TochingCloud Apps!

 

Last updated: September 14, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Application refers to Application, the software program provided by the Company.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Application.
  • Country refers to: Kazakhstan
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Application.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Camera, Face and Motion Data

The Application (DynamicPOV) turns the movement of Your head into camera movement inside a flight simulator running on Your own computer. To do this it can use the front camera and, on devices that have one, the TrueDepth camera by way of Apple’s ARKit face tracking API. This section describes that processing in full. Where it differs from the general statements elsewhere in this Privacy Policy, this section governs.

Information Collected Using the TrueDepth API

When, and only when, You switch on camera head tracking, eye tracking or hand tracking, the Application starts an ARKit face tracking session (ARFaceTrackingConfiguration) that uses the TrueDepth camera. The session is configured to track at most one face, with light estimation disabled. From that session the Application reads only the following:

  • The position and orientation of a single face relative to the device — the ARKit face anchor transform — which the Application uses as Your head position and head rotation.
  • The ARKit gaze direction (lookAtPoint), which the Application converts immediately into a single normalized point on the screen. This is read only while eye tracking is switched on.
  • Four ARKit blend shape coefficients — eyeBlinkLeft, eyeBlinkRight, eyeWideLeft and eyeWideRight — each a single number between 0 and 1 describing how open an eyelid is. These are read only while eye tracking is switched on, and are used to recognise the deliberate wide-eye gesture that engages the zoom feature.
  • Hand pose points returned by Apple’s on-device Vision framework from the same camera frames. These are read only while hand tracking is switched on, and describe hand position, not face data.

The Application does not read, request, derive, store or transmit the face mesh geometry, the depth map, the camera image, any other blend shape coefficient, or any face identifier or face template. No photograph, video, depth map or face model is recorded, saved to storage, included in a backup, written to a log, or sent anywhere by any means. Camera frames are processed inside the device and are released as soon as the values above have been computed from them.

Face data is never used to identify or authenticate anyone, is never used for advertising or marketing, is never used to build a profile of You, is never used to train any model, and is never used for any purpose other than the real-time camera control described below.

Purposes for Which Face Data Is Used

The information above is used for one purpose only: to work out, many times per second, where Your head is and where You are looking, so that the virtual camera in Your flight simulator can be moved to match. There is no secondary purpose. Each frame is converted at once into a small set of camera control numbers — three head translation values in centimetres, three head rotation values in degrees, an optional zoom or field-of-view value, a normalized gaze point, a pair of gaze aim angles, the four eyelid coefficients and a hand pointer state — and these derived numbers are what the Application sends to the flight simulator or head tracking software You have paired it with. They cannot be used to reconstruct an image of Your face, Your face geometry, or Your identity.

Storage and Retention of Face Data

Face data is held only in the temporary memory of Your device, for as long as it takes to compute the next camera position — a fraction of a second — and is then overwritten by the next frame. It is never written to the device’s storage, to a file, to a database, to a backup, or to a log, and it is never placed in any cloud storage.

The recentring baseline and the eye tracking calibration the Application computes while You use it exist only in memory while tracking is running, and are discarded when You switch tracking off, when the tracking session restarts, or when the Application quits. The settings the Application does save on Your device contain only Your own preferences and connection details — for example which movement axes are enabled, sensitivity values, and the address of Your computer — and never contain face data.

The retention period for face data is therefore zero beyond the live frame being processed. Because none of it is retained, there is nothing to delete and no deletion request is necessary: switching tracking off, revoking camera permission, or closing the Application ends the processing immediately and nothing survives it. This paragraph prevails over the general “Retention of Your Personal Data” and “Delete Your Personal Data” sections below in respect of face data.

Sharing, Disclosure and Transmission of Face Data

Face data is not shared with anyone. It is not sold, rented, traded, or disclosed to any third party, and it does not leave Your device. The only information that leaves Your device is the set of derived camera control numbers described under “Purposes for Which Face Data Is Used” above, and it travels only to the destination You have chosen:

  • Local network connection. The values go straight from Your device to Your own computer across Your own local network. They do not pass through Our servers, or anyone else’s.
  • Cloud relay connection, which applies only if You choose it and pair Your devices through it. The values travel over an encrypted (TLS) connection to a relay server operated by Us — fsmt.touching.cloud, or one of the regional relays fsmt-can.touching.cloud, fsmt-ger.touching.cloud and fsmt-sin.touching.cloud, hosted in America, Europe and Asia respectively — which passes them on to Your own computer. The relay keeps only the single most recent set of values in memory so that it can forward it, replaces it with the next set as it arrives, and discards it when the session ends. The relay does not write these values to a disk, a database or a log; its operational logs record connection counts and diagnostic events only, never head, gaze or hand values.

The Application contains no advertising, analytics, attribution or crash reporting software development kits, and sends no data of any kind to any third party for those purposes. We do not use Service Providers to process face data, and no face data is transferred to any affiliate, partner, advertiser or data broker.

Your Control Over Camera and Face Data

Camera-based tracking does not run until You switch it on. iOS asks for Your permission the first time the camera is needed, and You may withdraw that permission at any time in Settings > Privacy & Security > Camera. Head tracking, eye tracking and hand tracking are separate options that You may switch off individually inside the Application at any time; when the last of them is switched off the camera session stops immediately and the device’s camera indicator goes out. Head tracking using compatible headphones relies on their motion sensors only, and involves neither the camera nor any face data.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal 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 Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

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.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

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.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: