Mobile App Privacy Policy - Laine

Last updated: May 29, 2026

App: Laine (iOS & Android)

Data Controller: Tugi Care, Inc.

Overview

This Mobile App Privacy Policy explains how Laine ("we," "our," or "us") collects, uses, stores, shares, and protects information related to the use of the Laine mobile application and its connected services and device features.

Information We Collect

Information You Provide

• Account information (name, email address, phone number)
• Profile information (caregiving role, preferences, wellness goals)
• Conversation content, voice inputs, and chat history
• Documents, photos, and files you upload
• Care circle connections and pairing codes

Information Collected Automatically

• Device information (device type, operating system, device identifiers and app instance identifiers)
• App usage data, interaction events, and feature preferences
• IP address and network information
• Crash logs, performance data, and diagnostic information

Information With Your Permission

• Microphone and audio data (when enabled)
• Health, fitness, and smartwatch data (when connected)
• Location information (when enabled)
• Notifications access (when enabled)

Microphone and Audio Features

Laine may request microphone access to enable features such as:

• Voice conversations with the AI companion
• Speech-to-text input and voice commands
• Audio-based interactions and accessibility features

You can revoke microphone permission at any time through your device settings.

Audio Data Processing

• Audio may be processed in real time to support speech recognition and AI functionality
• Processed transcripts may be used to generate AI responses and improve app functionality
• Some audio, transcripts, conversations, or prompts may be processed by trusted third-party AI, cloud, analytics, or infrastructure service providers
• We do not sell audio recordings, transcripts, or personal audio data to third parties

Health, Wellness, and Smartwatch Data

With your permission, Laine may access health, fitness, wellness, or smartwatch-related information to provide wellness insights, caregiving support, coordination features, and personalized experiences.

Certain wellness or smartwatch information may be shared with authorized caregivers or connected care partners only when enabled or authorized by the user.

You can revoke health and fitness permissions at any time through your device settings.

Location Information

If enabled, Laine may collect location information to support safety, caregiving coordination, location-based features, and connected caregiver experiences.

You can disable location access at any time through your device settings. Location data is only collected when the app is in use or as needed for active features you have enabled.

Other Permissions

• Notifications: Used for reminders, alerts, and important updates. You can disable notifications at any time through your device settings.
• Network Access: Required for AI services, syncing, and cloud functionality
• Storage and Files: Used for uploaded documents, app data, and preferences
• Health and Fitness Permissions: Used for smartwatch and wellness-related features when enabled. You can revoke these permissions at any time through your device settings.

How We Use Your Information

We use the collected information to:

• Provide, maintain, and improve app functionality and AI companion services
• Personalize user experiences and caregiving support features
• Enable care circle coordination and sharing between authorized users
• Process voice inputs and generate AI responses
• Monitor app performance, diagnose issues, and improve reliability
• Ensure security, prevent fraud, and protect platform integrity
• Comply with legal obligations

Legal Basis for Processing

We process personal information based on:

• Consent: Where you have given explicit permission (e.g., health data, microphone, location)
• Contract: Processing necessary to provide the services you requested
• Legitimate Interests: Improving services, security, fraud prevention, and analytics
• Legal Obligation: Compliance with applicable laws and regulations

Analytics and Diagnostics

We may collect diagnostics, crash reports, usage analytics, app interaction events, device-related information, and performance data to improve app functionality, reliability, security, accessibility, and user experience.

Analytics providers may use device identifiers and diagnostic information to help us understand app usage and improve platform performance. We use industry-standard tools that collect aggregated or pseudonymized data where possible.

Data Storage and Security

Laine stores user data using trusted cloud infrastructure providers, including MongoDB Atlas for application databases and Cloudflare R2 for uploaded files and documents.

We use reasonable administrative, technical, and organizational safeguards designed to help protect personal information and data transmitted through the app. Data is encrypted in transit using TLS 1.2 or higher. Sensitive data at rest is protected using industry-standard encryption and access controls.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specific retention periods include:

• Account information: Retained while the account remains active. Deleted within 30 days of account deletion request.
• Conversation history and AI interactions: Retained until deleted by the user or until account deletion. Users can delete individual conversations or clear all history at any time.
• Uploaded files and documents: Retained until deleted by the user or until account deletion. Immediately removed from active storage upon user deletion.
• Smartwatch, wellness, and health-related data: Retained while associated features remain enabled and the account is active. Historical health data may be retained for up to 2 years or until account deletion.
• Analytics, diagnostics, and crash logs: Retained for 90 days to 1 year, depending on the data type and analytical needs. Aggregated statistics may be retained longer in pseudonymized form.
• Backup data: Secure backup copies may be retained for up to 30 days after deletion from primary systems before automatic purging.

In some cases, we may retain certain information for longer periods where necessary for legal, regulatory, security, fraud prevention, or dispute resolution purposes. When retention periods expire, data is securely deleted or anonymized.

Data Sharing and Third Parties

We do not sell, trade, or rent personal information to third parties. We may share information in the following circumstances:

• Service Providers: With trusted third-party vendors who provide services on our behalf, including cloud hosting, database services, analytics, AI processing, customer support, and security. These providers are contractually obligated to use data only for providing services to us and are bound by confidentiality and security requirements.
• Care Circle Members: With authorized caregivers or care recipients you have explicitly connected with through the app's pairing features, based on your privacy settings and permissions.
• Legal Requirements: When required by law, legal process, or government request, or when necessary to protect our rights, property, or safety, or that of our users or others.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice to users and continued protection of personal information.

International Data Transfers

Your information may be transferred to and processed in countries other than the country in which you reside. These countries may have different data protection laws. We rely on appropriate safeguards and work with providers who maintain appropriate security measures to help protect personal information during international data transfers.

User Rights and Controls

You have the following rights regarding your personal information:

• Access and Portability: Request access to your personal data or request a copy/export of your data in a commonly used format
• Correction: Update or correct inaccurate information through the app or by contacting us
• Deletion: Delete your account and associated data (see Data Deletion section below)
• Restriction: Request limitation of processing in certain circumstances
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for optional data processing at any time through device settings or by contacting us

To exercise these rights, contact us at privacy@tugi.care. We will respond to requests within 30 days.

Data Deletion

• Permissions such as microphone, health, fitness, notifications, and location access can be revoked at any time through your device settings
• Users can clear chat history and stored personal memory information within the app by going to Memories → Clear all
• Users can delete their account and all associated personal data within the app by going to Settings → Delete account
• Individual uploaded files can be deleted through the Vault feature
• Users may request a copy or export of their personal data by contacting us at privacy@tugi.care
• Users may contact us at privacy@tugi.care to request data deletion or for assistance with privacy-related requests

Upon account deletion request:

• Your account and personal profile data will be deleted within 30 days
• Conversations, memories, and uploaded files will be removed from active systems within 30 days
• Backup copies will be purged within 60 days total (30 days in primary + 30 days in backup systems)
• Aggregated, anonymized analytics data that cannot identify you may be retained
• Some information may be retained longer where required for legal, security, or fraud prevention purposes

Children's Privacy

Laine is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will promptly delete that information. If you believe we may have collected information from a child under 13, please contact us at privacy@tugi.care.

AI Processing and Automated Decision-Making

Laine uses artificial intelligence to process conversations, generate responses, and provide personalized caregiving support. This processing is based on the information you provide and your interactions with the app. While AI provides suggestions and assistance, important decisions regarding health, care, or wellbeing should always involve human judgment and consultation with qualified professionals.

Changes to This Policy

We may update this Mobile App Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. Updated versions will be posted with a revised effective date. We will notify users of significant changes through the app or via email where appropriate. Continued use of the app after changes constitutes acceptance of the updated policy.

Contact Us

Privacy Questions:
Email: privacy@tugi.care
Response time: Within 30 days

App Support:
Email: support@tugi.care