Mobile App and Website Privacy Policy

Introduction

Hi There Solutions, LLC is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy). When you visit our website, https://justtalklivechat.com/ or mobile application (“App”), and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. If at any point during your review you do not agree, please stop using the App. We keep our privacy policy under regular review. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to your email or when you next start the App. This policy together with our Terms of Use as set out at https://justtalklivechat.com/legal/terms (“TOU”) applies to your use of:

• Hi There Solutions App once you have downloaded the App onto your mobile telephone or handheld device (“Device”).
• Any of the services accessible through the App (“Services”) that are available on the App Site or other sites of ours (“Services Sites”) a text chat board product, “Just Talk! Live Chat”.
• If you are a resident of the European Economic Area or California, you might be entitled for additional rights on how we collect, use, and share your information. Please contact us at [email protected] to learn more.

This policy is provided in a layered format so you can click through to the specific areas set out below. [CHILDREN] [TYPE OF DATA WE COLLECT ABOUT YOU] [HOW WE COLLECT YOUR PERSONAL DATA?] [AUTOMATIC COLLECTION TECHNOLOGY] [COOKIE POLICY] [HOW WE USE YOUR PERSONAL DATA] [DISCLOSURES OF YOUR PERSONAL DATA] [ADDITIONAL PERSONAL PERMISSIONS] [YOUR LEGAL RIGHTS] [YOUR CHOICE] [DATA RETENTION] [INTERNATIONAL TRANSFER] [DATA SECURITY] [CONTACT DETAILS]

Children

In Short: We do not knowingly collect Personal Information from anyone under the age of 16 through Hi There Services unless we first obtain permission from that child’s parent or legal guardian.

Our App is not intended for children under 16 years of age. No one under age 16 may provide any personal information to the App. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this App. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please email [email protected] for more information.

Types of Personal Data We Collect

In Short: We may collect, use, store and transfer different kinds of personal data about you as follows:

• Information You Provide:
  • Identity Data: first name, last name, date of birth, gender.
  • Contact Data: billing address, delivery address, email address and telephone numbers.
• Information We Collect Automatically:
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use.
  • Transcription and Content Data: includes information temporarily stored, including contact lists, text messages, audio recordings, history of requests.
  • Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
  • Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
  • Location Data: includes your current location disclosed by GPS technology. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here {INCLUDE AS LINK TO DO NOT TRACK DISCLOSURES} for information on how you can opt out of behavioral tracking on this App and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

How We Collect Your Personal Data

In short: We will obtain your information either through ways you provide them to us or through an automatic collection though technology use.

• Information you give us. This is information (including Identity Data, Contact Data, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect during your use of the App. When you use our text chat board product, Just Talk! Live Chat to send and/or receive messages, we may temporarily process and store your Transcription and Content Data (in encrypted form), log and contact data, and other related information (collectively, the “Transcription and Content Data Information”) in order to provide Just Talk! Live Chat to you. We do not (and cannot) read your messages, and your messages are automatically deleted by you or upon exiting the Just Talk! Live Chat component.
• Information we receive from other sources including third parties and publicly available sources. We may receive information about you from third parties. For example, the Services may include features from social media platforms such as Facebook, and we may enable you to register or log-in to the Services through a social media platform. These features use session trackers to collect information about your IP address, and your use of the Services. Your interactions with those features are governed by the terms of use and privacy policies of the companies that provide them. Please note that these Apps and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these Apps or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these Apps or use these services.

Automatic Collection Technology

In short: Each time you visit one of our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.

As you navigate through and interact with our App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the App.

Information about your computer and internet connection, including your IP address, operating system, and browser type.

Automatic Data Collection Technologies. The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our App.
• Locally Stored Objects. Certain features of our App may use locally stored objects to collect and store information about your preferences and navigation to, from, and on our App. Locally stored objects may or may not be managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for locally stored objects, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our the App and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Hi There, for example, to count users who have visited those pages or opened an email and for other related App statistics (for example, recording the popularity of certain App content and verifying system and server integrity).

Cookie Policy

We use cookies and other tracking technologies to distinguish you from other users of the App, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our website and also allows us to improve the App and our Service Sites.

Third Party Use of Cookies: We use Google Analytics, to analyze the use of and improve the functionality of our App. By way of example, Google Analytics gathers information about App use by means of cookies. The information gathered relating to our App is used to create reports about the use of our App for marketing and improvement purposes. We have hyperlinked the privacy policy above. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Apps and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. If you at any point decide to opt out of sharing these cookies please visit this link. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Personal Data

In Short: We will only use your personal data when the law allows us to do so and to fulfill the purpose of this App in connection with Hi There Solutions’ Services.

Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to fulfill the purpose of the app or Hi There Solutions’ Services.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where it is necessary to determine how to improve the App and or Hi There Solutions’ Services.

Purposes for Which We Will Use Your Personal Data

Disclosures of Your Personal Data

In Short: When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties.

Non-Personal Information. We may disclose aggregated information or other information that does not identify any individual without restriction.

Personal Information. We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Hi There’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Hi There about our App users is among the assets transferred.
• To third parties with your consent, for a profit to market their products or services to you if you have consented to these disclosures. This disclosure would include information that you provided to us such as name; email address; mobile number. This also includes any optional field that a user may enter in their profile is an address which includes street name/number, city, state, zip code, and country. For more information, see Choices About How We Use and Disclose Your Information.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent. If you choose to allow third-party apps to integrate with Use with Just Talk! Live Chat, some data from these apps may be sent to Hi There Solutions to help Hi There Solutions understand your request, and portions of your request will be shared with the app to help provide a response or take an action (for example, send a message or book a ride). When Just Talk! Live Chat interacts with a third-party app on your behalf, you are subject to that app’s terms and conditions and privacy policy. If you choose to allow apps to use Just Talk! Live Chat for transcription, the voice data to be transcribed may be sent to Hi There Solutions.

Other Disclosures. We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use {INSERT AS LINK TO APP’S TERMS OF USE} and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Hi There Solutions, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Additional Personal Data Permissions

In Short: Depending on your specific device, the App may request certain permissions that allow it to access your device Data as described below. By default, you must give permissions before the respective information can be accessed.

Once the permission has been given, you can revoke it at any time. In order to revoke these permissions, you may refer to the device settings or contact Hi There Solutions for support at the contact details provided in the present document. Please note that the revoking of such permissions might impact the proper functioning of this App. If you grant any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this App.

• Camera permission — Used for accessing the camera or capturing images and video from the device.
• Contacts permission — Used for accessing contacts and profiles on your device, including the changing of entries.
• Microphone permission — Used for accessing and recording microphone audio from your device.
• Phone permission — Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
• Precise location permission — Used for accessing your precise device location. This Application may collect, use, and share your location Data in order to provide location-based services.
• Storage permission — Used for accessing shared external storage, including the reading and adding of any items.

Your Legal Rights

In Short: If you are a resident of certain locations, you may have additional rights. If you have a question regarding your rights, feel free to reach out to the contact information outlined below.

• If you are a resident of the European Economic Area you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
  • If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm
• If you are a California resident, California law affords you certain rights regarding our collection and use of your personal information. To learn more about your California privacy rights, please email us at [email protected].
  • California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
  • If you are under 18 years of age, reside in California, and have a registered account with the Apps, you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.
• If you are a Nevada Resident and wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: {TOLL-FREE NUMBER/EMAIL/APP URL.}

Please note that, prior to any response to the exercise of such rights, we will require you to verify your identity. In addition, we may require additional information (for example, why you believe the information we hold about you is inaccurate or incomplete) and may have valid legal reasons to refuse your request. We will inform you if that is the case. For more information on how to exercise your rights, or to exercise your rights, please email [email protected].

Your Choice

In Short: You have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information. You can opt out on the user profile screen or through any of the mechanisms listed below.

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may become inaccessible or not function properly. Additionally, please note that some cookies are necessary for the functionality of the app and will be unable to turn off or opt out.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share or sell your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to [email protected].
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to [email protected]. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s App.
• Accessing and Correcting Your Information. You can review and change your personal information by logging into the App and visiting your account profile page. You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Retention

In Short: Hi There Solutions stores all Personal Information for as long as necessary to fulfill the purposes set out in this Policy, or for as long as we are required to do so by law or in order to comply with a regulatory obligation.

When deleting Personal Information, we will take measures to render such Personal Information irrecoverable or irreproducible, and the electronic files which contain Personal Information will be permanently deleted.

International Transfers

In Short: In the event where we transfer, store and process your Personal Information outside of the EEA or the UK we will ensure that the appropriate safeguards are in place to ensure an adequate level of protection.

To facilitate our global operations, Hi There may transfer, store and process your operations with our partners and service providers based outside of the country in which you are based. Laws in those countries may differ from the laws applicable to your country of residence. Further details regarding the relevant safeguards can be obtained from us on request.

Data Security

In Short: We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Contact Details

Our full details are:

• Full name of legal entity: Hi There Solutions LLC
• Email address: [email protected]
• Postal address: 13780 Del Corso Way # 1211 Broomfield, CO 80020
• Telephone number: +1 (815) 975-7718

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues.