This privacy policy includes the provisions set forth herein and the Data Protection Agreement (available to view in Section 11) ("Privacy Policy") are designed to inform you of the policies and procedures that will apply to the collection, security, use and disclosure of any of your Personal Data (defined below) collected by Curebit, Inc. dba Talkable ("Talkable", "we", "us", or "our") through Talkable.com ("Site") or in connection with our products and services ("Services"). It also describes your choices regarding use, access and correction of your Personal Data. Please contact us with any questions you have about this Privacy Policy at: security@talkable.com
1. Changes to This Privacy Policy
We may modify this Privacy Policy from time to time to reflect changes to our information practices, so check back frequently. Any changes to this Privacy Policy will be posted on this page, and where appropriate (for example, if there are material changes to this policy), we will notify you by e-mail or by means of a notice on our home page prior to the changes taking effect.
2. Information We Collect from You
2.1. Overview. Our primary goals are to provide and improve our products and services, to provide quality customer service, to respond to your inquiries, and to enable users to effectively navigate the Site. We may collect Personal Data and Non-Personal Data about you and process the same as set forth herein.
Personal Data means data that allows someone to identify or contact you, including, for example, your first and last name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
- Identity Data - first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data - billing address, delivery address, email address and telephone numbers.
- Financial Data - bank account and payment card details.
- Transaction Data - details about payments and other transaction details.
- Technical Data - IP address, login data, browser type and version, time zone, operating system and platform.
- Profile Data - your username and password, requests, interests, preferences, and feedback.
- Usage Data - information about how you use our Site and Services.
- Marketing and Communications Data - your preferences in receiving marketing from us.
2.2 Merchant Data, Authorized User Data, and Visitor Data
Talkable provides its clients (each, a "Merchant") with tools and features to better manage their end-users' experience, including the Talkable Referral Program, Conversion Program, and Loyalty Program.
- Merchant Data - Personal Data collected and managed on Merchants' behalf as part of the Talkable Programs.
- Authorized User Data - Personal Data relating to Merchants and their authorized users.
- Visitor Data - data relating to visitors of the Site.
3. How Do We Use Your Personal Data?
We will use your Personal Data to carry out our obligations, provide you with Services, notify you about changes, improve the Services, and contact you with marketing materials (with opt-out available via support@talkable.com).
4. Purposes for Which We Will Use Your Personal Data
We process your Personal Data for subscription administration, carrying out Services, customer service, site maintenance, communications, analytics, and recommendations. Legal bases include performance of our agreement, compliance with legal obligations, and legitimate interests.
5. Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible reason. If we need to use it for an unrelated purpose, we will notify you and explain the legal basis.
6. Non-Personal Data We Collect
We collect Log Data (browser type, ISP, pages visited, clickstream data), IP addresses, and use Cookies, Web Beacons, Pixel Tags, Flash LSOs, and Google Analytics to analyze site usage and improve our Services.
7. Aggregated Data
After removing personally identifying information, we may combine data from multiple users for industry analysis, demographic profiling, and other purposes.
8. Your Choices
You can access and correct your Personal Data by contacting support@talkable.com. You can request deletion of your data, and we will comply within 30 days. You may opt out of Google Analytics and Google AdWords remarketing, and disable cookies in your browser.
9. Information Sharing & Disclosure
We may share data with Service Providers who perform tasks on our behalf (see our Subprocessors list). We may disclose data for legal compliance, law enforcement, business transfers, and to affiliates.
10. California Privacy Rights
California residents: please review our California Privacy Notice for information on how we collect, use, and disclose your Personal Information under the CCPA and CPRA.
11. International Transfers & Data Processing Agreement
Information collected in the EEA may be transferred to the US and other countries. We use EU standard contractual clauses to ensure adequate protection. You can download our Data Processing Agreement.
12. Your Rights
You have the right to request access, correction, erasure, restriction, transfer of your Personal Data, and to withdraw consent. Contact support@talkable.com to exercise these rights.
13-14. Additional Information & Dispute Resolution
No fee is usually required for data access requests. We aim to respond within one month. EU residents may contact their Data Protection Authority for dispute resolution.
15-22. Security, Data Retention & Contact
We maintain appropriate organizational and technical measures to protect your data. We retain Personal Data only as long as necessary. Our Site is not directed to children under 16.
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