Privacy Policy

Who we are

Suggested text: Our website address is: https://intouch-connect.com.

General

This privacy policy complements the Terms of Use of the mobile application INTOUCH (hereinafter referred to as « the Application »).

Terms not defined in this privacy policy or in the Terms of Use of the INTOUCH Application shall have the meanings given to them under the EU General Data Protection Regulation (GDPR) and Monaco data protection laws.

The purpose of this privacy policy is to inform you, as a User of the Application, how the Data Controller processes your personal data collected through the Application.

About the Organization Responsible for the INTOUCH Application (« Data Controller »)

INTOUCH, a Limited Liability Company (SARL) with a share capital of €15,000, whose registered office is located at 4/6 Avenue Albert II, 98000, Monaco, registered with the RCI of Monaco, represented by Mr. Axel Sategna, its President, is the legal entity responsible for the INTOUCH mobile application.

What Data? When?

The Data Controller collects the following data: Identification data (e.g., name, first name, age, username, password, email, mailing address, and telephone number);Personal characteristics (e.g., professional background, education, occupation);Connection data (e.g., IP address, city of connection, internet service provider);Your contact list, to help you easily find friends already active on INTOUCH.

This data is collected when the User: Accesses the Data Controller’s Application; Creates or modifies a user account on the Application; Provides location details; Posts a comment; Creates an event; Create a post; Indicates participation in an event; Uses the mobile Application to chat with other Users via the chat feature

Providing mandatory data is a legal or contractual requirement or necessary for access to the services of the Data Controller. Access to the Data Controller’s services cannot be granted without providing this information.

By voluntarily providing optional data, the User explicitly agrees to its processing under the conditions and for the purposes outlined below.

Cookies and Social Media

Cookies
Operational navigation within the Application requires the use of cookies, which are small tracking software elements stored on the User’s device. These give the Data Controller access to standard connection information.
The Data Controller’s cookie usage is defined in Appendix 2 of the Terms of Use.

Social Media
The Data Controller is active on various social media platforms, including Facebook, Instagram, Reddit, and Quora. The Data Controller may process publicly accessible user profile data of individuals who interact with it on these platforms.
The Data Controller is not responsible for public data shared on these platforms. Users are advised to consult each platform’s privacy policy and adjust their privacy settings accordingly.

Purpose of Personal Data Processing

The Data Controller processes Users’ personal data to deliver the services offered via the Intouch app and to communicate with them.

More specifically, the purpose of the Intouch App is to allow anyone to discover, discuss, create, and participate in activities with people near their geographic location.

Personal data processing by the Data Controller includes: Responding to inquiries and information requests; Measuring app usage (e.g., number of users, activity, frequency); Improving products and services by inviting users to surveys and product tests; Providing personalized content (completed activities, activity suggestions, etc.); Customizing products and services; Profiling and analyzing user activity preferences; Sending account-related information; Sending newsletters; Sending push notifications and activity alerts; Managing requests to access, rectify, or oppose data processing.

If User data is processed for different purposes, the Data Controller will notify the User and, where required by law, obtain their prior consent.

Legal Grounds – Applicable Law

Personal data processing on the Intouch Application is governed by this policy and by Monaco regulation protecting personal data.

User data is processed when: The User has given explicit, informed consent (e.g., newsletter subscription, cookies); Required by law or regulation (e.g., fraud prevention); Legitimate interests of the Data Controller apply (e.g., security, app functionality); Necessary for the exercise or defense of legal claims (e.g., debt collection, litigation).

Recipients of Personal Data

The Data Controller shares collected data with technical service providers handling IT maintenance and hosting, as well as marketing, legal, sales, accounting, and customer support teams, only to the extent necessary for their tasks.

Some User data may be shared with Intouch partners when required by a service contract, such as forwarding applications submitted by the User.

These recipients may contact the User using the contact information provided.

They are required to use the data only for service management and to comply with relevant data protection laws.

Personal data may also be disclosed to legally authorized third parties (e.g., judicial authorities upon formal request).

In case of mergers, acquisitions, or restructuring, the Data Controller may transfer User data, in which case the User will be notified before any transfer to a third party.

With explicit User consent, personal data may also be used for commercial prospecting, either directly or through partners.

Personal Data Storage

User data is stored within the European Union, in databases managed by the Data Controller or its providers.

Appropriate security policies, rules, and technical measures are in place to protect personal data processed through the Intouch App against unauthorized access, alteration, or destruction. Unverified requests are rejected.

All employees and subcontractors involved in data processing are required to maintain confidentiality.

Appropriate security policies, rules, and technical measures are in place to protect personal data processed through the Intouch App against unauthorized access, alteration, or destruction. Unverified requests are rejected.

All employees and subcontractors involved in data processing are required to maintain confidentiality.

Data is kept in accordance with legal requirements for a period justified by the processing purpose and subject to legal retention limits.

Occasionally, the Intouch App may include or offer third-party products or services. These entities have their own privacy policies, and the Data Controller disclaims any responsibility for their content or practices.

Using the Intouch App constitutes consent to the processing of personal data under the terms defined in this policy.

By registering on Intouch, Users may inadvertently reveal sensitive data (e.g., ethnicity, political or religious beliefs, union membership, health..). Users are advised not to disclose anything they wish to keep private.

Intouch will never ask for such data. However, if the User voluntarily discloses it, they consent to its processing as described under the “Purposes” section. To protect privacy, Intouch will never show Users’ exact location to others. If location is displayed, it will always be shown as an approximate radius.

In accordance with Law No. 1.165 of December 23, 1993, amended by Law No. 1.462 of June 28, 2018, relating to the protection of personal information, the Data Controller informs Users of their rights regarding their personal data.

Users have the following rights:

• Right of Access:
  The User has the right to obtain confirmation as to whether or not personal data concerning them is being processed and to receive communication of such data in an accessible form, along with information on its source and purpose.
• Right to Rectification:
  The User may request correction of inaccurate or outdated personal data and request the completion of incomplete data.
• Right to Object:
  The User has the right to object to the processing of their personal data, particularly for legitimate reasons, or when the data is used for marketing or commercial prospecting purposes.
• Right to Erasure (Right to Be Forgotten):
  In certain cases, especially when the data is no longer necessary for the intended processing, the User may request the deletion of their data, subject to legal obligations that may require its retention.
• Right to be Informed Before Data Transfer:
  Users have the right to be informed and to give consent before their personal data is transferred to a third party, particularly outside Monaco.
• Right to Lodge a Complaint:
  The User has the right to lodge a complaint with Monaco’s Data Protection Authority — the Commission de Contrôle des Informations Nominatives (CCIN) — if they believe their data has been processed in violation of applicable law.

Users can exercise these rights by contacting the Data Controller:

• By post: Intouch – 4/6 Avenue Albert II, Zone F, 98000
• By email: info@intouch-connect.com

Requests must include name, surname, email or postal address, and proof of identity. This proof will be destroyed after the request is processed.

Requests will be answered within one month.

Users can contact the CCIN (Commission de Contrôle des Informations Nominatives):

• Address:
  12, avenue de Fontvieille, MC 98000 MONACO
• Phone: +377 97 70 22 44
• Email: ccin@ccin.mc
• Website: https://www.ccin.mc

Whether or not the User resides in Monaco, their personal data processed by Intouch falls under the provisions of Monaco Law No. 1.165 of December 23, 1993, as amended. Therefore, all Users are entitled to exercise the rights defined in that law, regardless of nationality or place of residence, insofar as the data processing is carried out under the jurisdiction of Monaco.

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