Privacy Policy

1. Introduction

Strakk Digital B.V. ("Company," "we," "us," or "our") operates Talkpoint (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR) for EU users and the California Consumer Privacy Act (CCPA) for California residents.

2. Data Controller

For the purposes of GDPR, the data controller is:

• Company: Strakk Digital B.V.
• Location: Netherlands
• Email: privacy@talkpoint.app

For detailed company information including registered address, please refer to the Dutch Chamber of Commerce (KVK) registry. Our registered address is available through the KVK database.

3. Information We Collect

3.1 Information You Provide

• Account Information: Name, email address, and password when you create an account
• Payment Information: Billing details processed through our payment provider, Paddle
• Scan Content: Questions, settings, and branding you configure for your scans
• Response Data: Information collected through your scans from respondents
• Communications: Information you provide when contacting us for support

3.2 Information Collected Automatically

• Usage Data: Pages visited, features used, and actions taken within the Service
• Device Information: Browser type, operating system, and device identifiers
• Log Data: IP address, access times, and referring URLs
• Cookies: Essential cookies for authentication and preferences

3.3 Information from Third Parties

• Authentication Providers: If you sign in via Google or other OAuth providers, we receive your name and email
• Payment Provider: Transaction status and subscription information from Paddle

4. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide the Service you requested
• Legitimate Interests: Improving our Service, preventing fraud, and ensuring security
• Legal Obligations: Compliance with applicable laws and regulations
• Consent: Where required, we obtain your explicit consent for specific processing activities

5. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Process transactions and send related information
• Generate AI-powered insights and talking points from scan responses
• Send administrative communications (account updates, security alerts)
• Respond to your comments, questions, and support requests
• Monitor and analyze trends, usage, and activities
• Detect, investigate, and prevent fraudulent transactions and abuse
• Comply with legal obligations

6. Data Sharing and Disclosure

We may share your information in the following circumstances:

• Service Providers: Third-party vendors who perform services on our behalf (hosting, payment processing, analytics)
• AI Processing: Scan responses are processed by AI providers (OpenAI) to generate insights. This data is processed according to our data processing agreements and is not used to train AI models.
• Legal Requirements: When required by law, court order, or governmental authority
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: When you explicitly authorize sharing

We do not sell your personal information to third parties.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers:

• Standard Contractual Clauses approved by the European Commission
• Data processing agreements with all third-party processors
• Compliance with the EU-U.S. Data Privacy Framework where applicable

8. Data Retention

We retain your personal data for as long as necessary to:

• Provide the Service and maintain your account
• Comply with legal obligations (tax records, fraud prevention)
• Resolve disputes and enforce our agreements

Scan Data: Scans and associated responses are retained for 12 months from creation or last renewal. Expired scans may be deleted after a grace period.

Account Data: Retained until you request deletion or your account is terminated.

9. Your Rights

9.1 Rights for EU Residents (GDPR)

Under the GDPR, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing: Request limitation of processing
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge a Complaint: File a complaint with your local supervisory authority

9.2 Rights for California Residents (CCPA)

Under the CCPA, California residents have the following rights:

• Right to Know: Request disclosure of categories and specific pieces of personal information collected
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt-out of the sale of personal information (we do not sell personal information)
• Right to Non-Discrimination: Not be discriminated against for exercising your rights

Categories of Personal Information Collected: Identifiers, commercial information, internet activity, and professional information.

We Do Not Sell Personal Information: We do not sell, rent, or share your personal information for monetary consideration.

9.3 Exercising Your Rights

To exercise any of these rights, please contact us at privacy@talkpoint.app. We will respond to your request within 30 days (or 45 days for CCPA requests). We may need to verify your identity before processing your request.

10. Cookies and Tracking

We use cookies and similar tracking technologies to:

• Essential Cookies: Required for authentication and basic functionality
• Analytics Cookies: Help us understand how visitors use our Service (Google Analytics)
• Preference Cookies: Remember your settings and preferences

You can control cookies through your browser settings. Disabling essential cookies may affect Service functionality.

11. Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Regular security assessments and updates
• Access controls and authentication requirements
• Secure hosting infrastructure (Supabase, Netlify)

However, no method of transmission over the Internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

12. Children's Privacy

The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

13. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. For significant changes, we will provide additional notice via email.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

• Privacy Inquiries: privacy@talkpoint.app
• General Support: support@talkpoint.app
• Company: Strakk Digital B.V.

For EU residents, you also have the right to lodge a complaint with your local data protection authority.