Last update: October 9th, 2023.

This Privacy Policy is an “agreement” between “Talk2U· (“Talk2U”, “us”, “we” or “our”) and “you” (“Talker”), referencing to people that have voluntarily connected with one of our Journeys via our official communication channels, subscribed to our newsletter and social media, signed up for a free trial of our Products and/or Services, purchased any of our Products and/or Services, and participated in different co-creation processes, research and user testings as a Talker, where personal data is collected, used and processed.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, access and delete your information. This Privacy Policy applies to all of the services offered by Talk2U and its affiliates, excluding Special Learning Journeys where we officiate as processors and for them you will need to accept their specific privacy policy.

If you are purchasing our Services and/or subscribing to become a Talker, please read this Privacy Policy carefully to understand our treatment and use of personal data.

For everyone at Talk2U protecting and respecting your privacy is important. This is why this Privacy Policy is written as clearly as possible, to give you all the information you need, in an understandable way, so you can make an informed decision on whether you would like to participate in our journeys or not.

Changes to this policy. We may change this Privacy Policy from time to time. We always indicate the date the last changes were published and we offer access to archived versions for your review. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

Executive Summary

1. Identity of Controller. The Controller is Talk2U LLC - 777 Brickell Ave Ste 1210, Miami, FL, 33131 and the Data Controller Officer can be reached at privacy@talk2u.org

2. Data Purpose: Talk2U conducts research on human behavior as well as impact measurements and performance analysis of our Products and/or Services. All data including Talkers Content is anonymized before use for research purposes. This research looks at how different activities on Digital platforms or Journeys impact people’s mental well-being and/or behavior. Talk2U may use Talkers Content and other data collected from You in accordance with the Agreement. Research and Content outcomes are key to helping Talkers make real change and progress in their lives.

3. Data Collection. Data collected will apply to one or more of the following legal basis: (i) consent, (ii) legitimate interest or (iii) contractual necessity, and it will be collected directly from you through the conversations with our journeys, or other online or offline activities you accept to participate in. Only specific data is automatically transferred to us from mainstream chat platforms you are signed in to, like name, phone number, user id and/ or time zone. We do not knowingly collect information about children under 18 (or applicable laws) without parent consent.

4. Data Usage. Your Data may be subject to the following process activities: (i) storage and other processing necessary to provide, maintain and improve the Service; (ii) to provide technical support to the user; (iii) create a dashboard with relevant information about experience and users demographics; (iv) and disclosures as required by law or otherwise set forth in the Agreement.

5. Data retention. We will not retain sensitive personal data or information for longer than is required for the purposes for which such information may be lawfully used or is otherwise required under any law for the time being in force.

6. Data rights. You have the right to access and review personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us at privacy@talk2u.org

7. Data transfers. Your personal data may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”) or the UK or Brazil, for example, when one of our service providers uses servers or equipment based outside the EEA or UK or Brazil.

Processing of your personal data​ through our journeys

If you choose to become a Talker, you will be asked to provide your phone number, an email address and your name, so we can identify you, process your payments and connect you to the service, as well as comply with potential requests to delete or access your data, offer you different opportunities to participate in our projects and access our new products and features. We won’t spam you or distribute your personal data to any third party for marketing purposes.

You can unsubscribe at any time and the personal data you’ve provided to become a Talker will be deleted and data that has not been processed to that point, will be deleted as well. However, all the data processed prior to that request and stored anonymously will be kept for research purposes.

In this case, all of the information kept will not be anonymized for contractual reasons so we are able to fulfill our obligations with you. When processing at scale, we will aggregate your information and no information provided will be made public in a way that it can be identifiable to you.

How do we collect data?

Most information we process is collected directly from you when you voluntarily initiate a conversation with our journeys or you subscribe to become a Talker and use our exclusive products as well as activities we invite you to participate in.

Other types of personal data may be obtained from third party companies and mainstream chat platforms we use to provide our services, like Meta or Telegram, which may include your name, phone number, user id, time zone or even behavior like date and time you’ve interacted with the Services.

This connection is necessary for the Services to function properly, and even though we might not store the data, we will always have the ability to retrieve the basic information stated before in accordance with your Privacy Settings on those third party platforms. Therefore Talk2U shall not be liable for data missed use at this stage and will not hold responsibility in safeguarding issues since there are third party actors involved in data management, such as the mainstream chat platforms.

However, to deliver better confidentiality practices, Talk2U will anonymize information in dashboards and reports to remove any traces of specific Talker information that can make it identifiable. Access is only granted on a need-to-know basis to those people whose roles require them to process your personal data and have access to identifiable personal information since access to these Talkers’ information is unavoidable when working within those platforms via their API and fanpages.

What type of data do we collect and to what purpose?

Talk2U shall process Data, depending on the topic, only for the following purposes:

• (i) to perform, create, develop, operate, deliver, maintain and improve products and services provided or made by Talk2U;

• (ii) to elaborate aggregate reports in order to provide effective digital tools for behavioral change and to recommend new public policies to address topics around well-being and mental health; and

• (iii) to communicate with you about new Services, products or special learning journeys

• (iv) to comply with Law accomplishment or enforcements

When you use the Services, we may collect and process different personal data about you. The personal data we process, the basis of processing and the purposes of processing are detailed below. Sometimes, these activities are carried out by third parties (see “Who does Talk2U share data with?” section below).

Unfortunately, due to the nature of our services, for the time being we can’t discriminate between data that can be collected and processed and some that can’t. So if you continue with the experience, all of this information will be processed.

Sensitive personal information. If you send or disclose any sensitive personal information to us (such as when you submit Talkers content to the Services or surveys, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership), you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not provide it. You may use your data protection rights to delete such sensitive personal information.

How is your personal data stored and secure?

Talk2U operates and uses appropriate technical and organizational security measures to protect your personal data. Data collections are stored respecting anonymity and confidentiality procedures in all available cases. TALK2U makes a great effort to keep your conversations private and secure by taking measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.

You are also responsible for protecting your personal data since all conversations might be stored in your devices and apps used from third party providers such as but not limited to Facebook Messenger, Whatsapp, Telegram or Instagram to mention a few. You should take all security measures to safeguard your credentials, passwords and username that allow you to access and login and might be subject to security breaches. Unfortunately, we cannot guarantee the security of the personal data you provide since no system is 100% secure, so we will make our fullest efforts but Talk2U will not be held liable for unintentional disclosure of your personal data.

Storage of personal data​

We will keep your personal data for as long as it is necessary to fulfill the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. Sometimes in accordance with academic procedures, data used to develop a paper is required to be saved for a certain period of time. If that information differs from the information we provided when you started your conversation in one of our journeys, we will update our privacy policy to inform you.

Who does Talk2U share your information with?

Talk2U does not share your information with third parties, except as provided below:

1. Universities and other partners exclusively for analyzing, evaluating and providing effective tools for behavioral change or reporting on topics to encourage public policies reference to burning issues. The results of the study do not contain your messages with Talk2U unless otherwise instructed by you. In all cases, unless expressed differently in the related privacy policy of the project you participate in, this information will be shared anonymously.
2. Service providers, such as IT providers involved in the development and maintenance of services provided and Cloud storage providers, such as Google, Vercel, Active Campaigns, Hubsport and Hotmart to name a few, to store the information you provide and visualize it in a fast and friendly way. They will be subject to contractual restrictions prohibiting them from using the personal data of our members for any other purpose,
3. Government, law enforcement officials or private parties as required by law. Talk2U may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
4. Entity acquiring or merging with Talk2U: in case of a merger or sale proposal of Talk2U by another entity, we may share information while a due diligence exercise is being carried out or during the transitional process, provided that the information disclosed continues to be used to the purpose permitted and consented by you by this Privacy Policy by the new entity acquiring the information.

What are your rights?

There are several rights you may be entitled to according to the data protection legislation in your country, which may be the following:

1. The right of access: enables you to check what type of personal data we hold about you, what we do with that personal data and, if needed, to receive a copy of this personal data; this right also allows you to:
   1. The right to rectification enables you to correct any inaccurate or incomplete personal data that we hold about you;
   2. The right to erasure enables you to request that we erase personal data held about you in certain circumstances; and
   3. The right to data portability enables you to receive your personal data in a structured, commonly used and machine readable format and to have that personal data transmitted to another data controller.
2. The right to be forgotten: states that data must be erased immediately after it is no longer needed for their original processing purpose or you have withdrawn consent
3. The right to be informed: as we are detailing in this privacy policy, we are providing as much information as possible in a friendly way for you to understand what we do with your data, why we do it and for how long.
4. The right to lodge a complaint with supervisory authorities: we will try as hard as we can to comply with your requests, but if you are still unhappy please let us know using our contact info. However, you also have the right to complain to your local Data Protection Authority if you prefer.

Note that we will require you to take steps to verify your identity in accordance with applicable law, and in cases where the data has already been processed, some rights might not be able to be applied to published documents. However, these studies will maintain anonymization.

Unfortunately, our journeys do not have the possibility of selecting which information is saved or not. It’s an all or nothing condition. So we may not comply with the right to restrict processing of your personal data. But you can opt out of the whole experience and request an erasure.

If you wish to exercise any of the above rights, please contact us (see “Identity of the controller of personal information​” below).

Third parties’ compliance with law regulations

Since our Journeys and other Products and Services are hosted in third party mainstream chat platforms, you shall be bound by their Terms and Conditions, Privacy Policy, Cookies Policy and any updates on the fine print of that Platform given that you must have an account to be able to access the bot. Some of your rights must be explicitly executed by all parties.

Even if we eliminate your data from our databases, this does not mean that the conversation taking place within that platform will be erased on your end, unless you do it yourself.

However, please note that even if you eliminate it on your end, it does not mean that we cease to have access to it since we might have a copy on our own servers or information might have been transferred to one of our partners. So please, remember to send us your request in a timely manner to privacy@talk2u.org

#Children’s information​

Our Journeys, Products and Services are not targeted to children under 18 (or other age as required by local law), and we do not knowingly collect personal data from children. If you learn that your child has provided us with personal data without your consent, you may contact us as set forth below. If we learn that we have collected any personal data in violation of applicable law, we will promptly take steps to delete such personal data and terminate the child’s account.

Transfer outside the European Economic area/UK​ and Brazil

Your personal data may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”) or the UK or Brazil, for example, when one of our service providers uses servers or equipment based outside the EEA or UK or Brazil.

We are also a 100% remote company which allows our team to work everywhere in the world, but we take organizational measures like encryption of databases and confidential mode on emails to safeguard your privacy, fundamental rights and freedom, and also exercise your rights.

Identity of the controller of personal information​

In some journeys, controllers may be third parties, such as a University performing research on a certain topic and we will act as processors. This information will be available on the specific privacy policy of each experience which will be subject to your acceptance prior engaging in conversation with the Special Learning Journey.

The Controller for Movimiento Talkers is Talk2U LLC - 777 Brickell Ave Ste 1210, Miami, FL, 33131 and the Data Controller Officer, Lucila Suarez Battan, can be reached at privacy@talk2u.org

1. October 2021