Effective Date: November 10, 2020
Last Updated: November 10, 2020
iTalk Global Communications, Inc. (“iTalk”, “iTalkBB” “we”, “us”, or “our”) recognizes the value of privacy of our customers and website users. In this Privacy Policy (“Policy”), we describe how we and our affiliates collect, use, and disclose personal information that we obtain about subscribers to and customers of iTalkBB services, as well as users of our websites (“Sites”), mobile Applications (“Apps”) and the services available through our Sites and Apps (collectively, the Sites, Apps and the services available therein are the “Services”). This Policy also outlines your rights and choices with regard to the personal information collected about you related to the Services.
Applicable Terms. Your use of our Services, and any dispute over privacy, is subject to this Policy, the respective terms of use (the “Terms”), between you and iTalkBB, such as our Terms and Conditions, and any other relevant agreements, which are available. The applicable Terms are incorporated by reference into this Policy, including any of their applicable limitations on liability and the resolution of disputes. By disclosing your personal information to us or using our Services, you understand and agree that iTalkBB may collect, use, and disclose your personal information in accordance with this Policy and the applicable terms.
If you are a resident of California (USA) please see the Additional information for California Residents section below for important information about the categories of personal information we collect and disclose and your rights under California privacy laws.
We generally collect information about you directly from you, from third parties, and automatically through your use of our Services as further described below.
Information We Collect Directly from You. The type of information that we collect from you depends on your interaction with our Services. While you can browse most parts of our website freely, certain areas and features of our Services require you to create an account with us. To create an account, you must provide us with certain information, such as your name and username or nick name, email or phone number, and other contact information. If you subscribe to any of our Services, we will also collect your payment and billing information. We may also ask or allow you to submit additional profile information, such as authorized users, preferences and interests, and additional contact information. If you apply to become one of our Dealers or Sales Agents, we will collect information from you, including your first and last name, email address, contact address, phone number, occupation, whether you are a user of our Services, business ownership, desired sales model, hourly commitment to iTalk sales, other similar survey information, and information you choose to provide to us. If you decide to make a purchase with us or subscribe to our Services, we also collect information in order to process your order, such as payment and billing information, residential addresses, and shipping address. We also collect information about items in your online shopping cart and other order information that you submit.
Information We Collect Regarding Your Use of Our Services. We collect information about your use of our Services, such as your order and subscription history and purchases, as well as your credit bonus, for example when you earn credits and rewards by referring a friend to iTalk. We may also collect other information depending upon the services you subscribe to or use. For example, if you subscribe to our Aljia (CCTV) services we collect CCTV footage, including audio, (which is stored in accordance with the applicable terms) from your cameras. We also collect and maintain records about the services you use for purposes of administering, operating and billing for those services and as otherwise explained herein. For example, if you subscribe to our mobile communication or phone services, we will collect transactional information such as call logs and related usage records.
Information We Collect About You from Third Parties. We may also collect information about you from third parties, which we append to the information we have collected. If you refer another customer to as part of a referral program or offer, we make available, we may collect information (when provided by the referred customer), in order to process and credit you with the referral. If you sign up for or purchase our Services through a Dealer or Agent, or otherwise interact with a Dealer or Agent related to the Services, we may receive information about you from the Dealer, such as name, nickname, contact information, and subscription and payment details.
Communications and support. If you contact us by email, mail, phone, chat or otherwise regarding the Services, we collect and maintain a record of your contact details, communications and our responses. If you call us, we may also record calls and maintain logs and records of those calls.
Inquiries and requests. We also collect personal information when you submit information to or request information from us or sign up for marketing and communications from us (such as related to iTalkBB products, subscriptions, special offers and upcoming product releases). The information we may collect includes your name, contact information, and other information.
ITalkBB Chinese TV. If you subscribe to our Chinese TV services, we collect additional personal information about you. Depending on how you use the Chinese TV services, we may collect information such as information related to your registered Set-Top-Box device, geolocation, IP address, and contact details (including email). If you actively initiate contacting us for customer support purposes through one of our WeChat corporate accounts, WeChat and we may collect additional information such as for example your name, WeChat username, profile image, phone number used with WeChat, and conversation records related to your inquiry. For more information about WeChat’s privacy practices, please visit WeChat’s privacy policy.
Apps. In some cases, information about you is collected and combined through your interaction with the Apps we may offer related to our Services. For example, we collect information on the device and the App you are using, including IP Address, date, time and requests submitted through the App, unique identifiers and other information such as the type of device you use (including your operating system, language, network settings, telephone operator or internet provider, installed third-party applications and plug-in lists).
Other Information We Collect Automatically Through Our Services. We may also collect personal information about how you use the Services (e.g. using cookies and pixel tags), such as IP address, advertising ID, location information, browser type, device type, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services, and the links you click and your other activities within the Services. We may also use pixels in HTML emails to understand if individuals read the emails, we send to them (“usage data”). We may combine this information with other information that we have collected about you, including, where applicable, your name and other personal information. (For more information, see the Cookies and Other Tracking Information section below.)
We process your information and content, including your personal information, for the following purposes:
Providing and Improving Our Services. To provide you with and maintain our Services; to fulfil your orders and requests, or otherwise to improve our Services; to develop new features, products, or services; to authenticate users; to perform technical operations, such as updating software; and for other customer service and support related purposes.
Communicating with You. To provide you with the information or services that you have requested from us; to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes; and to administer surveys and questionnaires, such as for market research or user satisfaction purposes.
Dealers and Sales Agents. To provide you with the information or services that you have requested from us; to administer your application and communicate with you about your application to become an iTalk sales agent or dealer, and to respond to related inquiries.
Rewards. To assign, track, issue and post subscription rewards and credits to your account, for example if you participate in our referral program.
Personalizing Content and Ads. We may use the information we collect about you to personalize the information and content we display to you, including marketing, promotional and sponsored content, as well as providing you with more relevant ads.
Marketing and Communications. To communicate with you about your account and use of our Services via email, or phone, including to inform you about product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Please see the Rights and Choices section further below for more information about how to change your communications preferences.
Research and Analytics. To better understand how users access and use our Services and products, for other research and analytical purposes, such as to evaluate and improve our Services and business operations, develop new features, products, or services, to otherwise improve our Services and user experiences, and for other research, analytical, and statistical purposes.
In Support of Our General Business Operations. Relating to audits and assessments of our business operations, security controls, financial controls, records and information management program, and otherwise relating to the administration of our general business, accounting, record keeping and legal functions. These purposes are based on our legitimate interest in operating our business and maintaining adequate internal records and safeguards.
Securing and Protecting Our Assets and Rights. To protect our business operations, secure our network and information technology, assets and services; to prevent and detect fraud, unauthorized activities, access and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities and other situations involving potential threats to the rights or safety of any person or third party; and as necessary to defend our legal interests and rights.
Complying with Legal Obligations. To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
We may also use your personal information for other purposes, where you have consented.
Aggregate and De-identified Information. We may also use aggregate and deidentified information for various research, development, product improvement, analytics and other purposes.
We may use, store or transfer personal information outside your jurisdiction. In providing our services to you, we may also provide your personal information to subsidiaries and affiliates, service providers and/or third parties who may be located outside your jurisdiction. Please refer to “Contact Us” below to find out information about (i) our practices with respect to the use of third parties and service providers outside your jurisdiction, and (ii) questions you may have about the collection, use, disclosure or storage of personal information by parties located outside your jurisdiction.
We may share or disclose the information (including personal information) that we collect as follows:
Subsidiaries and Affiliates. With our subsidiaries and affiliated companies (i.e., companies under common ownership, control or management with us); their use and disclosure of such personal information is subject to this Policy.
Service providers. With our third-party service providers who use this information to perform services on our behalf, such as hosting providers, payment providers, auditors, advisors, consultants, customer service and/or support providers.
Third Parties. With third parties that provide advertising, campaign measurement, online and/or mobile analytics and related services. These third parties may receive or access browsing history and/or other data about your use of the Sites, in order to help us better reach individuals with relevant ads, measure our ad campaigns and/or to better understand how individuals interact with our Sites over time and across devices. Where you initiate and request interaction with us through a third-party platform, we may also share certain information with these third parties that provide the platform services for certain of our customer support channels (such as for example our WeChat corporate account). For more information on WeChat’s privacy practice, please refer to WeChat’s terms and privacy policy.
Legal Compliance. In response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.
Business Transfers. As part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
Protection of Rights. Where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, to protect the rights, property or safety of iTalkBB, our affiliates, clients, customers and/or others, and/or as evidence in litigation in which we are involved.
Aggregated and De-identified Data. We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics and/or other purposes.
We may use, store or transfer personal information outside your jurisdiction. In providing our services to you, we may also provide your personal information to subsidiaries and affiliates, service providers and/or third parties who may be located outside your jurisdiction. Please refer to “Contact Us” below to find out information about (i) our practices with respect to the use of third parties and service providers outside your jurisdiction, and (ii) questions you may have about the collection, use, disclosure or storage of personal information by parties located outside your jurisdiction.
We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the Sites and other Services. We may combine this “usage data” with other personal information we collect about you. We use this usage data to understand how our Services are used, track bugs and errors, provide and improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.
Pixel Tags. Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use pixel tags (also referred to as web beacons, web bugs or clear GIFs), in connection with our Services to, among other things, help us manage ads and content, and compile statistics about usage of our Services. We may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Cookie Preferences. You can adjust your cookie preferences for our Site, using our cookie preference manager. You can also block or disable cookies for the device and browser you are using, through your browser settings; however, certain features on our Sites may not be available or function properly if you block or disable cookies. Our Sites currently do not respond to “do not track” signals. Please note, that your preferences are applied on a browser and device basis. So, you may need to set your cookie preferences for each browser and device you use to access our Site. Further, if you subsequently delete cookies, your preferences may be lost and need to be reset.
We may work with third-party ad networks, channel partners, measurement services and others (“third party ad companies”) to display advertising on our Services, and to manage our advertising on third-party sites, and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information (e.g., derived from your IP address), and, with your consent, we may collect your device’s geolocation information through our Apps; we and these third-party ad companies use this information to provide you more relevant ads and content and to improve and evaluate such ads and content.
Cookie Preferences. As explained above, you can adjust your cookie preferences for our Site, including to opt out of advertising cookies, using our cookie preference manager, and you can also block or disable cookies for the device and browser you are using.
Industry Ad Choices. You can learn more about the information collection practices and "opt-out" procedures of many third-party ad companies by visiting www.networkadvertising.org/optout_nonppii.asp. Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs. If your browser is configured to reject cookies when you visit one of the above referenced opt-out pages, and you later erase your cookies, use a different computer or change web browsers, your preference may also need to be reset.
Our Services may link to other websites or online services (including those operated by our parent, affiliates, or others) that are not covered by this Policy. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
We have implemented safeguards designed to protect the information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
In this section we describe the choices you have regarding our collection, use and handling of your personal information.
Access and Update Information. You may access, update, and delete certain of your personal information by accessing and adjusting your account settings. You may also contact us using the information in the Contact Us section below to make an access, correction or other privacy request. Please note that we may maintain copies of information that you have updated, modified or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law. For example, if you request that we delete your information, but we believe that you have violated our Terms, we may retain information about you in order to attempt to resolve the issue before deleting it. Your access to or correction of your personal information is subject to applicable legal restrictions and the availability of such information. Further, we may take reasonable steps to verify your identity before granting such access or making corrections.
Marketing Communications. You may opt-out of receiving email marketing communications from us by using the unsubscribe link in any such email we send to you. Or alternatively, by emailing your request to Privacy.Legal@italkbb.com. Please note that we may still send you transactional emails, such as emails related to your account or subscriptions.
Third-Party Ads and Cookies. As noted above, you can control your cookie preferences on our Sites and opt out of most third-party advertising tags and cookies on our Sites.
Our Services are not targeted and directed at children and we do not knowingly collect any personal information from a child under 16. If you believe we have inadvertently collected personal information about a child, please contact us and we will take steps to delete this information.
If you have any questions about this Policy or our privacy practices, please email us at Privacy.Legal@italkbb.com or contact us at:
iTalk Global Communications, Inc.
William A. Burge, General Counsel
1120 S Capital of Texas Hwy, Bldg. 3, Suite 110, Austin, TX, 78746
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Services. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Services.
Last updated: November 10, 2020
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of iTalk Global Communications, Inc. and its affiliated companies (collectively, “iTalk” “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” “user” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this PRIVACY NOTICE FOR CALIFORNIA RESIDENTS.
If you are located elsewhere, please see iTalk Privacy Policy here.
While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Last Updated date above).
Categories of Personal Information Collected and Disclosed. The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the How we Use Information and the How we Disclose Information sections above.
| Personal Information We May Collect | Categories of Third Parties to Whom We May Disclose this Information | |
| Categories | Description | |
| Identifiers | Includes direct identifiers, such as name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; set top box identifier; IP address; MAC address, app ID, advertising ID, and other online or device identifiers; and other similar identifiers. |
• service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers • operating systems and platforms • dealers and agents |
| Customer Records | Includes personal information, such as name, account name, user ID, contact information, education and employment information, communications preferences, account number, and financial or payment information, that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services. |
• service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • internet service providers • operating systems and platforms • dealers and agents |
| Commercial Information | Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers. |
• service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • operating systems and platforms • dealers and agents |
| Usage Data | Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads. |
• service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers • operating systems and platforms • dealers and agents |
| Geolocation Data | Includes precise location information about a particular individual or device. |
• service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries |
| Audio, Video and Electronic Data | Includes audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage (e.g., collected from visitors to our offices and premises, or as part of our Aljia (CCTV) services, photographs and images (e.g., that you provide to us) and call recordings (e.g., of customer support calls). |
• service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • internet service providers • operating systems and platforms |
| Professional information | Includes professional and employment-related information [(such as current and former employer(s) and position(s), business contact information and professional memberships)]. |
• service providers • advisors and agents • government entities and law enforcement • our affiliates and subsidiaries |
| Inferences | Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads. |
• service providers • advisors and agents • government entities and law enforcement • our affiliates and subsidiaries • advertising networks • data analytics providers • internet service providers • operating systems and platforms • dealers and agents |
Sources of Personal Information. As further described in the Information We Collect section above, we may collect personal information from the following sources.
• directly from the individual and subscribers
• advertising networks
• data analytics providers
• social networks
• internet service providers
• operating systems and platforms
• government entities
• dealer and agents
Do We “Sell” Personal Information? Under the CCPA, a “sale” includes disclosing or making available personal information to a third party in exchange for monetary compensation or other benefits or value. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third-party ad companies (through third party-tags on our websites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. As defined by the CCPA, we may “sell” Usage Data and Identifiers to third party advertising networks and data analytics providers. You may opt out of a sale of personal information as described in the Exercising Your Rights section below.
You may request to review, make amendments, have deleted, or otherwise exercise your rights, under applicable privacy laws, with respect to your personal information that we hold by emailing us at the contact information below. Please note that we may maintain copies of information that you have updated, modified, or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law.
The CCPA provides California residents consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access Rights: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
• categories of personal information collected;
• categories of sources of personal information;
• categories of personal information about them we have disclosed for a business purpose or sold;
• categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
• the business or commercial purposes for collecting or selling their personal information; and
• a copy of the specific pieces of personal information we have collected about them.
Deletion Rights: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
Right to Non-Discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Do Not Sell (opt out): to opt-out of our sale of their personal information. While we may “sell” personal information as defined by the CCPA, we do not sell personal information about California consumers who we know are younger than 16 years old.
Exercising Your Rights. California residents may submit CCPA requests to opt out of sales, requests to know (access), and requests to delete their personal information through any one of the following methods:
• By submitting the request through our Contact Us form or by phone at 1888-254-8827 (toll free).
When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide us with this information by logging into your account or via email or the above toll-free number to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual through the above-listed methods; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at Privacy.Legal@italkbb.com, and include in your request a current California address and your attestation that you are a California resident.
This policy is current as of the date set forth above. We may change this policy from time to time, so please be sure to check back periodically. We will post any changes to this policy on our website. If we make any changes to this policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our website.
For more information about our privacy practices, please do not hesitate to contact us at:
| Email: Privacy.Legal@italkbb.com | |
| Toll Free: 1888-254-8827 | |
| Postal Address: | iTalk Global Communications, Inc. William Burge, General Counsel 1120 S Capital of Texas Hwy, Bldg. 3, Suite 110, Austin, TX, 78746 |