Last Updated: Oct 31, 2024
Welcome to Talk Now!
Talk Now (the "Platform") is provided and controlled by AtlasV Golbal Pte. Ltd. (“We” or “Us”). We are committed to protecting and respecting your privacy. This Privacy Policy (the “Policy”) sets out the basis on which any information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your information and how we will handle it. By accessing or using the Platform, services, applications, products, and content (collectively, the “Services”), you acknowledge the practices described in the Policy. For purposes of the Policy, “you” and “your” means you as the user of the Services.
Before you use or submit any information through or in connection with our Services, please carefully review this Privacy Policy. By using any part of our Services, you understand that your information will be collected, used, and disclosed as outlined in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services.
We collect and process information about you if you use the Platform and interact with the Services and related content such as our web pages. This includes your mobile phone number(if you provide), technical and behavioral information(including text content) about your use of the Services.
To comply with legal and regulatory requirements, we may ask for your name, physical address, and identity card. However, it is not mandatory to provide this information. If you choose not to provide it, we will implement the highest level of precaution to prevent scams and other illegal activities. However, if you want to use the service without strong limitations and agree to provide this information, we will collect and verify the necessary information to ensure compliance with legal requirements.
We utilize the information to enhance, maintain and deliver our Services. Additionally, we may employ this data to ensure your safety, adhering to legal and regulatory obligations.
We may share your information with third-party service providers who help us to deliver the Platform, or with any member of our group to improve the Platform or for internal business purposes. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.
We keep your information for the duration necessary to provide you with services and fulfill our contractual obligations and rights related to the collected information. If the information is not required for providing services, we retain it only as long as there is a legitimate business purpose or a legal obligation to do so. Additionally, we will retain your information if we deem it necessary for establishing, exercising, or defending legal claims.
We will use commercially reasonable efforts to generally notify all users of any material changes to the Policy through a notice on the Platform. However, you should look at the Policy regularly to check for any changes. We will also update the “Last Updated” date at the top of the Policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated Policy constitutes your consent to the updated Policy. If you do not consent to the updated Policy, you must stop accessing or using the Services.
Information you choose to provide. When you register or otherwise interact with the Services, you may give us information and content. We may also collect your feedback about the Services if you choose to provide it. Information we collect automatically. We may collect the following information about you:
We will use the information in the following ways:
We may use your information to:
As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organization, we may use your information to:
We don’t sell any of your information and we impose restrictions on how partners can use the data we provide. We may disclose the categories of personal information discussed above for a business purpose to selected third parties in or outside your country, including with:
We may share your information with law enforcement agencies, public authorities, or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
We may also disclose your information to third parties:
The Services may contain links to content maintained by third parties who we do not control. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by the Policy.
The information that we collect from you may be transferred to and stored at, a destination inside or outside of your country, for the purposes as described in the Policy. By submitting your information, you agree to this transfer, storing, or processing. We will take reasonable steps to secure your information and treat it in accordance with the Policy.
We provide tools in settings that allow you to control how you use the Platform. If you have any questions on how to use or want to know about any rights you may have in the country where you live, please contact us.
We will take reasonable steps to secure your information and treat it in accordance with the Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted through the Platform. We have put in place technical and organizational measures that we will amend and update from time to time to improve the overall security of our systems.
We will delete your information upon request. Otherwise, we will use the following criteria to determine the period for which we will keep your information:
Our contractual obligations and rights in relation to the information involved; legal obligations under applicable laws and regulations to retain data for a certain period of time; statute of limitations under applicable laws; our legitimate business purposes; and disputes or potential disputes. After you have terminated your use of our Services, we may store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we may also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and enforce our agreements.
Our services are not intended for users under the age of 13, or the minimum age required by applicable data protection laws in your jurisdiction. If you are under the specified age, you are not allowed use our Platform. If we become aware that personal information has been collected from a person under the relevant age, we will delete the user’s information in accordance with applicable law. If you believe that we may have information about or collected from a child under the relevant age, please contact us.
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at DPO@atlasv.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your information protection authority or follow the dispute process.
We will use commercially reasonable efforts to generally notify all users of any material changes to the Policy, such as through a notice on our Platform, however, you should look at the Policy regularly to check for such changes. We will also update the “Last Updated” date at the top of the Policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated Policy constitutes your consent to the updated Policy. If you do not consent to the updated Policy, you must stop accessing or using the Services.
Questions, comments, and requests regarding the Policy are welcomed and should be addressed to:
Vonage is a phone numbers management and communication service provided by Vonage Holdings Corp.
Vonage Holdings Corp. processes all personal data submitted by you exclusively on the basis of the General Data Protection Regulation, and will be transferred with SSL/TLS- encrypted and only use them to perform requested video or photo processing.
Place of processing:
For more information on the privacy practices of Vonage, please visit the Vonage Privacy Policy web page: https://www.vonage.com/legal/privacy-policy/?icmp=footerlegalpolicyprivacy.
We engage Vonage Holdings Corp. that acts as a data processor on our behalf in order to be able to provide you with messaging services within the App. Sending messages (SMS, MMS, Chat) using our App and Vonage's platform can be possible only when all applicable policies, regulations and laws are properly observed. Therefore, while sending messages using the phone numbers and other services available within the App you agree to be bound by and comply with the following requirements:
It is strictly prohibited to use the App for sending messages with the content that is illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or otherwise poses threat to the public, or that violates any law and/or regulation in the country where the message recipient lives (e.g. messages related to cannabis, offers for prescription medication that cannot legally be sold over-the-counter, messages containing hate speech, malicious content, etc.). It is also prohibited to send messages related to high-risk financial services, third-party lead generation services (companies that buy, sell, or share consumer information), “get rich quick” schemes, debt collection or forgiveness, gambling, as well as messages containing "S.H.A.F.T." (sex, hate, alcohol, firearms, tobacco) use cases. The specified list of prohibited content is not exhaustive, messages containing these categories of content cannot be sent via the App regardless of the fact whether or not you get consent from message recipients for such content. You undertake to comply with all requirements contained in the specified documents while using the App.
When you use the App to send messages, you also agree to take into account and comply with the requirements regarding the recipient’s consent to receive messages from you (including possible forms, scenarios of obtaining such consent), opt-out mechanisms, as well as with sender identification requirements.
Content verification for US/Canadian destination numbers. Please note that all content of messages that you send and/or transmit via the App to United States and Canadian numbers is subject to monitoring and verification process by Vonage Business Inc. Particularly, Vonage proactively identifies and does not accept the messages in violation of the Vonage Terms of Service (https://www.vonage.com/legal/unified-communications/tos/). The messages that are proactively identified as messages in violation of Vonage Terms of Service will be returned as an error prior to reaching carrier networks. Moreover, in the event that your message(s) violates Vonage Terms of Service or other applicable regulations your access to the App and/or to messaging services available within the App may be suspended or terminated. Taking into account the foregoing, you hereby provide us and Vonage Holdings Corp. with your relevant permission for collecting, processing, storing and monitoring the content of all messages you send using the App for the purpose of detecting spam, fraudulent activity, and violations of Vonage Terms of Service.
Your failure to provide relevant permissions and comply with the requirements stated above means that you cannot use the messaging services available via the App.
This SUPPLEMENTAL TERMS – Vonage API are incorporated into the present Privacy policy and constitute its integral part. By accepting the Privacy policy containing this SUPPLEMENTAL TERMS – Vonage API you hereby express you consent and give all appropriate permissions and authorizations regarding data processing, storage and sharing, the applicable procedures for sending messages and message content monitoring, as well as other issues reflected herein.
Twilio is a phone numbers management and communication service provided by Vonage Holdings Corp.
Twilio Inc. processes all personal data submitted by you exclusively on the basis of the General Data Protection Regulation, and will be transferred with SSL/TLS- encrypted and only use them to perform requested video or photo processing.
Place of processing:
For more information on the privacy practices of Twilio, please visit the Twilio Privacy Policy web page: https://www.twilio.com/en-us/legal/privacy.
We engage Twilio Inc. that acts as a data processor on our behalf in order to be able to provide you with messaging services within the App. Sending messages (SMS, MMS, Chat) using our App and Vonage's platform can be possible only when all applicable policies, regulations and laws are properly observed. Therefore, while sending messages using the phone numbers and other services available within the App you agree to be bound by and comply with the following requirements:
It is strictly prohibited to use the App for sending messages with the content that is illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or otherwise poses threat to the public, or that violates any law and/or regulation in the country where the message recipient lives (e.g. messages related to cannabis, offers for prescription medication that cannot legally be sold over-the-counter, messages containing hate speech, malicious content, etc.). It is also prohibited to send messages related to high-risk financial services, third-party lead generation services (companies that buy, sell, or share consumer information), “get rich quick” schemes, debt collection or forgiveness, gambling, as well as messages containing "S.H.A.F.T." (sex, hate, alcohol, firearms, tobacco) use cases. The specified list of prohibited content is not exhaustive, messages containing these categories of content cannot be sent via the App regardless of the fact whether or not you get consent from message recipients for such content. You undertake to comply with all requirements contained in the specified documents while using the App.
When you use the App to send messages, you also agree to take into account and comply with the requirements regarding the recipient’s consent to receive messages from you (including possible forms, scenarios of obtaining such consent), opt-out mechanisms, as well as with sender identification requirements.
Content verification for US/Canadian destination numbers. Please note that all content of messages that you send and/or transmit via the App to United States and Canadian numbers is subject to monitoring and verification process by Twilio Inc. particularly, Twilio proactively identifies and does not accept the messages in violation of the Twilio Terms of Service (https://www.twilio.com/en-us/legal/tos) and Twilio Messaging Policy (https://www.twilio.com/en-us/legal/messaging-policy). The messages that are proactively identified as messages in violation of Twilio Terms of Service and Twilio Messaging Policy will be returned as an error prior to reaching carrier networks. Moreover, in the event that your message(s) violates Twilio Terms of Service and Twilio Messaging Policy or other applicable regulations your access to the App and/or to messaging services available within the App may be suspended or terminated. Taking into account the foregoing, you hereby provide us and Vonage Holdings Corp. with your relevant permission for collecting, processing, storing and monitoring the content of all messages you send using the App for the purpose of detecting spam, fraudulent activity, and violations of Twilio Terms of Service and Twilio Messaging Policy.
Your failure to provide relevant permissions and comply with the requirements stated above means that you cannot use the messaging services available via the App.
This SUPPLEMENTAL TERMS – Twilio API are incorporated into the present Privacy policy and constitute its integral part. By accepting the Privacy policy containing this SUPPLEMENTAL TERMS – Twilio API you hereby express you consent and give all appropriate permissions and authorizations regarding data processing, storage and sharing, the applicable procedures for sending messages and message content monitoring, as well as other issues reflected herein.
In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction Specific that are relevant to your jurisdiction from which you access or use the Services, and the rest of the Policy, the relevant jurisdiction’s Supplemental Terms – Jurisdiction Specific will supersede and control.
If you are using our Services in the United States, the following additional terms apply:
If you are a California resident, you may request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our products do not support "Do Not Track" requests at this time, but you are able to adjust "Allow Tracking" option in the system setting.
Pursuant to the California Consumer Privacy Act (“CCPA”), California residents, subject to verification, may request to see what personal information we have collected about them over the past 12 months, including the categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, the categories of third parties with which the information was shared, and the specific pieces of personal information collected about them. If you are a California resident, you may also request that we delete your personal information subject to certain exceptions. Consistent with California law, if you choose to exercise either of these rights, we will not charge you different prices or provide different qualities of services unless those differences are related to your information. Please submit your request via legal@atlasv.com.
We do not sell personal information to third parties for purposes of the CCPA. We may permit third parties to collect personal information through our Services and share each of the categories of personal information described above with third parties for business purposes. These business purposes are described above and include providing advertising on our products and services and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”) and website and online service analytics. The information practices of these third parties are not covered by the Policy.
If you are using our Services in Brazil, the following additional terms apply:
Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.
We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD, once it comes into force:
Verifying your identity. For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.
Limitations to your rights. In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when disclosure could adversely impact our business whenever there is a risk of violation of our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request. In case of doubt about your privacy, your rights, or how to exercise them, please contact us via the provided information in "12. Contact". If you have any questions about the processing of your personal data, we would like to clarify them.
International Transfer of Data. We share your personal data globally with companies of our business group to carry out the activities specified in this Policy. We may also subcontract the processing of data involved in the Services or share your personal data with third parties located in other countries. Your personal data may therefore be subject to privacy laws other than those applicable in your country.
Whenever we transfer your personal data to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws and we will take all measures that are reasonably necessary to ensure the existence of adequate safeguards to protect your personal data and to ensure that are processed safely.
Parental and Guardian Consent. If required by Brazilian data protection laws, (i) if you are over the age of 16 but under the age of 18, you can only use and register for an account with the assistance of your parent or legal guardian and you declare and represent that you had such assistance to use the Services and to agree to the Policy; (ii) if you are over the age of 13 but under the age of 16, you can only use and register for an account with the representation of your parent or legal guardian, and you must obtain the consent from your parent or legal guardian to the use of the Services and acceptance of this Privacy Policy. Language. The Terms of Service are prepared in the English language and shall prevail in other versions (if any).
DPO. If you wish to contact the Data Protection Officer, please contact us: DPO@atlasv.com
If you are using our Services in South Korea, the following additional terms apply:
Data retention. We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in the Policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable, including, but not limited to:
Act on Consumer Protection in Electronic Commerce:
Destruction of Personal data. We destroy your personal data in a manner that renders it unrestorable by the relevant department. Your Rights
If you are using the Services in the EEA and Switzerland or the UK (the “European Region”), the following additional terms apply:
Where we store your information
If you are a citizen of the EEA, the personal data that we collect from you will be transferred to and stored at, a destination outside of the European Economic Area ("EEA"). Where we transfer your personal data to countries outside the EEA, we do so under the Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate).
How we share your information
If you consent to push notifications, we may also provide your device information to your operating system. Your rights You have the following rights:
Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.
If you would like to exercise any of your rights, please contact us via DPO@atlasv.com.