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Privacy Policy

Last Updated: May 30, 2025

UpTalk ("us", "we", or "our") operates the UpTalk mobile application (the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We are committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) and the laws of the Czech Republic.

1. Data Controller

The data controller responsible for your personal data is:

UpTalk
Vít Homolka
Via email: vit.homolka@uptalk.app

2. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Email address (if you create an account or contact support)
  • Usage Data (e.g., features used, game preferences, interaction patterns)
  • Device Information (e.g., device model, operating system version, unique device identifiers, IP address)

Usage Data

We collect information on how the Service is accessed and used ("Usage Data"). This Usage Data includes your device's Internet Protocol address (e.g., IP address), device type, operating system version, the features of our Service that you visit, the time and date of your visit, the time spent on those features, unique device identifiers, and other diagnostic data. This data helps us understand how users interact with our Service and to improve its functionality and user experience.

User-Generated Content

If you choose to create custom content within the app, such as personalized question packs ("User-Generated Content"), this content is stored on our servers, which are hosted on Google Cloud. We treat this content as your personal information.

Please be aware that User-Generated Content is subject to analysis for the purpose of detecting and preventing the creation and spread of harmful content, including but not limited to illegal, abusive, hateful, or explicit material, to maintain a safe and respectful environment for all users and to enforce our Terms of Use. This analysis may involve automated systems and, in some cases, human review if flagged by our systems or reported by users.

3. Legal Basis for Processing Personal Data

We process your Personal Data based on the following legal grounds under the GDPR:

  • Performance of a contract: To provide and maintain our Service, manage your account, and fulfill our obligations as per the Terms of Use.
  • Legitimate interests: To understand how our Service is used, improve our Service, provide customer support, ensure the security of our Service, detect and prevent fraud or technical issues, and to analyze and prevent the spread of harmful User-Generated Content. We ensure that our legitimate interests do not override your data protection interests or fundamental rights and freedoms.
  • Consent: In specific situations, we may ask for your consent to process your data (e.g., for certain types of marketing communications, if applicable). You can withdraw your consent at any time.
  • Legal obligation: To comply with applicable legal and regulatory obligations.

4. Use of Data

UpTalk uses the collected data for various purposes:

  • To provide and maintain the Service
  • To manage your account and your participation in the Service
  • To notify you about changes to our Service or Terms
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues
  • To analyze User-Generated Content for harmful material
  • To comply with legal obligations.

5. Data Storage, Security, and International Transfers

Your data, including Personal Data and User-Generated Content, is primarily stored and processed on servers provided by Google Cloud. Google Cloud implements robust security measures to protect data; however, no method of transmission over the Internet or method of electronic storage is 100% secure. We strive to use commercially acceptable means and industry best practices (such as encryption, access controls, and secure protocols) to protect your Personal Data, but we cannot guarantee its absolute security.

6. Data Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. User-Generated Content may be retained as long as your account is active or as needed to provide the Service, subject to your rights to deletion.

7. Service Providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services (e.g., hosting, data analysis, customer support), or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated (including through data processing agreements) not to disclose or use it for any other purpose.

Our primary service provider for data storage is Google Cloud.

8. Your Rights Under GDPR

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. UpTalk aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

  • The right to access: You have the right to request copies of your personal data.
  • The right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • The right to erasure (right to be forgotten): You have the right to request that we erase your personal data, under certain conditions.
  • The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions, particularly where we rely on legitimate interests.
  • The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
  • The right to withdraw consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time.

If you wish to exercise any of these rights, please contact us using the details provided in the "Contact Us" section. We may ask you to verify your identity before responding to such requests.

9. Children's Privacy

Our Service is not intended for individuals under the age of 15 ("Children"), which is the age of consent for information society services under GDPR as implemented in the Czech Republic. We do not knowingly collect personally identifiable information from anyone under the age of 15. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data without your consent (where applicable if the child is under 15), please contact us. If we become aware that we have collected Personal Data from children under 15 without verification of parental consent or another valid legal basis, we take steps to remove that information from our servers.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We may also provide notice through the Service or via email, especially for material changes. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

11. Governing Law

This Privacy Policy and any disputes related thereto shall be governed by and construed in accordance with the laws of the Czech Republic, without regard to its conflict of law provisions, and where applicable, the General Data Protection Regulation (GDPR).

12. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have any concerns regarding your data, please contact us:

Via email: privacy@uptalk.app