Privacy Policy
Last updated: October 1, 2026
Table of Contents
1. Introduction
OURTOR TECH LTD ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform and services (collectively, the "Service").
We are a data controller for the purposes of the General Data Protection Regulation (GDPR) and UK data protection laws. We are registered with the Information Commissioner's Office (ICO) in the United Kingdom.
2. Information We Collect
We collect information from you when you use our Service, create an account, or otherwise interact with us. You can explore OURTOR without giving us any personal information at all. The information we may collect includes:
Account Information
- •Device identifier: When you use OURTOR without registering, we create an account identified only by a random identifier created when you install the app. It holds no name or email address. It is deleted with the app, so reinstalling without having added an email address starts a new account.
- •Name: Asked for, with your email address, when you create an account. Shown on your profile and next to what you share, such as posts and comments.
- •Email address: Asked for only when you create an account, which you need for things that are shared or kept for you: posting, commenting, adding friends, creating and planning, and your profile. Exploring needs none. It lets you restore your account on a new device or after reinstalling, and lets us contact you about the Service.
- •Profile information: Optional details such as your home town, the name you give your guide, and the eras, themes and places you are interested in (your "Travel DNA"), gathered as you use the Service.
Usage Data
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include:
- •Your device's Internet Protocol address (IP address)
- •Device name, model and type, operating system and app version
- •Screens visited and time spent on our Service
- •Unique device identifiers and diagnostic data
Content You Create
We store the content you create in OURTOR: posts, comments, journal entries, travel stories — including their scripts and any narration recordings of your own voice — thoughts you leave at places and travel tips you file, photos you upload, and your messages to the in-app guide, including any photo you attach to them. Some of this is sent to AI services outside OURTOR, either to provide a feature you turned on or to check published content for harmful material. Section 9 names each service and what it receives.
Location Data
We may use and store information about your location if you give us permission to do so ("Location Data"). Location permission is optional — OURTOR works without it. We use this data to show you what is around you, to provide features of our Service, and to improve and customise our Service. You can enable or disable location services at any time through your device settings.
3. How We Use Your Information
We use the information we collect for various purposes, including to:
- Service Operation: Provide, operate, and maintain our Service
- Improvement: Improve, personalise, and expand our Service
- Analytics: Understand and analyse how you use our Service
- Development: Develop new products, services, features, and functionality
- Communication: Communicate with you, including for customer service, updates, and marketing purposes
- Transactions: Process your transactions securely
- Artificial intelligence features: Provide the AI-powered features described in section 9, such as your guide's voice and portrait, site chat and AI writing help
- Security: Find and prevent fraud and security issues
- Compliance: Ensure compliance with legal obligations
4. Legal Basis for Processing
Under the GDPR, we must have a legal basis for processing your personal information. We process your personal information on the following legal bases:
- •Contractual necessity: Processing is necessary to fulfil our contractual obligations to you.
- •Legitimate interests: Processing is necessary for our legitimate interests, such as improving our services or protecting against fraud.
- •Consent: You have given us consent to process your personal information for specific purposes, including sharing information with the AI service providers named in section 9. That consent is asked for separately and can be withdrawn at any time.
- •Legal obligation: Processing is necessary for compliance with our legal obligations.
5. Data Retention
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.
6. Your Data Protection Rights
Under the GDPR and UK data protection laws, you have the following rights:
- •Right of access: You have the right to request copies of your personal information.
- •Right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
- •Right to erasure: You have the right to request that we erase your personal information, under certain conditions.
- •Right to restrict processing: You have the right to request that we restrict the processing of your personal information, under certain conditions.
- •Right to object to processing: You have the right to object to our processing of your personal information, under certain conditions.
- •Right to data portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us using the contact information provided below.
Account Deletion and Withdrawing Consent
You have direct, self-service control over your account deletion and data sharing preferences:
- •Deleting your account in the app: Open Settings → Your Data → Delete Account. If you explore as a guest without an email address, you confirm by typing the confirmation phrase shown on screen. If you have registered an email address, you confirm with your account email.
- •Deleting your account online: You can also request account deletion on the web at ourtor.com/delete-account.
- •The 30-day grace period: When you request deletion, your account enters a 30-day grace period. During these 30 days, your account is deactivated, and your profile, public posts, and contributions are immediately hidden from other travellers. You can cancel deletion at any point during the 30 days by signing back in and tapping "Cancel Deletion" in Settings. Once the 30 days expire, your account, personal data, Travel DNA, visit history, and authentication credentials are permanently expunged or irreversibly anonymised from our production databases. Secondary system backup snapshots are overwritten in accordance with our regular 30-day backup cycle.
- •Withdrawing AI data sharing consent: You can withdraw your permission for any or all optional AI features at any time in the app under Settings → Privacy → AI features (or by tapping "Turn everything off"). Withdrawing consent takes effect immediately on our servers and stops further sharing with third-party AI services.
7. Cookies
Cookies are small pieces of data stored on your device. We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
8. Disclosure of Data
We may disclose your personal information in the following situations:
- •Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
- •To Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy.
- •To Service Providers: We engage trusted third-party service providers to operate, maintain, and support our platform. These non-AI processors include:
- Hosting, Infrastructure & Identity: Amazon Web Services (AWS), primarily in the United Kingdom (London region, eu-west-2), for serverless compute, relational databases (Aurora PostgreSQL), secure file storage (S3), and user directory & authentication services (AWS Cognito).
- Diagnostics & Crash Reporting: Sentry (Functional Software, Inc.) for application performance monitoring, real-time error logging, and crash diagnostics. Transmitted diagnostic data includes software stack traces, device model, operating system version, and build identifiers; request payloads and IP addresses are masked or stripped.
- In-App Purchases & Subscriptions: RevenueCat, Inc. for purchase receipt verification, subscription lifecycle management, and mobile store entitlement tracking in connection with Apple App Store and Google Play Store billing.
- Maps & Geolocation Display: Mapbox, Inc. for vector map rendering, tile delivery, and geocoding. When viewing maps, requests transmit viewport map coordinates and your IP address as necessary to stream map assets.
- Real-Time Communications & Audio: LiveKit, Inc. for real-time WebRTC audio transport supporting guide audio experiences.
- Transactional Communications: Amazon Simple Email Service (SES) for delivering passwordless one-time verification codes and critical administrative notices.
- Platform App Stores: Apple Inc. (Apple Push Notification service, StoreKit) and Google LLC (Firebase Cloud Messaging, Google Play) for application distribution, push notification delivery, and payment execution.
- AI Service Providers: Vetted third-party AI companies and routing infrastructure, detailed individually in Artificial Intelligence Services below.
We engage our third-party service providers under commercial agreements, developer terms, and data protection terms that require them to process information solely to deliver the services we have contracted, prohibit unauthorized secondary use of your data, and mandate appropriate technical and organizational security measures.
- •For Legal Purposes: We may disclose your information where required to do so by law or in response to valid requests by public authorities.
- •With Your Consent: We may disclose your information for any other purpose with your consent.
9. Artificial Intelligence Services
Some OURTOR features are provided with the help of third-party AI companies outside OURTOR. Where we use these services, we transmit only the data necessary to provide that specific feature. We do not automatically attach your account name, registered email address, account identifier, or device identifier to third-party AI requests. However, conversational messages you write (such as chatting with a site guide), photos you choose to attach or upload, and text you submit (such as travel stories, tips, or Thoughts) are sent to the designated AI provider to fulfill the request. If you choose to include personal details, identifiable photos, or names within your messages or uploads, that information will be processed by the recipient AI service. Your Travel DNA is calculated on our own systems, and only broad thematic descriptors are ever sent: the eras and themes it leans towards when you chat with a site, and your travel archetypes, your strongest preference categories, and how confident we are in them when you ask for an AI itinerary.
- •Your guide speaking aloud: we send the words to be spoken, along with the voice and style settings, to ElevenLabs, which returns the audio. If your language is not English, those words go through OpenRouter to be translated first.
- •Chatting with a site: we send your messages, the recent messages in that conversation, the name of the site and city, the eras and themes your Travel DNA leans towards, the countries you visit most, the name you gave your guide, and any photo you choose to attach, directly to OpenAI.
- •Captions for your own narration: if you record narration for a travel story, the audio recording is sent directly to OpenAI (Whisper) to transcribe captions. If you turn this off, captions are made from your script instead.
- •Translating your stories: if someone reads a travel story you made in another language, its captions are translated through OpenRouter. If you turn this off, readers see them in English.
- •Recommendations near you: to choose what to recommend, we send the nearby places we are choosing between, and how far each is from you, through OpenRouter. If you turn this off, they are ranked by distance instead.
- •Sorting what travellers say: the Thoughts you leave at a place, and the topic you file a travel tip under, are processed through OpenRouter to group what travellers say into themes. This is separate from the safety check on anything you publish.
- •Safety checks on content you publish: photos you publish are sent to OpenAI, and comments, Thoughts, and travel tips you publish are sent through OpenRouter (or our standby provider), to be checked automatically for harmful content before they appear.
- •Translating your guide's words: we send the words to be spoken through OpenRouter when your chosen language is not English.
- •AI itineraries and story music: we send your travel preference categories and the names of candidate places through OpenRouter; music is then generated by Suno, reached through AceDataCloud. Writing a story with AI help — finding a moment to tell, drafting or checking a script, suggesting a title or tags — sends that text through OpenRouter as well. When our staff design a relic or fill in a place's details with AI help, those details go through OpenRouter too, and Replicate draws the relic's image and 3D model.
- •Suggesting a new place: its name and position on the map go through OpenRouter to size its area, and to draft a description if you ask. Once you submit it, its name and city are looked up on the web the same way. Without your consent the area starts at a standard size and the place is looked up on Wikipedia and Wikidata only.
- •Guide portraits: we send a description assembled from the options you chose for your guide — its look, character and voice — to Replicate, which draws the portrait, and through OpenRouter for the short blurb shown beneath it. No photograph of you and no free text is included.
OpenRouter Safeguards
OpenRouter is an AI routing service that forwards requests to specific model endpoints. When we route requests through OpenRouter, we enforce strict architectural and configuration safeguards:
- •Approved models and vetted providers: Requests are strictly restricted to approved, vetted AI models and established hosting infrastructure.
- •Model training blocked: Account settings and routing parameters explicitly prohibit providers from using prompts or completions to train foundation models.
- •Public prompt publishing blocked: Automatic logging, sharing, or publishing of prompts and outputs to public prompt libraries is blocked.
- •Non-zero-retention endpoints blocked: Endpoints that require indefinite retention or that do not offer zero-retention or minimal operational logging are excluded from our routing pool.
- •Anonymous and stealth models excluded: We strictly bar anonymous, "stealth", or unverified community models where model provenance or hosting security cannot be verified.
Direct OpenAI and Anthropic Processing
A request that would go through OpenRouter can instead go directly to Anthropic (our automated standby provider) or OpenAI when OpenRouter is unavailable, or when a feature is routed to them directly. In addition, site chat, photo vision analysis, and Whisper caption transcription are connected directly to OpenAI.
For both direct OpenAI and Anthropic commercial API services:
- •No model training by default: Customer data submitted via commercial APIs is not used to train or improve foundation models by default.
- •Standard 30-day retention: Standard API services may retain content on secure servers for up to 30 days solely for the purpose of monitoring for abuse, enforcing safety rules, and complying with legal obligations, after which it is deleted.
- •Service-specific and legal exceptions: Certain specialized services or security investigations may operate under specific retention policies. We do not promise zero retention across all third-party AI services, as standard operational logging and security retention periods apply under each vendor's commercial terms.
Model Changes and Infrastructure Providers
The specific AI models powering OURTOR features may change, be upgraded, or be replaced over time as technology advances, while all stated safeguards, provider vetting, and training prohibitions remain continuously enforced. We distinguish between the model developer (the organization that designed the model architecture, such as DeepSeek, Meta, Mistral, OpenAI, or Anthropic) and the company actually processing and hosting the request (the infrastructure host or cloud inference provider that operates the physical servers running the model at request time via OpenRouter or direct cloud platforms). All requests are executed only by vetted hosting providers under contractual data protection standards.
How Consent and Exceptions Work
You choose which of these optional features are active. Before any optional feature sends information to a third-party AI service, the app asks for your explicit permission. You can change your choices at any time in the app under Settings → Privacy → AI features (including selecting "Turn everything off"). Turning a feature off stops that sharing immediately, including any queued background jobs; the rest of OURTOR continues to work normally.
Two operations are not behind an optional switch:
- •Safety checks on published content: Automated safety moderation checks on published comments, Thoughts, travel tips, and photos run automatically when you post to keep shared spaces safe for everyone (supporting platform safety obligations such as App Store Guideline 1.2). This check occurs only when you publish.
- •Introductory tutorial narration: A small set of fixed introductory guide narration lines in the first-run tutorial may be synthesized aloud via ElevenLabs (and translated through OpenRouter if using a non-English language) before you have recorded an AI choice. These lines consist strictly of fixed, static app copy featuring the default guide persona; they contain no personal data, no names, and no account identifiers. If you subsequently decline voice features or choose "Keep all of these off", all spoken audio stops immediately, including in tutorials.
Staff Administrative Tools
Separately from the traveller features above, authorized OURTOR staff use our AI routing to format and tidy pasted recipient lists — such as newsletter subscriber or announcement lists — into structured recipient records. When staff use this tool, the entire pasted text is sent for processing via OpenRouter. While intended to extract names and email addresses, the submitted text may include any other columns, contact details, or information contained within the pasted document. This processing is transient and used solely to prepare communications; it is not used for model training.
Third-Party Provider Terms
We engage third-party AI providers (including ElevenLabs for voice synthesis, Replicate for image and 3D generation, and Suno via AceDataCloud for music composition) under commercial API terms of service and standard developer agreements. Under these agreements, providers process data solely on our behalf to deliver the requested output, are prohibited from using customer API data to train public foundation models without consent, and are required to implement reasonable and appropriate technical and organizational security measures. Where services are routed via intermediaries or downstream infrastructure, processing remains subject to the applicable service agreements and privacy standards of those platforms.
10. International Data Transfers
OURTOR TECH LTD is based in the United Kingdom, and our primary application hosting and database infrastructure are located in the United Kingdom (AWS London region, eu-west-2).
In delivering our Service, your personal data and content may be transferred to, stored, and processed by third-party service providers and AI processors located in countries outside the United Kingdom and the European Economic Area (EEA), particularly in the United States (including Amazon Web Services, OpenAI, Anthropic, ElevenLabs, Replicate, Sentry, Mapbox, RevenueCat, and LiveKit).
Where we transfer personal data internationally, we ensure that appropriate safeguards are in place to provide a level of data protection essentially equivalent to that guaranteed under UK and EU GDPR laws. These transfer mechanisms include:
- •Standard Contractual Clauses & UK Addendum: Executing the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission's Standard Contractual Clauses (SCCs) with overseas service providers.
- •Adequacy Decisions & Data Privacy Framework: Relying on UK adequacy regulations or certifications under the UK Extension to the EU-U.S. Data Privacy Framework (DPF) where recipient entities participate in certified frameworks.
- •Technical & Operational Security: Enforcing industry-standard transport encryption (TLS 1.2 or TLS 1.3) and encryption at rest (AES-256) across all international data transmissions.
11. Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
12. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and, where appropriate, notifying you by email or other means.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
13. Contact Us
If you have any questions about this Privacy Policy, please contact us:
OURTOR TECH LTD
Email: tor@ourtor.com
If you have a complaint about our use of your personal information, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.