Privacy Policy


Privacy Policy


Last Updated: 05/04/2020
TIME2TALK INC (“Time2Talk”, “we”, “us” or “our”) is committed to protecting your (“you”, “your”, or “Customer”) privacy and empowering you with this privacy
policy (“Privacy Policy”). This Privacy Policy explains how we collect, use, disclose, and apply the information collected when you use or access our online website ( our mobile application, and other related services provided by us (collectively, the “Services”). Time2Talk’s terms of service (the “Terms of Service”) are expressly incorporated herein by reference and are an integral part hereof. The Terms of Service can be found here:
By using the Services, or interacting with us, you are agreeing to this Privacy Policy. If you do not agree with the terms, do not access or use the Services. Please read the following carefully to understand how we collect, use, and maintain your Personal Information. In addition, it describes your choices for use, access, and correction of your Personal Information.
1) Changes to this Notice. We may change this Privacy Policy from time to time. In the event we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy. If there are significant changes to this Privacy Policy, we will attempt to notify you directly by email or provide information via our home page prior to changes becoming effective. We encourage you to review our Privacy Policy whenever you use Services to stay informed of ways you can protect your privacy. 2) Information We Collect and Receive. We collect information about you from various sources and methods, including through the use of the following:

a) Information You Provide to Us. We collect Personal Information or Personal Data that you provide directly to us. “Personal Information” or “Personal Data” is any information that can be used to identify, either directly or indirectly, a natural person, such as name, email address, contact information, etc. If you chose to pay for the Services, you will also provide us with your payment transaction information. Personal Information is also information that we can link with other information to identify you. You can generally use our Site without providing us with Personal Information.

b) Information We Automatically Collect. We receive and store certain types of information automatically, such as whenever you interact with the Services. This information helps us address customer support issues, improve the performance of the Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

  • Usage Data: We collect data about how users interact with our Services. This includes data such as device information, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
  • Device Data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
  • Communications data: We enable users to communicate with each other and us through our Services. For example, we enable you and coaches to call, text, chat, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide and refine this service, to help measure your linguistic progress, and to better coach the coaches, we record your call, text, and chat content. Additionally, we receive some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. We may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics. Our call feature is facilitated by a third party, Zingaya, Inc. doing business as (dba) Voximplant. By using the call feature you are agreeing to Voximplant’s privacy policy (
  • Transaction information: We collect transaction information related to the use of our Services, including the type of services requested or provided, date and time the service was provided, amount charged, and payment method.
  • Content Information: We collect content you submit on our Services such as messages and the metadata that is provided with the content.
  • Camera and Photos: Our Services may require us access your camera or other information from your device’s camera and photos. For example, we enable you to upload a profile picture and message with coaches. You will not be able to upload a profile picture or message with coaches unless we can access your camera or photos.
  • Location Information: When you use our Services, we may collect information about your location. With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.
In addition to the above, like most online services and mobile applications, we use cookies and similar technologies that allow us and third parties to obtain information about your visits to our Services, including analyzing your usage patterns. Although you are not required to accept cookies when you visit our website, you may be unable to use all of the functionality of our website if your browser restricts our cookies. The information we collect from your web browser and from cookies and similar technologies does not identify you personally but in some cases, we may link it to Personal Information.
Below we explain the different types of cookies that may be used on the Services.

Necessary Cookies: These cookies (including local storage and similar technologies) are essential to enable your use of the Services, such as assisting with your account login, so we can show you the appropriate experience and features such as your account information, transaction history, and to edit your account settings. They may also provide authentication, site security, and help localize the language based on the geography of your visit.

Preference Cookies: We use these cookies to remember your settings and preferences, and to improve your experience on our Services. For example, we may use these cookies to remember your language preferences and pre-fill fields.

Session Cookies: These types of cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use session cookies to support the functionality of the website and to understand your use of the website—that is, which pages you visit, which links you use and how long you stay on each page.

Analytics Cookies: These cookies are used to collect information about traffic to our Services and how our users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages that they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services. For example, we can use these cookies to learn more about which features are the most popular with our users and which ones might need to be updated.

Third-Party Cookies: Some of our service providers and other third parties may also use cookies and Web beacons in connection with the services they perform and serve advertising on other third-party sites that are more relevant to you or your interests. They are also used to limit the number of times you see an advertisement, as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information may be shared with other organizations, such as advertisers. This means that after you have been to our website, you may see some advertisements about our Services elsewhere on the Internet. The information collected through this process by the third-party service providers does not enable us or them to identify your name, contact details or other Personal Information that directly identifies you unless you choose to provide these. Such advertising will only be delivered where permitted by applicable law.

Unclassified Cookies: Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

In addition to cookies, we may use other similar technologies, like web beacons to track users of the Services. Web beacons, or “clear gifs,” are tiny graphics with a unique identifier, similar in function to cookies. They are used to track the online movements of web users.

c) Information We Receive. We may receive information about you from other users, our affiliates, and third parties. Examples of information we may receive from others include, but are not limited to, information received from another service that you link to the Services.

3) How We Use Your Information. We use the information we collect, including Personal Data:

To support our legitimate interests consistent with your rights and preferences;

To communicate with you, respond to your requests, or provide you with updates and information;

To better understand our users, their interests, and their preferences;

To personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features;

To develop, deliver, and improve our products, services, and other offerings, some of which may be offered in partnership with other parties;

For security purposes;

For internal purposes such as auditing and data analysis;

To provide services that are subject to terms you have accepted, such as enforcing our licenses, agreements, and terms of service, which may include reasonable monitoring to detect and prevent misuse or fraud and to keep our games fair for all users;

To the extent you give consent, such as when we would like to process your Personal Information for a purpose that would otherwise be incompatible with this Privacy Policy;

To the extent you give consent, such as when we would like to process your Personal Information for a purpose that would otherwise be incompatible with this Privacy Policy;

To comply with legal obligations

4) How We Share and Disclose Information.

a) We may share your information such as your name and content you post or send with other users of our Services. How widely your information is shared depends on your personal settings and the type of service you are using.

b) We do not sell, rent, or otherwise share information that reasonably identifies you with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your prior permission. We may share aggregated or de-identified information, which cannot reasonably be used to identify you.

c) We may share information with our third-party service providers that perform services on our behalf, such as web-hosting companies, mailing vendors, analytics providers, and information technology providers. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

d) We may also disclose information about you when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose information about you to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our website; to enforce or apply our websites’ terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority.

5) Data Processing. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence. 6) Change of Control. We also reserve the right to transfer information about you to a successor organization if, we transfer the ownership or operation of one of our websites to another organization or if we merge with another organization. If such a transfer occurs, we will use reasonable efforts to direct the transferee to use Personal Information you have provided to us in a manner consistent with this policy. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Information with any inquiries concerning the processing of that information. 7) Security. We take security seriously and have implemented administrative, physical, and technological measures to protect your information from unauthorized access, loss, misuse, disclosure, alteration and destruction. If you wish to report a security concern or if you have a question around security, please submit your inquiry to: 8) Access and Your Choices.

a) a. Subject to local law, you may have certain rights regarding information that we have collected and that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate. You can also ask us to see what Personal Information we hold about you, to erase your Personal Information and you may tell us if you object to our use of your Personal Information. To help protect your privacy, we take reasonable steps to verify your identity before granting access to your information. In some jurisdictions, you may have a right to complain to your local data protection authority. If you would like to discuss or exercise the rights you may have, you may notify us in accordance with the “Contact Us” section below.

b) As it relates to the “Information We Automatically Collect” section above, in some browsers, you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. What this means is that you can disallow cookies from all sites except those that you trust. You can also opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance ( You may also opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on NAI’s Application.

c) If you limit the ability of websites and applications to set cookies, you may worsen your overall user experience and/or lose the ability to access the services, since it will no longer be personalized to you. It may also stop you from saving customized settings, like login information.

d) If you access any links to third party websites available to you via the Services that are provided by third parties (including, without limitation, any social media tools, plugins, or widgets), you will be subject to such the policies of those third parties. We do not control third parties’ collection or use of your information (including information related to interest-based advertising), and we are, therefore, not responsible for the content or privacy practices of third parties (or of any websites or applications provided by third parties).

9) Do Not Track. While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. 10) Personal Information Retention. We will retain information required to comply with privacy requests, manage active accounts, as required by law, in order to resolve disputes or enforce our agreements. We may also retain copies of your information for disaster recovery purposes. 11) Links to Third Party Websites. We may make available certain products or services to you through the Services (including via links to third party tools). When you click on a link to a third-party website from our website, your activity and use on the linked website is governed by that website’s policies, not by those of Time2Talk. We encourage you to visit their websites and review their privacy and user policies. 12) Children’s Privacy. We are committed to protecting children’s privacy and to follow the laws, regulations and guidelines in regard to children’s privacy. We do not knowingly accept or solicit Personal Information from a user known to be under the age of thirteen (13). If you have concerns regarding children’s privacy, please contact us at 13) Contact Us. If you have any questions or concerns about our Privacy Policy, please contact us via email at