AITourPilot App Privacy Policy
Effective Date: June 30, 2026 · Version 1.3
This Privacy Policy explains how AITourPilot ApS ("AITourPilot," "we," "us," or "our") collects, uses, stores, and protects your personal data when you use the AI Tour Pilot mobile application ("the App"). This policy applies specifically to data processed through the App and supplements our general website privacy policy.
We are committed to protecting your privacy in compliance with the EU General Data Protection Regulation (GDPR) and applicable Danish data protection law.
1. Introduction
This Privacy Policy applies to data processed through the AI Tour Pilot mobile application and supplements our general website privacy policy.
2. Data Controller
3. Data We Collect
a) Account Data
When you create an account, we collect your email address and display name (if provided) via our authentication provider. This is necessary for service delivery and to remember your preferences across sessions. Legal basis: contract performance (Art. 6(1)(b) GDPR).
b) Voice and Conversation Data
When you speak to Henry, our AI museum guide, your voice is captured by your device's microphone and streamed in real time to our voice AI provider for speech recognition and response generation. We do not store raw audio recordings. Audio exists only during the live conversation stream.
After each conversation, a text transcript of what was said is generated. This transcript is sent to our backend and stored in our database. Legal basis: consent (Art. 6(1)(a) GDPR) — you actively initiate each conversation.
c) Conversation Memory
After a conversation ends, the transcript is sent to our AI language model provider to generate a short memory summary (approximately 400 characters). This summary allows Henry to remember you on your next visit (e.g., "You mentioned you enjoyed the Klimt paintings"). The summary is stored in our database and used in future conversations. Legal basis: consent / legitimate interest (Art. 6(1)(a)/(f) GDPR).
d) Location Data
The App uses precise location (GPS, mobile and WiFi-based positioning, approximately 100 m accuracy) to show you nearby museums with the actual distance from your current location. Your location is processed on-device and is not stored on our servers or shared with third parties. You can revoke location permission at any time in your device settings. Legal basis: consent (Art. 6(1)(a) GDPR).
e) Device and Technical Data
The App may collect basic technical data such as device type, operating system version, and app version for crash reporting and service improvement. Our error monitoring provider receives no transcript content, no email addresses, and no personal identifiers. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
f) Tester Sign-up and Invitation Data
If you sign up via one of our tester sign-up pages, we collect your email address (and, where provided, your name and organisation) to contact you, approve your test access, and send you the app download links. When we send you an invitation email, we may record whether and when it was opened, to measure the reach and deliverability of our test programme; you can unsubscribe at any time via the link in each email. Legal basis: pre-contractual measure at your request and consent (Art. 6(1)(b)/(a) GDPR); open-rate measurement on legitimate interest (Art. 6(1)(f)).
g) Usage and Interaction Data
During our founding-partner testing phase, we collect data about how you interact with the App in order to improve its usability — for example, whether you use push-to-talk or hands-free speaking, how often you tap the conversation orb, whether you start a conversation after the introduction, and how a session ends (for example, you navigate away or close the App). This is information about how the App is used, not what is said in your conversations (your conversation content is covered separately in sections 3b–3c). This data is stored in our own EU database, linked to your account, is never used for advertising, and is deleted when you delete your account. Legal basis: legitimate interest (Art. 6(1)(f) GDPR) — improving the App's usability. You can object to this processing at any time (see section 9). For the public launch of the App, we will move this processing to an explicit, opt-in consent.
4. How We Process Your Data
| Purpose | Data used |
|---|---|
| Real-time voice conversation with Henry | Voice audio stream |
| Memory summary generation (post-conversation) | Text transcript |
| Cross-language memory translation | Memory summary text |
| Quality analysis (operator only, not automated) | Text transcript |
| App usability improvement | Usage and interaction signals (not conversation content) |
We do not use your data to train AI models. Our AI providers' commercial terms prohibit training on customer inputs. No fine-tuning or model training occurs on your conversations.
5. Categories of Service Providers
The following categories of third-party providers process your data on our behalf:
| Category | Purpose | Region | Data they access |
|---|---|---|---|
| Voice AI provider | Speech recognition, real-time conversation | USA | Voice audio, live transcript |
| AI language model provider | Memory summary, translation, analysis | USA | Text transcript |
| Cloud database provider | Primary data storage | EU (Ireland) | Transcripts, summaries, account data |
| Authentication provider | User sign-in and identity | USA | Email, display name, auth tokens |
| Web hosting provider | Backend API hosting | USA | Data in transit |
| Background processing host | Asynchronous task execution | USA | Data in transit |
| Job queue provider | Task scheduling | EU | Job IDs only (no transcript content) |
| Error monitoring provider | Crash and error reporting | USA | Error traces only (no personal content) |
| Sign-up / landing-page provider | Tester sign-up pages and lead capture | EU | Email, name, organisation |
| Email delivery provider (bulk) | Sending invitation emails in batches | USA | Email, name |
| Email delivery provider (personal) | Sending personal invitation and notification emails | USA | Email, name |
6. Data Storage and Retention
| Data type | Stored where | Retention |
|---|---|---|
| Account data (email, name) | EU database + auth provider | Until account deletion |
| Conversation transcripts | EU database | Until account deletion |
| Memory summaries | EU database | Until account deletion |
| Usage and interaction data | EU database | Until account deletion |
| Voice audio | Voice AI provider (USA) | Until account deletion |
| Error logs (no personal content) | Error monitoring provider (USA) | 30 days (automatic) |
| Deletion audit trail (anonymized) | EU database | 12 months (fraud prevention) |
We do not store raw audio recordings in our own systems. Audio recordings held by our voice AI provider are deleted when your account is deleted.
7. Account Deletion
When you request account deletion (via email to privacy@aitourpilot.com), we delete:
- All your data in our database (transcripts, summaries, memory snapshots, analysis data, usage and interaction data)
- Your conversation audio and transcripts stored by our voice AI provider
- Your authentication account and active sessions
A non-revertible audit entry (operator ID, anonymized account identifier, and deletion counts) is retained for fraud-prevention purposes.
8. International Data Transfers
Your primary data is stored in the EU (Ireland). However, real-time voice processing and AI analysis require data transfers to the USA. These transfers are protected by:
- EU Standard Contractual Clauses (SCCs) included in each provider's standard data processing agreement
- The EU-US Data Privacy Framework where applicable
9. Your Rights (GDPR)
As a data subject, you have the right to:
- Access (Art. 15): request a copy of all data we hold about you
- Rectification (Art. 16): correct inaccurate data
- Erasure (Art. 17): request deletion of your data
- Restriction (Art. 18): limit how we process your data
- Data portability (Art. 20): receive your data in machine-readable format (JSON)
- Object (Art. 21): object to processing based on legitimate interest
- Withdraw consent (Art. 7): at any time, without affecting prior processing
To exercise any right, contact privacy@aitourpilot.com. We respond within 30 days.
You may also lodge a complaint with the Danish Data Protection Agency (Datatilsynet).
10. Children's Privacy
The App is not directed at children under 16. We do not knowingly collect personal data from children under 16. Museums are family destinations — if a child under 16 uses the App, parental consent is required. If you become aware that a child has used the App without appropriate consent, please contact us and we will delete their data promptly.
11. Microphone Permission
The App requests microphone access to enable voice conversations with Henry. Your microphone is only active during a conversation session that you explicitly start. No background recording occurs. You can revoke microphone permission at any time in your device settings.
12. No Cookies, No Advertising
The App does not use cookies, advertising trackers, or third-party advertising SDKs, and we do not sell, rent, or share your personal data with advertisers or data brokers. To improve usability, we do collect first-party usage and interaction data within the App (see section 3g); this data stays within our own systems and is never used for advertising or shared with data brokers.
13. Changes to This Policy
We may update this policy to reflect changes in our practices or legal requirements. Material changes will be communicated through the App. The effective date at the top indicates the latest version.