LIMINAL TOUCH PRIVACY POLICY

Last Updated: April 22, 2026

Liminal Touch, LLC (“Liminal,” “we,” “us,” or “our”) recognizes that you are entrusting us with deeply personal and sensitive information. This Privacy Policy explains how we collect, use, share, and protect your data when you interact with our marketing website, the Liminal Setup Portal, and the Liminal Touch hardware device (collectively, the “Services”).

1. THE DATA WE COLLECT

We collect data across two distinct environments: the public-facing Marketing Website and the secure, private Setup Portal.

A. Marketing Website & Sales Data When you browse our main website or make a purchase, we collect standard e-commerce and analytical data:

Contact & Billing Information: Name, email address, shipping address, and phone number.
Payment Information: Processed securely via our third-party payment processor (Stripe). We do not store full credit card numbers on our servers.
Device & Tracking Data: IP addresses, browser types, and interaction metrics gathered via cookies and tracking pixels (see Section 6).

B. Setup Portal & Source Materials When you log into the Setup Portal to configure a Liminal Device, we collect the highly sensitive data required to build the Digital Persona.

Biographical & Boundary Data: Question responses, personality slider settings, relationship tags, and "Do Not Mention" directives.
Source Materials: Audio recordings, video files, and photographs uploaded by you.
Biometric Data: To synthesize the voice for the Digital Persona, our software analyzes your uploaded audio to extract a unique mathematical representation of vocal characteristics (a "Voiceprint").

C. Children’s Privacy (COPPA) While the Liminal Touch Services are intended for purchase and setup by adults 18 and older, we understand that family memorialization may involve the names or voices of minors. We do not knowingly collect personal information directly from children under 13. Any data regarding minors must be provided by a parent or legal guardian solely for the purpose of personalizing the Digital Persona.

2. HOW WE USE YOUR DATA (AND OUR PROMISE ON AI TRAINING)

Because of the emotional weight of grief support, we maintain strict boundaries on how your data is utilized.

Delivering the Service: Your Source Materials and biographical data are used strictly to generate, operate, and maintain the unique Digital Persona on your specific Liminal Device.
ZERO Global AI Training: We will never use your Source Materials, Voiceprints, or generated interactions to train, fine-tune, or improve our global AI models or any third-party AI models.
Aggregated/Anonymized Data: We may strip all personally identifiable information and use purely anonymized, aggregated data (e.g., "30% of users select the 'Nature' setting") to observe broad market trends and improve our overall service structure.

3. SENSITIVE CONTENT & POSTHUMOUS PRIVACY

We understand the unique nature of the data you provide to Liminal Touch.

Posthumous Privacy & Right of Publicity: Liminal Touch processes the Source Materials of the honoree based on your explicit representation that you are the executor, next of kin, or authorized representative of the estate. Because privacy laws vary regarding deceased individuals, we treat all uploaded Source Materials with the highest level of security, regardless of the legal status of the honoree.
HIPAA Disclaimer: Liminal Touch is not a healthcare provider and is not subject to the Health Insurance Portability and Accountability Act (HIPAA). Please be aware that any health-related anecdotes or medical history you include in the Setup Portal will be treated with our standard high-security protocols, but are not protected under HIPAA.

4. SHARING DATA WITH THIRD PARTIES

Liminal does not sell your personal data. We only share information with trusted third parties under strict confidentiality agreements or legal obligations:

AI & Synthesis Partners: We utilize secure, enterprise-grade third-party Application Programming Interfaces (APIs) to process the natural language and synthesize the voice audio. These partners act strictly as sub-processors; they are contractually prohibited from retaining your Source Materials or using your data to train their own models.
Cloud Hosting & Payment Processors: Your data is securely encrypted and stored using standard cloud infrastructure providers. Financial data is transmitted directly to Stripe.
Law Enforcement & Subpoenas: We will not disclose your Setup Portal data or Source Materials to law enforcement unless compelled by a valid subpoena, court order, or search warrant. If legally permitted, we will attempt to notify you before turning over any data.
Business Transfers: If Liminal Touch is involved in a merger, acquisition, or sale of assets, your personal data and Source Materials may be transferred. We will ensure that the acquiring entity agrees to be bound by the strict zero-retention, non-training, and biometric destruction standards outlined in this Privacy Policy.

5. BIOMETRIC DATA & THE 1-YEAR RETENTION POLICY

We do not hold your sensitive data indefinitely. To protect your privacy and the legacy of the honoree, Liminal enforces a strict data sunset policy.

The Retention Period: Unless you actively maintain an extended subscription, all Generated Content, Source Materials, and Biographical Data are stored for a maximum period of one (1) year following the initial generation date.
Destruction of Biometrics: At the conclusion of the Retention Period, your Voiceprint and all underlying biometric identifiers will be permanently and irretrievably destroyed from our servers and the servers of our third-party sub-processors.
Local Archival Format: It is your responsibility to utilize the Local Archival Tool before the Retention Period expires. You will be able to download your Generated Content in standard, non-proprietary formats (e.g., .mp3 for audio, .txt for transcripts). You will not be downloading the proprietary AI models or the underlying algorithmic software.

6. COOKIES & TRACKING TECHNOLOGY

We utilize cookies, web beacons, and similar tracking technologies only on our public Marketing Website to analyze traffic, improve site functionality, and deliver targeted advertising.

Marketing & Retargeting: We may use tracking pixels (such as Meta Pixel or Google Analytics) to show Liminal advertisements to users who have previously visited our marketing site.
The Setup Portal is Exempt: We do not deploy marketing, retargeting, or advertising cookies within the secure Setup Portal. Information provided within the portal is never used for advertising purposes.
Opting Out: You may disable cookies through your browser settings or utilize standard opt-out tools for targeted advertising.

7. STATE-SPECIFIC PRIVACY RIGHTS (CALIFORNIA)

If you are a resident of California (or other states with similar comprehensive privacy laws like the CCPA/CPRA), you possess the following rights regarding your personal data:

The Right to Know: You may request disclosure of the specific pieces of personal information we have collected about you.
The Right to Delete: You may request the deletion of your personal information and Source Materials prior to the standard 1-Year Retention expiration. (Note: Deleting this data will permanently disable the Liminal Device's AI functionality).
The Right to Opt-Out: You have the right to opt-out of the sharing of your personal information for cross-context behavioral advertising via our Marketing Website.
Non-Discrimination: We will not deny you goods or services for exercising your privacy rights. To submit a request, please contact us using the information provided in Section 10.

8. DATA SECURITY & BREACH NOTIFICATION

We employ industry-standard administrative, technical, and physical security measures to protect your personal information and Source Materials from unauthorized access, loss, or alteration. However, no internet transmission or electronic storage is 100% secure. You are responsible for maintaining the security of your Setup Portal login credentials. In the event of a security breach that compromises your unencrypted biometric data or Source Materials, Liminal will notify you and the relevant regulatory authorities in accordance with applicable state and federal laws.

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our technology or legal obligations. We will notify active users of any material changes via the email address associated with their Setup Portal account before the changes take effect.

10. CONTACT INFORMATION

If you have questions about this Privacy Policy, your biometric data, or wish to exercise your data rights, please contact our privacy compliance team at:

Liminal Touch, LLC