Talk@Ease mobile app – privacy policy

Last amedmendt: December 28, 2021

1. THE DATA CONTROLLER

Name:  Digital Language Solutions Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság (above and hereinafter referred to as “Digital Language Solutions Kft.”)
Registered seat:  3524 Miskolc, Leszih Andor utca 27. 4. em. 4., Hungary
Company registration number:  05-09-034616
Tax number:  27418651-2-05
Bank account number:  10102103-75412300-02005001
Registering Court:  Miskolci Törvényszék Cégbírósága, Hungary
Chamber membership:  Borsod-Abaúj-Zemplén Megyei Kereskedelmi és Iparkamara, Hungary
E-mail address:  info@talkatease.com
Tel.:  +36 30 2869550
Hosting services of the website (www.talkatease.com) held at:
    Name:  Rackhost Zrt.
    Address:  6722 Szeged, Tisza Lajos körút 41., Hungary
    Company registration number: 06-10-000489
    https://www.rackhost.hu/privacy-policy

Digital Language Solutions Ltd. (“Digital Language Solutions Kft.” or “data controller” or “we” or “us” or “our”) respects the privacy of its Users (“User” or “you” or “user” or “data subject”). This Privacy Policy explains how data controller collects, discloses, uses, and safeguards the Users’ information when they visit the mobile application called Talk@Ease (the “Application” or “App”) and use its related services. Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION.

DIGITAL LANGUAGE SOLUTIONS Kft. hereby reserves the right to unilaterally amend the present Privacy Policy upon its sole discretion. Users shall be notified on such amendments through pop-up windows, where such amendments shall be accepted by the Users at the first access to the App after such notification is made.

The Talk@Ease Application can be used free of charge without registration.

We hereby call your attention to the fact that since registration is not required the User of the Application is not identified and cannot be identified by DIGITAL LANGUAGE SOLUTIONS Kft., and all kind of information collected through the Application is anonymized and stored in a way ensures that the Users cannot be identified. The principles of data protection shall not be applied for anonymized data.

Data controller stores only summarized, anonymized data from the data provided by the User in the App and from the usage of the App, which serves the control of the correctness of answers and for statistical, survey making, and popularity monitoring aims in order to identify the future targets of the development of the App. DIGITAL LANGUAGE SOLUTIONS Kft. will not make any decision based on these statistics and algorithms prepared out of these non-identifiable data, which would affect the Users.

The Users must read carefully this privacy policy which has been written simply to ensure the understanding thereof so that the Users may determine freely whether they wish to submit their personal data to Digital Language Solutions Kft.

Users shall guarantee that the submitted data are accurate, full, truthful and the Users shall keep them up to date, and that they shall be responsible for any damage, or loss whether directly or indirectly, that may arise from a violation of such compromise. In the event that the delivered data belonged to a third party, the User shall guarantee that he or she has informed to said third party of the aspects contained in this document and has obtained his or her authorization to submit his or her personal data to Digital Language Solutions Kft. for the indicated purposes.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 16. If you become aware of any data we have collected from children under age 16, please contact us using the contact information provided below.

With respect to the under-sixteen years old, in no event shall Digital Language Solutions Kft. permit them to directly submit any personal data. Instead, Digital Language Solutions Kft. shall address their parents or legal guardians directly and may request confirmation by e-mail that the data have been indeed provided by adults. Nonetheless, Digital Language Solutions Kft. may also request at any moment the written consent of parents or legal guardians to verify their knowledge and authorization to the access of the children to the Application and to the related Services.

Digital Language Solutions Kft. also guarantees that no information shall be processed for purposes other than the ones indicated in the present Privacy Policy.

2. OUR PRINCIPALS REGARDING THE DATA PROCESSING

Personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’);
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).

3. THE PURPOSES FOR WHICH WE COLLECT AND PROCESS YOUR DATA

Data controller shall process the provided personal data – in the lack of legal regulation – only in compliance with the purposes and aims indicated in the present Privacy Policy to the extent and for the time that is necessary for the fulfillment of the purposes.

Digital Language Solutions Kft. shall process the personal data of the User for the following specific purposes:

  1. To permit the contracting and the fulfillment of contractual obligations and of the offered services
  2. To control your pronunciation and the correctness of answers
  3. To resolve queries, suggestions and claims and complaints raised by the users through the channels made available for that purpose (contact form of e-mail)
  4. To create anonymized statistical reports with respect to the habits of access and the activity of the users of the App, pursuant our cookies policy
  5. To comply with legal obligations

4. THE LEGAL BASIS FOR THE DATA COLLECTION AND PROCESSING

We collect data based on your expressed approval or in order to be able to fulfill our obligations arising from the performance of the contract or from any relevant legal regulation. Processing shall be lawful only if and to the extent that at least one of the following applies:

  • the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which the controller is subject;

5. THE TYPE OF DATA WE COLLECT

The information we may collect through the Application depends on the content and materials that the User uses, and the collection of information regarding our Free Services includes:

Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s microphone, notifications, sensors, storage. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data

Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, IP address and any other data you choose to provide.

Contact details

The processed data may be: name, e-mail address, contact information, query, complaint, subject of the correspondence, handling of the complaint and any relevant information. You write us an e-mail concerning a complaint, remark etc. related to the App, and data process is made with this regard, the present Privacy Policy shall be applied. In such cases these voluntarily provided information cannot be linked to any information recorded or stored in the App, identification cannot be made. In such cases the legal basis of the data processing is the fulfillment of the services (Article 6 (1) b)). You accept the data processing with the selection of the check-box.

6. THE NECESSITY OF THE REQUESTED DATA

The data requested by DIGITAL LANGUAGE SOLUTIONS KFT. in the forms located in the App are necessary to comply with the purpose stipulated in contract or in any relevant law.

Therefore, if the user does not submit such data, DIGITAL LANGUAGE SOLUTIONS KFT. will not be able to manage its services or the raised query.

Where the process of data is not necessary for the fulfillment of the contract and contractual obligations, and legal processing is not necessary for compliance with any kind of legal obligation that the data controller is the subject of, data controller processes your data regarding you expressed consent and approval. These consent-based data processing happens for example when you voluntarily contact the data controller and supply additional identifiable data to it.

7. USERS’ RIGHTS

The user may, at any time and free of charge, exercise his or her rights to access, to rectification, to erasure, to restriction, to data portability and to object by raising request to the postal or the e-mail addresses above-indicated in the terms established by the current legislation ensured in Articles 15-22 of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation- GDPR).

Data controller in all cases shall without delay within 30 days from the receipt of the User’s request provide information to the User and on the applied measures. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

The compliance of such requests is free of charge, but in case the request is unfounded or – considering its recurring manner – exaggerated, the data controller may charge with a reasonable fee to cover its administrational costs.

In case a doubt occurs in connection with the identity of the user further identifying information shall be asked from the User.

The user shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; to the source of the data; the existence of automated decision-making, including profiling, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

The controller shall provide a copy of the personal data undergoing processing.

The User shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. the User withdraws consent on which the processing is based;
  3. the User objects to the processing
  4. the personal data have been unlawfully processed;
  5. the personal data have to be erased for compliance with a legal obligation;
  6. the personal data have been collected in relation to the offer of information society services.

Data controller shall not erase the requested data, if to the extent that processing is necessary

  1. for exercising the right of freedom of expression and information;
  2. for compliance with a legal obligation which requires processing or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for reasons of public interest in the area of public health;
  4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes,
  5. for the establishment, exercise or defense of legal claims.

The data controller shall communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The data controller shall inform the data subject about those recipients if the data subject requests it.

The data subject shall have the right to object, at any time to processing of personal data concerning him or her, including profiling. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided. In exercising his or her right to data portability the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

At all events, hereby the user becomes informed that where he or she considers that DIGITAL LANGUAGE SOLUTIONS KFT. has violated or may have violated the rights granted by the applicable legislation on data protection, he or she may file a claim before the Hungarian National Authority for Data Protection and Freedom of Information (E-mail ugyfelszolgalat@naih.hu; Postal address: 1363 Budapest, Pf.: 9.; Official gate: NAIH, KR ID: 429616918; Telephone: +36 (30) 683-5969, +36 (30) 549-6838, +36 (1) 391 1400 , Facsimile: +36 (1) 391-1410; Address: 1055 Budapest, Falk Miksa utca 9-11., Hungary).

Furthermore, in case you experience unlawful data processing you can commence a civil lawsuit as well. By accepting the present Privacy Policy, you accept the jurisdiction of the Courts of Hungary and the exclusive competence of Miskolc Court of Appeal.

8. WITHDRAWAL OF CONSENT

Where the processing is based in your consent and does not affect to the data necessary to perform a contract between DIGITAL LANGUAGE SOLUTIONS KFT. and the data subject, the consent of the user to the processing of his or her data shall always be reversible, without retroactive effects. In order to withdraw said consent the users may address DIGITAL LANGUAGE SOLUTIONS KFT. by means of the channels above-mentioned.

9. LIMITATION OF LIABILITY

Data controller shall not be liable for the authenticity and accuracy of the data provided by the User, since it doesn’t verify such data. The data controller shall not be liable for the handling of incorrect or untrue data provided by the User, nor for any damage caused to the User or to any third party, as a result of the provided incorrect or untrue data.

The data controller shall not be liable for the loss of data stored on the User’s device or modified phone software. The data controller disclaims all direct and indirect liability for any damage and inconvenience resulting from the use of the Application (except Art. 6: 526 of the Hungarian Civil Code), including information generated from the comparison of anonymous data and obtained through the Application.

10. DEADLINE FOR THE STORAGE OF YOUR DATA

DIGITAL LANGUAGE SOLUTIONS KFT. shall store the personal data of the users for as long as it is deemed necessary to accomplish the purposes for which they were collected. In those cases where a relevant legal regulation requires we may process your data for the term, which is required by the relevant regulation.

All unnecessary data shall be erased immediately.

11. STORAGE AND SECURITY OF YOUR INFORMATION

Data controller stores all data on its safe server.

Data controller uses the latest administrative, technical, and physical security measures to help protecting your personal information. While data controller has taken reasonable steps to secure the personal information you provide to it, please be aware that despite its efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, data controller cannot guarantee complete security if you provide personal information.

12. SHARE OF DATA AND THE DISCLOSURE OF INFORMATION

DIGITAL LANGUAGE SOLUTIONS KFT. does not transfer personal data to third parties, except the ones listed in the present Privacy Policy. Nevertheless, where required by an agreement enforceable between the parties or by the law, DIGITAL LANGUAGE SOLUTIONS KFT. may be obliged to communicate personal data to third parties such as Courts or Tribunals.

Likewise, personal data may be shared with suppliers who render their services to DIGITAL LANGUAGE SOLUTIONS KFT. In this respect, DIGITAL LANGUAGE SOLUTIONS KFT. guarantees that these suppliers shall always comply with the applicable legislation and that in no event shall DIGITAL LANGUAGE SOLUTIONS KFT. process the personal data for purposes other than the ones indicated pursuant this Privacy Policy. Data processors and their privacy policies are available at:

Hosting services of the website (www.talkatease.com) held at:
Name: Rackhost Zrt.
Address: 6722 Szeged, Tisza Lajos körút 41.
Company registration number: 06-10-000489
https://www.rackhost.hu/privacy-policy

13. TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Application to help customize the Application and improve your experience. When you access the Application, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Application. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Application and Website Analytics

We may also partner with selected third-party vendors, such as Google Analytics, Google Firebase, Facebook App Events to allow tracking technologies and remarketing services on the Application through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can install and/or update your settings for one of the following: Google Analytics Opt-Out Plugin, Google Ads Settings Page, Facebook settings page
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

14. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and our mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

15. CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:
Digital Language Solutions Kft.
Miskolc, Hungary, 3524 Leszih Andor utca 27. 4/4
Phone Number: +36 30 2869550
Email: info@talkatease.com

© Digital Language Solutions Kft. 2021
All rights reserved.