This Privacy Policy ("Policy") describes how Talkroom Inc. ("Talkroom," "we," "our" or "us") collects, uses, processes and shares personal information collected through the Talkroom app and associated Services offered under the Talkroom User Agreement. This Policy applies to visitors and users (individually, "you") of Talkroom’s websites, applications, social media accounts, and other services, as well as all other online and offline interactions with us (collectively, our "Services"). Please note that your use of our Services is additionally subject to the Talkroom User Agreement at https://www.talkroom.com/terms. Any capitalized terms in this Policy that are not defined herein shall have the same meaning as such defined term in the User Agreement.

A. INFORMATION WE COLLECT AND USE

1. "Personal information" includes any information that identifies, relates to, describes, is reasonably capable of being associated, or could reasonably be linked, directly or indirectly, with a particular individual or household, that is subject to the protection of applicable data protection laws in the jurisdiction where you reside. This Policy applies only to Personal Information collected in connection with the Services.

We collect Personal Information directly from you. As you visit or use our Services, we collect the following categories of Personal Information directly from you:

Personal details (such as your name);

Contact information (such as email address, phone number);;

Contact information (such as transaction activity, including frequency, size, currency preferences);;

Account information (such as account settings);

Social media data (if you choose to link your Talkroom account with a social media account, we may collect personal information such as name, age, gender, photograph, and other personal information relating to your social media account);

Billing information (such as credit, debit, Mobile Money or other payment card information as may be required to use certain Services);

Your preferences (including survey and marketing responses);

Communications you send us (such as customer support and other requests you make through our Services);

Other information you may provide (including other information you provide about yourself or others through our Services or to which you provide us with access via third-party platforms). You may choose not to provide some of the Personal Information described above. Please note, however, that many of our Services require some Personal Information to operate, so if you choose not to provide the Personal Information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature. We do not proactively collect sensitive Personal Information, such as health-related information. However, our Services include text boxes that are designed for you to describe support issues and to provide us with Feedback. Please be aware that information you freely submit in these boxes may reveal to us certain information that may be considered sensitive Personal Information under applicable law. We do not use this information for the purpose of marketing or advertising products to you, and we do not intentionally store any such sensitive Personal Information. Please contact us at privacy@talkroom.com if you believe you may have erroneously submitted any sensitive Personal Information to us.

Personal information we generate. As you use our Services, we generate certain Personal Information about you, including through automatic data collection and by inferences based on the information we collect about you and your activity. We may automatically collect information about your interactions with the Services or communications you receive (such as email) using certain technologies such as cache, web beacons and other technologies. We generate the following categories of Personal Information about you (collectively “Usage Data”):

Device information. When you visit or use our Services, we automatically collect certain information about your device (e.g. your mobile device, computer or tablet), including information about your hardware and software, device configuration and nearby networks. Such data may include data about your device operating systems, browsers and other software installed on your device; device identifiers, such as IP address, IMEI number, MAC address or other device identifier; country of origin, region and language settings; and information about domain servers and wireless or network access points near your device.

Usage and performance information. We also automatically collect Personal Information about your usage of the Services, including information about your interactions with features of our Services; sites or pages visited; access times; and performance of our Services.

Inferences about you. We combine the information we collect, generate or otherwise obtain to draw inferences about your preferences and interests in order to provide and personalize our Services and tailor the offers we and our partners provide to you.

Aggregate Information. We aggregate Personal Information collected directly from you, information generated about you by us, and information obtained from third parties (with your consent, where required) with Personal Information collected about other users in order to produce general statistics that cannot be linked to you or any other specific user. Information that has been aggregated and de-identified is no longer considered “Personal Information” and may be subsequently used for any purpose in the app.

Anonymized Information. We may process information that cannot be linked to you or any other specific user using any means available to us, either because it was collected anonymously or has been subsequently anonymized. Information that is anonymous or has been anonymized is no longer considered “Personal Information” and may be subsequently used for any purpose.

Personal Information We Obtain from Third Parties. We may also receive certain categories of Personal Information from third parties, such as third-party websites, applications, social media networks and services (which may include publicly-available sources; each of these is a “third-party platform”). If you are an existing Talkroom customer, we will combine this information with information we collect through our Services and use and share it for the purposes described below. The categories of Personal Information we may obtain from third parties include:

B. HOW WE USE YOUR INFORMATION

We use your Personal Information for the following purposes ("Purposes"), to:

Provide the Services, which includes providing you with the services, products and functionality offered through our Services and fulfilling your requests.

Authenticate your account credentials and identify you,as necessary to log you in to the Services and ensure the security of your account;

Communicate with you about your account or use of our Services,products and/or functionality; respond to or follow up on your comments and questions; and otherwise provide customer service;

Communicate with you about your account or use of our Services,products and/or functionality; respond to or follow up on your comments and questions; and otherwise provide customer service;

Authenticate your credit or debit card account information;

Tailor your experience with our Services, such as by making inferences or combining different pieces of information we have collected about you to suggest products or services that you may be interested in or otherwise tailor our Services to you according to your preferences;

Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity;

Develop new and enhance existing service and product offerings;

Develop new and enhance existing service and product offerings;

Comply with our policies, procedures and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues and exercising rights or obligations conferred by law; and

As otherwise consented to by you and as required or permitted by applicable law.If you give your consent to any further use of Personal Information, you can withdraw that consent at any time by contacting us using the details set out below. You have choices about your Personal Information, and in some circumstances, you may have the right to opt-out or object to our uses of your Personal Information for these Purposes. Please contact us at privacy@talkroom.com if you have any concerns about our uses of your Personal Information. Please bear in mind that some of these uses are required for us to offer the Services and that your access of the Services may be impacted based on any choices you make with regard to our usage of your Personal Information.

Electronic Communications. Consistent with the above Purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email, text message or mobile push notification to:

Send you information relating to our products and Services.This may include technical notices, updates, security alerts and support and administrative messages.

C. HOW WE SHARE YOUR INFORMATION

We disclose the Personal Information we collect (or otherwise generate or obtain) as follows:

With cloud service providers. We may share information with cloud service providers to store certain Personal Information and for disaster recovery purposes, as well as to provide hosting for the Services. Our Services may also allow you to connect with us on, share on and use third-party platforms, including those on which Talkroom has a presence (e.g. Twitter, Facebook, Reddit). Please be mindful of your personal 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. Talkroom also does not control the privacy practices of third-party platforms. Please contact those sites and services directly to learn about their privacy practices.

To process payments. We require credit or debit card and Mobile Money information to allow you to pay us and we share payment information with third-party payment processors and other third-party service providers (such as fraud detection services). When you use a credit or debit card to secure a reservation through our Services, we provide your credit or debit card account information (including card number and expiration date) to our third-party payment service providers. These third parties may store your credit or debit card account information so you can use our payment services through our Services in the future, to the extent permitted by local law.

With other service providers. We share information with third-party vendors, consultants and other service providers who perform services or functions on our behalf (e.g. our accountants, lawyers, etc.).

With other service providers. We share information with third-party vendors, consultants and other service providers who perform services or functions on our behalf (e.g. our accountants, lawyers, etc.).

To comply with and as required by law. We may disclose your Personal Information to government authorities or other relevant third parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process or lawful requests from governmental authorities.

Aggregate information. We share aggregate statistical data for the improvement of our Services. We may also share aggregate or de-identified information with third parties at our discretion.

At your request. We also share your information as directed or requested by you, or subject to your consent.

D. HOW WE STORE AND PROTECT YOUR INFORMATION

Talkroom maintains commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

When your credit or debit card account information is being transmitted to our Services or through our Services it will be protected by cryptographic protocols. To be clear, Talkroom does not itself store your credit or debit card account information, and we do not have direct control over or responsibility for your credit or debit card account information. We use third party payment processors that are the controllers of your credit card information. Our contracts with third parties that receive your credit or debit card account information require them to keep it secure and confidential.

However, we cannot guarantee that transmissions of your credit or debit card account information or your other information will always be secure, or that unauthorized third parties will never be able to defeat the security measures taken by Talkroom or our third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access or other causes beyond our control.

You play an important role in keeping your information secure. You should not share your user name, password or other security information for your Talkroom account with anyone. If we receive instructions using your user name and password, we will assume you have authorized the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g. if you feel that the security of any account you might have with us has been compromised), please contact us immediately at privacy@talkroom.com

Retention. We may retain your Personal Information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information. We may also retain your Personal Information as necessary to:

a. Maintain logs and business records for analysis, security and/or audit purposes

b. Comply with record retention requirements under the law

c. Deal with any complaints regarding the Services; and

d. Comply with our legal obligations, protect or defend our rights, resolve disputes and enforce our contracts

We generally aim to retain the least amount of Personal Information for the minimal amount of time possible for us to provide the Services. Any Personal Information captured in logs that is not flagged for additional scrutiny (e.g. for regulatory, compliance or legal purposes) is automatically deleted within a week.

Device information such as IP addresses are not stored in an identifiable form. Except where prohibited by law, we may retain your Personal Information beyond the end of your relationship with us but only for so long as we are contractually bound to do so, or so far as it is necessary for audit, regulatory or other accounting purposes. When Personal Information is no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form. After you have terminated your use of our Services, we reserve the right to maintain your Personal Information as part of our standard back-up procedures in an aggregated format.

Once the retention period expires, information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability will not be available to you after expiration of the retention period.

E. CHILDREN

Our Services are not directed at or intended for use by children. We do not knowingly collect information from, children under 13 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at privacy@talkroom.com

F. APPLICABLE LAW

This Policy should be read in conjunction with the User Agreement, and as such shall be governed by and construed in accordance with local laws.

G. CHANGES TO THIS POLICY

Except to the extent limited by applicable law, we will update this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements and other factors by prominently posting notice of the update on our Services. Changes to our Privacy Policy will be effective when posted and the new effective date will be identified. If we make any changes to the Privacy Policy that materially impact previously collected Personal Information about you, we will make reasonable efforts to provide notice and obtain consent to any such changes as may be required by law.

H. HOW TO CONTACT US

If you have any questions about this Policy or the way in which your Personal Information has been used, please contact us by email at privacy@talkroom.com