TALKSY Privacy Policy

Effective: 05 April 2024

Last Updated: 05 April 2024

This Privacy Policy explains how we collect, use, store, protect, and share your personal information through our services.

If you reside in the European Economic Area (“EEA”), Russian Federation or United Kingdom, Cyberkoala LLC is the “data controller” of your personal information collected through the services (as defined in our Terms of Service). It’s important that you read this entire policy, but here’s a summary to get you started:

• We care a lot about privacy. We are committed to creating spaces where people can talk with friends and coworkers online. Respecting user privacy is a key part of that mission.
• We don’t sell your personal information. Our business is based on subscriptions and paid products, not from selling your personal information to third parties.
• We limit what information is required. We require the information that enables us to create your account, provide and maintain our services, meet our commitments to our users, and satisfy our legal requirements. The rest is optional.
• We care deeply about safety. Our dedicated Trust & Safety team works hard to help keep our community safe. We also use certain information to help us identify violations of our Community Guidelines and prevent harmful content from being distributed through the services.
• We give you control. We give you the ability to control your privacy on Talksy .

The information we collect

We collect certain information when you use Talksy. This includes information you provide to us, information we collect automatically, and information we receive from other sources.

Information you provide to us

Account information

When you create a Talksy account, you can come up with a username and password, and provide a way of contacting you (such as an email address and/or phone number). You’ll also need to provide your birthday. In some cases, we may require additional information to verify your age. You may be required to verify your account or provide additional information (like a verified phone number) to your account. You may also have the option to add your name or choose a display name.

Content you create

This includes any content that you upload to the service. For example, you may write messages or posts (including drafts), send voice messages, or post other content that you create with features that we develop. You may also upload and share files through the services. This also includes your profile information and the information you provide when you create servers. We generally do not store the contents of video or voice calls or channels. If we were to change that in the future (for example, to facilitate content moderation), we would disclose that to you in advance. We also don’t store streaming content when you share your screen, but we do retain the thumbnail cover image for the stream for a short period of time. We may build features that help users engage with voice and video content, like create or send short recordings.

Payment information

If you buy any paid services through Talksy, you may need to submit a valid payment method and associated billing information, including your full name and billing address. Our payment processors, like Stripe and PayPal, receive and process your payment information. Depending on the processor, we may also receive and store certain billing information, including the last four digits of the credit card number associated with the transaction. If you sell something through Talksy, you may be required to provide additional information to Talksy or to our payment processors, such as bank account information to facilitate payments, tax identification information, and copies of government issued identification required to identify users in accordance with regulatory obligations. If we decide to process our own payments in the future, we would receive and process this information ourselves.

Information from actions you take

We collect information about your use of Talksy and your activities on the services. This includes information such as the friends you add, the users, bots, and apps you engage with, the games you play on your device, the servers or other communities you join and participate in, your roles in servers, content moderation decisions you make, information about purchases or sales you make on or through Talksy including what you purchased or sold, and other related actions. You can control the extent to which we collect, use, and display this information as described in the “How to control your privacy” section below.

Information from optional features

Certain features, like contact syncing, may require that you provide additional information (or grant us access to such information) to make them work. This also includes third-party integrations you choose to enable and the data you authorize those third-party services to share with us. For example, when you link a music streaming account, we may collect information about that account such as the song you are listening to in order to display that information on your profile or as your status (if you have chosen to do so).

Other information you provide directly to us

You may have the option to submit additional information as you use Talksy. For example, you may participate in surveys where you can provide feedback on the services, or submit information to our Talksy Support teams.

Information about your device

We collect information about the device you are using to access the services. For example, this includes information like your IP address, operating system information, browser information, and information about your device settings, such as your microphone and/or camera.

Information about your use of the apps or websites

For example, we collect log and event information related to how and when you use our services (such as the pages, servers, and channels you visit, the activities you engage in, the features you use, and the surfaces or embedded content you interact with).

Other information that we collect automatically

When you take certain actions on other sites, we may receive information about you. For example, when we advertise for Talksy on third party platforms, if you click on the ad, we may receive information about which ad you saw and on which platform. Similarly, we may also receive certain information when you click on a referral link, such as which website you came from.

Information we receive from other sources

We may receive information about you from other sources, including from other users and third parties, and combine that information with the other information we have about you. For example, if you interact with our social media account on another platform, we may receive certain information about you like your username on that platform.

How we use your information

Under certain data protection laws like GDPR, companies must have a “legal basis”—a valid reason—to process personal information. Talksy relies on different legal bases to process your information for the purposes described in this Privacy Policy. We use the Information We Collect—Account information, Content you create, Payment information, Information from actions you take, Information used to enable optional features, Other information you provide directly to us, Information about your device, Information about your use of the apps or websites, other information that we collect automatically, and Information we receive from other sources—for the following reasons and according to these legal bases. For each reason, we describe why we process your information and how we process your information to achieve each purpose.

To provide you with the services

We use your information to provide you with the Talksy services. For example, when you start a video call, we process your images and audio to make that work. We similarly collect and store the messages you send and display them as you direct. We also use the information you provide to us to create and manage your account and to facilitate purchases. When you enable optional features (like connecting your Talksy account to other platforms), we use information from those services to power the feature (like displaying what song you are listening to on another service within the Talksy app).

To meet our commitments to the Talksy community

We work hard to try to make Talksy a safe, positive, and inclusive place. To do so, we use your information to monitor for and take action against users and content that violate our Terms of Service, Community Guidelines, and other policies. This includes responding to user reports, generating transcriptions of content as part of our investigation, detecting fraud and malware, and proactively scanning attachments and other content for illegal or harmful activity. We also use certain information, which may include content reported to us, content that violates our Terms of Service, and certain other content widely available on the service (such as public posts, usernames, avatars, banners, user profiles, server names, server icons, and server banners), to create systems and models that can be automated to more swiftly detect, categorize, and take action against prohibited content or conduct.

To contact you

We use your information to contact you in connection with your account, such as to verify or secure it with two-factor authentication. We may also use your information to contact you about important product or policy changes and to send you information about products you have purchased.

To provide customer service

We use your information to respond to your questions about our products and services, and to investigate bugs or other issues.

To protect our services

We use your information to keep our services secure, to prevent misuse, and to enforce our Terms of Service and other policies against users who violate them.

To report on our company’s performance

We use your information to track the fundamental metrics of our business, to perform financial reporting, to respond to regulatory obligations, and to debug billing issues.

To personalize the product

We use your information to personalize our services. This information is used to customize your experience on Talksy such as features that highlight activity on Talksy that may interest you. This information also helps us surface Talksy features and promotions from us and our partners that may be of interest to you. As discussed in the “How to control your privacy” section below, you can choose to what extent we will use your personal information to personalize your Talksy experience.

To improve our services

We use your information to help us understand how users interact with our services, what features or products users may want, to develop features that make Talksy safer and better to use, or to otherwise understand and improve our services. This includes information about how you use our services and how servers are structured. We may also use certain content that is widely available to better understand, for example, what topics servers cover and what content is most interesting within those servers. Similarly, you can limit to what extent we use your personal information for these purposes.

To advertise our services on Talksy and other platforms

We may tell you about our paid services and other features directly in the services and through our own channels, and we spend money advertising Talksy on other platforms. As part of that, we use certain information to assist in the delivery of our advertising, to measure the effectiveness of advertisements for our own products, and to improve such advertisements in the future.

To contact you

We may use your information to let you know about new products or features we think you’ll like, to ask you for feedback about our services, or to tell you about experiments that might interest you. You may opt-out of receiving such marketing communications. Where local law requires, we will obtain your consent before sending such communications.

We retain and use your information in connection with potential legal claims when necessary and for compliance, regulatory, and auditing purposes. For example, we retain information where we are required by law or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any of your applicable legal rights to access, amend, or delete your personal information, we may request additional information from you for the purpose of confirming your identity.

‍We may also collect and use personal information with your consent, such as to send you marketing communications where legally required. You can revoke your consent at any time (mostly through our services directly), though note that you might not be able to use any service or feature that requires collection or use of that personal information.

We may collect or share personal data if we think someone’s life is in danger—for example, to help resolve an urgent medical situation.

How we disclose your information

• When you tell us to. When you add your content to the services, you are telling us to make that content available to certain people or communities. Who can access that information is determined by who can access a particular space. For servers, those permissions are set by server owners or admins. They control whether a server requires an invite link or is open and accessible to anyone. And these permissions, like the size of the server, may change over time. Similarly, if you link your Talksy account with a third-party service, embed content, interact with third party content posted on Talksy, or participate in a server that has third-party features like bots enabled, we may provide certain information to that service or to other Talksy users to operate that service or feature. Additionally, if you purchase goods or services from other users on Talksy, we may disclose certain information to these users in order to facilitate the delivery of the goods or services purchased or help them understand and improve their business. We may also disclose your information as you otherwise instruct us or provide us your consent to do so.
• With our vendors. We may provide information to vendors we hire to carry out specific work for us. This includes payment processors like PayPal and YooMoney that process transactions on our behalf and cloud providers like Vercel that host our data and our services. We may also provide limited information to advertising platforms to help us reach people that we think will like our products and to measure the performance of our ads shown on those platforms. We do this to help bring more users to Talksy and make our business successful, and provide only the information required to facilitate these services. This may include information like the fact that you installed our app or registered to use Talksy.
• To comply with the law. We may disclose information in response to a request for information if we believe disclosure is required by law, including meeting national security or law enforcement requirements. Where allowed and feasible, we will attempt to provide you with prior notice before disclosing your information in response to such a request. Our Transparency Report has additional information about how we respond to requests from governments and law enforcement entities.
• In an emergency. We may disclose information if we believe in good faith that it`s necessary to prevent serious harm to a person.
• To enforce our policies and rights. We may disclose information if needed to enforce our Terms of Service, Community Guidelines, any of our other policies, or to protect the rights, property, and safety of ourselves and others.
• With our related companies. We may provide information to our related companies, including parents, affiliates, subsidiaries, and other companies under common control and ownership.
• Sale, Acquisition, or Transfer of Assets. We may disclose information if Talksy is evaluating and/or engaging in a merger, acquisition, reorganization, bankruptcy, or sale, transfer, or change in ownership of Talksy or any of its assets.
• Aggregated or de-identified information. We may disclose information that has been aggregated or anonymized such that it cannot reasonably be used to identify you. For example, we may share aggregated user statistics in order to describe our business, features, or promotions to partners or the public.

Data retention

We retain personal information until we determine it is no longer needed for the processing purposes for which we collected or retain it or for legal compliance.

How we protect your information

We take a number of steps to help protect your information. All information sent within our services is encrypted both in transit and at rest. For example, we use Transport Layer Security (“TLS”) to encrypt text and images in transit. We also enforce technical and administrative access controls to limit which of our employees and contractors have access to nonpublic personal information.

How to control your privacy

We believe that users should be able to tailor their Talksy experience to their preferences, including privacy. And while local laws may require different things, we believe that our users should have at least the same basic ability to shape their experience no matter where they are in the world. Here’s how you can control how we process your information, how to delete or correct certain information, and how to request access to your information. Users in certain places may have specific rights under their local laws. You can learn more about these in the relevant sections below.

‍Be aware of the Talksy spaces you choose to participate in You can choose what spaces to participate in and what information you add to our services. You can choose what messages to send or post, who to engage with (e.g., one or more particular users or a potentially unlimited group of users), what information to include in your profile, whether to connect any third party services to your Talksy account, and more. For example, if you share content in certain spaces, such as servers listed in Server Search or with public invite links, your content may be accessed by anyone.

Disable or delete your account

You can delete your account via the User Settings menu. Deleting your account permanently deletes identifying information and anonymizes other data as described in our data retention policy.

Manage your content and servers

You may edit or delete specific pieces of information within the services:

• You can edit or delete any message you have sent or content you have posted if you still have access to the space where you posted it.
• You can edit or delete a Talksy server if you have the permissions needed to do so.
• You can edit or delete a channel from a Talksy server if you have the permissions needed to do so.

Content may be retained by Talksyd for use as described elsewhere in this policy and in our data retention policy. Also, in limited circumstances, we may have a legal obligation to retain certain information, even if you delete the information or your account.

International data transfers

We are based in the Russian Federation, and we process and store information on servers located in the Russian Federation. We may also store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. These data transfers allow us to provide our services to you. By accessing or using our services or otherwise providing information to us, you understand that your information will be processed, transferred, and stored in the U.S. and other countries, where different data protection standards may apply and/or you may not have the same rights as you do under local law.

When transferring data outside the EEA, we use standard contract clauses (Module 1 and Module 2), and we rely on the European Commission`s adequacy decisions about certain countries, as applicable, or other legally compliant mechanisms or conditions for such data transfer.

Services offered by third parties

We allow third party developers to build certain features or other services and offer them within the Talksy services. For example, server administrators can add “bots” created by third party developers that provide features like content moderation.

Contact us

Email us at contact@cyberkoalastudios.com with any questions about this Privacy Policy or how we process your information. We’ll be happy to help.

Russian Federation
119602
Moscow
st. Troparevskaya, vld. 4
p. 3, office. 113