Privacy Policy

1. Introduction

This Privacy Policy describes how Jäggi & Co. Webworks KLG (“Company”, “we”, “us”, “our”), a general partnership (Kollektivgesellschaft) registered in Switzerland under UID CHE-425.063.102, collects, uses, and protects your personal data when you use the TourGuide AI mobile application (“App”).

We are committed to protecting your privacy in accordance with the Swiss Federal Act on Data Protection (FADP/DSG), the revised FADP effective September 1, 2023, and, where applicable, the European General Data Protection Regulation (GDPR).

2. Data Controller

3. Data We Collect

3.1 Account Data (registered users only)

• Email address
• Full name (if provided via Apple Sign-In)
• Hashed authentication credentials

3.2 User Preferences

• Tour preferences: pace, budget, interests, currency
• Theme preference (system, light, dark)
• Location preference setting

3.3 Tour Data (registered users only)

• Generated tour itineraries
• Tour stops and associated details
• Saved tours

3.4 Device and Technical Data

• Device type and operating system version
• App version
• Language/locale settings
• Crash logs and error reports (anonymized)

3.5 Location Data

Your device location, only when you explicitly grant permission and the “Always use current location” setting is enabled. Location data is used solely to suggest nearby destinations and is not stored on our servers.

3.6 Tracking and Advertising

We request App Tracking Transparency (ATT) permission on iOS. If you decline tracking, no advertising identifiers are collected or shared.

4. How We Use Your Data

We process your data for the following purposes:

• To provide and operate the App’s core functionality (tour generation, saving, sharing)
• To authenticate your identity and manage your account
• To synchronize your tours and preferences across devices
• To process your subscription and payments (handled by Apple)
• To respond to language requests and support inquiries
• To improve the App’s performance and fix bugs
• To comply with legal obligations

5. Legal Basis for Processing

Under Swiss data protection law and the GDPR (where applicable):

• Contract performance: Processing necessary to provide the Service (Art. 6(1)(b) GDPR)
• Legitimate interest: App improvement, security, and fraud prevention (Art. 6(1)(f) GDPR)
• Consent: Location data collection, tracking permissions (Art. 6(1)(a) GDPR)

6. Data Storage and Security

6.1 Account data, preferences, and tours for registered users are stored on Supabase (hosted on AWS infrastructure in the EU region).

6.2 Guest user data is stored locally on your device using AsyncStorage and is not transmitted to our servers.

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

• Encrypted data transmission (TLS/HTTPS)
• Row-level security (RLS) policies on all database tables
• Secure authentication via Supabase Auth with email OTP and Apple Sign-In
• No plaintext password storage

7. Data Sharing

We do not sell your personal data. We share data only with:

7.1 Service Providers

• Supabase (database hosting and authentication) — EU region
• Apple (payment processing for subscriptions, Apple Sign-In)
• Siemens AI API (tour generation — only the tour request parameters are sent, not personal data)
• OpenStreetMap / Nominatim (city search — only search queries, no personal data)
• Wikipedia API (city images — only city names, no personal data)

7.2 Legal Requirements

We may disclose your data if required by Swiss law or a valid court order.

8. International Data Transfers

Your data may be processed outside Switzerland. Where data is transferred to countries without an adequate level of data protection, we ensure appropriate safeguards are in place (e.g., standard contractual clauses).

9. Data Retention

• Account data is retained for as long as your account is active.
• Upon account deletion, all your data (profile, preferences, tours, tour stops) is permanently deleted from our servers immediately.
• Guest data remains on your device until you uninstall the App or clear the App’s data.
• Language requests are retained indefinitely in anonymized form for product improvement.

10. Your Rights

Under Swiss data protection law and the GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate personal data
• Erasure: Delete your account and all associated data (available directly in the App under Settings > Delete Account)
• Restriction: Restrict processing of your personal data
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interest
• Withdraw consent: Withdraw consent for location tracking or ATT at any time through your device settings

To exercise these rights, contact us at contact@tourguide-ai.com.

11. Children’s Privacy

The App is not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware that we have collected data from a child under 16, we will delete it promptly.

12. Cookies and Similar Technologies

The App does not use cookies. We use AsyncStorage for local data persistence on your device, which is not a tracking technology.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes through the App or via email. The “Last updated” date at the top indicates the most recent revision.

14. Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with:

15. Contact

For questions about this Privacy Policy or your personal data: