TALK2STUDY PRIVACY POLICY
Effective Date: 28/09/2021
1. INTRODUCTION TO POLICY
Thank you for downloading, accessing, and using the TALKS2STUDY mobile application and associated website cares about your privacy. We want to use this Privacy Policy (this “Policy”) to describe how we collect, use, disclose, and safeguard the information we collect about you when you use TALK2STUDY. This Policy also describes how we use certain tools to obtain information from you automatically and the rights and choices available to you.
This Policy applies to anyone using TALK2STUDY – either providing or buying services, including the Clients, Study Advisors, and Consultants (collectively, “users” and individually “you” or “your”).
By accessing and using TALK2STUDY and providing personal information to us, you agree to the descriptions in this Policy. Your agreement to this Policy will be binding when you tick the “I agree” box upon registration. However, if you do not agree to this Policy, you should refrain from using TALK2STUDY.
2. DEFINITIONS
· Personal information: Defined under the Privacy Act of 1988 as any information or opinion about an identifiable individual.
· Personal data: Refers to personal information above and as defined under the GDPR Law that came into effect on May 25, 2018.
· Processing: Any activity that concerns your personal information, including collection, use, disclosure, security, marketing, storage, transfer, retention, etc.
3. THE INFORMATION WE OBTAIN FROM YOU AND HOW
When you use TALK2STUDY (either as a provider or client), we collect the personal information you provide to us and the ones we obtain automatically through cookies and third party tracking technologies. This include:
· The Personal Information you provide us: Depending on the type of user account you operate, we may obtain and store any personal information you provide, such as your name, email address, phone number, age, address, country and city, photo, education, business name and number, bank details, and other user-specific information when you use TALK2STUDY. This personal information may be provided by you in certain ways, such as when you:
(i) request a user account on TALK2STUDY, either directly or via any social media account plugin, such as Facebook and Gmail;
(ii) contact us for inquiries, questions, claims, suggestions, feedback, and complaints;
(iii) take part in any of our surveys, promotions, or sweepstakes;
(iv) leave comments or review on TALK2STUDY;
(v) provide us with your payment method information; and
(vi) provide us with verification ID for user verification purposes.
You are not under any obligation to provide us with the information above. However, you are aware that not furnishing us with such information will make providing you with our services practically impossible.
· The Information we obtain automatically: We automatically obtain certain personal and anonymous information when you use our website and app, including when you take action on our content. We automatically collect this information through the use of certain tracking technologies and cookies. This information may include, without limitation:
§ Device information, including IP Address, browser type, and Operating System;
§ Log information, including reports of crashes and bugs;
§ Analytics information about how users use TALK2STUDY (anonymously collected);
§ Transaction information between providers and clients;
§ Longitude and latitude information of nearby consultants; and
§ Location of device IP Address.
4. WHAT WE USE YOUR INFORMATION FOR
As already established, we use the above-collected information to provide you with our services, including making TALK2STUDY available to you and improving it as and when due. We also collect information to:
· Provide you with a user account, identify you from other users, and provide TALK2STUDY to you depending on the account you operate;
· Identify your choices, interests, and study area and match you with the right services;
· Process your payments and commissions for our services (if you are a client) and your earnings (if you are a provider);
· Contact you about administrative messages, marketing communications, and any notice related to your use of TALK2STUDY;
· Respond to your questions, complaints, queries, suggestions, and feedback;
· Further verify the registration information you provided to us;
· Enforce our Terms and Conditions and comply with applicable law;
· Ensure the security of TALK2STUDY LTD and other users available through TALK2STUDY;
· Monitor TALK2STUDY and identify which areas we need to improve on;
· Monitor the transactions between you and other users for investigative purposes; and
· Facilitate your use of TALK2STUDY and provide upgrades where relevant.
5. WHO WE SHARE YOUR INFORMATION WITH
TALK2STUDY LTD will not share any information about you without your consent. Likewise, we may only share personal information about you unless as described under the circumstances below:
· Other Users and the Public: Providers’ profile and the Personal Information they have thereon are public information, as well as any content they provide (such as review and feedback). For example, if you are a Provider, a client (including unregistered website user) may search and see your profile in order to hire you or initiate a chat with you. Likewise, if you leave certain content, such as comments or reviews on TALK2STUDY, your name may be attached to such content, and any user who navigates to that part may have access to your name.
· Service Providers: TALK2STUDY LTD provides TALK2STUDY with the help of certain third party service providers (“Service Providers”). For example, we use certain companies/websites to set cookies, tailor adverts, improve features, provide video feature, send emails, and process payments. In order for these Service Providers to provide the above-listed services on our behalf, they may require relevant personal information about you. For example, Stripe (our payment processor Service Provider) requires access to your payment method information to process your earnings or payments for our commission/services. However, these Service Providers have obligations to keep any user information we share with them confidential and only for the purpose of the task we hire them for.
· Legal and Investigative actions: TALK2STUDY LTD will disclose any personal information about you to law enforcement agencies, as may be required by law and in response to legal requests, including in relation to your earnings. We may share personal information about you to government agencies if we believe that it may help solve a legal dispute, including in relation to subpoenas, court orders, and other legal summonses. We may disclose personal information about you if such disclosure is necessary (i) to protect our rights and properties and those of other users or third parties; or (ii) to prevent any activity we may consider to be illegal, unethical, or fraudulent.
· Business Transfers: We may share personal information about you during a business transfer action, such as in the event of a sale of an asset, merger, acquisition, or consolidation of TALK2STUDY LTD. We may also share information within the TALK2STUDY LTD group of companies, including our parent company or any future affiliates or subsidiaries.
6. COOKIES AND TRACKING TOOLS
Cookies are pieces of data attached automatically to your device browser to obtain some preferences about you when you access the website. We use cookies on the website to gather information and certain user navigations around the website. Likewise, most of our Service Providers use set cookies on your device to perform their services for us. For example, to use certain third party tools, such as social login, the relevant social media sets cookies. We also use cookies to gather analytics, provide certain features, remember your sessions, improve security, and tailor ads based on your preferences.
You have the option to block us from setting cookies on your device browser. However, be aware that blocking cookies from tracking your preferences may render some features unavailable to you. For example, if you block cookies, the social media features may not effectively function. To block cookies, please see the help section of any browser you connect to TALK2STUDY with.
7. THE RETENTION PERIOD OF YOUR INFORMATION
We do not keep information for longer than is necessary. We retain personal information about you for as long as you use TALK2STUDY and are active. If you remain inactive for 12 months, we will delete any personal information we hold about you, including your user account/profile and the content you have on it. Likewise, if you request the termination/deletion of your user account or personal information, we will immediately act on your request and delete such information. However, we may retain certain information, such as transaction information, for longer periods, in order to comply with legal requirements. Also, if you request the deletion of your personal information, we may not have control over the information you made available on certain parts of TALK2STUDY. For example, we may not be able to delete the personal information you have on your reviews or chats.
8. THE SECURITY OF YOUR INFORMATION
TALK2STUDY LTD cares about your privacy and the security of your personal information. We implement both modern and traditional methods of securing any information we have in our database. For one, we do not have access to the files/documents you share with another user. We access information strictly on a need-to-know basis. We do not share any information about you except as described under this Policy. The below describes the modern security measures we have in place for the information we hold about you:
· PCI DSS: For your payment method information in relation to payment processing; we comply with the Payment Card Industry Data Security Standard (PCI DSS). The PCI DSS is the industry-leading provider of security to card payments through websites and apps.
· 3-D Secure: This is additional security for payment transactions that occur through TALK2STUDY.
· CSRF Security: Cross-site-request-forgery Security (CSRF Security) is a type of security that ensures unauthorized users are unable to launch CSRF attacks while you use TALK2STUDY.
· SSL Protocol: Secure Socket Layer (SSL) is a form of security that allows communications within TALK2STUDY – between you and other users – to be secured without a third party having access to them.
· Tokenization: This is a form of security that helps turn a meaningful piece of information or data into random characters called token, which turns the meaningful piece of information into meaningless information in the event of a data breach.
· RTEPaaS Security: Real-Time Engagement Platform-as-a-Service (RTE PaaS Security) is a secure audio/video platform put in place by our Service Provider, Agora Inc., for all audio/video engagements between users. Agora Inc. provides a GDPR and HIPPA compliant audio/video platform that ensures the communication between you and another user through audio/video chat is confidential and secure.
Notwithstanding the security measures above, you are aware that no method of information transmission over the internet is completely secure. Therefore, while we do our best to ensure we safeguard any information or transmission on TALK2STUDY, we cannot guarantee you a 100% protection. We will not be liable for any unauthorized access or breach of our servers. You also have a duty to keep your login details confidential, and ensure you notify us of any attempts to gain unauthorized access to your user account.
9. MARKETING COMMUNICATIONS
When you submit your email address and download the mobile app, we may advertise and send certain offers and promotions to you via email newsletters and push notifications on the mobile app and website (“Marketing Communications”). Marketing Communications may contain offers on new products and services we think may match your interest or benefit you. However, you have a choice to prevent us from sending Marketing Communications to you. To reject email newsletters, unsubscribe using the “unsubscribe” link at the bottom of any email we send to you. To prevent push notifications or update your preferences, you may need to see the help section of your browser or mobile device settings. Please, be aware that preventing newsletters does not prevent us from sending administrative messages, such as changes to this Policy.
10.THE RIGHTS YOU HAVE OVER PERSONAL INFORMATION
· General user rights: Subject to the information we hold about you and your use of TALK2STUDY, you have certain rights. Some of these rights include the ability to request access or edit your personal information and/or terminate and delete your user account and any personal information we hold about you. We will grant these rights to the fullest extent permissible by applicable law.
To access and edit certain personal information, such as your name, email address, and phone number, see the menu section of your profile. Please, note that you may not be able to edit certain personal information, such as your age, date of birth, and gender, through your account settings. Such changes may only be done by reaching out to us via [email protected].
Likewise, you have the right to terminate and delete your user account and the personal information available on it. You may terminate and delete your user account by using the menu available on your profile area. Once you make such a request, we will review your account for pending transactions and act accordingly. We will delete your personal information and your profile as soon as possible. However, we may not be able to delete certain publicly available personal information, such as your comments, chats, and reviews. Please, be aware that even if you do not request for account termination, and your user account remains inactive for 12 months, we will automatically terminate your account.
· Additional Rights under the GDPR: Under the GDPR law, which applies to users from the EU and EEA communities, TALK2STUDY LTD is your data controller. We are permitted by law to process personal data (as defined under the GDPR Law) about you under lawful reasons, including to perform a contract; to comply with legal obligations; to serve our interest; and where you have consented to it. The GDPR also provides you with the following rights in addition to the general rights above:
§ The right to request a copy of the personal data we hold about you in a reasonable format (such as PDF);
§ The right to request rectification of your personal data, including to edit, delete, or restrict processing to the extent permissible by law;
§ The right of portability, which includes the ability to copy, transfer, or move your personal data from our database to be reused across different services; and
§ The right to report us to any data authority in your location if you believe that we are unlawfully processing your personal data.
· Additional Rights under the CCPA: For users located in California, you also have the following rights in relation to how we use your personal information:
§ The right to know the categories of information we collected, shared, or sold in the last 12 months (we have not sold any personal information in the past 12 months);
§ The right to opt-out of your information being sold or shared with third parties for their marketing needs; and
§ The rights not to be discriminated against for wanting to exercise these rights.
To exercise your rights as a California user, reach out to us via our email address at [email protected].
11.THE INTERNATIONAL TRANSFER OF INFORMATION
TALK2STUDY LTD provides TALK2STUDY from our base of operation. If you decide to submit personal information to us, your personal information will be transferred to us and processed from our base of operation. Also, we use Service Providers from different countries, who help us process some of this information. The countries these Service Providers belong to may not have adequate data protection laws as your country of location. However, when we transfer personal information to other countries, we will ensure adequate security and confidentiality is given to your personal information, as described under this Policy.
For users in the EU, EEA, and similar laws, if we are to transfer your personal information to Australia and other locations outside the EU, EEA, and countries with similar laws, such transfers are done in accordance with the GDPR Law, using standard contract clauses. You may contact us at [email protected] to learn more.
12.OUR POLICY ABOUT CHILDREN
TALK2STUDY is made available to users who are at least 13 years of age. We do not knowingly obtain or welcome people below 13 years of age to submit personal information to us. If you are below 13 years of age, you may only use TALK2STUDY under the direction of at least a parent or legal guardian. By using TALK2STUDY and submitting personal information to us, you represent to us that you are at least 13 years of age. You also warrant to us that any information you submit to us is accurate and complete.
13.CHANGES TO THIS POLICY
TALK2STUDY LTD may decide to review and change any paragraph in this Policy – with or without notice or liability to you or any third party. We may review and change this Policy for certain reasons, such as, without limitation, changes in applicable law, changes in how we use certain information, and changes in certain features on TALK2STUDY. Any and all changes will become effective by posting the affected portion and changing the Effective Date above. We reserve the right – but not the obligation – to notify you of changes via your email address or any other channel we deem fit. You also have a duty to review this Policy frequently for possible changes. By your continued use of TALK2STUDY after a certain change, you consent to such a change.
14.OUR CONTACT INFORMATION
We welcome complaints, questions, suggestions, feedback, and queries regarding this Policy and TALK2STUDY. If you would like to reach out to us, use the contact information below:
TALK2STUDY