5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. While we strive to link only to reputable third parties, we cannot monitor or control their actions, content, or data practices. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. We encourage you to approach interactions with third-party websites or applications cautiously, especially if providing personal or sensitive data. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Before sharing your personal information, you should investigate how those third parties will handle your data, including reviewing their privacy policies and security measures. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions. If you suspect misuse or improper handling of your data by a third party linked to our Services, we recommend notifying the third party directly and reporting any concerns to us at
[email protected] for review.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://talkpal.ai/cookie-policy/.
You can manage or disable cookies through your browser settings; however, please note that certain features of our Services may become limited or unavailable if cookies are blocked.
We are committed to transparency regarding our use of tracking technologies and encourage you to familiarize yourself with our Cookie Notice for detailed guidance.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Google, Apple, or Facebook logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The extent of information shared with us depends on your social media platform’s privacy settings and permissions you grant. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. We may also collect any other data explicitly shared during the login process, such as preferences or interactions tied to your social media account.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. To ensure transparency, we will never post on your behalf or share your activities without your explicit consent. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We strongly encourage you to regularly review and adjust your social media privacy settings to align with your preferences. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Netherlands, Sweden, United States, United Kingdom, France, Germany and other EU countries. If you are accessing our Services from outside Netherlands, Sweden, United States, United Kingdom, France, Germany and other EU countries, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in the Netherlands, Sweden, United States, United Kingdom, France, Germany, other EU countries, and other countries. We take steps to ensure that your information is handled securely and in accordance with this privacy notice, regardless of where it is processed. This includes leveraging industry-standard encryption protocols, secure server configurations, and stringent access controls.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
European Commission’s Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses are legally binding safeguards that ensure your data is treated with the same level of protection required by EEA and UK data protection laws. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. We maintain a documented data transfer assessment for these mechanisms to verify compliance and address evolving regulatory requirements. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
9. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). We periodically review our data retention policies to ensure compliance with changing laws and evolving best practices, minimizing unnecessary data storage. No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us. However, certain data, such as payment records or transaction details, may be retained for longer durations to comply with legal or regulatory requirements.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. We also ensure that any archived information is securely encrypted and inaccessible to unauthorized parties.
If you have questions about specific retention periods for your personal information, or if you wish to request deletion, you may contact us at [email protected].
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include, but are not limited to, encryption protocols, secure socket layer (SSL) technology, regular security audits, multi-factor authentication, and strict access controls for sensitive data. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. We strongly recommend that you use strong, unique passwords for your accounts and take additional precautions such as enabling multi-factor authentication when available. You should only access the Services within a secure environment. Avoid using public or unsecured Wi-Fi networks when accessing our Services to minimize potential risks.
11. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you confirm that all information provided is accurate and truthful, including representations regarding your age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. We may also restrict access to the Services until age verification is completed. If you become aware of any data we may have collected from children under age 18, please contact us at
[email protected].
12. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We will consider and act upon any request in accordance with applicable data protection laws. We strive to respond promptly, and no later than the timeframes prescribed by applicable law, to ensure your rights are respected.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the legality of any processing conducted prior to your withdrawal. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Archived data will be securely stored and encrypted until it is permanently deleted.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. However, please note that rejecting cookies may impact your experience on the Services, including certain features or functionality that rely on cookies to operate. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Notice: https://talkpal.ai/cookie-policy/.
If you have questions or comments about your privacy rights, you may email us at [email protected].
13. CONTROLS FOR DO-NOT-TRACK FEATURES
In Short: Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard or regulatory framework for recognizing and implementing DNT signals has been finalized. While some third-party services we utilize may independently honor DNT requests, we currently do not guarantee that all data collection activities across our Services adhere to these settings. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, or if we update our practices to align with evolving technology standards or legal requirements, we will inform you about that practice in a revised version of this privacy notice.
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California or Virginia, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
C. Protected classification characteristics under state or federal law | Gender and date of birth | YES |
D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
E. Biometric information | Fingerprints and voiceprints | NO |
F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
G. Geolocation data | Device location | NO |
H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | YES |
I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
J. Education Information | Student records and directory information | NO |
K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | YES |
| L. Sensitive personal Information | | NO |
We will use and retain the collected personal information as needed to provide the Services or for:
- Category A – As long as the user has an account with us
- Category B – As long as the user has an account with us
- Category C – As long as the user has an account with us
- Category D – As long as the user has an account with us
- Category F – As long as the user has an account with us
- Category H – As long as the user has an account with us
- Category K – As long as the user has an account with us
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?“
We collect and share your personal information through:
- Targeting cookies/Marketing cookies
- Social media cookies
- Beacons/Pixels/Tags
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.
We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
- Category K. Inferences drawn from collected personal information
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”
California Residents
California Civil Code Section 1798.83, also known as the “Shine The Light” law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a “residents” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, This includes exceptions such as (but not limited to):
- the exercise of another consumer’s right to free speech or other legal rights;
- our compliance with legal obligations, such as tax or regulatory reporting;
- internal uses that are reasonably aligned with your expectations as a consumer, such as maintaining transaction records for legitimate business purposes; or
- detecting or protecting against fraudulent, illegal, or harmful activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the retention periods for each category of personal information, or the criteria we use to determine such periods;
- the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties;
- the categories of personal information that we sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer’s sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. Verification is essential to protect your data and prevent unauthorized access or misuse. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may:
- Ask you to provide specific details, such as your name, email address, account information, or recent transactions made through our Services.
- Contact you through a communication method (e.g., email or phone) that you have previously provided to us.
- Use multifactor authentication, such as sending a verification code to your registered email or phone number, to confirm your identity.
- Request additional documentation if necessary, such as a government-issued ID or proof of address, to validate your identity for sensitive or high-risk requests.
In some cases, we may rely on third-party identity verification services to enhance the security and efficiency of the verification process.
We will only use personal information provided in your request to verify your identity or authority to make the request. This information will not be used for any other purpose unless required by law. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may:
- Request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
- Inform you of why the information provided was insufficient to complete the verification process and guide you on next steps.
We take your privacy seriously and have implemented strict security measures to protect any additional information provided during the verification process. We will delete such additionally provided information as soon as we finish verifying you. If we cannot complete the verification process after reasonable efforts, we may decline the request and inform you of your options, including how to appeal the decision.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by visiting https://talkpal.ai/contact/, by email at
[email protected],
or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.
“Sale of personal data” means the exchange of personal data for monetary consideration.
If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
- Right to lodge a complaint if you believe we are not processing your personal data in compliance with applicable laws, you have the right to file a complaint with a data protection authority in your jurisdiction.
Exercise your rights provided under the Virginia VCDPA
You may contact us by email at
[email protected] or visit https://talkpal.ai/contact/.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request. Authorized agents must provide verifiable documentation, such as a signed authorization letter or a valid power of attorney, to act on your behalf.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. If an extension is required, we will inform you in writing and provide a detailed explanation for the delay, as well as an expected completion date. In cases where we are unable to verify your identity with the information provided, we will notify you promptly and explain what additional steps are required to complete the verification process. If you fail to provide sufficient information for verification within a reasonable timeframe, your request may be denied, and we will inform you of the reasons for denial. We will maintain a record of verification requests and responses for legal compliance purposes, ensuring that we process all requests in accordance with applicable privacy regulations.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at
[email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
15. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. For significant changes that materially affect how we process your personal information, we will provide more prominent notice, such as a banner on our website, an in-app alert, or direct communication via email or other contact methods you have provided.
In some cases, where legally required, we will seek your explicit consent before implementing changes to how we process your personal information. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. Your continued use of our Services following the posting of updated versions of this privacy notice will constitute your acknowledgment of the updates and your agreement to comply with the latest version.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
[email protected] or contact us by post at:
Talkpal, Inc.
2810 N Church St
Wilmington, DE 19802-4447
United States
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: https://talkpal.ai/contact/.
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