Privacy Policy

1. Who is responsible for your data

The data controller is BLUKEEN TECHNOLOGY S.R.L., the company that operates OurTurn (Str. Soporului nr. 11, et. 4, ap. 59, Cluj-Napoca, Romania; CUI 41662668; Trade Register no. J2019003660124). You can reach us at privacy@ourturn.care for anything in this policy.

Two kinds of people use OurTurn: family caregivers, who create an account and enter information, and the person living with dementia, who has no account and no password — their tablet or phone is connected by the family with a six-digit Care Code.

2. The data we process

Your account

• E-mail address, name, your relationship to the person, country and language.
• Your notification choices and the push-notification token of your phone (only if you install the mobile app).
• Your household's subscription status (free, trial, Plus). Payment details never reach our servers — see Stripe and RevenueCat below.

About the person you care for (entered by the family)

• First name, optional date of birth and optional type of dementia.
• Home address (used for the “Take me home” button and safe zones) and emergency contacts (name, phone, relationship).
• What helps in a hard moment — what calms them, what upsets them, how they communicate — and a description of a normal day, in your words.
• Music they love (a title and a link you provide).
• Medicines exactly as you type them (name, dose, times) and the confirmations shown on the clock (“taken”, or not confirmed). OurTurn never gives dosing or medical guidance.
• Because this concerns a person living with dementia, some of this information is health-related data. See section 3 for the legal basis.

The day on the clock

• The daily plan: items, times, repeat pattern, optional instructions, photos and step-by-step guides.
• What was done and when (a tap on “Done” or “I took it” on the clock or phone).
• Notes the family sends to the clock (author name, text, how long it stays).

Photos and voice recordings for the clock

• Photos attached to notes or to items of the plan (including their step-by-step guides), and voice recordings the family records for reminders, are stored in private storage. Only your family's accounts and the connected clock/phone can open them, through short-lived links.
• You can remove any photo or recording at any time, on the clock page or in the plan; they are also deleted with the account.

The clock and the phone (devices)

• For each device that asks to connect or is connected: a random device identifier created by the app (we keep only a one-way scrambled form of it), whether it is the clock or the person's phone, platform, device model, app version, time zone, when it asked to connect and who in the family approved it, when it last reported in, and a push-notification token.
• The device reports in every few minutes while it is on, so the family can see whether the clock is running. It never receives your family's e-mail addresses.

Location of the person's phone

• Location sharing is optional, including on a phone displaying the Clock. It requires the person's consent on that device and operating-system permission; the family cannot enable it remotely.
• We store the phone's position history for 30 days, the safe zones your family defines, and the alerts they trigger (leaving a safe zone, tapping “I need help” or “Take me home”).
• The person can pause sharing at any time from the “What I'm sharing” screen; when sharing is turned off, the stored position history is deleted.

Your own wellbeing check

• If you answer the short weekly wellbeing check in the coach, we store your answers. They are about you, for you; we do not share them with other family members.

AI conversations

• When you talk to the coach or ask for help in a hard moment, we send your message, the recent conversation, and a summary of the person's profile and plan to Google's Gemini AI service to produce the answer. The person living with dementia never talks to the AI.
• We use Google’s paid Gemini API. Under its terms Google does not use this content to improve its products; it processes it as our data processor and keeps it only for a limited time to detect and prevent misuse of its service. We do not send your e-mail address or account identifiers with it, and we suggest not writing full names, addresses or other identifying details into the chat.
• Things that worked (“what helped”) can be saved from those conversations as short notes about the person. You can see and delete every one of them in Settings → About the person.
• Every AI message first passes an automatic safety check. For that check we keep a technical log (time, result category, language) without the message content, for 90 days.
• Once a week, if AI help is on, we send Gemini a short summary of the past week made only of numbers and categories — for example how many plan items were done and which kinds of situations your saved notes are about — without the person's name or anything you wrote, so it can suggest one or two observations for your Home page.

Reports, feedback and payments

• Summaries you generate for a doctor's visit are stored in your account until you delete them. They are built from information the family recorded and are not a medical record.
• Feedback and bug reports you send us, including the text you write.
• Payments: on the web through Stripe, on mobile through Apple/Google via RevenueCat. We receive only the subscription status and a customer reference, never card numbers.

Technical data

• Error and crash reports (through Sentry) with device type, operating system, app version and the technical context of the error.
• Standard server logs of our hosting providers (IP address, time, requested page), kept for security for a short period.
• Consent records: what was agreed, when, and from which app, so we can prove and honour your choices.

We use no advertising trackers and no analytics services, and we do not profile you for marketing.

With AI consent, Google Gemini receives the request and selected family context for guided help. We keep responses, approved drafts, usage counts and safety checks. We also keep subscription verification, family access changes and notification delivery outcomes.

3. Why we process your data and on what legal basis

Under the GDPR we rely on the following grounds:

• Performance of our contract with you (Art. 6(1)(b)): running the clock and the family app, syncing between family members, sending the reminders and alerts you set up, billing.
• Your consent (Art. 6(1)(a)): location sharing on the person's phone, AI conversations that use the person's profile, optional e-mails and evening reminders. You can withdraw consent at any time in Settings.
• Our legitimate interests (Art. 6(1)(f)): keeping the service secure, preventing abuse of Care Codes, fixing errors, and sending essential service messages.
• Legal obligations (Art. 6(1)(c)): tax and accounting records for payments, and answering lawful requests.

Information about a person living with dementia is health-related data (Art. 9 GDPR). We process it only on the basis of explicit consent (Art. 9(2)(a)): the family caregiver confirms, before the Care Code is shown, that they may set OurTurn up for the person and will explain what it shows and shares; the clock then shows the person a plain-words screen and asks for their agreement. If that consent is withdrawn, the sharing features stop and the data can be deleted in Settings.

4. The person living with dementia

We designed OurTurn so that the person is treated with dignity and stays in control of what concerns them:

• They have no account and are never asked for a password or an e-mail address.
• The clock shows them the day, the time, what comes next and messages from their family. It does not score, test or evaluate them, and no AI ever talks to them.
• Location is asked only on their own phone, in plain words, after the family's confirmation, and can be paused by them on the “What I'm sharing” screen.
• They can send a “thinking of you” message to the family from the clock; that is the only thing the clock sends on their initiative.
• Their rights under this policy (section 9) can be exercised by them, by a family member acting on their behalf, or by a legal representative — contact us at privacy@ourturn.care.

5. Who can see your data

• Your care circle: family members who join your household with the Care Code see the same plan, notes, photos, medicines, location (if enabled) and reports. The main caregiver is told by e-mail and notification each time someone joins, and can remove a member at any time.
• The connected clock or phone: it receives only what it needs to show the day — the plan, medicines, notes, photos, recordings, the first names of the family and the emergency contacts.
• We never sell personal data and we do not share it with advertisers.

Service providers who process data for us

• Supabase (database, authentication, file storage) — hosted in the European Union (Ireland). Stores all account and household data.
• Vercel (hosting of the website and family web app) — serves the pages and keeps standard request logs.
• Google Gemini API (AI answers for the coach and the hard-moment help) — receives conversation content and a profile summary, as described in section 2. Google LLC, United States.
• Google Maps (map display and turning a home address into map coordinates on the web) — receives the coordinates or address needed for the map.
• Expo (push-notification delivery for the mobile apps) — receives the push token and the text of each notification. By default that text names no one and gives no details, only that there is something to look at in the app; the person's first name and what happened are included only if you turn on “Show details on the lock screen” in Settings. Expo, Inc., United States.
• Resend (e-mail delivery) — receives your e-mail address and the content of the e-mails we send you. United States.
• Stripe (web payments) — handles card details entirely on its own systems. Stripe, Inc., United States / Stripe Payments Europe.
• RevenueCat (mobile subscriptions through Apple and Google) — receives a pseudonymous app user identifier and the purchase status. United States.
• Sentry (error monitoring) — receives error reports with technical context. Functional Software, Inc., United States.
• Apple and Google, under their own terms: the app stores and in-app purchases when you install the apps or buy a subscription through them, and the phone's own address lookup, which turns an address you type in the mobile app (the home address or a place for a safe zone) into map coordinates.
• GitHub (Microsoft group) runs daily database and file backups, including photos and voice recordings, and stores the encrypted archives for 7 days. The decryption key is kept outside GitHub. Backup processing may occur outside the EU.

Each provider is bound by a data processing agreement and may only use the data to provide its service to us. We may also disclose data when the law requires it or to protect someone's safety.

6. Where your data is stored

Your data is stored in the European Union (Ireland). Some providers listed above process data in the United States. For those transfers we rely on the European Commission's Standard Contractual Clauses and, where the provider is certified, on the EU-US Data Privacy Framework.

7. How long we keep it

• Account, the person's profile, plan, medicines, reports, AI conversations and saved notes: until you delete them or delete your account.
• Notes on the clock: removed 7 days after they expire. Photos and voice recordings: until you remove them or delete the account.
• Location history: 30 days, then deleted automatically; deleted immediately when the person turns sharing off.
• Connected devices: until the family forgets the device or the account is deleted. A device that asked to connect and was never approved is deleted after 7 days; a forgotten or declined device is kept for 30 days, marked as removed, then deleted.
• AI safety-check log (no content): 90 days. Care Code attempt counters: 24 hours.
• Your wellbeing-check answers: until you delete your account.
• Payment and invoice records: as long as tax law requires.
• Deleted data can remain in these encrypted backups for up to 7 days. Unmatched payment events are retried for up to 7 days, then account references are removed; completed or ignored events are deleted after 30 days. Subscription records remain until account deletion.

8. How we protect it

• Encryption in transit and at rest; the person's profile is encrypted on their device.
• Every database table is restricted per household: a family can only ever read its own data, enforced by the database itself.
• A new clock or phone sees nothing until someone in the family approves it in their app. Its token only sees its own household; forgetting the device disconnects it at once, and rotating the Care Code disconnects every device.
• Photos and recordings live in private storage and are opened through short-lived links.
• Care Code entry is rate-limited to prevent guessing.

9. Your rights

Under the GDPR you have the right to:

• Access your data and receive a copy — Settings → Export my data downloads everything in a machine-readable file.
• Correct anything that is wrong — most data can be edited directly in the app.
• Delete your account and all household data — Settings → Delete account; this removes the person's data, photos, recordings, reports and conversations immediately.
• Take your data with you (portability) — use the export above.
• Withdraw consent at any time (location, AI, e-mails) — in Settings, or on the person's phone for location.
• Object to, or ask us to restrict, processing based on our legitimate interests.
• Not be subject to a decision based solely on automated processing that has legal or similarly significant effects on you — OurTurn makes no such decisions.
• Complain to a supervisory authority: in Romania, the National Supervisory Authority for Personal Data Processing (ANSPDCP, dataprotection.ro), or the authority in your own country.

For anything you cannot do in the app, write to privacy@ourturn.care. We answer within one month.

10. Children

OurTurn is for adults (18+). We do not knowingly collect data from children. If you believe a child has given us personal data, contact us and we will delete it.

11. Cookies and local storage

The web app uses only what it needs to work: a sign-in session, your language and display preferences, and your cookie choice. There are no advertising or analytics cookies.

12. Changes to this policy

When we change this policy in a meaningful way, we will tell you by e-mail or in the app before the change takes effect. The date at the top shows the current version.

13. Contact

E-mail: privacy@ourturn.care

Address: BLUKEEN TECHNOLOGY S.R.L., Str. Soporului nr. 11, et. 4, ap. 59, Cluj-Napoca, Romania

If a data breach is likely to put your rights and freedoms at high risk, we will notify the supervisory authority within 72 hours and inform you without undue delay.