Privacy Policy

Last Updated: July 16, 2025

Introduction

Echo is an Augmentative and Alternative Communication (AAC) app developed by Ace Centre, a registered UK charity (no. 1089313). This privacy policy explains how the Echo app handles your personal information, with particular attention to facial gesture recognition features.

Information We Collect

App Usage Data

Echo operates primarily offline and stores data locally on your device:

  • Communication vocabulary and custom phrases you create

  • App settings and preferences

  • Switch and gesture configurations

  • Audio settings and voice preferences

Facial Gesture Data (Optional Feature)

When you choose to enable facial gesture recognition, Echo uses your device's front-facing camera to detect facial movements for accessibility control.

What Facial Data is Collected:

  • Real-time facial movement patterns (eye blinks, jaw movements, head position, etc.)

  • Facial geometry measurements for gesture recognition

  • Head orientation and movement data

  • Temporal expression data for configured gestures

Important Privacy Protections:

  • No Storage: Facial data is processed in real-time and immediately discarded

  • On-Device Only: All processing occurs locally using Apple's ARKit framework

  • No Transmission: Facial data never leaves your device

  • No Identification: No facial recognition or biometric authentication is performed

  • User Control: Facial gestures are disabled by default and require explicit activation

How We Use Your Information

App Functionality

  • To provide AAC communication features

  • To save your vocabulary and settings locally

  • To enable customizable access methods (switches, gestures, controllers)

  • To provide auditory scanning and voice output

Facial Gesture Accessibility

Facial data is used exclusively for:

  • Enabling users with limited mobility to control the app through facial movements

  • Providing customizable gesture recognition for individual needs

  • Supporting automatic gesture detection and calibration

  • Offering real-time feedback during gesture configuration

Data Storage and Retention

Local Data Storage

  • App settings, vocabulary, and configurations are stored locally on your device

  • Data remains on your device and is not transmitted to external servers

  • You can delete all app data by uninstalling the app

Facial Gesture Data

  • No Retention: Facial gesture data is not stored or retained

  • Real-Time Processing: Data is processed instantly and discarded

  • No Caching: No facial information is cached or logged

  • No Backup: Facial data is never included in device backups

Data Sharing

Echo does not share your personal information with third parties:

  • No data is transmitted to Ace Centre servers

  • No analytics or tracking data is collected

  • No facial data is shared with any organization

  • No user identification or profiling occurs

Your Privacy Rights

Control Over Facial Gestures

  • Facial gesture features are disabled by default

  • You must explicitly enable camera access and facial gesture recognition

  • You can disable facial gestures at any time in app settings

  • You can revoke camera permissions through device settings

Data Control

  • You control all data stored in the app

  • You can delete custom vocabulary and settings at any time

  • You can reset the app to default settings

  • Uninstalling the app removes all local data

Technical Implementation

ARKit and TrueDepth Technology

Echo uses Apple's standard ARKit framework for facial gesture recognition:

  • TrueDepth Devices: Uses TrueDepth camera for enhanced precision (iPhone X and later Pro models, iPad Pro)

  • Neural Engine Devices: Uses Neural Engine-based tracking on compatible devices without TrueDepth cameras

  • Privacy by Design: Follows Apple's privacy-focused, on-device processing guidelines

  • No Raw Images: Only processed gesture data is used, not camera images

Security Measures

  • All processing occurs within Apple's secure ARKit framework

  • No network connections required for facial gesture functionality

  • Camera access is clearly indicated by iOS system indicators

  • Facial gesture detection can be completely disabled

Device Compatibility

Facial gesture recognition is available on:

  • iPhone X and later (all models)

  • iPad Pro with TrueDepth camera

  • iPad Air (4th generation and later)

  • iPad (9th generation and later)

  • Other devices with A12 Bionic chip or later

On unsupported devices, facial gesture features are not available and no facial data is collected.

Children's Privacy

Echo is designed to be accessible to users of all ages, including children. For users under 13:

  • Parental consent should be obtained before enabling facial gesture features

  • Parents can control camera permissions through device settings

  • No personal information is collected or transmitted

  • All data processing occurs locally on the device

Changes to This Policy

We may update this privacy policy to reflect changes in our practices or applicable laws. Updates will be posted in the app and on our website. Continued use of the app after changes constitutes acceptance of the updated policy.

Contact Information

If you have questions about this privacy policy or Echo's privacy practices:

Ace Centre

  • Website: https://acecentre.org.uk

  • Email: [email protected]

  • Address: Ace Centre, Hollinwood Business Centre, Albert Street, Oldham, OL8 3QL, UK

Regulatory Compliance

This privacy policy complies with:

  • UK Data Protection Act 2018

  • General Data Protection Regulation (GDPR)

  • Apple App Store privacy requirements

  • Accessibility and assistive technology guidelines

Echo is developed by Ace Centre, a registered charity dedicated to supporting individuals with complex communication and physical difficulties.

PreviousAppearance

Last updated