How we handle your data

Who we are

This privacy policy applies to the Touly marketing site at touly.ai. The data controller is:

Aurum Ventures SL
Company number B23860331
Cami de Genova 33, 07014 Palma de Mallorca, Spain
Contact: hello@touly.ai

For data-protection questions, write to hello@touly.ai.

What data we collect, and why

We try to collect as little as possible. Here is the full picture.

1. Waitlist email

When you join the waiting list, we store the email address you provide. We use it only to send you updates about Touly — when it's ready, what we've built, and occasional context about the work. You can unsubscribe from any email we send, and you can ask us to delete your address at any time by writing to hello@touly.ai.

• Legal basis: your consent (joining the list).
• Retention: until you ask us to delete it, or until the waiting-list programme ends, whichever comes first.

2. Google Analytics (only if you accept)

We use Google Analytics 4 (property G-572Q3M1DVS) to understand how visitors discover and read this page. Google Analytics sets cookies and processes your IP. We don't fire any of this until you accept the cookie banner. If you decline, no analytics cookies are set and no data is sent to Google.

• Legal basis: your consent (the cookie banner).
• Processor:Google Ireland Ltd. Data may be transferred to the United States under Google's Data Processing Terms and EU Standard Contractual Clauses.
• Retention: Google retains analytics data for up to 14 months by default.
• Withdraw consent:click “Manage cookies” in the footer of the home page at any time.

3. Hosting and basic server logs

This site is hosted by Vercel Inc. Vercel processes standard request logs (IP address, user-agent, requested URL, timestamps) for security and to keep the site running. These logs are not used for profiling or marketing.

• Legal basis: legitimate interest in keeping the site online and safe.
• Processor: Vercel Inc. (United States), under its own Data Processing Addendum.
• Retention: typically a few days.

What we don't do

• We don't sell your data. Ever.
• We don't run advertising tags, retargeting pixels, or social media trackers on this page.
• We don't combine your waitlist email with the analytics data.
• We don't use your data for profiling or automated decision-making.

Your rights under GDPR

Because we're a Spanish company processing personal data of people in the EU, the EU General Data Protection Regulation (GDPR) applies. You have the right to:

• Access — ask what data we hold about you.
• Rectification— correct anything that's wrong.
• Erasure — ask us to delete your data.
• Restriction — ask us to pause processing while you sort something out.
• Portability — ask for your data in a machine-readable format.
• Objection— object to processing that's based on legitimate interest.
• Withdraw consent — change your mind about the waitlist or analytics at any time.

To exercise any of these rights, email hello@touly.ai. We will respond within 30 days.

You also have the right to lodge a complaint with the Spanish supervisory authority: Agencia Española de Protección de Datos (AEPD) — aepd.es.

International data transfers

Some of our processors (Google, Vercel) are based in the United States. Data transferred to them is protected by EU Standard Contractual Clauses and, where applicable, certifications under the EU–US Data Privacy Framework.

Children

Touly is not directed at people under 18. We don't knowingly collect data from minors. If you believe a minor has joined the waiting list, write to hello@touly.ai and we will delete the record.

The Touly product itself

The Touly app is currently available for controlled testing. It provides additional privacy notices and consent choices for account, conversation, reflection, and relationship data. This page primarily describes the marketing site and waitlist; the app notices describe the additional processing that applies when you create an account or use a coaching flow.

Changes to this policy

If we change anything material, we will update the date at the top and let waiting-list members know by email. The current version always lives at this URL.

Contact

Questions, requests, complaints — all at hello@touly.ai.