TransTalk Privacy Policy

1. About This Policy

This Policy applies to information we collect through the App, through our websites, and through email and other electronic communications between you and TransTalk. It does not apply to information collected by third parties, including through any application or content that may link to or be accessible from the App. For the purposes of the EU/UK General Data Protection Regulation ("GDPR"), TransTalk is the controller of the personal information described in this Policy.

We comply with the Apple Developer Program License Agreement, the Google Play Developer Distribution Agreement, the Google Play User Data Policy, and applicable data protection laws, and we adhere to the principles of clear purpose, informed consent, minimum necessity, and transparency. Please read this Policy carefully before using the App. If you do not agree with this Policy, please do not use the App.

2. Information We Collect

To provide stable and secure real-time call translation services, we collect only the information necessary to deliver the Services, following the "minimum necessity" principle. Some of this information may be considered personal information or personal data under applicable laws, including the GDPR and the California Consumer Privacy Act ("CCPA"). This section explains what we collect and where it comes from.

2.1 Sources of Information

Some of the information we hold is provided directly by you, some is collected automatically when you use the Services, and our business partners and service providers may also provide us with information about you (including personal information). In providing the Services, or to make them easier for you to access, we may collect information, including personal information, from third parties and sources that we integrate into the Services.

2.2 Information You Provide

Account & identity information:

• Email address and verification code: collected when you register or log in with an email address, to complete registration, login verification, and password recovery.
• Account identifiers: we assign you an internal user ID and, for guest use, an anonymous device-linked identifier. Guest use does not require an email address.
• Third-party sign-in identifiers: if you sign in with Google or Apple, we receive an identifier and, where you consent, an email address from the authentication provider. We do not receive your password for those accounts.

Other information you voluntarily provide: when you provide feedback or submit suggestions, you may voluntarily provide your name and contact details so that we can communicate with you. This is optional and does not affect your use of the App's core services.

2.3 Call & Translation Information

• Call metadata: when you make or receive a translated call, we collect the account identifiers of the parties to the call (linked to your account), the call time, call duration, call type, translation language pair, and translation trigger records.
• Transcripts and translations: the resulting transcripts and translations are stored on our servers and linked to your account so that you can review them in the App. You can delete this content at any time through the in-app functionality.
• Local recordings: if you actively enable the "Call Recording" feature, the corresponding call audio is stored on your local device and is not uploaded to our servers.

2.4 Audio, Video & Device Permissions

When you use real-time translation, the call audio (from your device's microphone and from the other party) is captured and processed as described in Section 4.1. Permission requests are triggered only when you use the corresponding function, and the operating system displays its standard permission prompt before any access is granted. You may grant or deny permissions at your discretion, and you can adjust your device settings at any time. If you deny a permission, some features may not function, but unrelated features are unaffected.

Microphone permission notice. We ask for microphone permission so that the App can capture your voice during calls and translate it in real time. The permission prompt appears the first time you start a translated call or use a voice feature. We do not access your microphone until you grant permission and start such a feature, and we do not record in the background. If you decline, voice calls and live translation will not work, but you can still log in, view call records, and use other features. You can grant or revoke this permission at any time in your device settings (iOS: Settings > Privacy & Security > Microphone; Android: Settings > Apps > TransTalk > Permissions).

Camera permission notice. The App reserves camera access in preparation for future video-call features. The App does not currently provide video calling or any other camera-based feature, and it does not access your camera or store video content today. We do not turn on your camera in the background. When we release video-call features, we will ask for your permission at that time before accessing the camera, and you will be able to grant or revoke that permission at any time in your device settings (iOS: Settings > Privacy & Security > Camera; Android: Settings > Apps > TransTalk > Permissions). If you decline, video features will be unavailable, but voice calls and translation will continue to work.

Other permissions:

• Notifications: used to alert you to call events and service messages.
• Storage: used when you actively enable call recording to store audio on your local device.
• Network: used for account login, call connectivity, and real-time translation data transmission.
• App Tracking Transparency (iOS): used to request tracking authorization for personalized advertising.

2.5 Automated Information & Tracking Technologies

The tracking technologies described in this Policy may be deployed by us or by our service providers on our behalf. As you use the App, we and our service providers automatically collect device and network information ("Automated Information"), including:

• browser type and version (for example, Chrome version 104.0.5112.102 (Official Build) (64-bit));
• browser language (for example, English);
• the operating system used (for example, Windows 8);
• device make, model, and type;
• device settings and the online services used;
• device and advertising identifiers (such as IDFA on iOS and Android Advertising ID on Android, which are randomly generated numbers that you can reset in your device settings);
• network type, carrier, and time zone;
• IP address;
• dates and times of access; and
• usage events (for example, when you open a screen or tap a button) and subscription data.

Even if you have not authorized access to your device's location services, we may infer your approximate location (for example, country or city level) from the IP address used to connect to the Services, for service optimization, regional compliance, and security protection. We do not collect precise GPS location unless you separately grant access.

To match information about you (including personal information and Automated Information) that we or our service providers obtain from different sources or at different times, we or our service providers may assign you a special identifier by automated means. We will then use this information as described in this Policy.

Do Not Track. Our systems do not currently recognize browser "do-not-track" signals. You may, however, limit ad tracking or reset your advertising identifier in your device settings (on iOS: Settings → Privacy & Security → Tracking; on Android: Settings → Privacy → Ads). Disabling tracking may affect personalized advertising and ad reward eligibility.

2.6 Purchase & Subscription Information

Purchases of credits and subscriptions are processed by the Apple App Store or Google Play, not by us. We do not receive your payment card number or billing address. Neither Google nor Apple provides us with any personal information about you (such as your name, email address, or payment information); what is sent to TransTalk is merely an anonymous subscription ID or order ID. We receive that anonymous order or subscription identifier together with product/plan identifiers and purchase status, which we use to grant and manage credits, VIP benefits, and entitlements, and to handle support, fraud prevention, and refunds. If you create a TransTalk account, this de-identified subscription data is added to your record so that it can be shared across devices when you use your account. We maintain records of orders and transactions (including amount, currency, plan, and time) for accounting and legal-compliance purposes.

2.7 Advertising

To support the App's free services, we integrate third-party advertising platforms to display rewarded video ads through which you can earn free call credits. The App may access your device's advertising identifier (IDFA on iOS, AAID on Android) so that advertising partners can perform frequency capping, conversion attribution, and personalized ad delivery. This is a resettable identifier that you can reset or limit in your device settings at any time. Advertising platforms collect interaction data such as impressions, clicks, and watch duration for measurement and anti-fraud purposes. To issue ad rewards correctly, we transmit an anonymous user ID — not your email address or other directly identifying information — to the advertising platform for reward verification.

3. How We Use Your Information

• Providing and operating the Services: to make and receive translated calls; to perform speech recognition, machine translation, and text-to-speech; to save your translation history; and to deliver core features.
• Account management: to register and verify accounts, authenticate logins, reset passwords, provide customer care, and prevent account theft and abnormal login.
• Payments, credits, and subscriptions: to process orders and transactions, grant and manage credits and VIP benefits, verify purchases with app stores, prevent fraud, and handle refunds.
• Communications: to send you verification codes and service-related communications; with your consent where required, to send you information about our products and special offers.
• Service optimization and security: to provide a functional, user-friendly experience; to safeguard the App against cyber threats; and to detect, prevent, and address fraud, abuse, hacking, and other illegal activity.
• Analytics and improvement: to understand and evaluate how the Services perform and how users interact with the App (for example, when you open a screen, tap a button, accept a notification, upgrade, or otherwise interact with it); to measure the effectiveness of our communications and marketing; to better understand existing and prospective customers so that we can adjust our marketing; to develop and improve features and products; and to tailor the Services to you.
• Debugging: to detect and correct deficiencies in the App's intended and existing functionality.
• Legal and compliance: to comply with legal or regulatory requirements, judicial process, industry standards, and our company policies.

We may aggregate and/or de-identify information so that it can no longer be used to identify you, and use such information for legitimate business purposes such as statistical analysis and business planning. We will not use your call content or translation content for advertising or marketing purposes.

4. How We Share Your Information

Other than as described in this Policy, we do not share, transfer, or disclose your personal information to third parties without your consent. Wherever we share personal information, we require the recipient, by contract, to provide protection of your personal information that is the same as or equal to the protection described in this Policy, to act only on our instructions, and not to use your data for its own purposes (including not to use it to train their models). We may share information in the following circumstances.

4.1 Third-Party Translation API

To provide real-time translation, we transmit the minimum data necessary (the transcript text of the conversation) to our third-party translation API, which performs machine translation on our behalf. It processes this data as our service provider (processor) and does not use it for its own purposes or to train its models. Speech recognition, text-to-speech, and the text generation model used for the free AI practice call are performed within our own systems and are not sent to any third-party AI service. We share this data only as necessary to provide the translation feature you have requested.

4.2 Infrastructure, Connectivity & Other Service Providers

• LiveKit Cloud — provides the real-time media infrastructure for calls (room and real-time audio transport). Call audio passes through LiveKit Cloud's servers in order to connect the parties, and LiveKit receives the phone number that a call is placed to in order to establish the call. LiveKit does not perform speech recognition or translation and does not use your data for its own purposes.
• Other service providers: our affiliates and service providers that help us operate the Services, including cloud hosting and storage, customer communications and support, business analytics, measurement and attribution, and email delivery (for example, our email provider used to send verification codes).
• Advertising partners: as described in Section 2.7, we share device advertising identifiers and an anonymous user ID with advertising platforms to display rewarded ads and verify rewards.

4.3 Other Disclosures

• Legal, regulatory, and safety reasons: where required by law, regulation, or judicial or administrative authorities, or to protect our legal rights or the rights, property, or safety of you or others, or to investigate and address fraud and illegal activity.
• Corporate transactions: in connection with a merger, acquisition, reorganization, bankruptcy, liquidation, or sale of assets. Your information may be transferred as part of the transaction, and we will require the recipient to continue to comply with this Policy.

We do not sell or rent your personal information to third parties.

5. Legal Bases for Processing (EEA/UK)

If you are located in the European Economic Area or the United Kingdom, we process your personal information based on one or more of the following legal bases:

• Your consent: for example, for personalized advertising and for marketing communications. You may withdraw your consent at any time.
• Performance of a contract: to provide the Services you have requested (including the real-time translation feature) and to perform our agreements with you, including processing purchases and subscriptions.
• Legitimate interests: to operate and improve the Services, ensure security, and prevent fraud and abuse, where our interests are not overridden by your rights and freedoms.
• Legal obligation: to comply with laws and regulations to which we are subject.
• Vital interests: to protect your vital interests or those of another person in exceptional circumstances.

6. Your Privacy Rights

Depending on where you live, you may have the following rights:

• Access: you may view your account information, call records, and translation records within the App, and you may request a copy of the personal information we hold about you.
• Correction: you may request correction of inaccurate personal information.
• Deletion: you may delete your call records and translation content in the App, and you may request deletion of your account and related personal information, except where we are required by law to retain it.
• Withdrawal of consent and permissions: you may revoke device permissions (microphone, camera, storage, tracking) in your device settings, and you may opt out of promotional communications, at any time.
• Additional rights under the GDPR: if you are in the EEA/UK, you also have the right to data portability, to object to or restrict certain processing, and to lodge a complaint with your local supervisory authority.
• California rights (CCPA): if you are a California resident, you have the right to know the categories and specific pieces of personal information we collect, the sources and purposes, and the categories of third parties with whom we share it; the right to delete; the right to correct; and the right not to be discriminated against for exercising your rights. As described in Section 4, we do not sell your personal information.

To exercise these rights, contact us using the details in Section 13. Before responding, we may ask for identification and, where relevant, confirmation of account ownership in order to protect your privacy. We will respond within a reasonable period not exceeding 15 business days. If we update or delete your personal information, or if you choose not to share certain information with us, we may not be able to provide some Services or features.

Uninstall

You may deactivate your account by following the steps on the service settings screen, then remove the App using your device's usual uninstall procedure. Some identifiers associated with your mobile device may remain retained after you delete the App; if you reinstall the App on the same device, we may be able to re-link this identifier to your prior activity.

Email

You can unsubscribe from promotional emails at any time by following the instructions in any promotional email you receive, or by sending your request to the support email listed in Section 13. It may take up to ten business days to process your request. Even if you opt out, we may still contact you for administrative or transactional purposes relating to the Services.

7. Data Retention & Deletion

• Account information is stored for the duration of your account. If you delete your account, we will delete or anonymize your personal information after the deletion is completed, except where we are required to retain it by law.
• Call metadata, device, and network information are retained for a reasonable period (not exceeding 6 months) after the service ends, then automatically deleted or anonymized.
• Transcripts and translations are retained for the duration of your account. You may delete them at any time through the in-app functionality, and deletion takes effect immediately.
• Purchase and transaction records are retained as required for accounting, tax, fraud-prevention, and legal-compliance purposes.
• Advertising-related data is retained for a reasonable period for reward verification and then automatically deleted.

We may retain non-personally identifiable information for backup, archiving, fraud and abuse prevention, or analysis. You are responsible for backing up any call content you wish to preserve, for example by transferring it to your email or cloud storage.

8. Data Security

We employ industry-standard security measures, including encryption of sensitive data at rest, encryption in transit (TLS) for call audio and data, access controls, and security auditing, to protect your personal information from unauthorized access, leakage, tampering, or misuse.

However, no method of transmission or storage is completely secure, and we cannot guarantee that information will never be intercepted or accessed without authorization. You provide information to us at your own risk. You are responsible for protecting the confidentiality of your password and for all activity under your account. If we become aware of a security incident affecting your personal information, we will notify you and the relevant authorities as required by applicable law.

9. International Data Transfers

We operate globally, and our service providers may process your information in countries other than your own, including the United States. When we transfer personal information out of the EEA, the UK, or Switzerland, we use appropriate safeguards recognized under applicable law, such as Standard Contractual Clauses.

10. Children's Privacy

The Services are rated 4+ and are designed for a general audience. We do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian and believe that a child under 13 has provided us with personal information, please contact us at [email protected], and we will take steps to delete the information and deactivate the associated account as quickly as possible.

11. Links to Third-Party Content

The App or our websites may contain links to third-party websites, applications, or content that we do not own or control. Their privacy policies, not this one, govern their collection and use of your information. We encourage you to read the privacy policy of every third party carefully before providing personal information to them.

12. Changes to This Policy

We may change this Policy from time to time, so please be sure to check back periodically. When we make significant changes, we will endeavor to provide you with notice in advance by highlighting the change in the App, on our websites, or by email or other appropriate means. The "Last updated" date at the top of this Policy indicates when it was last revised. Your continued use of the App after the revised Policy takes effect will constitute your acceptance of the revised Policy. If you do not agree, you should stop using the App and may delete your account.

13. Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, or if you wish to exercise your personal information rights, please contact us at:

You may also wish to review the Terms of Service (EULA) and the Auto-Renewal Subscription Agreement, which govern your use of the App.