Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how Touclabs Srls ("we", "us", "our", "Controller") collects, uses, stores, and protects the personal data of users ("you", "user") of the TwinLightReality Viewer application ("App").

By using the App, you agree to the practices described in this Policy. If you do not agree, please do not use the App.

This Policy has been drafted in compliance with the General Data Protection Regulation (GDPR – EU Regulation 2016/679), the California Consumer Privacy Act (CCPA), and other applicable data protection laws worldwide.

02 Data we collect

We collect only the following personal data, provided directly by you when creating an account:

• Email address

If you choose to connect your Google Drive account (optional feature, see 2.1 below), we may also receive limited data from Google as described below.

We do not collect location data, payment data, media/photo content stored on your device, device contacts, or any other data not listed above, unless a specific and separate consent is requested in the future, in which case this Policy will be updated accordingly.

2.1 Optional Google Drive login

The App offers an optional feature that allows you to connect your Google Drive account. If you choose to use this feature:

• You will be redirected to an external browser window to complete sign-in through Google's own authentication system (OAuth 2.0).
• We do not see or store your Google password at any time; authentication is handled entirely by Google.
• Once authorized, we receive an access token from Google that allows the App to access the Google Drive data and permissions you explicitly grant during authorization.
• We may also receive basic profile information tied to your Google account (such as your Google email address), depending on the permissions you approve.
• This feature is entirely optional — if you don't connect your Google Drive account, none of this data is collected.
• You can revoke the App's access at any time via your Google Account permissions settings.

Google's own handling of your data is governed by the Google Privacy Policy.

03 Purposes of processing

We do not use your data for direct marketing purposes without your explicit consent.

04 Data retention

We retain your personal data for as long as your account remains active. If you request account deletion, your data will be deleted or anonymized within a reasonable timeframe, unless a longer retention period is required by law.

05 Data security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Secure connections (HTTPS/TLS)
• Restricted access to data limited to authorized personnel

Despite our efforts, no system is completely secure, and we cannot guarantee absolute security.

06 Data sharing

We do not sell, rent, or share your personal data with third parties for commercial purposes. Data may only be disclosed:

• When required by law or a competent authority
• To protect the rights, property, or safety of Touclabs Srls, users, or third parties
• In the event of a merger, acquisition, or sale of business assets, with appropriate notice to users
• With Google, solely to the extent necessary to enable the optional Google Drive connection you have chosen to activate

07 Your rights

If you are in the European Union (GDPR)

You have the right to access, rectify, or delete your data ("right to be forgotten"), restrict or object to processing, request data portability, withdraw consent at any time, and lodge a complaint with your national supervisory authority.

If you are in California (CCPA)

You have the right to know what personal data we collect, request its deletion, opt out of its sale — note: we do not sell personal data — and not be discriminated against for exercising these rights.

08 International data transfers

Since the App is used globally, your data may be transferred to and processed in countries other than your country of residence. In such cases, we implement appropriate safeguards — such as standard contractual clauses — to ensure a level of protection equivalent to the GDPR.

09 Children

The App is not intended for children under 16 (or the minimum age required by applicable local law). We do not knowingly collect data from children. If we learn we have collected a child's data without parental consent, we will promptly delete it.

10 Changes to this policy

We reserve the right to update this Policy at any time. In the event of material changes, we will notify you through the App or via email. The date of the last update is indicated at the top of this document.

11 Contact us