PriveTalk Privacy Policy 2023

1. INTRODUCTION & DEFINITIONS

This document is the Privacy Policy of PriveTalk.  The Privacy Policy document, together with the Terms & Conditions document and the Dating Safety Guide document constitute collectively the “Agreement” which is the legal contract between you, the user of PriveTalk, and us, SocioBright Ltd, the owner of PriveTalk. All three documents are available on the PriveTalk’s application registration page, on the PriveTalk’s application’s “About” section and also at the footer of the official website, https://privetalk.com.

In this document and in the Agreement, “you” refers to you as the user of the PriveTalk application(app) or of any of PriveTalk’s related Service(s) including its website. As the user of PriveTalk, you are entitled to use our provided Service only by reading, understanding, complying, accepting and following the terms and provisions found in the Agreement.

“Service” refers to the access or use of any of SocioBright’s products and services, including your access and use of the PriveTalk application or website. The term “user” refers to the user of the Service, regardless of when or for how long the Service was used.

The Privacy Policy explains how information about you or associated with you (“personal information”) is collected, used and disclosed by SOCIOBRIGHT LTD (“company, “we” or “us“) when you use any part of the Service(s).

2. PRIVACY POLICY EXPLANATION & TERMS

2.1. General Description

In SocioBright Ltd, we respect deeply the privacy of our users, as reflected in all of our products, including PriveTalk. We do our best to make our Privacy Policy easy to understand and transparent. This Privacy Policy describes the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. We encourage you to read this Privacy Policy carefully before and when using our application or services or transacting business with us.

2.2. Acceptance of the Privacy Policy

By either registering, using or subscribing to the Services, you confirm that you have read and consent to our entire Privacy Policy, and the entire Agreement as defined in section 1 of this document.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy at section titled “How to contact us”, section 2.12 for information on how to contact us.

2.3. Information we collect about you

When you register, use or subscribe to any of our Services, we may collect a variety of information including:

• Sensitive Account informationsuch as your full name, date of birth, email address, PriveTalk password, phone number, billing/living address, credit card data and related billing information, that allow PriveTalk to personalize your contact/customer experience, monitor your account security and securely process your payments. That information is confidential and you should not share it with any PriveTalk users.
• Public Account Information including first name, age, gender, gender of sexual preference and manually set location (or GPS location if you wish), that will be shared publicly on your profile to ensure a high standard of online dating experience.
• Other Personal Informationsuch as appearance characteristics, smoking/drinking habits, known languages, education level, occupation, religion, zodiac sign, GPS location, interests etc. Those information are voluntarily completed by you, and will be shared with all users visiting your profile. The purpose of those information are to allow other users to know you better and identify common information with you, or search for you based on some specific characteristics on our customized search tool.
• Uploaded Content Information such as the personal pictures and other personal data that you upload on your profile. At least one uploaded personal picture has to be verified by us in order for you to unlock the chatting mode with other users for free. In the verification process, three consecutive verification purpose pictures will be taken live in order for us to confirm that the user has uploaded his/her real pictures. The personal pictures uploaded by the user will be shared publicly among PriveTalk users while the verification purpose pictures will be kept hidden from PriveTalk users and used strictly for moderation purposes.
• Your Communication with Other Users. Currently when our users exchange information by messaging each other they see an expiration timer that starts counting once the user who received the new information opens the message. The expiration timer for all messages is set by default at 7 days, meaning that in approximately 7 days after both users view the new information, the specific information will expire from their screens. However, users who have an active subscription can manually set/change the expiration time for the messages that they send to be less than the 7 days. Even though the exchanged information may thus expire in 7 days or less from both the sender’s and the receiver’s phones, our company may keep records of all the exchanged information for a longer period of time for safety and moderating reasons. For these reasons, the company by default is keeping the records all personal communication information for one month, and after that period of time this information is automatically set to be deleted from our records permanently. However, the company reserves the right to change the time that it keeps such information with or without any notice.
• Your Communication with Us. We collect information that you send to us (such as emails or via the contact us form found in the PriveTalk app), comments that you post on the pages we have on a third-party service, such as our YouTube, Twitter and Facebook pages and messages that you send us directly through those services.
• Information from Social Media Accounts. If you choose to integrate a third-party social media account such as Facebook, Google+ or Vkontakte with our services, you permit PriveTalk to access certain information about you that is made available from the connected Social Networking Site. The information obtained by PriveTalk varies by Social Networking Site and may be affected by the privacy settings you establish at that Social Networking Site, but can include information such as your name, email, profile picture, gender, age or birthday, language, location, interests, contacts’ list, friends’ lists and other information. Specifically, when choosing to connect your Facebook account to PriveTalk, you grant to the app permissions to obtain your email address that will be used as your default email when creating your account and that should not be shared among other PriveTalk users. Additional information we can collect by your Facebook account is your friend list, age range, gender, public profile and Facebook profile url and that information should be publicly available among other PriveTalk users. Accepting this integration means that you agree that this information can be shared among other users of the app. Regarding your friend list, only common friends who both use PriveTalk and Facebook services will show on your as your “Common Friends” on the appropriate app sections, and only if both PriveTalk users have chosen to give us those permissions by connecting Facebook with our app.
• Information Provided by Others.We may be provided with information relating to you or your conduct on the Services by other users of the Services. We also collect information that third-party organizations may provide to us, such as contact details, demographic information, internet navigation details, credit reference or fraud prevention information. Financial institutions or payment processors may also provide us updated payment information or payment methods related to your paid account or paid subscription.
• Information Automatically Collected.When you access the Services we may automatically record information from your device and its software about your participation and actions on the Services, by using in-house or third party technologies such as cookies and web beacons. 

We may collect all of the information mentioned in this document through a website or a mobile application or other means. By using the Service, you agree that you are authorizing us to gather, parse and retain data related to the provision of the Service.

Below you can see a more analytical table of the information we collect from you:

Table1: Data collection Table

2.4. How we use the information we collect & to whom we may share it with

Wwe may use information that we collect about you in the following ways:

• manage your account and provide you with a high quality of customer support;
• protect our users’ safety and maintain a respectful social community that uses our products;
• deliver and improve our products and services, and manage our business;
• perform research and analysis about your use of, or interest in our products, services, or content;
• communicate with you by email, mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or from third parties;
• develop, display, and track content and advertising tailored to your interests on our Service and other sites;
• enforce or exercise any rights in our Terms and Conditions and in our Agreement and
• perform functions or services as otherwise described to you at the time of collection.

We can share  you infromation in those circumstances and with the following 3rd parties:

• Information Shared with Other Users. When you register or use our services, your PriveTalk public profile data will be viewable by other users of the Service within various areas in the Service.
• Service providers/ 3rd Parties. We may share information, with third parties that perform certain services on our behalf. Those third parties include Facebook, Google, and Instagram. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, member screenings, supporting our Service functionality and technical assistance, or other features offered through our Service. These service providers may have access to personal information needed to perform their explicitly assigned functions but are not permitted to share or use such information for any other purposes.
• Other Situations. Also in extraordinary cases we may disclose your information, including personal information:
  • In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • 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 Terms or other agreements or policies.

In some circumstances, we may perform these functions directly or use a third party vendor to perform these functions on our behalf. Also, if you access our Service from a third party social platform, such as Facebook, we may share non-personal information with that platform to the extent permitted by your agreement with it and its privacy settings.

For a more analytical explanation on how we use your information, please consulat Table 1 above, at section 2.3.

Our policy is to not disclose your personal data, except in the limited circumstances described below:

Sharing your personal data with Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which PriveTalk shares User personal data vary depending on a variety of factors, such as which of our Apps and Sites a User engages with. For example, to provide our services to PriveTalk App Users, we typically use the following suppliers:

• Billing services – to allow customers to purchase paid features of our App (for example, Google Play)
• Authentication services – to allow customers to authenticate their account (for example, Twilio)
• Social media providers – to allow customers to create/connect their PriveTalk account with their account(s) on such platforms (for example Apple, Google, Facebook or Instagram)
• Product improvement and market research – we use third party platforms (such as Typeform) and agencies to carry out customer surveys and market research to improve our products and services
• Growth marketing services – to allow us to market and advertise PriveTalk to potential customers (for example Facebook)
• IT services – some of the third-party software providers used in the operation of our business may process customers’ personal data

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

Sharing your personal data with Marketing Service Providers and Advertising Partners

We may partner with advertising publishers to place third party adverts on our App and Sites (‘Advertising Partners’). We also partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:

• to exclude you from advertising campaigns aimed at finding new users, if you already have a PriveTalk account;
• to show PriveTalk adverts to users who have visited the PriveTalk App/Sites but haven’t yet created a PriveTalk account;
• to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers hold about you (also known as a Lookalike Audience); or
• to include you in a ‘custom audience’ that will receive PriveTalk advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

We share a limited amount of your personal data with companies that help us with marketing and advertising, such as:

• the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer), know when an ad has been viewed or clicked on in the App or sites, and when an ad causes a “conversion” (for example downloading the app advertised to you))
• your estimated location (based on your IP address)
• age and gender
• data about your visit to our Sites or App and action was taken on those (for example, if you downloaded our App or created an Account with our App)
• a hashed* version of your email address (to create ‘custom audiences’).

*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters – this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.

Some platforms require user consent before PriveTalk is permitted to use data gained through the platform for advertising purposes and where it is the case, PriveTalk will only use this data where the necessary consent has been obtained. Through your device’s security settings, you also have the option to prevent or limit device identifiers being shared with third-party advertisers and what use is made of the device identifiers. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit this page.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising-related services provided to other clients.

Sharing with Facebook

Where we share data with Facebook as our Marketing Service Provider (including via the Facebook “Like” function), we are Joint Data Controllers with Facebook Ireland for this processing. This arrangement means that PriveTalk has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information as an independent data controller, can be found in Facebook Ireland’s Data Policy. If you want more information relating to the nature of the arrangement we have in place with Facebook, please email support (at) privetalk.com. 

This data referred to above can include actions that you take on our website such as your interactions with our website or other information collected from cookies or similar technologies including the Facebook pixel. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook).

Google’s reCAPTCHA service

To protect the input and comment areas of our App against spam and abuse, we use the reCAPTCHA verification tool. This service is provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and is subject to Google’s privacy policy and terms of service.

reCAPTCHA makes it possible to differentiate between inputs of human origin and those that are carried out improperly by a bot. Certain device and application data will be transmitted to Google’s servers in order to determine whether actions on our App really come from humans. Google may also use this data to improve the reCAPTCHA service. This data may include: URLs; user IP address; Google account information if the user is logged in to their Google account at the same time; browser information, including browser type, browser size, browser resolution, browser plug-ins, language settings and date; mouse and touch events within the page; and information collected from cookies. This processing is based on our predominant legitimate interests in protecting our App from abusive bots.

2.6. How We Contact You

We may contact you personally by email, mail, in-app notification, in-app private messages, push notification or other communication tools.

To change specific communication settings or privacy settings, please use the “settings” menu found on the main menu screen of our PriveTalk application.

Customer Service Requests may be answered either by your account email, or directly via our secure direct messaging in-app platform facilitated by our PriveTalk application. To submit a Customer Service ticket please use the “contact us” button found in the “about” section at the main app menu screen.

2.7. How we protect your personal information

We take security measures to help safeguard your personal information from unauthorized access and disclosure, with encrypted technologies, expiration timers, anti-hacking third-party and in-house tools, and strong moderation, among other safety features that are offered in our apps. However, no system can be completely secure. Therefore, although our high efforts to secure your information, we do not promise, and you should not expect, that your personal information, chats, or other information will always remain secure. Users should also take care with how they handle and disclose their personal and private information. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov/bcp/menus/consumer/data.shtm  for information about how to protect yourself against identity theft, and also be sure to read our Dating Safety Guide document for advices regarding your personal safety when using online dating services.

2.8. Minor’s privacy

Although our Service is a general audience Service, we restrict the use of our service to individuals age 18 and above. We do not knowingly collect, maintain, or use personal information from people under the age of 18.

If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their Profile information from PriveTalk. If we do delete a Profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

2.9. E-mail Subscriptions & Lists

If you register an account via our application or website(s) you provide us with your email address which is a unique identifier of your account to our Services and that is used for our communication with you. In order to create your account, you are also required to read carefully our Terms & Conditions, Privacy Policy, Dating Safety Guide and the entire Agreement in general (as defined at section 1 of this document and agree to give us consent to all the terms stated on those documents, by checking/ticking the corresponding checkbox/opt-in box that states the following: “I have read and accept the Terms & Conditions, Privacy Policy and Dating Safety Guide”.  Please note that each of the three documents directs to a URL/website where you can and should read those documents in full.

If you agree to all our Terms/Agreement and positively check the opt-in box this action gets you automatically subscribed to our email lists that can be used for marketing, customer services, account security, account moderation or legal compliance. If you do not provide consent for your email to subscribe to any of our email lists, then you have the right to contact us as described on sections 2.10 and 2.12 and asked to be removed from those email lists.

Please note that we have the right to add additional means of asking you to subscribe to our email lists or any other marketing list besides the ones described in detail above. However, in every case we will make clear to you that you need to actively understand and give consent to subscribe to any of our marketing lists and that you need to actively opt-in in such lists to participate in them. We will also make sure that there will be always available transparent and reliable means for you to unsubscribe at any moment from such lists.

2.10. User Rights

Privacy laws applicable in your country may give you the following rights:

1. Right to be informed: what personal data an organisation is processing and why (this notice).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision that has legal or significant effects for the individual. In these circumstances, your rights include the right to ensure that there is human intervention in the decision-making process.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

If you want to exercise any of your rights listed above, including the deletion of your personal data please send an email to our Data Protection Officer at support (at) privetalk.com.  You can also contact us by post at the following address: Sociobright Limited, Makedonias 5, Meba, Pafos. Cyprus. 8250.

For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.

If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.

If you feel we have not resolved your concern, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Live in a country or territory located in the European Union (EU) or European Economic Area (EEA). You may also get in touch with your local Data Protection Regulator. If you live in a country outside the EU, you may have the right to lodge a complaint with your local privacy or data protection regulator.

EU Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), PriveTalk has appointed SocioBright Ltd as it’s GDPR representative in the EU. If you usually reside in an EU Member State you can contact SocioBright Ltd Ltd regarding matters pertaining to the GDPR by using this form here:

Using the online request form at – https://privetalk.com/contact/

Postal address: Makedonias 5, Emba, Pafos, Cyprus. 8250

2.11. Data Retention & Data Deletion

You may request to permanently delete your Account or specific personal data anytime. The option to delete your account is provided directly on the application by opening the burger menu, then selecting settings, and then selecting the “Delete your account” link.

In the extraordinary case that there is an error by deleting your account automatically in the app, or in the case that you want to delete only specific personal data please send an email to our Data Protection Officer at support (at) privetalk.com with your request . You can also contact us by post at the following address: Sociobright Limited, Makedonias 5, Emba, Pafos. Cyprus. 8250.

When you choose to delete your account, the account may be placed in a temporary deactivation mode until your request is fully processed.  When your Account is deactivated, we take reasonable efforts to ensure it is no longer viewable on the App. For up to 28 days may is still possible to restore your Account if it was accidentally or wrongfully deactivated. After 28 days, we should conclude the process of deleting your personal information from our systems unless:

1. we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may need to be kept for accounting purposes);
2. we must keep it to evidence of our compliance with applicable law;
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.

Where PriveTalk uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

To prevent abuse and/or misuse of PriveTalk by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that a User does not open a new Account and profile in breach of our Terms and Conditions of Use and to ensure compliance with all laws and regulations.

Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

Your data that are utilized for your use of the PriveTalk Service are automatically and manually reviewed at regular time intervals and can be deleted by our system or administrator when there is a long period of inactivity or any potential attempt to breach the Service of the App, or any 3rd Party terms of service (including Facebook/Meta, Google, and Apple). A more extensive user review process typically takes place every 6 months, and profiles that remain inactive for a period that is longer than 6 months are not viewable by other users. After 1 year of continuous inactivity, the system will automatically delete your data. Therefore, it is possible that your account data may be deleted due to inactivity unless you explicitly define that you do not wish your account data to be deleted by using the contact information available at https://privetalk.com/contact/. Your request will be reviewed by our administrator and if your use of the Service complies with the Agreement your data retention can be extended.

2.12. Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time, in our sole discretion.  The modified Privacy Policy would be made publicly available on either the PriveTalk application, or/and PriveTalk website or/and through other communication media such as the Application Stores that will host our app, e-mail communication or/and other means of communication.

When we post changes to this Privacy Policy, we will revise the “Last Revision Date” at section 2.13 found at the bottom of this document. You should review the newest modified version of the Privacy Policy each time it’s available, because if you continue to use the Services you are agreeing to be bound by it.

If you don’t agree to be bound by the modified Privacy Policy, then you can’t use the Services anymore. If you object to any change or modification, your sole recourse shall be to cease using the Services and you should contact us as stated on section 2.12, letting us know that you no longer agree to be bound to the Agreement, Privacy and Terms statements and thus wish to discontinue the usage of our Services.

You agree that the Company shall not be liable to you or to any third party for any modification, suspension or discontinuance of the Service.  Except as may be expressly specified otherwise by SocioBright Ltd with respect to paid portions of the Services, we reserve the right to add, change, suspend or discontinue the Services, or any aspect or feature of the Services, without notice or liability.

2.13. How to contact us

If you have any questions about this Privacy Policy or want to exercise any of your rights as stated in the Privacy Policy, please contact us at support (at) privetalk.com. In your email, you may include your full name or other relevant information if it’s needed. Our customer service team will be glad to provide you with support in a timely and efficient manner.

Alternatively, you may also mail us at :

SocioBright Limited

Makedonias 5, Emba

Pafos. 8250

Cyprus

2.14. Last Revision Date

This document was last revised on March 24th , 2023