Privacy Policy

Website visitors and prospective customers

When you interact with our website, request information, contact us, sign up for communications, participate in a survey or promotion, or otherwise communicate with Touchstone, we may collect information such as:

• Identifiers, including your name and email address;
• Contact information, including your email address, telephone number, and mailing or shipping address;
• Commercial information, including products purchased, products considered, order information, and transaction history;
• Communications, including information contained in messages, support requests, inquiries, feedback, and other communications you send to us;
• Preferences, such as communication or marketing preferences;
• Survey and research responses, when you voluntarily participate in surveys or other research activities; and
• Other information you voluntarily provide, including information submitted through free-text fields, forms, or customer-support interactions.

Touchstone users

If you create a Touchstone account or use the Touchstone Services, we may collect information that you voluntarily provide, including:

• Account information, such as your name, email address, username, account credentials, and profile information;
• Device configuration information, such as information necessary to connect, configure, authenticate, or manage your Touchstone Device;
• Goals and preferences, including screen-time goals, selected focus settings, app-management preferences, and other settings you choose;
• Journal and reflection content, including text or other content you voluntarily enter into Touchstone's journaling or reflection features;
• Squad and social information, including invitations, group memberships, challenges, and information you choose to make available to other participating users;
• Support information, including information you provide when requesting troubleshooting, customer service, or technical assistance;
• Feedback, including product feedback, survey responses, reviews, or other information you voluntarily provide; and
• Payment and transaction information, as necessary to process purchases or transactions. Payment card information may be collected and processed directly by third-party payment processors rather than stored by Touchstone.

Information you choose to share with other users

Some Touchstone features may allow you to share information with friends, Squad members, or other participating users.

Depending on the feature and your settings, this may include information such as:

• Your name or profile information;
• Participation in a Squad;
• Challenge participation;
• Goals or progress;
• Streaks or achievements;
• Other information expressly presented to you as shareable.

You should carefully consider what information you choose to share through social or accountability features.

Information that you intentionally make available to other Touchstone users may be visible to those users and should not be considered private from them.

Certain Touchstone features require access to information about your smartphone use.

Depending on the platform, permissions you grant, and features you enable, this may include:

Screen-time and application usage information

Touchstone may receive information made available through your device's operating-system frameworks concerning your use of applications and your device.

This may include information such as:

• Amount of time spent using applications;
• Application usage sessions;
• Application categories or identifiers;
• Device pickups or interactions, where supported and enabled;
• Notification-related information, where supported and enabled;
• Focus or blocking activity;
• Information concerning applications you select for blocking or focus; and
• Aggregated or derived measurements concerning your technology-use habits.

The precise information Touchstone receives and stores may vary depending on the operating system and technical implementation.

Apple's Screen Time framework

On supported Apple devices, certain Touchstone features may use Apple's Screen Time APIs and related frameworks.

Apple controls the information made available through these frameworks and the technical mechanisms governing access to it.

Touchstone does not independently control Apple's Screen Time framework and may not be able to identify or access all information associated with your device usage.

The information Touchstone receives may also be limited by Apple's privacy protections, technical restrictions, and the permissions you grant.

Device and Touchstone hardware information

When you connect or use a Touchstone Device, we may collect information necessary to establish and maintain the Device connection and provide related functionality.

This may include:

• Device identifiers;
• Device model or hardware information;
• Firmware or software version;
• Connection status;
• Pairing or configuration information;
• Diagnostic information;
• Device event information; and
• Information necessary to troubleshoot Device functionality.

The Touchstone Device communicates with your smartphone using NFC. It is a passive device with no battery and no independent network connection: it holds no information about you, and it transmits nothing on its own. Any information described in this section is generated by your phone when you tap the Device, not by the Device itself.

Usage, diagnostic, and performance information

We may automatically collect information concerning your use of the Services, including:

• App events and interactions;
• Feature usage;
• Error reports;
• Crash information;
• Performance information;
• Device and operating-system information;
• App version;
• Network information;
• Timestamps; and
• Other technical information necessary to operate, secure, troubleshoot, and improve the Services.

When you visit our website or interact with the Services, we may automatically collect certain technical information.

This may include:

• Internet Protocol (IP) address;
• Browser type and version;
• Operating system;
• Device type;
• Device identifiers;
• Application version;
• Referring and exit pages;
• Pages or screens viewed;
• Date and time of interactions;
• Clickstream information;
• General geographic information derived from IP address;
• Network information;
• Crash and diagnostic information;
• Performance information; and
• Other technical information generated through your interaction with the Services.

We may use cookies, software development kits (“SDKs”), pixels, local storage, logs, and similar technologies to collect some of this information.

We may receive information from third parties that help us operate the Services.

Depending on the Services we offer and the providers we use, these may include:

• Payment processors;
• Shipping and fulfillment providers;
• Authentication providers;
• Cloud hosting and infrastructure providers;
• Customer-support platforms;
• Email and communications providers;
• Analytics providers;
• Advertising and attribution providers;
• Fraud-prevention and security providers;
• App stores and operating-system platforms; and
• Other vendors that provide services on our behalf.

We may also receive information from social media platforms or other third parties when you interact with Touchstone through those services, subject to the applicable third party's privacy practices and your settings with that third party.

We may use third-party analytics providers to help us understand how visitors interact with our website and how users interact with portions of the Services.

These providers may use cookies, SDKs, pixels, or similar technologies to collect information such as:

• Pages visited;
• Features viewed;
• Approximate geographic information;
• Device and browser information;
• Referring sources;
• Time spent on pages;
• Navigation behavior; and
• Other aggregated or pseudonymous usage information.

Analytics information may be used to:

1. understand how our website and Services are used;
2. identify technical problems;
3. improve product design and functionality;
4. measure the effectiveness of marketing campaigns;
5. conduct internal research and analysis; and
6. develop new products and features.

We will identify material third-party analytics providers in this Privacy Policy or through applicable consent and privacy-management mechanisms where required by law.

If Touchstone uses third-party advertising, attribution, or remarketing technologies, those providers may collect information about interactions with our website or marketing communications.

Depending on the technology and applicable law, this information may be used to:

• Measure advertising effectiveness;
• Attribute purchases or sign-ups to marketing campaigns;
• Understand aggregate audience behavior;
• Deliver or measure advertisements;
• Prevent fraudulent advertising activity; or
• Create audience segments for marketing purposes.

We will not intentionally provide third-party advertisers with your individual Touchstone screen-time history, application-usage history, journal entries, or other sensitive behavioral information for the purpose of targeting advertisements to you, unless we clearly disclose such practice and obtain any consent required by applicable law.

You may be able to control cookies and similar technologies through your browser settings or through privacy controls provided on our website.

Depending on your location, we may provide a cookie-consent or privacy-preference mechanism that allows you to accept or reject certain categories of tracking technologies.

Blocking or deleting cookies may affect the availability or functionality of certain website features.

Where required by applicable law, Touchstone will recognize and respond to legally recognized opt-out preference signals, including Global Privacy Control (“GPC”), in accordance with applicable requirements.

The availability and effect of such signals may depend on your browser, device, jurisdiction, and the specific technology involved.

• Create, authenticate, and maintain your account;
• Connect, configure, and operate your Touchstone Device;
• Provide screen-time insights, dashboards, and usage summaries;
• Operate focus sessions, app-blocking, goals, streaks, and reminders;
• Store and display your journal and reflection entries;
• Operate Squads, challenges, and other accountability features;
• Process orders, payments, shipping, returns, and warranty claims; and
• Provide customer support and respond to your requests.

• Diagnose and fix errors, crashes, and performance problems;
• Understand which features are used and how, in order to improve them;
• Develop new features and products;
• Test changes and conduct internal research and analysis; and
• Detect, investigate, and prevent fraud, abuse, and security incidents.

• Send transactional messages about your account, orders, or Device;
• Send service notices, security alerts, and changes to our terms or policies;
• Send reminders and notifications you have enabled;
• Respond to your inquiries; and
• Send marketing communications where permitted, which you can opt out of at any time using the unsubscribe link or by contacting us.

• Comply with legal obligations, including tax, accounting, and consumer-protection requirements;
• Respond to lawful requests from public authorities;
• Establish, exercise, or defend legal claims; and
• Protect the rights, property, and safety of Touchstone, our users, and the public.

We may create aggregated or de-identified information that can no longer reasonably be associated with you, and use it for any lawful purpose, including research, analytics, and describing our Services publicly.

Where we hold de-identified information, we will maintain it in de-identified form and will not attempt to re-identify it, except as permitted by law to test our de-identification.

We do not sell Personal Information for monetary consideration, and we do not use your individual screen-time history, application-usage history, or journal content to target advertising to you or to build advertising profiles about you.

We share information with vendors who process it on our behalf and under contract, only to provide services to us. These include:

• Payment processing (card details are handled by the processor, not stored by Touchstone);
• Shipping and fulfillment;
• Cloud hosting, storage, and infrastructure;
• Customer-support tooling;
• Email and notification delivery;
• Analytics and diagnostics; and
• Fraud prevention and security.

These providers are not permitted to use your information for their own purposes.

When you use Squads, challenges, or other social features, information you choose to share becomes visible to the users you share it with, as described in section 3.A. We do not make your journal entries visible to other users.

We may disclose information where we believe in good faith that it is reasonably necessary to:

• Comply with applicable law, regulation, legal process, or an enforceable governmental request;
• Enforce our Terms of Service, including investigating potential violations;
• Detect, prevent, or address fraud, security, or technical issues; or
• Protect against harm to the rights, property, or safety of Touchstone, our users, or the public as required or permitted by law.

Where lawful and appropriate, we will attempt to notify you of a legal demand for your information before disclosing it.

If Touchstone is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, information may be transferred as part of that transaction. We will require the recipient to honor this Privacy Policy, or we will notify you and give you any choices required by law.

We may share information for other purposes with your consent or at your direction.

• Account information. You can review and update your account information in the App.
• Permissions. You can grant or revoke device permissions — including Screen Time, notifications, and NFC — in your device settings. Revoking a permission may disable the features that depend on it.
• Sharing. You choose what you share through Squads and can leave a Squad at any time.
• Marketing. You can unsubscribe from marketing email at any time. We will still send transactional and service messages.
• Deletion. You can delete content and close your account as described in our Terms of Service.

Depending on where you live, state privacy laws may give you the following rights with respect to Personal Information we hold about you:

1. Know and access — to confirm whether we process your Personal Information and to obtain a copy of it;
2. Correct — to correct inaccurate Personal Information;
3. Delete — to request deletion of your Personal Information;
4. Portability — to receive your Personal Information in a portable format;
5. Opt out — of the sale or sharing of Personal Information and of targeted advertising. As described in section 2, we do not sell Personal Information or use it for cross-context behavioral advertising; and
6. Non-discrimination — to not receive discriminatory treatment for exercising these rights.

The rights available to you, and the exceptions that apply, depend on the law of your state. Some information may be exempt from a request, for example where we are required to retain it by law.

To make a request, email contact@touchstone.so with the nature of your request and the email address associated with your account.

We will verify your request, typically by confirming control of the account email address, before acting on it. We may need additional information to verify a request; we use that information only for verification.

We will respond within the timeframe required by applicable law. If we decline a request, we will explain why, and you may appeal that decision by replying to our response. If your appeal is denied, you may contact your state attorney general.

An authorized agent may submit a request on your behalf with proof of authorization, and we may still ask you to verify your identity directly.

As described in section 4.D, where required by applicable law we honor legally recognized opt-out preference signals, including Global Privacy Control.