Talko Privacy Policy
Last Revision Date: January 16, 2025
I. Introduction
At Talko, your privacy matters deeply to us. We've put in place a comprehensive and reliable system to safeguard your personal information. This way, you can fully enjoy our services, knowing they are secure and dependable.
II. Protection of Minors' Personal Information
Our services are not intended for individuals under 18. We make it a point not to knowingly collect any personal data from minors. To enforce this policy and keep our platform safe, we gather age-related details. This helps prevent underage access. In case we accidentally collect data from users younger than 18, we'll act fast to remove it. If you're under 18, you must not use our services. And if you notice a minor's data has been collected, reach out to us immediately.
III. Collection and Use of Personal Information
(I) Registration
To get started with Talko services, you need to set up an account. Remember, safeguarding your account is your responsibility. Never share your login credentials with others.
(II) Device Information
1. Device Identification and Unique Identifiers: We use this information to ensure our software and services run smoothly and securely.
2. Device-related Information: Automatically, we gather details about your device. This includes the device ID, brand, model, operating system and its version, current device status, hardware specs, and info from your internet service provider or mobile carrier like the IP address. When you use our app, we also note the network type, platform, and your interactions with its features.
(III) Data Collection for Analysis
To enhance your experience and the quality of our services, we collect device logs and usage data. Every time you engage with our services, our servers record detailed activities. This covers device configuration, IP address, access times, viewed pages and files, and used features. We also gather diagnostic data such as crash reports, hardware settings, and error logs. Sometimes, we may use your device ID and Advertising ID for further analysis. This helps us evaluate marketing strategies, boost service performance, and offer more personalized services and promotions. But we always do this with your explicit consent.
(IV) Permissions
To provide you with a rich user experience and ensure all our service features work, Talko might ask for certain permissions:
1. Photo Library Access: When you want to upload photos from your device's photo library, we'll request access. This lets you share pictures during chats or update your profile picture.
2. Camera Access: If you start taking photos or initiate a video call, we'll seek permission to use your camera. This enables functions like photo sharing and live video calls.
3. Audio and Video Access: When you choose to make a video call or record audio, we'll need access to your audio and video features for smooth communication.
4. Bluetooth Access: To give you a better audio experience when connecting to audio devices, we may ask for Bluetooth access. This allows seamless pairing.
5. External Storage Access: When you save or download content, we'll request permission to read from and write to your device's external storage. This helps us manage files like photos and videos.
6. Advertising IDs: To optimize our marketing, we may collect your device's Advertising IDs. This is for analyzing the effectiveness of our campaigns and refining our promotions.
Remember, these permissions are only used when you give your explicit consent. And you can manage or change them anytime in your device settings. We're committed to protecting your privacy, and your personal information will always stay confidential. It will never be used for unauthorized purposes.
IV. Sharing, Transfer, and Disclosure of Personal Information
(I) Information Sharing
1. With Explicit Permission: Your personal data will only be shared with third parties if you clearly say yes. You have full control over this.
2. To Comply with Legal Obligations: Sometimes, due to laws, regulations, or government requests, we might need to share your information. But we'll only disclose the minimum amount necessary to meet the legal requirement.
3. With Authorized Partners: We work with partners to offer certain services or complete specific tasks. In these cases, we'll only share the data they need to do their job. Our partners are strictly forbidden from using your information for any other purposes.
We also collaborate with third-party suppliers, service providers, and partners who support our service operations. This includes providing technical infrastructure, analyzing service performance, handling customer service, processing payments, conducting research, and evaluating advertising effectiveness. For example, we might share data related to app usage, user behavior, and marketing effectiveness with partners like Appsflyer for marketing analysis and attribution. We might also use platforms like Facebook for statistical tracking to understand user behavior and collect payment information. We have strict data protection agreements with these third parties. They must process your personal information according to our instructions, privacy policy, and relevant confidentiality and security standards.
If you don't agree with any part of this policy, we suggest you stop using our services. Talko is dedicated to maintaining a safe community, and sharing specific data is crucial for that.
V. Protection of Personal Information
We take a multi-faceted approach to secure your personal information. We follow industry best practices and regulatory requirements to keep your data confidential. We implement various measures: anonymizing data whenever possible, using reliable security systems to fend off malicious attacks, and setting up a strong access control mechanism. This limits access to personal information, following the principle of least privilege. Only authorized personnel can access sensitive data. Our staff also undergoes regular training to enhance their knowledge of personal information security and best practices.
We only collect the data relevant and necessary for our services, avoiding over-collection. If you suspect your personal data has been compromised, like through unauthorized account access, contact our customer support right away. We'll take prompt action to protect your information.
Please note that any information you share publicly while using our services, including personal and sensitive details, might be seen by others. So, be careful when sharing. Also, if a security incident involving your personal data occurs, we'll report it to the relevant regulatory authorities as per applicable laws.
VI. Management of Personal Information
(I) Accessing Personal Information
According to the law, you have the right to access your personal data. You can manage it in these ways:
1. Account Details: Log in to your account and go to [My - Settings]. There, you can view or update your account information.
2. Customer Support: If you can't access your data through the settings, contact our customer support. We'll respond to your inquiry within 15 days.
3. Other Personal Data: For other personal data generated while using our products or services, we'll provide access following relevant agreements and procedures.
4. Requesting a Copy: If you need a copy of your personal data, you can ask our customer support team.
(II) Deleting Personal Information
You can delete specific personal data using the steps for accessing personal information. Additionally, you can request deletion in these situations:
1. If our collection or processing of your data violates applicable laws or regulations.
2. If we process your personal data without getting your explicit consent.
3. If our handling of your data breaks our agreement with you.
4. If you no longer use our products or services and want to delete your account.
5. If we permanently stop providing products or services to you.
Once your deletion request is confirmed, we'll notify any third parties that have your personal data to also delete it. Unless the law requires us to keep it or they have separate authorization from you.
Please note that due to technical or legal reasons, personal data might not be removed immediately from our backup systems. But it will be stored securely and isolated until it can be fully deleted or anonymized.
(III) User Content
The content you share might be retained by other users. They could use screenshots, in-app tools, or other methods. Even if you request deletion, digital content might be recoverable for a while through forensic methods or temporary device storage. Although we try our best to delete user data quickly, we can't always guarantee immediate removal. Sometimes, we need to keep data briefly to meet legal obligations or for backup purposes.
(IV) Managing Your Information
We offer tools to help you control your personal data:
1. Access and Update: You can manage your personal information through the app's settings page. Some requests might be denied if they affect other users' privacy or violate legal obligations. You can submit requests to access, update, or delete your information through our designated process. You can also delete the app or request account deletion directly from your mobile device.
2. Deletion: You can delete or modify your account ID. But be aware that this could lead to the permanent loss of your account data. Talko will stop processing your personal information unless we have valid reasons, like legal requirements or protecting others' rights and freedoms.
VII. Legal Basis for Data Processing and Your Rights
(I) Legal Basis for Data Processing
We process your personal data in line with applicable privacy laws. The legal grounds include:
1. Consent: In certain cases, we'll ask for your explicit consent to collect and use your personal data.
2. Contractual Obligations: When processing your data is needed to fulfill a contract with you, we'll rely on this basis.
3. Legitimate Interests: We may process your data when it's necessary for our legitimate interests, like ensuring app security, maintaining functionality, and enhancing user experience.
4. Legal Compliance: Sometimes, we process your data to comply with legal or regulatory obligations.
5. Public Interest: In some situations, when it's required for matters of public interest, we'll handle your data accordingly.
(II) Your Rights
Under applicable data protection laws, you have these rights regarding your personal information:
1. Right to Deletion: In specific circumstances, you can ask for your personal data to be deleted.
2. Right to Restrict Processing: Sometimes, you can request that we limit the processing of your data.
3. Right of Access: You can ask to access the personal data we hold about you at any time.
4. Right to Data Portability: You have the right to ask us to provide your personal data in a transferable format to you or a third party.
5. Right to Correction: If your data is inaccurate or incomplete, you can ask for corrections or updates.
6. Right to Object: In particular cases, especially when data is processed based on legitimate interests, you can oppose the processing.
7. Right to File a Complaint: If you think we've violated privacy laws in processing your data, you can file a complaint with your local data protection authority.
8. Right to Withdraw Consent: If we're processing your data based on your consent, you can take back your consent at any time. This won't affect the lawfulness of processing done before you withdrew.
(III) International Privacy Law Compliance
We abide by international privacy laws and regulations for different regions:
1. PIPEDA (Personal Information Protection and Electronic Documents Act): Applicable to users in Canada.
2. LGPD (Brazilian General Data Protection Law): Applicable to users in Brazil.
3. Other regional or national privacy laws: Depending on where you are, like the CCPA (California Consumer Privacy Act) for Californians and the GDPR (General Data Protection Regulation) for EU and EEA users.
VIII. Privacy Rights of California Residents under the CCPA
California residents have special rights under the California Consumer Privacy Act (CCPA):
1. Right to Know: You can ask for details about the personal information we've collected, used, shared, or sold in the last 12 months. You can do this twice a year. This includes:
￮ The categories and specific pieces of personal information about you.
￮ The sources of your data (e.g., directly from you, your device, or third parties).
￮ The business purposes for collecting your data (e.g., service improvements, marketing, or fraud prevention).
￮ The categories of personal information disclosed for business purposes.
￮ The categories of personal information sold to third parties, if applicable.
￮ The third parties we've shared or sold your data with (e.g., ad networks, analytics services).
2. Right to Delete: You can request the deletion of your personal data. Once we confirm your request, we'll delete it and tell any service providers or others to do the same. Unless the law requires us to keep it or for reasons like fraud prevention or transaction completion.
3. Right to Know If Your Data Is Sold: You can ask if your data has been sold to third parties. If so, we'll notify you and give you an option to opt out. You can exercise this right anytime.
4. Right to Opt-Out of the Sale of Personal Information: California law lets you say no to the sale of your personal information. You can do this by going to our "Privacy Settings" page and submitting your request. Once you opt out, we'll stop selling your data, though we might still share with service providers for operational needs.
5. Right to Opt-Out of Sharing Personal Information for Targeted Advertising: You can choose not to share your data for targeted advertising. You can do this by visiting our "Ad Preferences" page or contacting us directly.
6. Right to Lodge a Complaint: If you think your data privacy rights have been violated or you're worried about how we handle your data, you can file a complaint with your local data protection authority. We encourage you to contact us first to sort out your concerns, but this doesn't stop you from making a formal complaint.
7. Right to Non-Discrimination: You can exercise your privacy rights without facing discrimination. We won't deny services, change rates, or alter quality if you do. But if necessary data is removed, some features or services might be affected.
IX. LGPD Compliance Notice (Applicable to Brazil)
Talko highly values your privacy and is fully committed to protecting your personal data as per the Brazilian General Data Protection Law (LGPD). If you're in Brazil, here's what you need to know about how we handle your data:
1. Right to Access: You can ask for information on the personal data we hold about you and understand how it's processed.
2. Right to Correction: If any of your data is wrong, incomplete, or outdated, you can ask us to correct it.
3. Right to Erasure: Where legally allowed, you can ask for your data to be deleted from our systems.
4. Right to Information: You can ask which organizations we share your data with, why, and the scope of sharing.
5. Right to Revoke Consent: You can take back your consent for specific data processing activities at any time.
6. Right to Object: You can oppose the processing of your personal information if it's based on legitimate interests.
7. Right to Data Transfer: You can ask us to transfer your personal data to you or a third party you choose.
8. Right to File a Complaint: If you think your data protection rights have been violated, you can file a complaint with the National Data Protection Authority (ANPD).
We're dedicated to respecting your rights and following the LGPD to keep your data safe and handled properly.
X. Compliance Interpretation of Data Collection Based on VCDPA
Under Talko's strict privacy protection framework, we further fine-tune our privacy regulations according to the Virginia Consumer Data Protection Act (VCDPA). This is to create a comprehensive, compliant, and worry-free privacy environment for you. When collecting your personal data, we always stick to the VCDPA's principles of transparency and necessity. We only gather data essential for Talko's core service functions. For example, during user registration, to create your account, verify your identity, and ensure smooth service delivery later, we may collect basic info like your name, contact details (email, phone number), and age. This collection is based on your voluntary provision. Beforehand, we'll clearly and explicitly tell you key details like the data's purpose, recipients, and storage period. This fully safeguards your right to know, strictly complying with the VCDPA's provisions on data subject's right to know.
XI. Changes to This Privacy Policy
We may update our privacy policy from time to time to reflect changes in our practices or legal requirements. Any changes that could affect your rights will be clearly communicated. We won't reduce your rights without your explicit consent. For major updates, you'll get prominent notifications, like in-app announcements or pop-up notices. We encourage you to review the policy regularly to stay informed.
Key updates might include:
1. Significant changes to our service offerings, such as new data processing purposes, changes in collected data types, or shifts in how we handle and use your data.
2. Corporate restructuring or ownership changes, like mergers, acquisitions, or other control transitions.
3. Modifications in how we share or disclose data, especially with third parties, or updates to our data processing partners.
4. Changes in your rights regarding personal data, including how you can exercise them or access your data.
5. Adjustments in how we manage data security, like contact details for security personnel and new communication or complaint channels.
6. Important findings in data security risk assessments, which might lead to extra security protocols or warnings.
By continuing to use our services after a change notice, you accept the revised policy. If you don't agree with the updated terms, you can limit your usage to guest mode without sharing personal data.
For your convenience, previous versions of the policy will be archived. If you want to access older versions, contact us using the provided contact information.
XII. Data Protection Officer (DPO)
If you have any questions, requests, or concerns about how we process your personal data, or if you want more info about your privacy rights, contact our Data Protection Officer (DPO), Ethan Walker, at debendronathmanik@gmail.com.
XIII. Controller Information
Date Controller: Ethan Walker
Responsibilities: Responsible for managing your personal information related to our service, including the collection, use, storage, and disclosure of any personal data you provide while using our services.
Contact information(Email): debendronathmanik@gmail.com
Address：Bangladesh，Sadi, Mandalerhat-5620, Ulipur, Kurigram
If you have any questions regarding your personal data, please contact us via the above email.
XIV. Contact Us
You can contact us in these ways, and we'll respond within 15 days:
If you have any questions, comments, or suggestions about this policy's content, contact our official customer service in the Talko application or send an email to our service mailbox at debendronathmanik@gmail.com.