PRIVACY POLICY

Last updated February 28, 2022

Welcome to Smalltalk! This Privacy Policy describes how Smalltalk (“Smalltalk”,“we”, “our”, or “us”) collects, uses, and shares personal information when you access and use the Smalltalk website and the services offered thereon (the “Services”). 

INFORMATION COLLECTION AND USE

Information collected from you

Smalltalk will collect and use your personal information in the following instances:

• To join Smalltalk, we collect your mobile telephone number to text you a code to join the Services. Once your profile is created, your mobile telephone number will be used for account verification purposes and for payment receipts. You can opt-out of text messages at any time by replying STOP to any text message from Smalltalk. When you opt-out, you will receive communications necessary to the Services to your email address. 

• Upon your first login, we will collect your name, email address, and profile picture to create your Smalltalk profile. We also use this personal information to communicate with you and facilitate your access to the Services. 

• To purchase access to a Smalltalk room or to add funds to your profile, we collect your payment card number, CVV, and expiration date. Please note our payment processor collects this payment information directly on our behalf and Smalltalk only maintains historical payment information.

• You can withdraw your Smalltalk earnings from your profile at any time. You can withdraw these earnings through Venmo (with your telephone number), PayPal (with your email address), or ACH (with your bank account number and routing number).  

• Smalltalk may use your email address to send you marketing communications we feel may be of interest to you. You can opt-out of these emails at any time by clicking the ‘unsubscribe’ link provided with each email. Please note that we will continue to send you emails necessary to Smalltalk or any assistance you request.

• Smalltalk may use your personal information collected in limited circumstances described in INFORMATION SHARING.

Cookies

In addition to the personal information you provide, we also collect information automatically via cookies as you use the Services. This personal information includes:

• Information about your interaction with the Services, such as pages visited, frequency of access, time spent on each page, and referring website details. 

• Information about your location, which may be determined by your IP address. 

• Information about the device you use to access the Services, such as model, operating system, browser, and your preferences.

To collect this information, the Services utilize essential, functional, and first-party analytics cookies. Cookies are small pieces of text sent by your browser to your device. The cookies on our Services are utilized to: (i) enable the Services to function properly; (ii) identify user sessions and authenticate users; (iii) prevent fraudulent use of the Services; (iv) provide enhanced functionality and personalization; (v) diagnose and repair errors, and in cases of abuse, track and mitigate the abuse; and (vi) conduct analytics to improve the Services and user experience. 

Essential cookies cannot be disabled. In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent. When you opt-out an opt-out cookie will be placed on your device. The opt-out cookie is browser and device specific and will only last until cookies are cleared from your browser or device.

INFORMATION SHARING

Smalltalk will share your personal information in the following instances:

• Google API Limited Use Disclosure

• Your personal information is shared within Smalltalk in order to efficiently carry out and improve our business and to the extent permitted by law. 

• If you accept a Smalltalk room invite, your name, email address, and telephone number will be shared with the room host. 

• Your personal information is shared with service providers that assist us in providing the Services. These service providers include our IT support, payment processor, and email vendor. 

• In the event that we enter into, or intend to enter into, a transaction that alters the structure of our organization, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our assets, we would share your personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would also share your personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.

• We will share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights; as required to enforce our terms of use or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.

CORRECT OR VIEW YOUR PERSONAL INFORMATION

You may access your Smalltalk profile to correct or view certain personal information of yours in our possession and which is associated with your profile. 

NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of certain of your personal information. To submit a request to opt-out, contact us at privacy@imonsmalltalk.com. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

DO NOT TRACK

The Services do not support Do Not Track (DNT). 

INFORMATION SECURITY 

We implement and maintain reasonable security measures to protect the personal information we collect and maintain. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the information we have collected from you.  

AGE RESTRICTION

The Services are not intended for individuals under the age of eighteen (18). 

CHANGES 

We may change this Privacy Policy from time to time. We will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If we make changes that materially affect your privacy rights, we will notify you with a prominent post on the Services and/or via email and obtain your consent, if required.

CONTACT

If you have any questions about this Privacy Policy, please contact us at privacy@imonsmalltalk.com.