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
(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