Politique de confidentialité

Last Updated: November 8, 2023

Your privacy is important to us. This privacy statement explains our collection, use, and disclosure of personal data.  This privacy statement applies to POCKETALK CORPORATION and to our controlled affiliates and subsidiaries (“POCKETALK”). References to our “services” in this statement include our customer-facing websites, apps, devices, and other products. This statement applies to our services that display or reference this statement, but it does not apply to any services that display or reference a different privacy statement.

In some cases, in providing those services, we process personal data of consumers or end-users at the direction of our enterprise customers. When we do, we do so as a service provider or a “data processor” to those organizations, but we do not control and are not responsible for the privacy practices of those organizations. This privacy statement does not apply to personal data we process as a service provider or data processor on behalf of our enterprise customers. If you are a consumer or end-user of one of those organizations, you should read that organization’s privacy statement and direct any privacy inquiries to that organization.

PERSONAL DATA WE COLLECT

The personal data we collect depends on how you interact with us, the services you use, and the choices you make.

We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, information from third-party data sources, and data we infer or generate from other data.

Information you provide directly. We collect personal data you provide to us. For example:

• Name and contact information. We collect name, username or alias, and contact details such as email address, postal address, and phone number.
• Demographic data. In some cases, we request that you provide age, gender, and similar demographic details.
• Payment information. If you make a purchase or other financial transaction, we collect payment information.  We do not store credit card information in our own environment. We store and process it in a secure processor environment (e.g. Stripe).
• Content and files. We collect the photos, documents, text and speech or other files you upload to our services; and if you send us email messages or other communications, we collect and retain those communications.
• Sensitive Personal Information.
  • Account access information. We collect information such as a username or account number in combination with a password, security, or access code, or other credential that allows access to an account.

Information we collect automatically. When you use our services, we collect some information automatically. For example:

• Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including Wi-Fi access point information, mobile communications base station information, type, version, language, settings, and configuration. We also collect the terminal identification number and communication identification number of our products. As further described in the “Cookies, Mobile IDs, and Similar Technologies” section below, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.
• Usage data. We automatically log your activity on our websites, apps, and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.

Information we create or generate. We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address, and we may infer what language you are speaking for the purposes of translation and assigning an appropriate translation engine.

Information we obtain from third-party sources. We also obtain the types of information described above from third parties. These third-party sources include, for example:

• Third-party partners. Third-party applications and services, including social networks you choose to connect with or interact with through our services.
• Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.
• Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
• Publicly available sources. Public sources of information such as open government databases.

When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

COOKIES, MOBILE IDs, AND SIMILAR TECHNOLOGIES

We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our websites and online services and to help collect data, including usage data, identifiers, and device information.

What are cookies and similar technologies?

Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our email messages or newsletters to tell us if you open and act on them.

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables us and our third-party analytics and advertising partners to access these mobile IDs.

How do we and our partners use cookies and similar technologies?

We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal data (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information) when you use our services, including personal data about your online activities over time and across different websites or online services. This data is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, deliver and tailor interest-based advertising combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the data we collect or infer with third parties for these purposes. For more information about the third-party analytics and advertising partners that collect personal information on our services, please see the “Our Disclosure of Personal Data” section of this statement.

 

OUR USE OF PERSONAL DATA

We use the personal data we collect for purposes described in this privacy statement or as otherwise disclosed to you. For example, we use personal data for the following purposes:

Purposes of Use	Categories of Personal Data
Product and service delivery. To provide and deliver our services, including troubleshooting, improving, and personalizing those services.	Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences. Sensitive Information: account access information.
Business operations. To operate our business, such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.	Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences. Sensitive Information: account access information.
Product improvement, development, and research. To develop new services or features, and conduct research.	Contact information demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences. Sensitive Information: account access information.
Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services.	Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences. Sensitive Information: account access information.
Customer support. To provide customer support and respond to your questions.	Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences. Sensitive Information: account access information.
Communications. To send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.	Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences. Sensitive Information: account access information.
Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners (see the “Choice and Control” section of this statement for information about how to change your preferences for promotional communications).	Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences. Sensitive Information: account access information.
Advertising. To display advertising to you (see the “Cookies” section of this statement for information about personalized advertising and your advertising choices).	Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences. Sensitive Information: account access information.

We combine data we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.

OUR DISCLOSURE OF PERSONAL DATA

We disclose personal data with your consent or as we determine necessary to complete your transactions or provide the services you have requested or authorized to the extent lawful under applicable law. In addition, we disclose each of the categories of personal data described above, to the types of third parties described below, for the following business purposes:

• Public information. You may select options available through our services to publicly display and disclose your name and/or username and certain other information, such as your profile, demographic data, content and files, or geolocation data.
• Service providers. We provide personal data to vendors or agents working on our behalf for the purposes. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions.
• Partners. We provide personal data to third parties who may use this data for their own purposes and others subject to their own privacy statements. For example, third parties whose tools we use to translate certain languages.
• Financial services & payment processing. When you provide payment data, for example to make a purchase, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
• Affiliates. We enable access to personal data across our parent company, subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business.
• Corporate transactions. We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
• Legal and law enforcement. We will access, disclose, and preserve personal data when we believe doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:
  • protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
  • operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
  • protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

Third party analytics and advertising companies also collect personal data through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), usage data, and inferences based on and associated with that data, as described in the “Cookies” section of this statement. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

Please note that some of our services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy statements.

Finally, we may disclose de-identified information in accordance with applicable law.

 

YOUR RIGHT

You have the right to ask us

• to access your personal data
• to correct your or delete your personal data
• to restrict processing of personal data.

If you wish to access, correct, delete or restrict certain personal data about you that we hold, you may access your account by logging into the POCKETALK services you use.   If you are unable to access, copy, correct, delete or restrict certain personal data we have via the means described above, you can send us a request by using contact methods described at the bottom of this privacy statement. We will respond to you in accordance with the laws applicable to you.

EUROPEAN DATA PROTECTION RIGHTS

If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

• You can request access to, and rectification or erasure of, personal data;
• You can request us to send you a copy of your personal data you provided to us in a structured, machine readable format.
• If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
• If the processing of personal data is based on your consent, you can withdraw consent for future processing at any time;
• You can object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
• For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, please use the contact information at the bottom of this statement.  When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party.  You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.

 

RETENTION OF PERSONAL DATA

We retain your personal data for a period of six months maximum after your account is deleted, except where legal requirements imposing that we keep your personal data longer or less longer apply.

 

LOCATION OF PERSONAL DATA

The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data. Currently, we primarily use data centers in Japan     , U.S.A., Singapore and Taiwan. The storage location(s) are chosen to operate efficiently and improve performance. We take steps to process and protect personal data as described in this statement wherever the data is located; however, some countries where we store data may have laws that offer a different level of data protection than the country in which you reside.

Location of Processing European Personal Data. We transfer personal data from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use legal mechanisms, including contracts (SCC) and adequacy decision, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.
For further information, including obtaining a copy of the documents used to protect your personal data, please contact us as described in HOW TO CONTACT US.

 

SECURITY OF PERSONAL DATA

We take reasonable and appropriate steps to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction.

To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

 

CHANGES TO THIS PRIVACY STATEMENT 

We will update this privacy statement when necessary to reflect changes in our services, how we use personal data, or the applicable law. When we post changes to the statement, we will revise the “Last Updated” date at the top of the statement.  If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law.

 

HOW TO CONTACT US

If you have a privacy concern, complaint, or a question for POCKETALK CORPORATION., please contact us at privacy@pocketalk.com.

Our address is 33F Shiodome City Center, 1-5-2 Higashi-Shinbashi, Minato-ku, Tokyo, Japan

Our data protection representative for the European Economic Area and Switzerland is POCKETALK B.V. at Keizersgracht 482 1017EG Amsterdam Netherlands.