There are three basic categories of information we collect:
- Information you choose to give us.
- Information we get when you use our services.
- Information we get from third parties.
By visiting and interacting with ToTalk, its App and/or its Service, you provide us with Personal Information which may include, but is not limited to, the following:
- Personally Identifiable Information: may include, without limitation, information provided when you register to use the App and/or the Service, including your name, profile picture, date of birth, phone number, phone book content, address, email address, occupation, employer, gender, age, birthday, Facebook account info and friend list, and/or other social network usernames and 'likes' and preferences, friend lists and number of friends you have via social networks, messages to other users of the App and the Service, use information regarding your use of the Service, profile picture that you upload via the App or the Service, and browser information.
- The information you choose to provide above may be shared with your contacts on our service. You have total control over your profile information and you can access to modify at any time. In addition, if you register to our service with your Facebook account (e.g. Facebook Connect), we may store your Facebook ID and corresponding token on our servers and, if you give us your expressed consent, we will have access to and may collect certain information that you make available on Facebook (for example, your first and last names, email address, profile picture, your friend lists and birthdays). Your Profile is available to other users of the Service who are connected to you on our service. In addition, unless you opt-out (which you may do so at any time in the settings of our application), your Profile is discoverable by other users. You may choose to "block" any user on our platform to prevent unwanted access of your Personal Information.
- You may also choose to share your mobile device's Contacts list with us (including names, numbers, emails, Facebook ID, Apple ID, etc) and we will store it on our servers to help you better improve our service, e.g. connecting with friends on our service. If you do not want us to store this information, you may opt-out through your account settings or notify us via email. If done so, we will not be able to offer some of our features on our service.
Of course, you'll also provide us whatever information you send through the services. Keep in mind that the users you send texts, images, and any other content to can always save that content or copy it outside the app. So, the same common sense that applies to the Internet at large applies to ToTalk as well: Don't send messages or share content that you wouldn't want someone to save or share.
It probably goes without saying, but we'll say it anyway: When you contact ToTalk Support or communicate with us in any other way, we'll collect whatever information you volunteer.
When you use our services, we collect information about which of those services you've used and how you've used them. We might know, for instance, that you used one of the filters in app and the number of times you have used this filter. Here's a fuller explanation of the types of information we collect when you use our services.
We collect information about your activity through our services. We may collect information including but not limited to:
- How you interact with the services, such as which filters you view or the number of times apply to discover.
- Content created when using the service. It includes creating or uploading different kinds of content to the App, including without limitation, photos, text, messages, posts, html, URLs, pictures, video and other content (collectively, "User Contributed Content"), and the metadata that is provided with the content. As you upload User Contributed Content you should be mindful of your privacy as well as the privacy of others.
- How you communicate with other ToTalk users, such as their names, the time and date of your communications, the number of messages you exchange with your friends, which friends you exchange messages with the most, and your interactions with messages (such as when you open a message or capture a screenshot). We allow you to share text messages, photos, screenshots, videos and other forms of communications on our service with other users, and if you choose to do so your text messages, photos, screenshots, videos and other communications may be stored on our servers. In addition, if you choose to share these items with other users, we may not be able to remove them from our servers or make them unavailable to anyone you have shared them with. Sending and sharing text messages, photos, screenshots, videos or other communications on our service is your decision. By choosing to share that information, you should understand that you may no longer be able to control how that information is used and that it may become publicly available. We are not responsible for any use or misuse of information you share.
- Device Information. We collect device-specific information, such as the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, none direct display of content moderation, and mobile network information (including the mobile phone number).
- User content e.g. photos, screenshots, comments, and other materials that you create on the service may also be collected. Your photos and videos may be captured by other users on the service, and those content can be stored and used by us or third party services (e.g. Facebook) for content moderation and community safety monitoring purposes. You can change third party sharing options in our product settings or writing to us directly.
- Device Phonebook. Because ToTalk is all about communicating with friends, we may-with your consent-collect information from your device's phonebook.
- Location Information. When you use our services we may collect information about your location. With your consent, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.
- Log Information. We also collect log information when you use our website. That information includes, among other things:
- Details about how you've used our services.
- Device information, such as your web browser type and language.
- Access times.
- Pages viewed.
- IP address.
- Identifiers associated with cookies or other technologies that may uniquely identify your device or browser.
- Pages you visited before or after navigating to our website.
- If you contact us by email and other means (Twitter, Facebook etc) we may keep a record of your contact information and correspondence and will use these contact info and correspondence if we respond to you.
of your contact information and correspondence and will use these contact info and correspondence if we respond to you.
We may collect information that other users provide about you when they use our services. For example, if another user allows us to collect information from their device phonebook-and you're one of that user's contacts-we may combine the information we collect from that user's phonebook with other information we have collected about you. We may also obtain information from other companies that are owned or operated by us, or any other third-party sources, and combine that with the information we collect through our services.
What do we do with the information we collect? The short answer is: Provide you with an amazing set of products and services that we relentlessly improve. But we do a lot more as well, such as:
- Develop, operate, improve, deliver, maintain, and protect our products and services.
- Communicate with you.
- Monitor and analyze trends and usage.
- Personalize the services by, among other things, suggesting friends or profile information, or customizing the content we show you, including ads.
- Enhance the safety and security of our products and services.
- Verify your identity and prevent fraud or other unauthorized or illegal activity.
- Use information we've collected from cookies and other technology to enhance the services and your experience with them.
- Enforce our Terms of Service and other usage polices.
We may also store some information locally on your device. For example, we may store information as local cache so that you can open the app and view content faster.
In certain instances, we may share your personal information with third-party service providers to further improve and optimize our service for you. We may share information about you in the following ways:
- With other users. We may share the following information with other users
- Information about you, such as your username and name;
- Information about how you have interacted with the services, such as the names of users you are friends with, and other information that will help users understand your connections with others using the services. For example, because it may not be clear whether a new friend request comes from someone you actually know, we may share whether you and the requestor have ToTalk friends in common;
- Any additional information you have consented for us to share. For example, when you let us access your device phonebook, we may share information about you with other users who have your phone number in their device phonebook;
- With all users and the general public. We may share the following information with all users as well as the general public:
- Public information like your profile pictures that you submit to Local. If a Local service is streamed on the web or broadcast in some other media, it may be viewed by the public at large.
- With our affiliates, we may share information with entities within the ToTalk family of companies.
- With third parties, we may share your information with the following third parties:
- With service providers, sellers, and partners. We may share information about you with service providers who perform services on our behalf, sellers that provide goods through our services, and business partners that provide services and functionality.
- With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
- Comply with any valid legal process, government request, or applicable law, rule, or regulation;
- Investigate, remedy, or enforce potential Terms of Service violations;
- Protect the rights, property, and safety of us, our users, or others; or detect and resolve any fraud or security concerns.
- With third parties as part of a merger or acquisition. If ToTalk gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.
- In the aggregate or after de-identification. We may also share with third parties, such as advertisers, aggregated or de-identified information that cannot reasonably be used to identify you.
You expressly agree that information provided when you register the App and/or the content your created when using the App (including without limitation, photos, text, messages, posts, html, URLs, pictures, video and other content), may be recorded, stored, published and made available to the rest of ToTalk users. Furthermore, other users may follow you on the App, and your followers can see, for example, the user contributed content that you have uploaded to the App. Individuals reading this information may use it or disclose it to other individuals or entities without our control and without your knowledge. We therefore urge you to think carefully about including any specific information you may deem private in the information you provided or content that you create in the App.
Your information may also be stored and process in any country in which we provide service to due to server facilities and third-party service teams. By using our service, you consent to any such transfer of information outside of your country.
The services may also contain third-party links and search results, include third-party integrations, or be a co-branded or third-party-branded service that's being provided jointly with or by another company. By going to those links, using the third-party integration, or using a co-branded or third-party-branded service, you may be providing information (including personal information) directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. To the extent that you use a profile that may be available to others on our Service, you are solely responsible for its content and accuracy at all times. As always, we encourage you to review the privacy policies of every third-party website or service that you visit or use, including those third parties you interact with through our services.
Finally-and this is important-you should understand that users who see the content you provide can always save it using any number of techniques: screenshots, in-app functionality, or any other image-capture technology. It's also possible, as with any digital information, that someone might be able to access messages forensically or find them in a device's temporary storage. If any deletion of user information of our App happens, we cannot promise that deletion will occur within a specific timeframe. And we may also retain certain information in backup for a limited period of time or as required by law.
Protecting user privacy and personal information is a top priority for us. We process your personal information to improve and enforce our security measures, combat spam, malware, malicious activities, or security risks, and to monitor and verify your identity so that unauthorized users do not access your account with us. Access to any user information is restricted to our employees, contractors, agents, and third-party service providers ONLY whom needs to know the information in order to provide, operate, develop, maintain, support, and optimize the our service experience and security. We use password protection, access logs, and system monitoring to safeguard the confidentiality and security of all user information. Due to the inherent nature of the internet and related technology, we do not guarantee the protection of information under our control against loss, misuse, or alteration.
We want you to be in control of your information, so we provide you with the following tools.
- Access and Updates. We strive to let you access and control the personal information that we have about you. There are limits though to the requests we'll accommodate. We may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users or is unlawful. You can access and update your account information right in the app by visiting the app's Settings page. If you need to access, update, or delete any other personal information that we may have, you can put in a request here. Because your privacy is important to us, we may ask you to verify your identity or provide additional information before we let you access or update your personal information. You can also remove our service from your mobile device or process account deletion.
- Revoking Permissions. If you change your mind about our ongoing ability to collect information from certain sources that you have already consented to, such as your phonebook, camera, photos, or location services, you can simply revoke your consent by changing the settings on your device if your device offers those options. Of course, if you do that, certain services may lose full functionality.
- Account Deletion. You can remove your data anytime you want. Account deletion can be accessed within the app. Upon your request, we will temporarily disable your account to prepare for removal. During this time you can cancel your deletion request and we will resume your account. Upon the end of 30 days, we will use commercially reasonable efforts to remove your data from our servers. Please note, some information may remain in archived/backup copies for legal purposes or required by law (for instance, some "traffic data" may be kept for one year to comply with statutory data retention obligations).
Analytics and Advertising Services Provided by Others
We may need to transfer your information to other Groups or service providers in countries outside the European Economic Area (EEA). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein and Norway: they are considered to have equivalent laws when it comes to data protection and privacy. This kind of data transfer may happen if our servers (i.e. where we store data) or our suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.
If ToTalk sends your information to a country that is not in the EEA, we will make sure that your information is properly protected. We will always ensure that there is a proper legal agreement that covers the data transfer. In addition, if the country is not considered to have laws that are equivalent to EU data protection standards then we will ask the third party to enter into a legal agreement that reflects those standards.
Our services are not intended for-and we don't direct them to-anyone under 16. And that's why we do not knowingly collect personal information from anyone under 16.