Privacy Policy

When does this privacy statement apply?

This Privacy Statement is applicable to the processing of personal data in the context of:

Visiting the Toqi website;
Downloading the Toqi life assistant application ("Toqi App" or "Toqi") and creating or updating the user profile;
Your use of the Toqi App;
Your interactions with MIH AI BV (we/us) in the context of support and deployment of Toqi App.

For interactions or engagements with Prosus or the companies of the Prosus Group, please refer to the Prosus Privacy Statement available at www.prosus.com/privacy and the privacy statements of the respective companies.

Use of the Toqi App is also subject, as applicable, to the Toqi App Terms of Service (ToS), in particular to the provisions on the fair use of the Toqi App and the limitations resulting therefrom.

Please note that the Toqi App cannot be used by individuals below 18 years of age and you explicitly confirm that you are above the age of 18. We reserve the right to conduct further checks and analysis to confirm that our users are above the age of 18.

Who is responsible for your personal data?

MIH AI BV, a company of the Prosus Group, is the controller responsible for processing your personal data. This Privacy Statement provides you with the information on what personal data we may collect, for which purposes and under which legal grounds, as well as who may have access to your personal data.

We collect your personal data

When you become a Toqi App user — this includes information such as your username, e-mail, name to display, profile photo (non-mandatory), language preference, third-party Services (Gmail on/off, etc.) (please see more information on third-party services below);
When you use the Toqi App — depending on the nature of your use of the Toqi App you may choose to provide us with information about you, your identity & goals, your life stage, values, long-term aspirations, current focus areas, active projects, priorities, work & productivity style, peak energy hours, task preferences, communication & social style, interaction patterns, your knowledge, personal skills, experiences, life history, routines & constraints and your daily schedule. When you use the Toqi App you may choose to provide us with information about people that are important to you and the nature of your relationship with them;
Information about other individuals: Where you choose to share information about other individuals, we will use it solely to provide and personalise the Toqi App's services for your use. By sharing such information, you confirm that you have an appropriate basis for doing so. Those individuals may exercise their data subject rights by contacting us at privacy@prosus.com.
If you consent and decide to use the Toqi App for such purposes, you may provide us with information about physical habits, life management preferences, health habits, dietary preferences, financial approach;
User Content: personal data that you provide as part of the content you share and upload in the Toqi App, such as files, images, audio and video and data from third-party services (please see more information below), depending on the features you use.
When you provide feedback or report errors or irregularities.

Indirectly (automatically) as a result of your interactions with the Toqi App

Location (city/region) — with your permission;
Log data;
Your device type information and identifier;
Timezone;
Voice input — with your permission;
Push notification token;
Play Integrity (Android) or App Attest (iOS) for fraud prevention;
Task title and completion status and history of conversations/usage;
Which third party services you connected to;
Your assistance preferences (how you want to be helped) and errors or irregularities in your use of the Toqi App.

Third-Party Services

Whilst using the Toqi App you may decide to connect the Toqi App to External third-party services for more personalized recommendations such as your Gmail, Calendar, Outlook or other providers such as food delivery companies (such as Just Eat Takeaway), your online grocery stores (such as Picnic) or messaging platforms (such as WhatsApp) — you remain in full control of enabling and disabling such connections.

If connected, the Toqi App can retrieve data from those services on-demand during a conversation based on the nature of your request. This data is not permanently stored in our database — it is retrieved, used in the AI generated response, and the result appears in the conversation message (which is stored).

The data collected and processed by the providers of third-party services will be subject to the provisions of the Privacy Statements (Privacy Policies) of such providers.

Third-party Services: Google User Data

If you choose to connect Toqi with your Google account (Gmail, Calendar, Google Drive), your Google user data will be used solely to respond to user requests and perform functions that you explicitly authorize. User data received from Workspace APIs will be used in accordance with the Google User Data Policy, including the Limited Use requirements. Your Google user data will never be transferred to any third-party AI service providers (such as tool or model providers) for the purpose of training or improving their AI/ML models.

For which purposes do we process your personal data?

To operate the Toqi App and deliver the services

When you create an account and interact with the Toqi App, we will process your personal data to deliver the services provided by the Toqi App, that may include such features as: facilitation of food delivery, booking reservations at restaurants, creating reminders and suggestions for events, creating appointments, to-do-lists, providing suggestions for improvements of schedules, creating ordering lists (such as groceries baskets), suggesting best products or services based on your preferences, monitoring the price of certain products or services, providing alerts about the availability of certain products or services (such as tickets) etc. The nature of the services provided depends on your interactions with the Toqi App and the third-party services you may choose to give Toqi access to.

On what legal grounds we process personal data for such purposes?

Depending on the nature of your engagements with the Toqi App, we process your personal data to fulfil the contract with you (please see more information in the Toqi App ToS) or we may rely on your consent. We rely on your consent to process your data regarding your dietary restrictions, life and health habits, relationships with other people, religious beliefs (for instance in the context of food delivery) or similar. In such case, you may withdraw your consent at any time and/or close your account and delete your data at any time by using the functionality in the Toqi App or by contacting us.

Which personal data we use for such purposes:

Account information — your username, e-mail, name to display, profile photo (non-mandatory), language preference, connected services (Gmail on/off, etc.)
Information that you may choose to provide on your identity & goals, your life stage, values, long-term aspirations, current focus areas, active projects, priorities, work & productivity style, peak energy hours, task preferences, communication & social style, interaction patterns.
Information you may choose to provide us about people that are important to you (see "Information about other individuals" above for further details on how we handle this data) and the nature of your relationship with them; you may also provide information about your knowledge, personal skills, experiences, life history, routines & constraints and your daily schedule.
Information you may choose to provide us about physical habits, life management preferences, health habits, dietary preferences, financial approach.

To personalise your Toqi App experience and profile

In order to enhance, customize and personalize your experience of using the Toqi App, we will store the details of your engagements (prompts, conversations, tasks etc) with the Toqi App to provide more accurate output and more efficient execution of the tasks you requested as well as tailor the recommendation for other tasks.

On what legal grounds we process personal data for such purposes?

Which personal data we use for such purposes:

Account information — your username, e-mail, name to display, profile photo (non-mandatory), language preference, third-party services (Gmail on/off, etc.)
Information that you provide on your identity & goals, your life stage, values, long-term aspirations, current focus areas, active projects, priorities, work & productivity style, peak energy hours, task preferences, communication & social style, interaction patterns.
Information you may provide us about people that are important to you (see "Information about other individuals" above for further details on how we handle this data) and the nature of your relationship with them; you may also provide information about your knowledge, personal skills, experiences, life history, routines & constraints and your daily schedule.
Information you provide us about physical habits, life management preferences, health habits, dietary preferences, financial approach.
Log data about the way you use the Toqi App.

For the technical and functional management of the Toqi App

When you use the Toqi App, we process your personal data to enable access to the Toqi App, to allow users to connect third-party services, to detect potential misuse of Toqi App in violation of the Fair Use Policy. This processing may be done via automated systems without the use of human review. Please note that no automated decision-making as referred to in Article 22 of the European General Data Protection Regulation (GDPR) takes place. We also process your personal data to analyse and evaluate usage of the Toqi App and measure its efficiencies and impact. We may also process your personal data to improve the Toqi App; this relates specifically to enabling the context-awareness of the product to improve the quality and accuracy of output in the following ways:

By giving Toqi App the ability to respond to messages in the same thread/channel;
Through personalisation of certain product features;
To enable agents to access and perform actions on select third-party applications or files that a user chooses to give it access to via integration or file upload.

We also process your personal data to conduct further research in relation to the use of the Toqi App, to respond to user queries, troubleshooting and other forms of providing technical support.

On what legal ground do we process personal data for this purpose?

We process your personal data whilst using Toqi App either (i) for the performance of the Toqi App ToS (performance of a contract) to the extent the processing is indispensable to enable your access and use of the Toqi App; (ii) based on our legitimate interest to improve Toqi and monitor its performance and efficiency, as well as adherence to the fair use policy terms (iii) to comply with applicable legal obligations and/or enforceable governmental requests. In case we process your personal data based on our legitimate interest, we have conducted a legitimate interest's assessment to ensure that our legitimate interests are not overridden by your interests or rights and freedoms.

Which personal data do we process for this purpose?

We process the following categories of personal data in the context of your use of Toqi:

Account information — your username, e-mail, name to display, profile photo (non-mandatory), language preference, third-party services (Gmail on/off, etc.)
Content of your engagements with the Toqi App, including any files, pictures, web searches and specific user feedback to the generated output;
Other types of feedback and details of support queries;
Authentication data for any databases and/or tools you wish to integrate with Toqi for access control purposes;
Any personal data contained within files, databases and repositories that you choose to give the Toqi App access to when using certain features.

To protect Toqi App from fraud, enforce Toqi App ToS and for age verification

We process your personal data to monitor whether your usage of the Toqi App complies with its ToS, in particular the Fair Use Policy and does not involve fraud or other types of misuse of the Toqi App. We may also process your personal data for purposes of age verification.

On what legal ground do we process this personal data?

We process your personal data based on our legitimate interest to protect the Toqi App and to ensure that the Toqi App is used in alignment with its ToS by users above the age of 18. In case we process your personal data based on our legitimate interest, we have conducted a legitimate interest's assessment to ensure that our legitimate interests are not overridden by your interests or rights and freedoms.

Which personal data do we process for this purpose?

Account information;
Content of your engagements with the Toqi App, including any files, pictures, web searches and specific user feedback to the generated output;
Authentication data for any databases and/or tools you wish to integrate with Toqi for access control purposes;
Any personal data contained within files, databases and repositories that you choose to give the Toqi App access to when using certain features.

Who has access to your personal data?

Access to your personal data within Prosus Group

As a global company, data we collect may be transferred internationally. Your personal data may be exchanged with the parent company of MIH AI BV, i.e., the Prosus Group located in the Netherlands, as well as with other entities within the Prosus Group, including its affiliates and subsidiaries, which you can view here. Where this entails an international data transfer outside the European Economic Area, the transfer shall take place in accordance with applicable data privacy requirements, particularly, when transferred to a non-adequate country, in conformity with the European Commission Standard Contractual Clauses (SCCs).

Employees in the group are authorised to access your personal data only to the extent necessary to serve the applicable purposes we describe above and to perform their jobs.

Access to your personal data by our suppliers

If the nature of services provided by our suppliers requires access to your personal data, we will take the appropriate contractual, technical and organisational measures, to ensure that your personal data is securely processed only to the extent that this processing is necessary for the provision of such services.

If such third parties act under our instructions (as data processors), we enter into an agreement with such data processors and include obligations to ensure that your personal data is processed by the data processor solely to provide products or services to us.

In particular, the following categories of third parties may have access to your personal data:

Technology and hosting providers (for instance, Google);
Providers of authentication tokens and analytics events;
Providers of large language models (LLMs);
Providers of browser automation tasks;
Providers of cybersecurity solutions;
Auditors, consultants and law firms.

If your personal data needs to be transferred internationally to a recipient in a country that does not provide an adequate level of protection for personal data under the terms of GDPR, we will take appropriate measures to ensure that your personal data remains adequately protected, in particular through entering into the SCCs or other equivalent data transfer mechanism.

Access to your personal data by other third parties

We may share your personal data if it is required by applicable law or agreement, legal process or a binding governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This also includes sharing data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

How is your personal data secured?

We have taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.

Your rights

Under applicable data protection and privacy laws, you may have the right to:

Access your personal data

You may ask us what personal data we process that relates to you and to provide you with a copy of the personal data we process insofar as required by applicable data protection laws.

Correct and delete your personal data

You may request that we correct any inaccurate personal data we process about you. Also, you may ask us to delete the personal data that relates to you if it is no longer necessary for the purposes for which we processed them, if you have withdrawn your consent and we do not have another legal ground for processing your personal data, if your personal data have been unlawfully processed, or if your personal data must be erased following applicable EU or EU Member State laws.

You may also delete your personal data by using the "Delete Account" functionality in the Toqi App.

Object to processing your personal data

You may object to our processing of your personal data based on our legitimate interest. We will then no longer process your personal data for this purpose, unless we have an overriding legitimate interest to do so. You may also ask us to erase your personal data, unless there is an overriding legitimate interest for the processing.

Data portability

Where applicable, you may request the receipt or transmission to another organisation in a machine-readable form, of the personal data that you have provided to us.

Lodge a complaint with the appropriate Data Protection authority

If you feel that we do not comply with the applicable data protection and privacy laws, you have the right to lodge a complaint with your local supervisory authority. In the Netherlands this would be the Autoriteit Persoonsgegevens.

Restrict the processing of your personal data

You may request restriction of the processing of your personal data where you contest its accuracy, where the processing is unlawful but you oppose erasure, where you require the data for legal claims, or where you have objected to processing based on our legitimate interest pending our verification.

How to exercise your data protection rights

If you would like to exercise any of your data protection rights, please contact us at privacy@toqi.life. Your request should contain a description of the personal data you want to access and/or other right you want to exercise. You will need to provide us with information that allows us to authenticate your identity, as appropriate.

Retention of Personal Data

Your personal data will only be retained for as long as we need in order to provide the Toqi App services to you, our legal obligations to retain data under applicable law, or for other legitimate business purposes such as safety, fraud prevention and adherence to the Toqi App ToS. Retention periods for your personal data depend on the type of data, how we use it, and also your settings. Upon deletion of your account, personal data will be deleted within 30 days, unless retention is required on one of the aforementioned grounds.

You have the right to delete your personal data generated as a result of the use of the Toqi App by using the functionality in the Toqi App. Once you choose to delete Personal Data, we will remove it from our systems within 30 days unless we need to retain it for longer as described below, or it has already been de-identified and disassociated from your account. In some cases, we need to retain Personal Data for longer even after you request to delete it, for example because we are legally required to, to address fraud and abuse, for security reasons.

Contact information and changes to this privacy statement

Should you have any questions regarding the processing of your personal data, or if you want to exercise any of your individual rights, please send us an email at privacy@toqi.life.

This Privacy Statement may be changed over time. The most up-to-date Privacy Statement will be available in the Toqi App with information on the last date of update.