TalkingLime Privacy Policy

This TalkingLime Privacy Policy ("Privacy Policy") describes how your personal data is processed when you use TalkingLime ("Services"), a platform that lets you practice oral language skills with Avatars powered by Large language models (LLMs). This Privacy Policy aims to help you understand how we collect, use, store, and share your personal data (“Personal Data”). It also outlines your rights concerning your Personal Data. Under data protection laws, Personal Data includes any information that identifies or can be used to identify an individual. At TalkingLime, we process Personal Data strictly in accordance with applicable data protection laws and regulations. This Privacy Policy applies to activities by 01.AI Pte. Ltd. (together with our affiliates, "we", "us" or "TalkingLime").

1 Personal data we collect

Personal data You Provide:

o    Third-Party Application Login: You can log into your TalkingLime account using third-party applications (e.g., Google or Apple). When you do so, we collect your name and email address associated with the third-party application for authentication and identity verification purposes.

Profile Information: This includes your username and age group.

o    Language Learning Information: We collect details such as your native language, language learning goals, and current proficiency level.

o    Subscription Information: This includes the start date and duration of your subscription to the Service, as well as any applicable free trial periods.

o    Purchase Information: We process confirmation of your subscription purchase through your App Store or Google Play account.

o    AI Tutor and Avatar Selection: The AI tutor or avatar you choose within the Service.

o    Recordings and Transcripts: We collect recordings and transcripts of your conversations with the AI tutor, as well as data on your learning behavior, personal vocabulary, and grammar proficiency. This may include content and voice recordings, where applicable.

o    Lesson Plan and Progress: Information related to your lesson plan and learning progress.

o    Preferences: This includes settings such as push notification preferences, app interface language, and email communication preferences.

o    Communication Information: If you contact us through our Avatars on the Help site, email, or social media pages, we collect your name, contact details, and the contents of your messages.

o    Other Information You Provide: We collect any additional information you provide, such as participation in events or surveys, or details submitted to verify your identity or age.

Personal data We Receive Automatically From Your Use of the Services:

o    Log Data. This includes information that your browser automatically sends when you use our Services. Log data may include your Internet Protocol (IP) address, browser type, log files, log settings, the date and time of your request, timestamps, clickstream data, and details about how you interact with our website, marketing emails, and ad impressions.

o    Troubleshooting Data.  If you or your device experiences an error, we may collect and track information about the error or crash, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred. Basic contact details, such as name, address, phone number, and email.

o    Usage Data. We may automatically collect information about your use of the Services, such as your time zone, country, access dates and times, user agent and version, type of computer or mobile device, your computer connection, activity logs, user behavior statistics, installation and engagement metrics, your search and browsing history, the links you click, the actions you take, the technology and devices you use to access the Services, and other details about how and when you use the Services.

o    Device Information. This includes details about your device, such as its type, operating system information, unique device identifiers, Internet Protocol (IP) address (including location information derived from your IP address), network information, browser information, web page referrers, mobile network and connection information, mobile operator or Internet Service Provider (ISP), system logs, time zone setting. It also includes identifiers such as device or advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers.

o    Location Information: We may determine the general area from which your device accesses our Services based on information like its IP address for security reasons and to make your product experience better, for example to protect your account by detecting unusual login activity or to provide more accurate responses. In addition, some of our Services may allow you to choose to provide more precise location information from your device, such as location information from your device’s GPS.

o    Analytics Information. We may use various online analytics tools, such as Google Analytics, which use cookies or other technologies to help us analyze how users interact with our Services and enhance your experience. For more information about our use of cookies, please refer to Section 3 of the Privacy Policy.

2 How we use personal data

We may use Personal data for the following purposes:

To provide our Service, including to provide the features and functionalities of the Service and improve the Service.

To manage your Account: To manage your registration as a user of the Service and grant you access to various features available to registered users.

To contact you: To contact you by email or other electronic means, such as push notifications from the mobile application, regarding updates, service-related information, and security updates when necessary or appropriate.

To provide marketing and promotional content: To share news, special offers, and general information about our products, services, and events that are similar to those you have previously purchased or inquired about, based on your preferences.

To manage your requests: To process and respond to any inquiries or requests you submit.

To facilitate business transfers: To assess or carry out a merger, divestiture, restructuring, reorganization, dissolution, or other transfer of some or all of our assets. This may include a sale, bankruptcy, liquidation, or similar proceeding, in which Personal Data of Service users may be among the transferred assets.

To analyze and enhance the Service: To monitor service performance, conduct data analysis to identify usage trends, and improve our Service, products, marketing efforts, and overall user experience.

To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks;

To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

3 How We Disclose Personal Data

o    Affiliates & corporate partners. We disclose the categories of personal data described above between and among its affiliates and related entities.

o    Service providers & business partners. To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal data to service providers or business partners, including providers of LLMs providers, cloud services, and other information technology services providers, email communication software, and web analytics services, among others. Pursuant to our instructions, these parties will access, process, or store Personal data only in the course of performing their duties to us.

o    Legal Requirements: We may share your Personal data, including information about your interaction with our Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.

o    We require third parties to safeguard your data and process it in compliance with relevant data protection laws. All third-party service providers must implement appropriate security measures, including but not limited to data backup, bastion host management, network port management, and access control. We only allow them to process your Personal Data based on our instructions, for specified purposes, and under appropriate circumstances.

4 Data Retention

We’ll retain the data you submitted to our Services for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations.

5 International Data Transfers

When you access our website or Services, your Personal Data may be transferred to our servers in Singapore.

Where information is transferred outside of your jurisdiction of residence that has laws and regulations that may not guarantee the same level of security and protection of personal data as your jurisdiction. However, we will take reasonable and necessary steps to ensure that we handle personal data in accordance with this Privacy Policy and provide a standard of protection that it is comparable with the protection under the laws of your jurisdiction, regardless of where your personal data is transferred to or accessed from.

6 Your rights

Subject to applicable law, and depending on where you reside, you have at least the following rights:

o    Right to know. You may have the right to know and access to information confirming whether and, if so, to what extent TalkingLime is processing Personal Data concerning you, including the categories of personal data, the categories of sources from which it is collected, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it.

o    Access & data portability. You may have the right to request a copy of the personal data TalkingLime processes about you, subject to certain exceptions.

o    Deletion. You may have the right to request that we delete personal data collected from you and retained, subject to certain exceptions.

o    Correction. You may have the right to request that we correct inaccurate personal data TalkingLime retains about you, subject to certain exceptions.

o    Objection. You may have a right to object to some processing activities or restrict us from processing your Personal Data.

o    Withdrawal of consent. Where our processing of your personal data is based on consent, you have the right to withdraw your consent.

o    Complaint: If you believe that the processing of your Personal Data does not comply with data protection laws, you have the right to lodge a complaint against TalkingLime with the relevant supervisory authority. We encourage you to contact us first so we can address your concerns and attempt to resolve any issues regarding the processing of your Personal Data before escalating the matter to the authority.

o    Sale & targeted advertising. TalkingLime does not "sell" your personal data in exchange for monetary considerationas that term is defined by applicable laws and regulations. TalkingLime also does not engage in profiling in connection with direct marketing or targeted advertising using your Personal Data.

To exercise your rights, you or an authorized agent may submit a request by emailing us at [email protected]. After we receive your request, we may verify it by requesting information sufficient to confirm your identity. You may also have the right to appeal requests that we deny by emailing [email protected].

7 Use of AI-Tools

TalkingLime leverages AI tools to operate, enhance, and refine our services, as well as to introduce new product features. Specifically, AI tools are used for conversation design, speech recognition, audio-to-text conversion, and generating responses.

Personal data is processed in this context, particularly the data you provide or input while using AI-powered features. This data is used to train our AI models, generate content, deliver services, and continuously improve our offerings. Additionally, we may analyze usage data for quality assurance purposes.

AI tools are provided by third-party vendors and integrated into TalkingLime’s systems via secure interfaces. These vendors act as our data processors, and we contractually requires them to implement appropriate technical and organizational measures to safeguard your personal data.

8 Cookies & Similar Technologies

We and our service providers use cookies, scripts, or similar technologies, such as mobile SDKs ("cookies") to manage the Services and to collect information about you and your use of the Services. These technologies help us to recognize you, customize or personalize your experience, offer additional products or services to you, and analyze the use of our Services to make it more useful to you. These technologies may also allow us to collect demographic and statistical data and provide this information to our service providers to help deliver their services.

Most browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your browser, or access http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may mean that you may not be able to take full advantage of our Services.

 

9 Children

Our Services are not directed towards, and we do not knowingly collect any information of, children under the age of 18. If you become aware that a child under the age of 18 has provided any personal data to us while using our Services, please email us at [email protected] and we will investigate the matter and, if appropriate, delete the personal data.

10 Information for California Users

We collect the following categories of personal data:

o    Identifiers: such as your username, the email address and phone number you used to sign up, and device identifiers;

o    Commercial information: such as your transaction history, if anything;

o    Internet or other network information: Content and how you interact with our Services, such as browsing history, browser type and settings, the date and time of your request, network information;

o    Geolocation data.: because your IP address may indicate your general location;

o    Sensory data: such as audio, electronic or similar information.

o    Your account login credentials and payment card information (Sensitive Personal data)

We collect the categories of Personal Data listed above from the following sources:

o    Directly from you: This includes information you provide when filling out forms on our Service, setting preferences, or making purchases.

o    Indirectly from you: This includes data gathered by observing your interactions and activity on our Service.

o    Automatically from you: This includes data collected through cookies and similar tracking technologies set by us or our service providers on your device as you navigate our Service.

For more information about what we collect and the sources of such collection, please see the "Personal data we collect" section above. We collect personal data for the business and commercial purposes described in "How we use personal data" above. If we decide to collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Disclosure of personal data: We may share your personal data with third parties as described in the "How We Disclose Personal Data" and “Third-Party Websites and Services” section above. We disclose the categories of personal data mentioned above for business or commercial purposes.

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Data by the business to a third party for valuable consideration. We do not sale Personal Data. But We may share your Personal Data identified in the above categories with the following categories of third parties:

o    Service Providers

o    our affiliates

o    Third party vendors to whom you or your agents authorize us to disclose your Personal Data in connection with products or services we provide to you

To the extent provided for by local law and subject to applicable exceptions, individuals may have the following privacy rights in relation to their Personal data:

o    The right to be notified and to know information about our processing of your Personal data, including the specific pieces of Personal data that we have collected from you;

o    The right to request deletion of your Personal data;

o    The right to say no to the sale or share of Personal Data (opt-out).

o    The right to correct your Personal data;

o    The right to ask for a copy of personal information that we have collected and maintained about you.

o    The right to be free from discrimination relating to the exercise of any of your privacy rights.

11 Information for EEA, UK or Swiss users

Our legal bases for processing your Personal data include:

o    Performance of a contract with you when we provide and maintain our Services. When we process Account Information, Third Party Application Login, Content, and Subscription Billing Data solely to provide our Services to you, this information is necessary to be able to provide our Services. If you do not provide this information, we may not be able to provide our Services to you.

o    Our legitimate interests in protecting our Services from abuse, fraud, or security risks, or in developing, improving, or promoting our Services, including when we train our models. This may include the processing of Content, Log Data, Usage Data, Device Information, and Analytics.

o    Your consent when we ask for your consent to process your Personal data for a specific purpose that we communicate to you. You have the right to withdraw your consent at any time.

o    Compliance with our legal obligations when we use your Personal data to comply with applicable law or when we protect our or our affiliates', users', or third parties' rights, safety, and property.

12 Changes to the Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law.

13 Contact Information

If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact us via email: [email protected] or via postal mail at 120 ROBINSON ROAD #13-01, SINGAPORE, Zip code: 068913.