PRIVACY POLICY

 

Last updated May 24, 2024

 

 

This privacy policy (“Privacy Policy”) for VISIONFLOW PTE. LTD. (“we”, “us”, or “our”), describes how and why we might collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), such as when you:

  • Download and use our mobile application Talkit, our web-based Talkit, our Talkit for headset and other wearable devices or any other application of ours that links to this Privacy Policy
  • Engage with us in other related ways, including any sales, marketing, or events

As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Use.

 

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at Feedback@visionflow.ai.

 

 

TABLE OF CONTENTS

 

1. WHAT PERSONAL INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR PERSONAL INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

6. IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?

7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

8. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

12. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

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

 

 

1. WHAT PERSONAL INFORMATION DO WE COLLECT?

 

In Short: We collect personal information that you provide to us, personal information we collect when you use our Services and personal information we receive from other sources.

 

Personal information you disclose to us:

 

  • Account Information. We collect personal information that you voluntarily provide to us when you register on the Services, and/or when you participate in activities on the Services. Where applicable, we indicate whether and why you must provide us with your personal information, as well as the consequences of failing to do so. 
  • Social Media Login Information and other Third-Party Accounts. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X (Twitter), or other social media account. If you choose to register in this way, we will collect the personal information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below. When you register with us using an ID from other third-party accounts (e.g., your AppleID on iPhones or your Google account on Android phones), we will receive personal information from those third-party accounts such as your name, email address, gender, date of birth, profile photo, and friends.
  • Profile Information. We will also ask you for personal information to complete your profile, including your email address, country or region, username, language selection(s), learning preference (i.e., topic preference, learning motivations) and subscription plan. We may receive personal information about your passwords.
  • Communications. If you contact us directly or express an interest in obtaining information about us or our products and Services, we may receive additional personal information about you, such as your name, email address and the contents of a message or attachments that you may send to us. 

 

Personal information we collect when you use our Services:

 

Application and Website Information. If you use our application(s) or our website, we also may collect the following personal information:

  • Mobile and Desktop Device Information. We automatically collect device information (such as your mobile or Desktop device ID, model, and manufacturer), mobile advertising IDs, operating system, version information and system configuration information, device and application identification numbers, application installations, browser type and version, hardware model Internet service provider and/or mobile carrier and manufacturer, and Internet Protocol (IP) address (or proxy server), which we may use to infer your general location. If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s) and we will receive push notification tokens. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

 

This personal information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

Audio information. If you give us access to your microphones, we collect your voice information, such as content of spoken conversations, pronunciation and other related personal information.

Personal Information from Cookies and Similar Technologies. We and our third-party partners may collect personal information using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain personal information that is transferred to your computer’s hard drive. We and our third-party partners may also use pixel tags and web beacons on the Services. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect personal information about your browsing activities and to distinguish you from other users of the Services. This aids your experience when you use the Services and allows us to improve the functionality of the Services. Cookies can be used for performance management (i.e., collecting information on how the Services are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. 

Below is an overview of the types of Cookies we and third parties may use to collect personal information.

  • Strictly Necessary Cookies. Some Cookies are strictly necessary to make the Services available to you. We cannot provide you with the Services without this type of Cookies. 
  • Functional Cookies. Functional Cookies are used to recognize you when you return to the Services. This enables us to adapt our content for you and remember your preferences. 
  • Analytical or Performance Cookies. We also use Cookies for website analytics purposes to operate, maintain and improve the Services. We may use our own analytics Cookies or use third-party analytics providers.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential. You can find more information about your rights and choices, and how to block the use of certain Cookies in the section called “WHAT ARE YOUR PRIVACY RIGHTS?” below.

Personal information we receive from other sources:

 

Payment Information from Third-party Payment Processors. We may collect payment information from third party payment processors, like Apple App Store and Google Play Store.

 

Personal Information from Other Third Parties. If you choose to link our Services to a third-party account, we may receive personal information about you, including your profile information and your photo, and your use of the third-party account. If you wish to limit the personal information available to us, you should visit the privacy settings of your third-party accounts to learn about your options. 

If you choose to register with us using your existing social media account details, like your Facebook, X (Twitter), or other social media account, we will collect the personal information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

We may receive additional personal information about you from third parties such as data or marketing partners and combine it with other personal information we have about you. 

 

Referral Program. We may receive your name, phone number, and email address from one of your friends as part of our referral program.

 

 

2. HOW DO WE PROCESS YOUR PERSONAL INFORMATION?

 

In Short: We process your personal information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your personal information for other purposes with your consent.

 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To provide, maintain, improve, and enhance our Services. For example, to create and log in to your account, to keep your account in working order, to provide automatic speech recognition, language proficiency assessment and AI conversation services and to enhance the performance of ASR, dictation (or voice transcription) and natural language understanding features in our app.
  • To personalize your experience on our Services such as by providing tailored content and recommendations.
  • To understand and analyze how you use our Services and develop new products, services, features, and functionality.
  • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support.
  • To send you invitation codes or invitation links to encourage you to invite new users.
  • To send you notifications via mobile phones or emails.
  • To find and prevent fraud and abuse, and respond to trust and safety issues that may arise.
  • For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
  • For other purposes for which we provide specific notice at the time the personal information is collected.
  • To save or protect an individual's vital interest. We may process your personal information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

 

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

 

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

 

The General Data Protection Regulation (“GDPR”) and United Kingdom (“UK”) GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your personal information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Contractual Necessity. We may process your personal information where required to provide you with the Services. For example, we may need to process your personal information to respond to your inquiries or requests.
  • Legal Obligations. We may process your personal information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your personal information as evidence in litigation in which we are involved.
  • Legitimate Interests. We may process your personal information where we or a third party have a legitimate interest in processing your personal information. Specifically, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Services. We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests. 
  • Vital Interests. We may process your personal information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

 

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this Privacy Policy, since we determine the means and/or purposes of the data processing we perform. This Privacy Policy does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your personal information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

 

 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share personal information in specific situations described in this section and/or with the following third parties.

 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“Third parties”) who perform services for us or on our behalf and require access to such personal information to do that work. We have contracts in place with our Third parties, which are designed to help safeguard your personal information. The Third parties we may share personal information with are as follows:

  • Cloud Computing Service providers such as Microsoft Azure and AWS. You can learn more about Microsoft’s practices by visiting https://privacy.microsoft.com/en-us/privacystatement and about AWS by visiting https://aws.amazon.com/privacy/. 
  • Payment processing vendors such as Apple and Google. You can learn more about Apples’ practices by visiting https://www.apple.com/legal/privacy/en-ww/ and about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.
  • AI-powered conversational service providers such as Microsoft, OpenAI, Elsa speak and Isuntone. You can learn more about Microsoft’s practices by visiting https://privacy.microsoft.com/en-us/privacystatement; about OpenAI by visiting https://openai.com/policies/privacy-policy/; about Elsa speak by visiting https://elsaspeak.com/en/privacy/.
  • Text-To-Speech (TTS) vendors such as Elevenlabs to synthesitze a unique voice based on your speaking voice to create an avatar for you and facilitate virtual social interactions within the app. You can learn more about Elevenlab’s practices by visiting https://elevenlabs.io/privacy. 
  • Third-party SDK service providers. We work with third-party SDKs such as CrashSight, provided by Shenzhen Tencent Computer Systems Co., Ltd, to primarily collect app crash data and monitor device temperatures. CrashSight processes WiFi status, mobile phone model, operating system, third-party developer custom logs, Logcat logs, APP crash stack information. The purpose of the processing is to: Provide developers with the ability to capture and report crashes, errors, OOM and other information, and support full-platform, multi-language, and multi-engine access. You can learn more about CrashSight’s practices by visiting their website https://crashsight.qq.com/ and their privacy policy https://crashsight.qq.com/welcome#/policy. We also work with third-party push service providers such as Aurora to primarily send push notifications to our mobile applications (both on iOS and Android). You can learn more about Aurora’s practices by visiting https://www.engagelab.com/license/privacy.  
  • Social Networks and other online service providers. Our Services allow you to, upon your direction, disclose personal information such as your conversation scores and your own achievements to social networking services, such as X, Facebook and Instagram. You understand and agree that the use of your personal information by any social networking websites will be governed by the privacy policies of these third-party platforms and your settings on that platform. We encourage you to review their privacy policies.

 

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your personal information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your personal information to service providers, advisors, potential transactional partners, or other Third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your personal information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable personal information was collected.

Consent. We may also disclose your personal information with your permission. For example, if you consent to participate in the arena to compete against other users, your voice when you are speaking during a particular dialogue task will be audible to the user you are competing against.

Affiliates. We may share your personal information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

 

 

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

 

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain personal information about you.

 

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X (Twitter) logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other personal information you choose to make public on such a social media platform.

 

We will use the personal information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their Privacy Policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

 

 

6. IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?

 

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

 

Our servers are located in Switzerland. If you are accessing our Services from outside Switzerland, please be aware that your personal information may be transferred to, stored, and processed by us in our facilities and by those Third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in other third countries.

 

If you are a resident in the European Economic Area (“EEA”), UK, or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

 

We may transfer personal information from the EEA or the UK to the United States and other third countries based on European Commission-approved or UK Government-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws.

 

We have implemented measures to protect your personal information, including contracts such as the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. For more information about the tools that we use to transfer personal information, you can contact us as described below.

 

Update Your Personal Information. You can update your account and profile information or close your account through your profile settings or by sending an email to feedback@visionflow.ai with your request.

 

 

7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

 

In Short: We keep your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

 

We will only keep your personal information for as long as it is 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). In principle, we aim to retain your personal information for no longer than twelve (12) months past the termination of the user's account.

 

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

 

8. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?

 

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

 

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your personal information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your personal information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

9. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short: In some regions, such as the EEA, UK, and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

 

In some regions (like the EEA, UK, and Switzerland), 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; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?” below.

 

We will consider and act upon any request in accordance with applicable data protection laws.

 

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

 

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

 

Withdrawing Your Consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?” below.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Opting Out of Marketing and Promotional Communications. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

 

Reviewing or Changing Your Account Information. If you would at any time like to review or change the personal information in your account or terminate your account, you can contact us using the contact information provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?” below.

Upon your request to terminate your account, we will deactivate or delete your account and personal information from our active databases. However, we may retain some personal information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

 

How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Services. By using the Services, you consent to our use of Cookies and our processing of personal information collected through such Cookies, in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse the Services using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store personal information on your device, you should change your browser settings accordingly. You should understand that some features of the Services may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

If you choose not to provide us with personal information we collect, some features of the Services may not work as intended.

If you have questions or comments about your privacy rights, you may email us at Feedback@visionflow.ai.

 

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 you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage 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.

 

11. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

 

In Short: Yes, we will update this Privacy Policy as necessary to stay compliant with relevant laws.

 

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material 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 of how we are protecting your personal information.

 

12. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

 

If you have questions or comments about this Privacy Policy, you may contact our Data Protection Officer (DPO), Liubo, by email at liubo@visionflow.ai, or contact us by post at:

 

VISIONFLOW PTE.LTD.

6 SHENTON WAY #37-03 OUE DOWNTOWN SINGAPORE (068809)

 

If you are a resident in the EEA, we are the “data controller” of your personal information. You can contact them directly regarding our processing of your personal information, by email at liubo@visionflow.ai, or by post to:

 

VISIONFLOW PTE.LTD.

6 SHENTON WAY #37-03 OUE DOWNTOWN SINGAPORE (068809)

 

EU Representative. Pursuant to Article 27 of the GDPR, we have appointed VeraSafe Ireland Ltd. (“VeraSafe EU ”) as our GDPR representative in the EU. You can contact VeraSafe EU regarding matters pertaining to the GDPR by using VeraSafe EU’s online request form, or writing to VeraSafe EU at VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland.

 

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

 

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that personal information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.