PRIVACY POLICY FOR PICTALK

Last updated on November 29, 2024

Thank you for choosing to be part of our Pictalk community ("company," "we," "us," "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or practices regarding your personal information, please contact us at alex@pictalk.org.

When you visit our website https://www.pictalk.org, our mobile application, and use our services, you entrust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We aim to explain as clearly as possible what information we collect, how we use it, and what rights you have regarding it. We hope you take the time to read this document carefully, as it is important. If you do not agree with any terms of this privacy policy, please stop using our Sites or Applications and our services.

This privacy policy applies to all information collected through our website (such as https://www.pictalk.org), our mobile application ("Applications"), and/or any related services, sales, marketing, or events (collectively referred to in this privacy policy as "Sites").

Please read this privacy policy carefully as it will help you make informed decisions regarding sharing your personal information with us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH OTHERS?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE PROTECT YOUR INFORMATION?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE UPDATE THIS POLICY?
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

Information collected through our Applications

In summary: We may collect information about you when you use our applications.

If you use our Applications, we also collect the following information:

Information collected from other sources

In summary: We may collect limited data from public databases, marketing partners, and other external sources.

We may obtain information about you from other sources, such as public databases, common marketing partners, as well as other third parties. Examples of information we receive from other sources include: social media profile information; marketing leads and search results and links, including sponsored ads.

2. HOW DO WE USE YOUR INFORMATION?

In summary: We process your information for purposes based on legitimate business interests, the performance of our contract with you, compliance with our legal obligations, and/or your consent.

We use the personal information collected through our Sites or Applications for various business purposes described below. We process your personal information for these purposes relying on our legitimate business interests ("Business Purposes"), to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or to comply with our legal obligations ("Legal Reasons"). We indicate the specific legal bases we rely on next to each purpose listed below.

We use the information we collect or receive:
• To facilitate account creation and the login process. If you choose to link your account with us to a third-party account (like your Google or Facebook account), we use the information you have authorized us to collect from those third parties to facilitate account creation and the login process.

3. WILL YOUR INFORMATION BE SHARED WITH OTHERS?

In summary: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold on the following legal bases:
• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

• Performance of a Contract: When we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

• Legal Obligations: We may disclose your information when we are legally obligated to do so to comply with applicable law, governmental requests, a judicial proceeding, a court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests: We may disclose your information when we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, and illegal activities, or as evidence in a lawsuit in which we are involved.

Specifically, we may need to process your data or share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, asset sale of the company, financing, or acquisition of all or a portion of our business by another company.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In summary: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use these technologies and how you can refuse certain cookies is described in our Cookie Policy: https://www.cookiepolicygenerator.com/live.php?token=xm3SQ9mQ110UGGl6SaepTxYTdsOTfYFP.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In summary: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the UK. If you access our Sites or Applications from outside the UK, please note that your information may be transferred, stored, and processed by us in our facilities and by the third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH OTHERS?" above), in other countries.

If you reside in the European Economic Area, these countries may not have data protection laws or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

EU-U.S. Privacy Shield Framework:

In particular, Pictalk complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States and has certified its compliance with it. In this regard, Pictalk commits to subjecting all personal information received from EU member countries, relying on the Privacy Shield Framework, to the applicable Principles of the Framework. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield list.

Pictalk is responsible for processing personal information it receives, under the Privacy Shield, and subsequently transfers that information to a third party acting as an agent on its behalf.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Pictalk is subject to the regulatory enforcement powers of the U.S. FTC. In certain situations, we may be required to disclose personal information in response to legal requests from public authorities, including to meet national security or law enforcement requirements.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In summary: We keep your information for as long as necessary to fulfill the purposes described in this privacy policy, unless the law requires otherwise.

We will only retain your personal information for as long as necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your personal information longer than the period during which users have an account with us.

When we no longer have a legitimate business need to process your personal information, we will delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE PROTECT YOUR INFORMATION?

In summary: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal information, the transmission of personal information to and from our Sites or Applications is at your own risk. You should only access the services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In summary: We do not knowingly collect data from children under 18 and do not market to them.

We do not knowingly solicit data from children under 18 and do not market to them. By using the Sites or Applications, you represent that you are at least 18 years of age or that you are the parent or guardian of such minor and consent to the use of the Sites or Applications by such minor in your charge. If we learn that personal information of users under 18 has been collected, we will deactivate the account and take reasonable measures to delete such data from our records quickly. If you become aware of any data we have collected from children under 18, please contact us at alex@pictalk.org.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In summary: In certain regions, such as the European Economic Area, you have rights that provide you greater access and control over your personal information. You can review, change, or terminate your account at any time.

In certain regions (like the European Economic Area), you have certain rights under applicable data protection laws. These rights 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) where 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 we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. However, please note that this will not affect the lawfulness of the processing before its withdrawal.

If you reside in the European Economic Area and believe that we are unlawfully processing your personal information, you also have the right to lodge a complaint with your local data protection authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Account Information

If you wish to review or modify 

the information of your account or terminate your account at any time, you can:
• Log in to your account settings and update your user account.

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and your information from our active databases. However, certain information may be retained in our files to prevent fraud, resolve issues, assist with investigations, enforce our Terms of Service, and/or comply with legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can generally choose to set your browser to remove cookies and reject cookies. If you choose to remove or reject cookies, this could affect the availability of certain features or services on our Sites or Applications. To opt out of interest-based advertising by advertisers on our Sites or Applications, visit http://www.aboutads.info/choices/. For more information, please review our Cookie Policy: https://www.cookiepolicygenerator.com/live.php?token=xm3SQ9mQ110UGGl6SaepTxYTdsOTfYFP.

Email marketing opt-out: You can unsubscribe from our marketing mailing list at any time by clicking the unsubscribe link in the emails we send or by contacting us using the contact details provided below. You will then be removed from the marketing mailing list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To unsubscribe in other ways, you can:
• Note your preferences when registering for an account on the site.

• Access your account settings and update your preferences.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

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

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In summary: Yes, if you are a California resident, you have specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, allows our users who are residents of California to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) that we have disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with whom we have shared personal information during the preceding calendar year. If you are a California resident and wish to make such a request, please submit your request in writing using the contact details provided below.

If you are under 18 years of age, reside in California, and have a registered account on the Sites or Applications, you have the right to request the removal of unwanted data that you publicly post on the Sites or Applications. To request the removal of such data, please contact us using the contact details provided below, and include the email address associated with your account and a statement that you reside in California. We will ensure that the data is not publicly displayed on the Sites or Applications, but please be aware that the data may not be completely or comprehensively removed from all our systems.

12. DO WE UPDATE THIS POLICY?

In summary: Yes, we will update this policy as necessary to remain compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revision" date, and the updated version will be effective as soon as it is accessible. If we make significant changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed about how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have any questions or comments about this policy, you can send us an email at alex@pictalk.org or by postal mail at:

Pictalk
13 rue Pierre Marion
Lyon, Rhône-Alpes 69005
France

If you reside in the European Economic Area, the "controller" of your personal information is Pictalk. Pictalk has appointed Alexandros SIDIRAS GALANTE as its representative in the EEA. You can contact him directly regarding the processing of your information by Pictalk, by email at alex@pictalk.org, or by postal mail at:

13 rue Pierre Marion
Lyon 69005
France

HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, to modify that information, or to delete it in certain circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.

This privacy policy was created with the help of the Termly Privacy Policy Generator.

Privacy Policy

This privacy policy (hereinafter the “ Privacy Policy ”) is defined by Pictalk (Pictalk Speech Made Easy), whose headquarters is located at 13 rue Professeur pierre marion – 69005 Lyon, and details how Pictalk collects and processes personal data of Users who have an account on the Service.

Pictalk is particularly committed to respecting the privacy of its Users and protecting their personal data. 

As the Data Controller, Pictalk processes the Personal Data of Users in accordance with the applicable national and European regulations, particularly the Data Protection Act and the General Data Protection Regulation (hereinafter “ GDPR ”).

By using the Service, Users acknowledge that they have read this Privacy Policy and accept its terms.

1. Definitions

 

Term	Meaning
Account	Refers to a valid account granting access to the services of the Service.
Personal Data	Refers to any information relating to an identified or identifiable natural person; a “identifiable natural person” is a person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements reflecting the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
Data Protection Act	Refers to the Law No. 78-17 of January 6, 1978 relating to information technology, files, and freedoms, as amended.
Data Controller	Refers to the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of processing; where the purposes and means of processing are determined by Union law or the law of a Member State, the Data Controller may be designated or specific criteria applicable to its designation may be laid down by Union law or the law of a Member State.
Service	Refers to the service offer Pictalk Buddy by Pictalk consisting of an agenda adapted for individuals with intellectual disabilities.
Processing of Personal Data or Processing	Refers to any operation or set of operations performed on Personal Data, regardless of the process used such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, transmission by transfer, dissemination or any other form of making available, alignment or combination, as well as locking, erasure or destruction.
User	Refers to any natural or legal person using our Service and belonging to one of the user profiles described in Article 4 of the General Terms of Use. A User must have an active Account to access the Service.

 

2. Nature of the Personal Data Collected

 

Users may view certain Personal Data concerning another User. A User may edit their own profile.

The personal data listed below is collected when creating the User's account and for using the Service :

•           Name and surname of the Representative or Accompanying Person

•           Email address of the Representative or Accompanying Person

•           Font size

•           Application language

•           Type of robotic voice

•           Location, date, and time of events

•           Description of images/pictograms

•           Images uploaded by the Representative or Accompanying Person

•           Labels for the pictograms

•           Browsing history and interactions with the application

•           IP address and information related to the connecting device.

 

The processing of this data is based on the legal ground of exercising a public interest mission of the Data Controller.

3. Purposes of Processing Personal Data 

The purposes of Processing Personal Data are to provide the following services :

4. Recipients of Personal Data

As the Data Controller, Pictalk only processes the Personal Data of Users strictly necessary for pursuing its internal purposes. This data may only be processed by employees in charge of the administration of the Service, within the limits of their respective roles. 

However, Pictalk may be required to disclose to third parties the Personal Data it processes when such communication is required by law, a regulatory provision, or a judicial decision, or if such communication is necessary to ensure the protection and defense of its rights. 

5. Retention Period of Personal Data

Pictalk retains Users' Personal Data for the duration of the Service and for 6 months following the end of the Service, subject to a User's request for deletion of their Personal Data. 

However, Pictalk may be required to retain Personal Data for a longer duration in accordance with its legal obligations.

6. Transfer of Personal Data outside the European Union

No transfer of Personal Data is made outside the European Union.

7. Security Measures 

Pictalk is committed to taking all appropriate technical and organizational measures to safeguard the confidentiality and security of Users' Personal Data and to protect them against any loss, theft, or unauthorized disclosure.

8. Exercise of Rights of Data Subjects 

In accordance with applicable legal and regulatory provisions, particularly the Data Protection Act and the GDPR, Users have the following rights :

·       Right of access (article 15 GDPR) and rectification (article 16 GDPR), updating, and completion of data ;

·       Right to erasure of personal data (article 17 of GDPR) ;

·       Right to withdraw consent at any time (article 13-2c GDPR) ;

·       Right to restrict data processing (article 18 GDPR) ;

·       Right to object to processing (article 21 GDPR) ;

 

We invite you to consult the website of the National Commission for Informatics and Liberties (CNIL) for more information on your rights.

Any User may exercise their rights by directly modifying information concerning them in the “My Profile” section. They may also exercise their rights by sending any questions or requests related to the processing of their Personal Data to the president of Pictalk.  This request should be sent to the following address :

·       By electronic means : alex@pictalk.org

If a User believes, after contacting Pictalk, that their rights have not been respected or that any data processing is not compliant with data protection regulations, they have the possibility to file an online complaint with the CNIL (https://www.cnil.fr/fr/plaintes).

9. Changes to the Policy 

This Privacy Policy may evolve to comply with legislative and regulatory changes. Any amendments will be notified via our Pictalk project website (https://www.pictalk.org/fr/privacy-policy) whenever possible, at least thirty days before they take effect.

In case of disagreement with the terms of the new Privacy Policy, the User has the option to delete their account under the conditions provided in the Terms.  

By continuing to use the Service after the new provisions come into effect, the User agrees to be bound by the new Privacy Policy. 

10. Applicable Law and Competent Jurisdictions 

This Privacy Policy is established in compliance with French law and the law of the European Union. French jurisdictions are territorially competent to hear any disputes concerning the Service.