smallTalk Privacy Policy
Last Updated: June 24, 2021
Your privacy is important to us at Thrive Neuromedical, LLC. Please read this Privacy Policy (the “Policy”) carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information, as well as any rights you may have with respect to such information. This Policy applies to our offerings (collectively, the “Services”), including but not limited to our Website(s) (https://www.smalltalk.tech), our App(s) (smallTalk), and our Products (smallTalk Connect, the smallTalk Egg), and information collected via:
The Services; and
In email and other electronic messages between you and the Services.
This Policy does not apply:
To information collected by any third party including any application, website, service, or content that may linked to or be accessible from our Services; or
Where a particular part of the Services posts its own privacy policy, in which case that policy, not this Policy, applies when inconsistent.
By using or accessing our Services, or by providing your information to us, you agree that we may process your personal information in the manner described in this Policy.
Index:
Key Terms
Personal Information We Collect About You
How your Personal Information is Collected
How and Why we use your Personal Information
Promotional Communications
Who we Share your Personal Information With
Where your Personal Information is Held
How Long your Personal Information Will be Kept
Your Rights Under the CCPA
Children’s Privacy
Keeping Your Personal Information Secure
Changes to this Privacy Notice
How to Contact Us
Key Terms. Here are several key terms used in this Policy:
We, us, our | Thrive Neuromedical, LLC, d/b/a/ smallTalk
User, customer, you, and your | Individuals about whom we may collect personal information.
Personal information | Any information relating to an identified or identifiable individual or user of our Services.
2. Personal Information We Collect About You. Personal Information is required to provide our Services to you. We may collect and use the following Personal Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Categories of Personal Information & Specific Types of Personal Information
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
Name, email address, user credentials, and postal address
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information
Name, email address, user credentials, phone number, and payment information
Characteristics of protected classifications under California or federal law (e.g. Age, race, national origin or citizenship, veteran or military status)
None
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)Services purchased and accessed, and purchase history
Biometric information
Voice
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
IP addresses, information from devices used to access the Services, and activity on the Services.Geolocation data
None
Professional or employment-related information (e.g. current or past job history or performance evaluations)
None
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
None
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
We track user and visitor information and behavior on our Services to understand overall usage patterns for the Services
3. How Your Personal Information is Collected. We collect most of this Personal Information directly from you—via our Services. However, we may also collect information:
From publicly accessible sources (e.g., IP and publically available routing information);
From a third party with your consent (e.g., your credit card provider);
From cookies our website and other methods to include third party tools such as Google Analytics; and
Via our IT systems, including: Automated monitoring of our Services, such as our computer networks and connections, communications systems, email and instant messaging systems.
4. How and Why We Use Your Personal Information. Under certain data protection laws, we can only use your Personal Information if we have a proper reason for doing so, for example:
To comply with our legal and regulatory obligations;
For the provision of our Services to you or to take steps at your request;
Where you have given consent; or
For our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your Personal Information for and our reasons for doing so:
What we use your personal information for & Our reasons
To provide our Services to you
For the provision of our Services to you, and to improve our Services
To prevent and detect fraud against you or us
For our legitimate interests or those of a third party (i.e. to minimize fraud)
Conducting checks to identify our customers and verify their identity
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, (e.g. policies covering security)
For our legitimate interests or those of a third party (i.e. to ensure we are following our own internal procedures so we can deliver our best Services to you)
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party (i.e. to be as efficient as we can so we can deliver our best Services for you at the best price)
Statistical analysis to help us manage our business (e.g. in relation to our financial performance, customer base, products or other efficiency measures)
For our legitimate interests or those of a third party (i.e. to be as efficient as we can so we can deliver the best Services for you at the best price)
Preventing unauthorized access and modifications to systems
For our legitimate interests or those of a third party (i.e. to prevent and detect criminal activity that could be damaging for us and for you), To comply with our legal and regulatory obligations
Updating customer records
For the provision of our Services to you, To comply with our legal and regulatory obligations, For our legitimate interests (e.g. making sure that we can keep in touch with our customers about existing orders and new products)
Ensuring safe working practices, staff administration and assessments
To comply with our legal and regulatory obligations. For our legitimate interests (e.g. to ensure we are following our internal procedures and working efficiently so we can deliver our best Services to you)
Marketing our Services
For our legitimate interests or those of a third party (i.e. to promote our business to existing and former customers)External audits and quality checks (e.g. for ISO or the audit of our accounts)
For our legitimate interests or a those of a third party (i.e. to maintain our accreditations so we can demonstrate we operate according to applicable standards). To comply with our legal and regulatory obligations
5. Promotional Communications. We may use your Personal Information to send you updates about our Services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your Personal Information for promotional purposes (see above “How and why we use your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your Personal Information with the utmost respect and never sell it to other organizations. We may share certain non-personal summary information regarding customers with affiliates or other third parties.
You have the right to opt out of receiving promotional communications at any time by:
Contacting us using the details below; or
By using the “unsubscribe” link in emails or “STOP” number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further Services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. Who We Share Your Personal Information With. We do not sell your Personal Information. We will not share your personal information except as listed in Section 4. Any Personal Information so shared shall be used only to perform or complete necessary transactions or functions related to provision of our Services. To the extent our Services are hosted or accessed through a third party (e.g. using a mobile device) which collects Personal Information, then that third party’s privacy policy, not this Policy, will apply. We may routinely share Personal Information with trusted third parties, including:
Service providers we use to help deliver our Services to you, such as payment service providers, and storage providers to include Amazon Web Services;
Other third parties we use to help us run our business, such as marketing and sales platforms or providers; and
Third parties approved by you, including when you create and provide your own recordings to be played through your smallTalk device or within your own mobile device. These recordings are kept private to you unless you specifically request for your recording to be made available to another user, such as a friend of family member.
7. Where Your Personal Information is Held. Information may be held at our offices, and as described in Section 6 (see above: “Who We Share Your Personal Information With).
8. How Long Your Personal Information Will Be Kept. Personal Information is stored as long as you use our Services. Once you decide to stop using our Services, we can completely remove the account from our database. However, we will keep your personal information for as long as is reasonable:
To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.
9. Your Rights Under the CCPA. California residents have specific rights under the California Consumer Privacy Act (“CCPA”) with respect to processing of their Personal Information. Section 2 of this Policy lists the categories of information that we processed or used for a business purpose in the last 12 months. Subject to exceptions, you may request deletion of your Personal Information or disclosure by using the contact details provided below.
However, we can only respond to verifiable request received from individuals who desire to exercise their rights in accordance with applicable law. When contacting us, you will need to provide sufficiently detailed information about the Personal Information you are requesting that we update, correct, amend, or remove, to include the timeframe and manner you believe we collected your Personal Information. If the information was obtained via a customer or third party acting on your behalf, you will need to contact the individual or entity you provided your information to.
10. Children’s Privacy. You must be at least (18) years of age to register for and use our Services. We do not offer our Services for use by children absent parental consent. If you are under the age of (18), do not provide any Personal Information to us without parental consent. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it.
11. Keeping Your Personal Information Secure. The App and the smallTalk egg, are required to be on the same network. The smallTalk Egg has several layers of security in place, starting with your WiFi network, your smallTalk account, our internal security protocols, etc. Access must be expressly granted to your WiFi network and to your smallTalk Egg in order to use the audio speaker.
Additionally, we will maintain appropriate administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of our Services and related data However, no security measures are perfect or impenetrable, and we cannot guarantee the security of your Personal Information transmitted to or through our Services. We limit access to your Personal Information to those who have a genuine business need to access it. However, it is also your responsible to maintain the confidentiality and security of your credentials.
12. Changes to This Privacy Notice. We may change this privacy notice from time to time to reflect changes to our information practices. If we make significant or material changes to how we use Personal Information, we will notify you by email if feasible or by means of a notice on our Services. We encourage you to periodically check this page for the most up-to-date information on our information practices.
13. How to Contact Us. Please contact us if you have any questions about this Policy or the information we hold about you.
Our contact details are shown below:
Thrive Neuromedical, LLC
1275 Kinnear Rd.
Columbus OH 43212
support@smalltalk.tech