Privacy Policy

This Privacy Policy discloses the practices of Smalltalk Group Ltd. (d/b/a “Smalltalk”) concerning information we obtain by and through your use of the Getsmalltalk.com website (the “Site”) our Smalltalk mobile application (the “Application”) and the services offered through either the Site or the Application (the “Services”).

Smalltalk is committed to respecting your privacy and recognising your need for appropriate protection and management of Personally Identifiable Information you share with us. The purpose of this privacy policy is to explain the types of information Smalltalk obtains about visitors to our Site and users of our Application and Services, how the information is obtained, how it is used, and the choices you have regarding our use of, and your ability to review and correct, the information. By using the Site, the Services and/or the Application, you are accepting and consenting to the use of your information as described in this policy.

A. What information we collect

The information we collect on our Site and through the use of our Services or Application generally falls into the following two categories: Personally Identifiable Information and Non-Personally Identifiable Information. If we do combine Non-Personally Identifiable Information with Personally Identifiable Information, the combined information will be treated as personal information for as long as it remains combined.

(1) Personally Identifiable Information
“Personally Identifiable Information” refers to information that lets us know the specifics of who you are. Smalltalk collects and stores personally identifiable information that you provide to us. The Personally Identifiable Information we collect may include: your name, date of birth, e-mail address, login name, passwords, etc. We request Personally Identifiable Information when you register on the Site or through the Application.

(2) Non-Personally Identifiable Information
“Non-Personally Identifiable Information” refers to information that does not by itself identify a specific individual. This can be can be technical information or it can be demographic information, such as your age, gender or interests. The non-personally identifiable data we collect when you visit our Site may include: your Internet Protocol (“IP”) address; “cookies” or small text files that collect information about our activity on our Site, including the Uniform Resource Locator (“URL”) of the Web site that you came from before visiting our Site, which pages you visit on our Site, which URL you go to next, which browser you used to come to our Site, and any search terms entered on our Site. More information about Cookies appears below.

We may also collect and use Non-Personally Identifiable Information in the form of demographic information, such as your gender, age and interest. We use this information to provide you with personalised services and information that we believe may be of interest to you. We may also collect, analyse and use aggregated and anonymised information about you for market research.

Your use of the Application may also include collection of information from your mobile device. For example, the Application may request your permission to collect location data and/or may request access to multimedia (photos or videos) stored on your mobile device. If you do not wish for your location data to be shared with Smalltalk, please respond accordingly when prompted on your mobile device, or visit your mobile device settings. Multimedia will only be collected from your device if you affirmatively select it to upload to the Application (i.e. you choose an image or video to store within the Application).

Cookies

Our Site uses or may use “cookies” to gather Non-Personally Identifiable Information. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Generally, we use cookies to store information about your preferences and activity during and after your visit to a web site. Most browsers automatically accept cookies, but you can usually refuse cookies, or selectively accept certain cookies, by adjusting the preferences in your browser. If you turn off cookies, though, there may be some features of our Site that will not be available to you and some Web pages may not display properly. By using the Site and/or Application, you consent to Smalltalk’s use of “cookies.”

B. Use of information we collect

(1) Our primary goals in collecting information from and about you are to:

• Provide you with the all features and functions of the Site, the Services and the Application;
• Communicate with you regarding our Services and/or Application;
• To complete a transaction or service requested by you;
• Provide all visitors a smooth, efficient, and personalised experience while using our Site, Services and/or Application.
  

  
  Specifically, we may use your Personally Identifiable Information for the following purposes:
  
  
• To deliver services, such as educational programs, information, or content that is of interest to you;
• To alert you to special offers, updated information and other new services from Smalltalk, or other third parties, or to forward promotional materials;
• To complete a transaction or service requested by you;
• To fulfil the terms of a promotion;
• To ensure the content you view on Site and Application are relevant to your needs and interests;
• To help us create and publish content most relevant to you;
• To notify you about a material change to this privacy policy or the Terms of Use, if necessary;
• To allow you access to certain functions or features of our Site or Application;
• To contact you in response to requests or inquiries we may receive from you.

We may also use Non-Personally Identifiable Information on an aggregated and anonymous basis to analyse customer behaviour and to help us understand how visitors use our Site, Services and/or Application. We use this information to gather statistical information, improve the content of our Site, Services or Application, to make our Site, Services or Application easier to use, and we may use it to customise our advertising or your experience on the Site or within the Application (but we will not provide Personally Identifiable Information to advertisers). We may also use information relating to use of the Site, Services and the Application internally for research purposes, for marketing and promotional purposes, and to develop new tools and solutions.

(2) Non-Personally Identifiable Information
Non-personally identifiable information is used as described above and in other ways as permitted by applicable laws, including combining non-personally identifiable information with personally identifiable information (except with respect to non-personally identifiable information collected from children under the age of 13).

C. How we collect information

We collect Personally Identifiable Information only when you provide it to us. If you do not wish for your Personally Identifiable Information to be used or collected, please do not submit it to us. There may be times, such as when a user registers through the Site and/or Application or signs up for any other product or service we may offer through the Site or the Application, when we will ask you to provide certain information about yourself, such as your name, e-mail address, etc. Whether or not you choose to provide such information is completely your own choice, but if you choose not to provide the information we request, you may be unable to use certain services, offers, and content on our Site, or that may be available by using the Application.

Our Site and Application may automatically collect Non-Personally Identifiable Information, including the web page from which a visitor enters our Site, which pages a visitor visits on our Site, and how much time a visitor spends on each page. Your mobile device may also collect certain information if permitted by you, including geolocation data.

D. Sharing and disclosures of information

Generally speaking, we do not shared your Personally Identifiable Information with third parties, except as follows:

• With Service Providers and/or Affiliates: We may use other companies to perform services including, without limitation, facilitating some aspects of our Site or Services such as processing transactions and/or sending emails. These other companies may be supplied with or have access to your information solely for the purpose of providing these services to you on our behalf.
• Special Circumstances: We also may disclose your information, including Personally Identifiable Information, in the following circumstances:
  • In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law;
  • When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Site’s terms and conditions or other agreements or policies.
  • In connection with a corporate transaction, such as the sale of all or a portion of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy. We will endeavour to contact you in the event of any of these transactions, but we do not promise to do so.

Notice to California residents

California law permits California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. Generally speaking, we do not disclose personal information to third parties for that purpose. However, if you would like to make a request to review information regarding such disclosures, if any exist, please contact us at hello@getsmalltalk.com.

E. How we protect your information

We use reasonable technological and physical safeguards to protect Personally Identifiable Information you provide to us from loss, misuse and unauthorised access, disclosure, alteration and destruction. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it.

We urge you to keep any password for use of the Application and/or Site in a safe place and not to divulge it to anyone. Also remember to sign off your account and close your browser window when you have finished your visit to the Site.

F. How to correct or remove personal information

If you do not want your Personally Identifiable Information collected or stored, please do not submit it to us. If you have already submitted personal information and would like us to correct or remove your information from our records, please contact hello@getsmalltalk.com.

G. Links to third party sites and/or integration with third party platforms

Our Site and Application may interface with third party sites and services, (for example, social media platforms like YouTube, Facebook, Twitter, Google+ or other third party applications, sites or services). Our Site may also contain links to websites operated and maintained by third parties, over which we have no control.

Privacy policies for these third party sites and services may be different from our privacy policy. You access these third party sites and services at your own risk. You should always read the privacy policy of a linked site or integrated service before disclosing any personal information on such site and/or through such service. Smalltalk is not responsible for and cannot control the use of any information you submit to third parties.

Currently, to help facilitate login to our Application and our Site, we offer a sign-on service that allows you to sign in using login credentials from your existing social media account. This allows you to associate your existing social media profile with your Smalltalk account. By linking these accounts, Smalltalk may access to certain profile information contained within your social media profile; this may include your full name, e-mail, locale, gender, profile picture, and friends list as well as other publicly available profile information. Smalltalk uses this information only to facilitate and enhance your use of the Site, the Services and/or Application and your sharing of Smalltalk content with existing friends and contacts. You can disassociate your social media account from your Smalltalk account at any time by accessing your social media platform settings.

H. Interactive public posting areas

Please note that any information you include in a message you post as a comment in any public posting area or interactive area of our Site or Application is available to anyone who accesses our Site or Services. If you don’t want people to know your username, for example, or specific information about you, don’t post publicly or include such information in any comment you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.

I. Opt-out

We communicate with users who subscribe to our Site or Services on a regular basis via email. For example, we may use your email address to confirm your request, to send you notices or information about our products and services, and to send notices and other disclosures as required by law.

We provide you the opportunity to exercise an opt-out choice if you do not want to receive certain types of communication from us, such as emails or updates from us regarding new services and products or information that we think may be of interest to you. The opt-out choice may be exercised by following instructions included within our email communications. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.

J. International transfer of information

If you choose to provide us with personally identifiable information, Smalltalk may transfer that information to its affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personally identifiable information to the United States which does not have the same data protection laws as the EU and by providing your personally identifiable information you consent to:

• The use of your personally identifiable information for the uses identified above in accordance with this privacy policy; and
• The transfer of your personally identifiable information to the United States as indicated above.

K. Policy Changes

To improve the services it can offer you, Smalltalk may opt to expand its capabilities for obtaining information about users in the future. Smalltalk will update this privacy statement continually to ensure that you are aware of developments in this area. We will post those changes here so that you will always know what information we collect online on through our Application, how we use it, and what choices you have. Please be sure to check this page before proceeding to use our Site or using the Application. Any material changes will be communicated to you directly via email or other notice on the Site or within the Application.

L. Questions or Feedback

If you have any questions or comments regarding our privacy policy and practice, please contact us at hello@getsmalltalk.com.