Privacy Policy
1. Introduction
Tiro Translator - Travel AI ("we", "our", or "the App") provides AI-powered translation services including voice translation, camera/image translation, and an AI Agent that helps you communicate with service staff (e.g., in restaurants). We follow data minimization and privacy by design. Most data is processed in real time and not stored on our servers. Where temporary processing is required (e.g., for multi-turn Agent conversations), we apply strict retention limits.
2. Legal Basis for Processing (GDPR Article 6)
We process your data only when one of the following applies:
- Your consent (e.g., for microphone, camera, or speech recognition access) - you can withdraw anytime in device Settings.
- Performance of a contract (providing the translation service you requested).
- Legitimate interests (improving app stability via anonymous crash reports) that do not override your rights.
- For voice cloning (biometric data), we rely on your explicit consent, which you provide when enabling the feature.
3. What Data We Process and How
3.1 Voice Translation
- Data: Your voice recording (temporarily) + transcribed text.
- Processing: The recording and text are sent to our own AI translation server (Amphion) solely to generate the translation result.
- User consent: Before you use voice translation for the first time, the App will display a pop-up explaining that your voice data will be sent to our secure server for processing, and ask for your permission. You can decline, in which case voice translation will not be available.
- Storage: Audio is discarded immediately after translation. No translation history is stored on our servers.
3.2 Camera / Image Translation
- Data: The image you capture (e.g., a menu).
- Processing: The image is sent to our own AI processing server (Amphion) to extract and translate text. The image is not stored after translation.
- User consent: The first time you use image translation, the App will ask for your explicit permission before sending any image to our server.
- Important: Do not capture images containing other people's faces, ID cards, or sensitive personal data. If you do, you are responsible for having obtained necessary consent.
3.3 AI Agent (Help you talk to service staff)
- Data: Conversation history (your questions, AI suggestions, and optionally the staff's response you type back) - kept temporarily to maintain context.
- Processing: The context is sent to our own Amphion API to generate helpful replies. Voice cloning (if enabled) uses the same infrastructure.
- User consent: Before you start an Agent session for the first time, the App will request your permission to send conversation data to our server. You can withdraw consent anytime by closing the session or disabling the feature.
- Storage: No cloud storage beyond the active session. All context is erased from server memory when you close the Agent view or after 15 minutes of inactivity. Voice samples are not stored after session end.
3.4 Device Permissions
We request only essential permissions:
- Microphone - for voice translation.
- Camera - for image translation.
- Speech Recognition - to convert your voice to text (using Apple's on-device or Apple-provided framework).
You can manage or revoke these anytime in iOS Settings.
3.5 Anonymous Diagnostics
We may collect non-identifiable crash logs and performance metrics to improve the App. This data contains no personal information and cannot be linked back to you.
4. Data Processing Infrastructure
All AI processing (translation, conversation, voice cloning) is performed by Amphion, our own secure server infrastructure. We do not share your data with any external AI service provider (such as Google, OpenAI, or others).
- Amphion servers are hosted on Tencent Cloud. For users in the European Economic Area, data is processed in Frankfurt, Germany. For users in China, data is processed in mainland China (Beijing/Shanghai/Guangzhou).
- All data sent to our servers is transient - processed only to generate a response and not retained beyond the request.
- No third-party AI company has access to your data. Amphion acts as the data processor under our direct control.
International Data Transfers (if applicable): Because we use regional servers (EU / China), data from European users stays in Europe. No transfer outside your region occurs except as necessary to provide the service (which is not the case for Amphion).
Changes to Infrastructure: If we ever add a third-party AI service, we will update this policy and notify you via an in-app notice. You will have the right to stop using the App.
5. Data Retention & Your Control
- Cloud storage: We do not store your translations, images, voice recordings, Agent conversations, or voice clones on our servers beyond the few seconds needed to process your request.
-
Local storage: The App may temporarily keep recent
translations on your device for convenience (e.g., history). You can
clear this data at any time by:
- Tapping "Clear History" inside the App (if available), or
- Deleting the App entirely.
- Agent conversation context & voice clone settings: Automatically erased when you close the Agent view or after 15 minutes of inactivity.
6. Your Rights under GDPR
You have the right to:
- Access - ask what data we hold about you. We will confirm that we hold none that can identify you.
- Erasure ("right to be forgotten") - since we store nothing on our servers, simply delete the App to remove all local data.
- Restrict processing - withdraw permissions in device Settings.
- Data portability - not applicable as no structured personal data is stored.
- Lodge a complaint with your local EU supervisory authority (e.g., ICO in UK, CNIL in France).
To exercise these rights, contact us at Contact@makaw.ai. We will respond within 30 days.
7. Children's Privacy
We do not knowingly collect information from children under 16 years of age (or higher if your country's law requires, e.g., 16 in some EU states). If you believe a child has used our App, please contact us and we will ensure no residual data exists (though we store none by design).
8. Changes to This Privacy Policy
We may update this policy. If changes significantly affect your rights, we will notify you via an in-app notice or on the App Store update description.
9. Contact Us
Data Controller:
Tiro Translator - Travel AI (represented by Amphion technology)
Address: Amphion Technology Ltd., Chuangtou Building 405A, Tengfei Road, Shenzhen, China
Email for GDPR requests: Contact@makaw.ai
For GDPR requests, please include "GDPR Request" in the subject line.
10. Additional Information for Users in China
We comply with the Personal Information Protection Law of the People's Republic of China (PIPL).
- Data localization: All personal information from users located in China is processed and stored exclusively on servers located within mainland China. No data collected from Chinese users is transferred outside of China.
- Server location: Our China-specific infrastructure is hosted on Tencent Cloud with data centers located in mainland China (Beijing/Shanghai/Guangzhou regions).
- No long-term storage: As stated in Section 5, we do not retain your translations, voice recordings, images, or Agent conversations on our servers beyond the few seconds needed to process your request.
- Your rights under PIPL: You have the right to access, correct, and delete your personal information, and to withdraw your consent. To exercise these rights, contact us at Contact@makaw.ai. We will respond within 15 working days as required by Chinese law.
- Complaint channel: If you believe your privacy rights have been violated, you may file a complaint with the Cyberspace Administration of China (CAC) via https://www.12377.cn.
For any questions regarding this China-specific notice, please email us at Contact@makaw.ai.