Privacy Policy - Tugi Care

Last updated: May 29, 2026

Data Controller: Tugi Care Inc.

Overview

Tugi Care Inc. ("Tugi Care", "Laine", "we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect information when you use our applications, websites, and related services (collectively, "Services").

Information We Collect

Information You Provide

• Account information such as your name, email address, and phone number
• User-generated content including notes, reminders, uploaded files, and documents
• Conversation history and interactions with AI-powered features
• Profile information such as caregiving role, preferences, and wellness goals
• 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
• Diagnostics, crash reports, and performance data

Information With Your Permission

• Audio recordings and microphone input when voice features are enabled
• Health, wellness, smartwatch, and fitness-related information
• Location information when location-based features are enabled
• Notifications access for alerts and updates

How We Use Your Information

We use the collected information to:

• Provide and maintain our AI companion and caregiving services
• Enable personalized features and wellness insights
• Support caregiver and care recipient coordination
• Process voice inputs and generate AI responses
• Improve app performance, reliability, and functionality
• Respond to support requests and communicate with users
• Protect security, prevent fraud, and enforce our policies
• 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

Health and Wellness Information

Some features may use health, wellness, fitness, or smartwatch-related data when you explicitly grant permission. This information is used solely to provide app functionality and wellness-related insights. Certain wellness information may be shared with authorized caregivers or connected care partners only when enabled or authorized by you.

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

AI and Third-Party Services

Some features use third-party service providers, including AI and cloud infrastructure providers, to process information necessary for app functionality.

• Audio, transcripts, conversations, or prompts may be processed by trusted third-party AI providers
• Cloud infrastructure providers host and store user data
• Analytics providers help us understand usage and improve services
• All providers are contractually bound to use data only for providing services to us

These providers process data on our behalf subject to contractual confidentiality and security obligations.

Data Sharing

We do not sell, trade, or rent personal information to third parties.

We may share information:

• Service Providers: With vendors who help operate our services, including cloud hosting, databases, analytics, AI processing, and security. These providers are contractually obligated to use data only for providing services to us.
• Care Circle Members: With authorized caregivers or care recipients you have explicitly connected with, based on your settings and permissions.
• Legal Requirements: When required by law, legal process, or government request.
• Protection: To protect users, rights, safety, security, or platform integrity.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice to users.

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.
• Health, wellness, and smartwatch data: Retained while associated features remain enabled and the account is active. Historical 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.
• Backup data: Secure backup copies may be retained for up to 30 days after deletion from primary systems.

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 Storage and Security

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

• Secure encrypted communication using TLS 1.2 or higher
• Industry-standard security measures to protect against unauthorized access
• Access controls and limited internal access to sensitive information
• Monitoring and technical safeguards to improve platform security

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.

Your 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
• Deletion: Delete your account and associated data
• Withdraw Consent: Revoke permissions such as microphone, location, health, and notifications at any time through your device settings
• Objection and Restriction: Object to or request limitation of processing in certain circumstances
• Communications: Opt out of certain non-essential communications

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

Account Deletion

You may delete your account and data:

• Within the app: Go to Settings → Delete account
• By contacting us at privacy@tugi.care

Upon account deletion:

• Account and profile data will be deleted within 30 days
• Conversations, files, and uploaded content will be removed from active systems within 30 days
• Backup copies will be purged within 60 days total
• Aggregated, anonymized analytics data may be retained
• Some information may be retained longer where required for legal, security, or fraud prevention purposes

AI Processing and Automated Decision-Making

Our Services use 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 Services. While AI provides suggestions and assistance, important decisions regarding health, care, or wellbeing should always involve human judgment and consultation with qualified professionals.

Children's Privacy

Our services are 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.

Changes to This Policy

We may update this 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 Services after changes constitutes acceptance of the updated policy.

Contact

Tugi Care Inc.
Email: privacy@tugi.care
Response time: Within 30 days