Privacy policy

last updated May 20th, 2021

This Privacy Policy explains how Howtotalk (“Howtotalk”, “we” or “us”) collects, uses, and discloses information about you when you access or use our websites, mobile application, and other online products and services (collectively, the “Services”), and when you contact our customer service team, engage with us on social media, or otherwise interact with us. This policy does not apply to information we process on behalf of our enterprise business customers.

We may change this Privacy Policy from time to time. If we make

changes, we will notify you by revising the date at the top of the

policy 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 the

Privacy Policy whenever you access the Services or otherwise

interact with us to stay informed about our information practices

and the choices available to you.

Collection of Information

Information You Provide to Us

We collect information when you register for an account,

participate in interactive features, fill out a form or a survey,

participate in a contest or promotion, make a purchase,

communicate with us via social media sites, request customer

support, or otherwise communicate with us. The information you

may provide includes your name, email, password, goals, street

address, payment method information, feedback and survey

responses, and other information about you included within your

messages to us.

Other Information About Your Use of the Services

When you use our Services, we collect the following information

about you:

Usage Information: Whenever you use our Services, we

collect usage information, such as the sessions you use,

videos you view or what screens or features you access, and

other similar types of usage information.

Transactional Information: When you make a purchase or

return, we collect information about the transaction, such as

product description, price, subscription or free trial

expiration date, and time and date of the transaction.

Log Information: We collect standard log files when you use

our Services, which include the type of web browser you

use, app version, access times and dates, pages viewed,

your IP address, and the page you visited before navigating

to our websites.

Device Information: We collect information about the

computer or mobile device you use to access our Services,

including the hardware model, operating system and

version, device identifiers set by your device operating

system, and mobile network information (like your

connection type, carrier and region).

Information we Record: On some occasions, we may record

phone or video calls with your consent, such as in

connection with our coaching program.

Information we Generate: We generate some information

about you based on other information we have collected. For

example, like most platforms, we use your IP address to

derive the approximate location of your device. We also use

your first name to make an educated guess about your

gender and use information about your activity to help

determine the likelihood of you continuing to use our

Services in the future (which we hope will be the case!).

Information We Collect from Other Sources

We also obtain information about you from other sources,

including transaction information from third-party app stores you

use to install our app or purchase a subscription, and name and

contact information from third-party calendar services.

Additionally, if you create or log into your account through a

social media service account, we will have access to certain

information from that account, such as your name and other

account information, in accordance with the authorization

procedures set by that social media service.

Use of Information

We use the information we collect to:


Provide, maintain and improve our Services, including

debugging to identify and repair errors, and develop new

products and service;

Process transactions and fulfill orders;

Send you transactional or relationship messages, such as

receipts, account notifications, customer service responses,

and other administrative messages;

Communicate with you about products, services, and events

offered by Howtotalk and others, request feedback, and

send news, gifts or other information we think will be of

interest to you;

Monitor and analyze trends, usage, and activities in

connection with our Services;

Detect, investigate and prevent fraudulent transactions and

other illegal activities and protect the rights and property of

Howtotalk and others, including to enforce our agreements

and policies. If you feel your transaction was declined in

error, please contact us for assistance at

support@howtotalk.com

Comply with the law, such as by processing transactional

records for tax filings and other compliance activities;


Personalize your online experience and the advertisements

you see on other platforms based on your preferences,

interests, and browsing behavior;

Facilitate contests, sweepstakes, and promotions and

process and deliver entries and rewards.

Sharing of Information

We share information about you as follows and as otherwise

described in this Privacy Policy:

With companies and contractors that perform services for

us, including email service providers, payment processors,

fraud prevention vendors and other service providers;


In response to a request for information if we believe

disclosure is in accordance with, or required by, any

applicable law or legal process, including court order,

subpoena, or other lawful requests by public authorities to

meet national security or law enforcement requirements;


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

Howtotalk or others;

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;

Between and among Howtotalk and our current and future

parents, affiliates, subsidiaries, and other companies under

common control and ownership;

With your consent or at your direction. For instance, you

may choose to share actions you take on our Services with

third-party social media services via the integrated tools we

provide via our Services.

We also share aggregated or other information not subject to

obligations under the data protection laws of your jurisdiction with

third parties. For example, we sometimes share aggregate

information with research organizations to help facilitate their

research.

Advertising and Analytics Services Provided by


Others

We allow others to provide analytics services and serve

advertisements on our behalf across the web and in mobile

applications. These entities use cookies, web beacons, device

identifiers and other technologies to collect information about

your use of the Services and other websites and online services,

including your IP address, device identifiers, web browser, mobile

network information, pages viewed, time spent on pages or in

apps, links clicked, and conversion information. This information

may be used by Howtotalk and others to, among other things,

analyze and track data, determine the popularity of certain

content, deliver advertising and content targeted to your interests

on our Services and other websites and online services, and

better understand your online activity. For more information

about interest-based ads, including to use ad industry tools to opt

out of having your web browsing information used for behavioral

advertising purposes, please visit

www.aboutads.info/choices

(if you are in the EU, please visit

www.youronlinechoices.eu/). Your

mobile device should also include a feature that allows you to opt

out of having certain information collected through apps used for

behavioral advertising purposes.


Data Transfer

Howtotalk is based in the Netherlands and processes information

in the Netherlands, which may not provide equivalent levels of

data protection as your home jurisdiction.


Your Choices

Account Information

You may update certain account information you provide to us

(such as your password, name and email address) by logging into

your account or contacting us through our Help Center at

support@howtotalk.com

If you wish to disable your account, please

contact us at

support@howtotalk.com

, but note that we retain

certain information when required or permitted by law. We also

retain cached or archived copies of information about you for a

certain period of time.

Promotional Communications

You may opt out of receiving promotional emails from Howtotalk

by following the instructions in those emails or by logging into

your account. If you opt out, we may still send you non-

promotional emails, such as those about your account or our

ongoing business relations

Mobile Push Notifications/Alerts

With your consent, we send promotional and other push

notifications to your mobile device. You can deactivate these

messages at any time by changing the notification settings on

your mobile device.

Information for Individuals in Switzerland, UK and

the EEA

The sections below apply to you if you use our Services while in

Switzerland, the United Kingdom or the European Economic Area

(collectively, “Europe”).

Legal Basis for Processing

When we process your personal data we will only do so in the

following situations:

As necessary to perform our responsibilities under our

contract with you (like processing payments and providing

the products or services you have requested);

When we have a legitimate interest in processing your

personal data, including to communicate with you about

changes to our Services, to help secure and improve our

Services (including to prevent fraud) and to analyze use of

our Services;

As necessary to comply with our legal obligations; and

When we have your consent to do so.

Data Retention

We retain personal data for no longer than is necessary for the

purposes for which it is processed, unless applicable law requires

storage for a longer period of time.

Data Subject Requests

Subject to certain limits and conditions provided under law, you

have the following rights:

You have the right to access personal data we hold about

you and to ask that your personal data be corrected, erased,

or made available in a portable form.

You also have the right to object to certain processing (like

receiving direct marketing), or request that we restrict

processing in certain circumstances (like to retain but not

further process pending resolution of a claim).

When we ask for your consent, you may withdraw that

consent at any time.

You have the right to file a complaint regarding our data

protection practices with a supervisory authority. Please see

this directory for contact details:

https://edpb.europa.eu/about-edpb/board/members_en

. If

you are in Switzerland, please visit this FDPIC site for contact

details:

https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

If you are in the United Kingdom, please

see this site for contact details:

https://ico.org.uk/global/contact-us/

If you would like to exercise any of these rights and can’t do so

directly via the Services or your device, you may contact us as

indicated below.

Information for California Residents

This section provides additional disclosures required by the

California Consumer Privacy Act (or “CCPA”).

Please see the chart below for a list of the personal information

we have collected about California consumers in the last 12

months, along with our business and commercial purposes and

categories of third parties with whom this information may be

shared. For more details about the personal information we

collect, including the categories of sources, please see the

“Collection of Information”

section above

.

Categories of personal information we collect

Identifiers , such as your name, phone number, email address,

social media handle, and unique identifiers (like IP address) tied

to your browser or device. Characteristics of protected

classifications under state or federal law , such as gender and

age. Commercial information , such as your payment information

and Howtotalk product or service purchases. Approximate

geolocation data. Internet or other electronic network activity,

such as browsing behavior and information about your usage and

interactions with our Services. Audio, electronic, visual, or similar

information , such as profile photo or personal information you

may provide during customer support calls and call recordings.

Other personal information you provide , including opinions,

preferences, goals and previous meditation experience and other

personal information contained in product reviews, surveys, or

communications. Inferences drawn from the above, such as

product interests, and purchasing insights.

Business or commercial purposes for which we may use your

information

Performing or providing our services, such as to maintain

accounts, provide customer service, process orders and

transactions, and verify customer information. Improving and

maintaining our Services, such asby improving our Services and

developing new products and services. Debugging , such asto

identify and repair errors and other functionality issues.


Communicate with you about marketing and other relationship or

transactional messages. Analyze usage , such as by monitoring

trends and activities in connection with use of our Services.


Personalize your online experience , such as by tailoring the

content and ads you see on our Services and on other platforms

based on your preferences, interests, and browsing behavior.


Legal reasons, such as to helpdetect and protect against security

incidents, or other malicious, deceptive, fraudulent, or illegal

activity.

Parties with whom information may be shared

Companies that provide services to us , such as those that assist

us with customer support, subscription and order fulfillment,

advertising measurement, communications and surveys, data

analytics, fraud prevention, cloud storage, bug fix management

and logging, and payment processing. Third parties with whom

you consent to sharing your information , such as with social

media services or academic researchers. Our advertisers and

marketing partners, such as partners that help determine the

popularity of content, deliver advertising and content targeted to

your interests, and assist in better understanding your online

activity. Government entities or other third parties for legal

reasons, such as to comply with law or for other legal reasons as

described in our

Sharing section

.

Subject to certain limitations and exceptions, the CCPA provides

California consumers the right to request to know more details

about the categories and specific pieces of personal information,

to delete their personal information, to opt out of any “sales” that

may be occurring, and to not be discriminated against for

exercising these rights.

We do not “sell” the personal information we collect (and will not

sell it in the future without providing a right to opt out). We do

allow our advertising partners to collect certain device identifiers

and electronic network activity via our Services to show ads that

are targeted to your interests on other platforms.

California consumers may make a rights request by emailing us at

support@howtotalk.com

We will verify your request by asking you

to provide information that matches information we have on file

about you. Consumers can also designate an authorized agent to

exercise these rights on their behalf. Authorized agents should

submit requests through the same channels, but we will require

proof that the person is authorized to act on your behalf and may

also still ask you to verify your identity with us directly.

Notice of Financial Incentives: We offer various financial

incentives. For example, we may provide incentives to customers

who participate in a survey or provide testimonials. When you

participate in a financial incentive, we collect personal information

from you, such as identifiers (like your name and email address)

and information about your experiences using our Services. You

can opt into a financial incentive by following the sign-up or

participation instructions provided. In some cases, we may

provide additional terms and conditions for a financial incentive,

which we will provide to you when you sign up. The value of your

personal information is reasonably related to the value of the

offer or discount presented to you.

Howtotalk strives to make this privacy policy accessible in line

with the World Wide Web Consortium’s Web Content Accessibility

Guidelines, version 2.1.

Contact Us

If you have any questions about this Privacy Policy, please contact

us at: info@howtotalk.com

If you are in Europe, you may contact our representative at:

EEA : Happarandaweg 67, B7, 1013B Amsterdam