PRIVACY POLICY
Last Updated: January 7th, 2026
Effective from – February 24th, 2026
GENERAL
- Digiotouch OÜ (hereinafter "Digiotouch", "we", "us", and "our") takes the protection of your personal data seriously. When processing personal data, Digiotouch abides by applicable data protection related laws, especially Regulation (EU) 679/2016 of the European Parliament and of the Council (hereinafter the "GDPR"). This privacy policy (hereinafter "Privacy Policy") explains our practice and policy regarding how we collect, use and share your personal data.
- The AI-powered tool offered by Digiotouch is available as a web application, a desktop application, and a mobile application (hereinafter the "Tool"). The Tool can be used to capture meetings (both audio and video data), transcribe meetings, record voice memos, and upload previous meeting recordings to summarise and generate action items and share a list of summary, action items, transcription, and recorded meeting data.
- This Privacy Policy explains how Digiotouch as a controller processes, including collects, uses and retains, your personal data when you or the legal entity you represent conclude a contract with us, when you visit our website and/or app, when you communicate with us, or engage in any other actions that involve us receiving and processing your personal data.
- Please note that this Privacy Policy does not describe how we process personal data when providing the Tool, as we process personal data as a processor. The processing of such personal data is governed by the data processing agreement concluded with the user, the controller. By confirming that you have read this Privacy Policy, you confirm that you have understood and that you acknowledge that the user is in the role of a controller pursuant to the GDPR when you are using the Tool.
- You acknowledge and accept that if you act as a data controller, you are obliged to fulfil all obligations stipulated for data controllers in the GDPR. Among other obligations, it is your obligation to determine the suitable legal bases which allow you to use the Tool for processing personal data. In addition, it is your obligation to give information to the data subjects according to Art 13-14 of the GDPR.
CATEGORIES AND SOURCES OF PERSONAL DATA
- Personal data is any information that can be used to directly or indirectly identify you as an individual. We may process the following personal data about you:
Category of personal data Types of personal data Main Data - name
- e-mail address
- the legal entity you represent and your position (if applicable)
- role
- industry
- primary use case
Payment Data data about the transaction Communication Data - name
- e-mail address
- the legal entity you represent and your position (if applicable)
- date and time of the communication
- your message
Marketing Data - name
- e-mail address
- obtained consent
Usage and Analytics Data - user ID
- actions made, attributes to that action
- error logs
- clickstream data
- session duration
- user agent string
- page load times
Log Data - session ID
- IP address
- device information
- date and time of your visit
- visited pages and screens
- referrer URL
- session duration
- geolocation data
- network data
- If you do not provide the necessary data, we may not be able to contact you, conclude a contract with you or the legal entity you represent or fulfil any other purposes provided in this privacy notice.
- We may collect the personal data from you, for example if you contact us, the legal entity you represent or when you visit the website or app.
PURPOSES AND LEGAL BASES OF PROCESSING PERSONAL DATA
- The legal basis for processing your personal data is determined by the purpose and context in which the data is collected. We may process your personal data for the following purposes and legal basis:
| Processing purpose | Legal basis | Category of personal data |
|---|---|---|
| Handling pre-contractual negotiations and communications | If we conclude a contract with an individual: taking and implementing pre-contractual measures of the potential contract to be concluded between us. If we conclude a contract with a legal entity: our legitimate interest in taking and implementing pre-contractual measures of the potential contract to be concluded between the legal entity you represent and us. | Main Data Communication Data |
| Performing the contract, including managing contractual relationship, managing account, providing information about updates, responding to communications you send to us, monitoring the fulfilment of the contract | If we concluded a contract with an individual: performing the contract concluded between us. If we concluded a contract with a legal entity: our legitimate interest in performing the contract concluded between the legal entity you represent and us. | Main Data Payment Data Communication Data |
| Handling, reviewing, and responding to communications | Our legitimate interest in ensuring effective communication | Communication Data |
| Analysing the use of our Tool to improve, upgrade and enhance the Tool | Our legitimate interest in improving, upgrading and enhancing our Tool | Usage and Analytics Data Log Data |
| Making available the website, administering the website, including gathering information about your navigation on the website, enhancing user experience, and improving website performance and content relevance | Our legitimate interest in providing the website, ensuring optimal functionality, enhancing user experience, and improving website performance and content relevance | Usage and Analytics Data Log Data |
| Conducting direct marketing to promote our services, including sending newsletters | Consent | Marketing Data |
| Measuring the effectiveness of marketing tools | Our legitimate interest in improving the efficiency of marketing tools | Marketing Data |
| Storing information containing personal data in our backup systems | Our legitimate interest in ensuring the continuity and security of data processing operations | All data categories (as necessary) |
| Complying with legal or regulatory obligations or requests | Performance of legal obligation | All data categories (as necessary) |
| Establishing, exercising, or defending legal claims, whether in court, administrative, or out-of-court proceedings | Our legitimate interest in protection our, our clients' and/or employees' rights | All data categories (as necessary) |
RETENTION OF PERSONAL DATA
- We retain your personal data for as long as is necessary for the purposes set out in this privacy notice or until the legal obligation stipulates that we do so. When determining the retention period for personal data, we consider the type of personal data being processed, including its nature and sensitivity, the purpose of processing, whether the purpose can be achieved by other means, and the potential risks and impact associated with personal data breaches. We also take into consideration the need to resolve disputes and enforce contracts.
DISCLOSURE OF PERSONAL DATA
- We may disclose your personal data to service providers (for example payment services provider, CRM software provider), public sector authorities, including supervisory and law enforcement authorities, professional advisors and legal successors and/or potential acquirers.
TRANSFER OF PERSONAL DATA OUTSIDE OF THE EEA
- If we transfer personal data to recipients located outside the European Union or European Economic Area (hereinafter the "EU/EEA"), we implement safeguards, such as standard contractual clauses approved by the European Commission, to ensure that your personal data receives a level of protection comparable to that within the EU/EEA. Upon request, we will provide additional information regarding the safeguards in place.
DATA SUBJECT RIGHTS
- As a data subject, you have the following rights, which you may exercise at any time, subject to the limitations imposed by applicable data protection laws:
- Right to access: you have the right to request access, including receive a copy, of your personal data;
- Right to rectification: you have the right to request that we correct any of your personal data if we process inaccurate or incomplete personal data. You can also update or modify your personal data at any time via your account settings on the platform;
- Right to erasure: you have the right to request that we delete your personal data, for example when the personal data is no longer necessary for the purposes for which it as collected, the personal data has been unlawfully processed or if the personal data must be erased for compliance with a legal obligation to which we are subject to. You can delete your account at any time via the Tool;
- Right to restrict the processing: you have the right to request that we restrict certain processing of your personal data, for example if the accuracy of the personal data is contested by you or if we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
- Right to data portability: you have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and transmit those data to another controller if the processing is based on consent or on a contract and the processing is carried out by automated means;
- Right to object: you have the right to object to the processing of your personal data, for example if we process your personal data for marketing purposes or when processing is based on our legitimate interests;
- Right to withdraw your consent: if the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time. The withdrawal of your consent does not affect the lawfulness of the processing of your personal data prior to the withdrawal;
- Right to submit a complaint to a data protection authority: if you are not satisfied with our response to your request, or if you believe we are processing your personal data in violation of applicable law, you have the right to submit a complaint to your local data protection authority. In Estonia it is the Data Protection Inspectorate (www.aki.ee, info@aki.ee).
- To exercise the above rights, please contact us as at contact@digiotouch.com. Please note that you should supply us with adequate information for us to respond to your requests. Prior answering your request, we may ask you to provide additional information for the purposes of authenticating you and evaluating your request.
AMENDMENTS TO THIS PRIVACY POLICY
- We may update or modify this Privacy Policy from time to time to reflect changes in our personal data processing practices. The most recent version of the Privacy Policy will always be available on this webpage. Please revisit this page regularly, especially before providing any new personal data.
CONTACT
- If you have any questions or comments, if you have a concern about the way we are processing your personal data or if you would like to exercise any of your rights as a data subject, please contact us at contact@digiotouch.com.
