and email services. No database of survey responses is created. Unsubmitted answers are not transmitted to us by the survey function.

Legal basis and right to object

Where answers or technical data are personal data, we rely on Article 6(1)(f) GDPR for the limited evaluation of voluntarily provided product feedback and secure operation of the survey. Our legitimate interests are identifying usage problems, improving Touchly based on actual experiences and limiting abusive submissions. We do not request contact details, use answers for personalised advertising or link them to a user account. Personal information about children provided inadvertently is not needed for evaluation and is removed or anonymised.

You may object to processing on this basis on grounds relating to your particular situation under Article 21 GDPR. Contact contact@touchly.net. We will stop the processing concerned unless the legal requirements for continuing it apply. As no participant account is maintained, we may be unable to identify a particular response. In that case, provide only the information needed to locate it, such as the approximate submission time and a description of your answer. Additional information about a child is not required.

Retention of survey responses

We delete original survey responses, including the emails, after evaluation is complete and no later than six months after receipt, or convert them into a permanently anonymised form by then. Permanently anonymised, aggregated findings may be kept longer to improve the product. Requests to exercise your rights follow the separate retention period for contact messages and are not included in survey analysis. The counter files and local app settings described above have separate retention periods.

Technical data and spam protection

Accessing and submitting the survey may create hosting server logs, for example including the IP address, time, requested page and browser information. The survey email does not contain an IP address or device identifier added by the survey function.

To limit repeated submissions, the server uses a hash derived from the IP address and timestamps in a temporary file. Hashing does not automatically make an IP address anonymous. The counter considers the preceding 60 minutes. Files not updated for more than 24 hours are cleaned up on the next technically valid survey submission attempt; without such an attempt, a file may remain longer. No answers or raw IP addresses are written to counter files. Hosting provider server logs are separate from these counters.

Unlock code and local app storage

After a successful submission, a general Halloween campaign code is displayed directly on the completion page. No personal email address or user account is needed. The app checks the code locally and stores on your device whether Halloween is unlocked and whether the startup survey invitation has already been shown. These settings remain until the relevant app data is reset or deleted.

The code entered and local status settings are not transmitted to us by this unlock function. There is no automatic matching of survey responses to device unlocks. Where local information necessary for the requested unlock is personal data, it is processed to provide that feature under Article 6(1)(b) GDPR. Later deletion of survey responses or an objection does not revoke an existing unlock. See the participation terms for details of the campaign.

Cookies and similar technologies

The website currently uses a language preference cookie. It does not intentionally use advertising cookies, analytics cookies, tracking pixels or newsletter tracking. The video preview is served as a file from the website server without an external video player. If these are added later, this policy and any consent flow must be updated first.

External resources

The website loads Bootstrap from jsDelivr, Font Awesome from cdnjs, and the Baloo 2 font from Google Fonts. When these resources load, the visitor's browser may contact those providers directly and transmit technical information such as the IP address.

Recipients and processors

Contact messages are sent by email to contact@touchly.net. The website and email service are hosted by STRATO. External resource providers include jsDelivr, cdnjs and Google Fonts. If you follow the App Store link, Apple may process data under its own terms and privacy policy.

Retention

Contact messages are kept for up to 12 months after the last interaction, unless a longer period is required to handle an ongoing request, protect legal interests, or comply with legal duties.

Your rights

Subject to the GDPR, you have rights including access, rectification, erasure and restriction of processing, and data portability where the legal requirements apply. The right to object to processing based on legitimate interests is described separately above. You may complain to a data protection supervisory authority.

You may complain in particular to the Independent Centre for Data Protection Schleswig-Holstein or another competent supervisory authority, including one where you live or work. Contact us at contact@touchly.net about your rights.

Children's privacy

The website does not intentionally collect personal information from children. If you believe a child has sent personal information, contact us so it can be deleted.

International transfers

External providers may process technical data outside your country. Where required, transfers are based on adequacy decisions, Standard Contractual Clauses, or other appropriate safeguards.