Last Updated: December 2015
TalkLife Ltd (“we”, “our”, “us”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is TalkLife Ltd of Somerset House, Victoria Embankment, London, England, WC2R 1LA.
1. Information we may collect from you
We may collect and process the following data about you:
·Information that you provide by filling in forms on our sites http://talklife.co, http://invite.talklife.co/ and http://web.talklife.co/ (“our sites”) and our mobile application TalkLife (“our app”). This includes information provided at the time of registering to use our sites and our app, downloading and sharing data via our app, making in-app purchases, subscribing to our service, posting material on forums and on your profile, or requesting further services. We may also ask you for information when you report a problem with our site. The information which you provide us may include your:
·name, date of birth, address, e-mail address, phone number and username;
·profile photo and any additional photos which you upload to our app; and
·Facebook, Apple and/or Play Store account information;
·Information we collect about your device, including the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device, sometimes referred to as a device ID or token), mobile network information, your mobile operating system and the type and version of mobile software which you use;
·Information stored on your device, including contact information, friends lists, login information, photos, videos or other digital content and check ins;
·Information regarding your location. We may use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by emailing us on email@example.com;
·General, aggregated, demographic, and non-personal data (such as aggregated anonymous information about website usage and other forms of analytical data). It will not be linked to any of your personal data, through cookies or other means, without your consent;
·If you contact us, we may keep a record of that correspondence;
·Information which you provide to us by completing surveys or polls, and which we use for research purposes. You do not have to respond to these surveys;
·Details of transactions you carry out through our site and of the fulfilment of any in-app purchases; and
·Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.
2. IP addresses and cookies
We may collect information about your computer, including where available your IP address, operating system and browser type, and your mobile phone, including details of your mobile handset and mobile software, for system administration and to collate aggregate information. This is statistical data about our users’ browsing actions and patterns and the use of our app, and does not identify any individual.
3. Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL or other appropriate technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
4. Uses made of the information
We use information held about you in the following ways:
· to deliver the products and provide the services which you have requested and to tailor the product experience to your particular needs or requirements where appropriate;
· to ensure that content from our sites and our app is presented in the most effective manner for you, your mobile device and your computer;
· to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
· to carry out our obligations arising from any contracts entered into between you and us;
· to allow you to participate in interactive features of our service, when you choose to do so; and
· to notify you about changes to our service.
Please also note that information we hold and information that you share may be passed to the appropriate authorities or regulators where:
· this is required or requested by the authorities or by law;
· we have concerns that any individual is likely to cause harm to themselves or other people; or
· there is an actual or suspected case of cyber bullying and we are requested by appropriate authorities to provide such information or cooperate with their investigation.
5. Information You Share Socially
Our sites and our app allow you to connect and share your actions, comments, content, and information publicly or with friends. Please be mindful of your own privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.
6. E-mail Marketing and Newsletters
We may use your personal data from time to time to contact you (via electronic means) with our internal newsletters and details of new blog posts and other communications or services that we are available on our site or our app, where we think these may be of interest to you. Our emails will contain links which enable you to “unsubscribe” to such communications at any point.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregated information about our users. We may also use such aggregated information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
Our site and our app may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7. Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries and our ultimate holding company and its subsidiaries.
We may disclose your personal information to third parties:
· In the event of a merger, acquisition, reorganization, sale of all or substantially all of its assets, or the sale of an individual website owned by us, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets or to a third party as a part of such merger, acquisition, reorganization, or sale;
· If TalkLife Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
We may also disclose data obtained from our sites and our app to academic institutions and research bodies for research purposes. We ensure that any such data is anonymised before it is transferred and that any recipients of this data adhere to adequate standards of data security and privacy.
8. Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
9. Our Policies Concerning Minors
We are committed to complying with the United States’ Children Online Privacy Protection Act (COPPA). The site and services are not targeted at children under the age of 13. We do not knowingly collect information from children under the age of 13 and if you are under this age you must not use our app or our site. If we become aware that you are under 13 and using our app or our site, we may terminate your user account.
10. “Do Not Track” and Third Party Tracking
TalkLife does not currently respond to browser “Do Not Track” signals sent from web browsers on our app or our site.