TALKOOT PRIVACY NOTICE
Last updated [March 8, 2021]

Thank you for choosing to be part of our community at Talkoot, Inc. (“Company”, “we”, “us”, “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice (“Privacy Notice”), or our practices with regards to your personal information, please contact us at anna@talkoot.com.

This Privacy Notice applies to information we collect from or about you when you visit our website http://www.talkoot.com (the “Website”), and more generally, when you use [our mobile application], or any of our other online services (the “Services”, which include the Website), [contact our customer service team, engage with us on social media,] attend one of our marketing events, or otherwise interact with us. This Privacy Notice does not apply to aggregated or de-identified information that cannot reasonably be used to identify you. We take your privacy very seriously. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Notice that you do not agree with, please discontinue use of our Services immediately.

We may change this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Notice and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review this Privacy Notice regularly to stay informed about our information practices and the choices available to you. 

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WHO WILL YOUR INFORMATION BE SHARED WITH?

4. ADVERTISING AND ANALYTICS

5. TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

6. YOUR CHOICES

7. ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. CALIFORNIA PRIVACY RIGHTS

10. DO WE COLLECT INFORMATION FROM MINORS?

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?


1. WHAT INFORMATION DO WE COLLECT

Personal information you disclose to us

In Short:  We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; and other similar information.

Information automatically collected

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

·       Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

·       Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You may stop the collection of location information at any time (see Your Choices below for details). Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

·       Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

In Short:  We may collect information about you from third-parties.

We may also obtain information about you from other sources. For example, if you create or log into your Talkoot account through a third-party platform or social network, we will have access to certain information from that site, such as your name, birthday and profile picture, in accordance with the authorization procedures determined by such third-party platform.

Information We Derive

In Short:  We may derive information from the information collected about you.

We may derive information or draw inferences about you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

2. HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

 

·       Request feedback. We may use your information to request feedback and to contact you about your use of our Website.

 

·       To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.

 

·       To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

 

·       To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

 

·       To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).

 

·       To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

 

·       To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

 

·       Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.

 

·       Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

 

·       To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).

 

·       Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information, see the Advertising and Analytics section below.

 

3. WHO WILL YOUR INFORMATION  BE SHARED WITH?    

In Short:  We only share information with the following third parties. 

We only share and disclose your information with the following third parties or as otherwise set forth in this Privacy Notice: ””

 

·       Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

 

·       Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time.

 

·       Required by Law. If we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;

 

·       Enforce our Rights. If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Talkoot, our users, the public, or others;

 

·       Advisors. With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;

 

·       Business Transfers. In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

 

·       Affiliates. Between and among Talkoot and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and

 

·       Consent. With your consent or at your direction.

 

4. ADVERTISING AND ANALYTICS

In Short:  We use and allow others to use your information for analytics [and to provide targeted advertising]. 

We allow others to provide analytics services on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Talkoot and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

5. TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES 

Talkoot is headquartered in the United States and we have operations and service providers in the United States. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

6. YOUR CHOICES

In Short:  We offer you choices with respect to your data as set forth below:

Location Information 

When you first launch our Services on a website browser that collects precise location information, you will be asked to consent to our collection of this information. If you initially consent to our collection of this location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, some of our Services may no longer function properly.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of some of our Services. You may refuse to accept cookies from the Services at any time by activating the setting on your browser which allows you to refuse cookies. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen. You may wish to refer to http://www.allaboutcookies.org… for information on commonly used browsers.

Promotional Communications

You may opt out of receiving promotional emails or text messages from Talkoot by following the instructions in those communications or by managing your communication preferences in your account settings menu. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.


7. ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area, the United Kingdom or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

In Short:  We process or share your data that we hold based on the following legal basis:

·       Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

 

·       Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

 

·       Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

 

·       Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

 

·       Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.


DATA RETENTION

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

DATA SUBJECT REQUESTS

In Short:  In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/da….


If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. 

If you have questions or comments about your privacy rights, you may email us at anna@talkoot.com.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our Services do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

9. CALIFORNIA PRIVACY RIGHTS

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below

””“”“”’”“”“’”“

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age. 

The Services are not intended for use by anyone under 18 years of age and we do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?    

If you have questions or comments about this notice, you may email us at anna@talkoot.com or by writing us at:

Talkoot, Inc.

1001 SE Water Ave

Portland, OR 97214-2147

United States

Talkoot helps  brands tell brand-right, shopper-friendly product stories at scale.  Faster. Together.

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