Privacy Policy
VERSION 3 - 14 September 2023
Privacy statement
TALK Sàrl (hereinafter referred to as "TALK" or "we") is a company whose purpose is to provide services in the fields of training, communication, media strategy and content production (hereinafter referred to as the "Services") to its clients (hereinafter referred to as the "Clients" or "you"). Among these Services, we provide the TALK application, which enables simultaneous analysis of relational and communicational phenomena and the development of various self-leadership skills. It is available on the Apple Store and Google Play and can be used on computers, mobile phones and tablets as well as a web application (hereinafter referred to as the "Application"). TALK also offers seminars and masterclasses in areas such as leadership, personal communication, public speaking and media training (hereinafter referred to as "Training").
In the context of the processing of personal data referred to in this privacy statement (hereinafter: the "Privacy Statement"), TALK acts as data controller. In this context, the protection of your data is at the heart of our ethical principles. We apply the principle of minimising personal data as strictly as possible and only process personal data that is necessary for the purposes for which it is to be used.
The Privacy Statement sets out how we process and protect your personal data as data controller in connection with our Services, such as using the Application, participating in our Training courses and activities, visiting our website (talk.swiss) (hereinafter referred to as the "Website").
Therefore, if you have any questions about this Privacy Statement, or more generally about the protection of your personal data, you can contact us directly using the details below:
TALK Sàrl
Chemin de l'Aubépine 1
1350 Orbe
+41 24 441 63 63
direction@talk.swiss
The personal data we process
When you use the Application
When you subscribe to or use the Application, we collect a certain amount of personal data relating to your identity, in particular in order to establish your profile (first name, surname, etc.), as well as your contact details (e-mail address, postal address, telephone number, etc.), or your payment details. In addition, in order to provide you with its analysis, the Application processes data relating to your voice and image during video and/or audio recordings made on your computer device (your computer, tablet or telephone). This data is then automatically processed by the Application's algorithm to provide you with your results.
All of this data, including audio and/or video recordings of your voice and/or face, is necessary for TALK to fulfil its contractual obligations under the Services requested, in particular to provide you with the analyses and evaluations requested.
When you take part in our Training courses or activities
When you take part in one of our Training courses or in any of our activities (events, competitions, etc.) we must also process personal data relating to your identity (first name, surname, gender, etc.) as well as your contact details (e-mail address, telephone number, etc.) or your payment details, particularly if the Training course is subject to a fee. Other data relating to your participation may also be processed in this context, such as your presence or absence at the said events. It should be noted that, in the context of our Training Courses, you may be required to use the Application under the same conditions as set out above.
This data is necessary for TALK to fulfil its contractual obligations with regard to the organisation and follow-up of the said Training and activities. In principle, this data is provided voluntarily by you, but it is possible that personal data may be communicated directly by your employer to TALK with a view to your participation in our Training courses. It is your employer's responsibility to inform you of the terms of this Privacy Statement.
When you visit our website
When you browse and interact with our Website, its extensions or our social network pages, we collect certain information about your actions. This includes information such as the links you click on, the pages or content you view, the viewing time, the learning path, and other similar information and statistics about your interactions, such as content response times, download errors and the length of time spent on certain pages, the type of browser used or the place of connection. This information is captured using technologies such as cookies or web beacons. It is also collected through external tracking services (for example, Pixel Meta: for more information on how Meta processes data, click hereGoogle Analytics or Google Adwords: for more information on how Google processes data, click here).
In this context, our Website uses both cookies that are strictly necessary for its operation and that cannot be deactivated (for example, in order to remember your personal configurations), and cookies to help us understand how you use the Website in order to improve it, in particular cookies for statistical, advertising or audience measurement purposes. This data is processed to make it possible for you to browse the Website and also to improve it. For all cookies that are not strictly necessary for the operation of the Website, you may at any time determine your preferences and give or withdraw your consent for each type of cookie. The data collected by the necessary cookies is processed on the basis of our legitimate interest in ensuring the proper functioning of our Website and the other personal data is processed on the basis of your consent.
In addition, when you use the Website, we also collect data that you spontaneously provide to us via online forms (contacts, event registration, etc.). This data processing is based on your consent.
Finally, the Website may contain links to other websites. If you access other sites using the links provided, the operators of these sites may collect personal data which will be used in accordance with their own privacy policies. We are in no way responsible for the practices of other websites, particularly with regard to the protection of personal data, and encourage you to consult their respective privacy policies.
When you subscribe to the Newsletter
When you ask to receive our newsletter, we collect your e-mail address so that we can send it to you. A confirmation e-mail is sent to your address to ensure that we have your consent. This processing is based on your consent and you can unsubscribe from our newsletter at any time.
Shelf life
Unless we are required to do so by law or you request that we delete your data in the meantime, we will keep your personal data for the following periods:
- Data linked to the Application12 months since the last contact or last use of the Application
- Information on participation in our training courses and activities24 months
- Website usage data (cookies)13 months
However, they may be kept for a longer period if required by law or regulation. For example, the data required to keep accounts and accounting records is kept for 10 years (art. 958f CO).
Deleting data
You may delete data relating to your use of the Application (audio and/or video recordings, results, assessments, progress certificates, etc.) at any time, including individually. With the exception of data that has been anonymised and unless a law or overriding private or public interest prevents it, we do not keep any copies of your personal data once you have deleted it. In principle, a deleted record is lost forever.
To delete your account, go to "profile". This operation is irreversible and, unless a law or overriding private or public interest prevents it, all data relating to the use of the Application is destroyed (audio and/or video recordings, results, assessments, progress certificates, etc.).
Data security
The security of your data is our priority and we consider that your trust in us depends on it. This is why we ensure that you remain in control of your data and have established appropriate organisational and technical measures to prevent any data security breach.
For example, we encrypt your data, which is hosted in Switzerland within a cloud architecture that is secured by access requiring double authentication.
Data communication
We may use subcontractors and service providers, in particular technical and IT service providers, to the extent necessary to carry out the services entrusted to them. All our subcontractors are contractually bound to respect the confidentiality of your data and the laws applicable in this respect.
In addition, by providing us with your employer's contact details, in particular as your billing address, you expressly authorise us to communicate to your employer not only the information required for billing, but also other data relating to the courses (participation, duration, results, etc.).
If TALK were to be acquired by or merge with another company, we may need to disclose your data in order to ensure the continuation of the Services or to meet our obligations, including in the event of bankruptcy.
We may also transmit your data to third parties if required to do so by law or at the request of a judicial or administrative authority, to protect our rights or interests or to enforce the contract, to the extent permitted by applicable law.
Transmission abroad
With the exception of data from our website which may be processed by Pixel Meta and Google Analytics in the United States, we process and host your personal data in Switzerland or within the European Economic Area (EEA) (see: Appendix 1 to the Privacy Statement below).
If we need to use a foreign service provider located in a country that does not have an adequate level of data protection according to the competent personal data protection authorities, we will adopt the additional measures required by law before any communication of your data abroad, such as signing standard contractual data protection clauses.
Research and development
Your data may be used by us or partners for purposes that do not relate to individuals, in particular for research and statistical purposes. In such cases, your data will be anonymised as soon as possible and measures will be taken to ensure that the persons concerned cannot be identified. In all cases, the results will be published in a form that does not allow the persons concerned to be identified.
Your rights
You have the right to know what personal data is held about you and to obtain a copy of it, as well as the right to update, rectify, erase and limit the processing of your personal data. The data concerning you that you have provided to us will be given to you in a structured, commonly used and machine-readable format.
Subject to a legitimate reason justifying the processing, you also have the right to object to the processing of your personal data. Where processing is based on your consent, you may withdraw it at any time.
If you wish to exercise any of these rights, please contact us by writing to the details given below. supra. You also have the right to lodge a complaint with the competent supervisory authority for the protection of personal data.
Applicable law
Our activities are subject to the provisions of the Federal Data Protection Act (DPA). The competent supervisory authority for personal data protection is the Federal Data Protection and Information Commissioner (FDPIC).
If you reside within the European Economic Area (EEA), Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on data protection (RGPD) may apply, and the data protection supervisory authority of your place of residence may be competent.
Appendix 1
List of countries to which your personal data may be transferred:
Germany, Belgium, United States*.
This list will be regularly updated if necessary.
* Only in the case of use of our website via Google and Meta
