Talko Inc.
If you’re to permit us to facilitate your private communications, some of which might be quite sensitive, earning your trust is essential. In short,
We don’t look at your content.
We do not monitor the content of your communications or those of your peers.
Your personal information is only used for the services we’re providing.
We only collect personal information to make our services work and to improve them over time.
Your personal information is used in limited ways.
Your email addresses or phone numbers, should you choose to provide them, are used so that you can be recognized by us and found by others. Your device and network information are used so that our service and others can see that you’re online and can communicate with you. That’s pretty much it.
Your personal information is kept confidential.
We don’t share your personal information with advertisers, data brokers, or similar types of companies. Our vendors, such as those who provide us cloud computing services, will be required to uphold your confidentiality and not use your data for their own purposes.
Your user profile is public by design.
Any information that you may choose to enter in your user profile so that others may find you, such as your name or photo, is not confidential — by design. Your profile and device/network online status will be visible to anyone with whom you’ve communicated or shared contact information.
We must obey the law.
If the law requires us to disclose personal information (such as because of a court order) we will, but we’ll question and resist such disclosures as long as our lawyers tell us we can.
That’s basically what you can expect as we work to earn your trust. Talko’s formal Privacy Policy follows.
Trust
Privacy Policy
Talko Inc. has developed Internet services and associated software applications (collectively the “Talko Services”) primarily to serve the purpose of communications and information sharing. This Privacy Policy should be viewed as our Terms of Trust because, in building and operating a communications service, trust is essential to our mission.
We shape our practices accordingly and safeguard your privacy no less stringently than if it were our own. We do not monitor the content of your communications. We use service usage metadata in the course of providing and improving the Talko Services, but we do not disclose content or metadata to third parties. To the extent that we are required to disclose confidential information by applicable law, we must and will comply. However it is our policy to treat such requests with a high degree of skepticism and, subject to advice of counsel, resist them.
1. Scope
This Privacy Policy covers the collection, use, and disclosure of information by Talko Inc., including Personally Identifiable Information (“PII”).
2. Peer Use and Disclosure
Talko Services are primarily used to facilitate communications among users. We do not monitor or constrain your use or disclosure of user generated content, identity and profile information, or device status information. Similarly, we do not constrain or monitor your peers’ use or disclosure of such information.
3. Talko Use and Disclosure
In the course of using the Talko Services, you may provide information, including PII, that can be used to identify you and your devices. Some of this information may be provided manually by you, such as a verifiable email address or phone number. Other information is automatically sensed and used by the Talko Services in the course of its normal operations, such as the IP addresses of your devices and online status information.
If you choose to provide personally identifying information to Talko such as your name, email address or phone number, the Talko Services will make use of this information in the course of its normal operations. The Talko Services also automatically generate and uses electronic addressing information that uniquely identifies you, including an account identifier, device identifiers, notification tokens and network addresses. As a general rule, you should also be aware that, in the Talko Services and in all Internet services, the content you create and your patterns of usage also create trails from which your identity might possibly be deduced.
At a technical level, some of this information is needed by the Talko Services to establish and maintain ongoing secure communications between you, your devices and the Service. Other information, such as online user and device awareness, is further utilized to enable the full spectrum of Talko’s functionality and user experience.
Over time, it is our goal to continuously improve and refine the Talko Services. Given the importance of trust to our mission and to Talko’s ongoing viability, we articulate the following principles that guide our collection and use of information:
Clear Understanding. Communications and information sharing software and services are inherently complex. Our designers will observe usage patterns and will use good faith efforts in helping users to genuinely understand how the service actually operates, especially with regard to those areas impacting privacy and information disclosure.
No Surprises. As the service gains more users, and to ensure that Talko’s business grows by delivering increasing value to its paying customers, the Talko Services must and will evolve. Evolution of the service will involve making periodic ongoing changes to the features, functions, user experience and business model. Some of those changes may relate to how and what information is stored and shared. As users grow to rely upon and trust the Talko Services, some will view these inevitable changes as positive while others will view these changes with some dissatisfaction. Above all, we view it as our responsibility to minimize surprise, so as to engender genuine ongoing trust between Talko Inc. and our community of users. As such, we accept it as Talko’s responsibility, using reasonable business practices, to inform and give notice when our service’s behavior is about to change in a material way, so as to enable them to adjust or reconsider their use of the service as they deem appropriate.
Expect Confidentiality. Talko’s designers, developers and operations personnel will build and operate the Talko Services in such a way as to maintain a clear distinction between a user’s own, closely-held content, and more broadly the metadata necessary to enable the Talko Services’ user experience and technical operation. Talko systems and personnel will account for this distinction in product architecture, processes and practices so as to respect the confidentiality and privacy of users and customers.
Quiet Enjoyment. In the course of normal operations the Talko Services need to communicate with individuals by a variety of mechanisms such as email and SMS, device notifications, and through the service itself. The Talko Services will be designed to make clear why Talko may be communicating, and how to stop any communications that may be perceived as being repetitive or annoying.
4. We Do Not Disclose PII to Unaffiliated Third Parties, with Limited Exceptions
We will not disclose your PII to unaffiliated third parties without your express consent, except in the following limited circumstances:
Vendors. We may employ other companies to perform functions on our behalf, such as hosting or maintaining the Talko App, providing services related to the Talko Services, collecting information, or other functions necessary to our business. We may need to share your PII with these companies (collectively, "Vendors"). We will provide Vendors with only that information necessary to perform their functions, and we will not allow them to use your PII for any other purpose.
Legal. We will only release PII and/or non-PII to law enforcement officials if required to do so by law, such as in response to a court order, subpoena, or search warrant or equivalent. Talko has never received an order under either Section 215 of the USA Patriot Act or Section 702 of the FISA Amendments Act.
Transfer of Information in the Event of the Sale of All or Part of Talko. Talko is entitled to transfer to a third party information it collects, including any PII, in connection with a sale the business entity responsible for the information under this Policy, or a sale of all or substantially all of its assets, provided the acquiring third party has agreed to safeguard your Personally Identifiable Information with protections that in all material respects are the same as, or more protective than, those set out in this Privacy Policy.
We do NOT disclose PII to third-party advertising companies. Many websites and apps share PII with advertisers for purposes of retargeting and behavioral advertising across websites and apps. We do not.
5. User Status Profile
In the course of using the product, the Talko Services will maintain a system-wide user list containing information that others may use to generally recognize you and your availability. You understand and agree that your User Status Profile will be treated by the Talko Service as public information and that Talko does not guarantee confidentiality with respect to User Status Profile. You may optionally elect to provide information such as a name and a photograph for this User Status Profile, containing real or pseudonymous information at your discretion. So as to assist others in knowing when and how best to communicate with you, certain other device and network information is also automatically associated with your User Status Profile including, for example, online status awareness, which includes network, device, and other communication to help others contextually understand whether you’re available to communicate. Talko, by design, will selectively disclose your User Status Profile to other Talko users where we have a reasonable basis to believe that you have communicated with them before or have shared contact information with them.
6. Our Commitment to Data Security
Talko uses industry best practices to prevent unauthorized access to your account and to conceal the content of network communications. We commit to staying diligent with regard to emerging threats and engineering best practices. Due to the evolving nature of Internet communications threats, however, we cannot provide, and therefore expressly disclaim, any assurances that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
7. Participation by Children and Teens
Due to federal law (as reflected in the Children's Online Privacy Protection Act), WE DO NOT KNOWINGLY ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 13 TO USE OUR APPLICATION OR SERVICES.
8. Relationship to Terms of Service
This Privacy Policy must be read in conjunction with our Terms and Conditions of Use, and the provisions of our Terms and Conditions of Use are incorporated herein. To the extent the Terms and Conditions of Use conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.
9. Notification of Changes
From time to time, Talko may change its Privacy Policy. In the event that we make changes, we will post notice of the new Policy from the privacy link on our website and mobile apps.
10. Contact Us
If you have any questions about this Privacy Policy, our practices with regard to Personally Identifiable Information, or your dealings with us, please contact us at:
Talko Inc.
12 Central Street
Manchester, MA 01944
Effective Date
September 23, 2014