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Last Updated: September 1, 2023
Table of Contents:
1. Overview of this Policy
This Privacy Policy (this “Policy”) relates to the personal information that you submit when you access and use New Terra LLC d/b/a Real Talk (“Real Talk,” “we,” “us,” or “our”) tools and services (our “Services”) through our Website, Community platform and other experience platforms (collectively referred to as the “Platform”) and other information we automatically collect when you access the Platform. This Policy explains all activities regarding your information, including but not limited to how we collect, use, disclose, and secure it and the rights available to you.
You are required to read, understand, and agree to how we process (collection, use, disclosure, security, etc.) your information in this Policy. You are also required to read our Terms of Service and print a copy of each for future reference. All defined terms not defined in this Privacy Policy shall have the meaning subscribed to them in the Terms of Service. By your use of the Platform and your submission of the requested personal information, you hereby agree to how we process your information as described in this Policy. If you do not agree, you should not use the Platform or submit information.
2. What information does Real Talk collect from you?
2.1 We collect information from and about users of our Platform:
  • Directly from you when you provide it to us.
  • Automatically when you use the Platform.
2.2 We do not collect special categories of personal data such as information relating to or about the below (“sensitive personal information”):
  • Social Security Number
  • Driver’s License and Passport Numbers
  • Account Numbers and credentials
  • Precise Geolocation
  • Health information
  • Credit or criminal records
  • Racial or ethnic origin
  • Political opinions
  • Membership of a political association, professional or trade association
  • Membership of a trade union
  • Religious beliefs or affiliations
  • Philosophical beliefs
  • Sexual orientation or practices
  • Biometric information
  • Contents of mail, email or text messages except for messages sent via the Platform
2.3 Information that you provide to us (“personal information”) when you register on our Platform may include:
  • First Name, Last Name.
  • Email Address.
  • Telephone number.
  • Profile Photograph
  • Birthdate
2.4 This information may also include:
  • Your conversations and messages within the Platform with other Participants.
  • Some of the Real Talk features may access and collect your current location data, including GPS coordinates or other similar information regarding the location of your device.
3. What does Real Talk use information collected for
Any information collected by us is for a purpose in relation to your use of our Platform, including:
  • Provide Services to you: We collect information to enable you to create an Account and use the Platform, send you email about your registration, perform tasks required to complete a transaction, provide customer support, or provide other types of customer relationship management and fulfillment.
  • Fulfilling legal and compliance obligations: We collect information to enable you to create an Account and use the Platform, send you email about your registration, perform tasks required to complete a transaction, provide customer support, or provide other types of customer relationship management and fulfillment.
  • To allow communication with you: We collect your email address and phone number to either directly, in the case of the Administrator, or indirectly, in the case of the Participant, (i) contact you regarding your use of our Platform, (ii) respond to your questions, complaints, and queries, and (iii) send you updates regarding our Services or this Policy and other agreements.
  • Analytics: We collect information for use in performing various types of analytics. For example, we use the information to analyze how visitors interact with our Platform, where visitors to our Platform arrive from and exit to, pages visited, links clicked, text entered and mouse movements to understand site usage, to detect fraud and potential threats and improve our Services.
  • Provide technical support. We collect information to optimize or improve our Platform and operations, for example, training and quality assurance, data analysis, audits, developing new products, enhancing our Services, improving our products and/or Platform, and identifying Platform trends.
  • For other purposes through your consent: We may collect process your information for some other reasons which your consent will be sought before we process such information.
We may use anonymous information that we collect from you for any legal purpose whatsoever, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as your personal information). If we combine your information that is not in a personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as your personal information as long as it is combined.
4. Do third parties collect or use information?
  1. When you use the Platform, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:.
    • The services providers in Section 4.4 below.
    • Analytics companies.
  2. These third parties may use tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, and other online services or websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
  3. We do not control these third parties tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
  4. Third-Party Software/Services.We use the following third-party software/services to collect and process your personal data for the following reasons:
    • Stripe: Your Community may use Stripe as a payment processing merchant to receive payment from you during your use of the Services. We do not collect any payment data, including credit cards, but rather it is sent directly to Stripe.
    • Agora: We currently use Agora as our video livestreaming platform to provide the Services through the Platform. We reserve the right to record and store the videos.
    • Google Firebase: We use Google Firebase to collect and analyze user analytics from our Platform.
    • Dynatrace: We use Dynatrace to monitor user information and ensure the Services are operating properly.
    • Jira: We use Jira to facilitate support tickets about the Platform. They are associated with your user id and username.
By using and continuing to use the Platform, you agree to all privacy policies and other terms of these third-party software/service companies.
5. How personal data is collected?
5.1 Active Collection.Some of our Services may ask you to submit your personal information in order for you to benefit from the specified features. We collect personal information from you only when you voluntarily submit it to us, such as when you:
  • Become a User.
  • Submit materials through our Services.
  • Complete a service request or registration, survey, application or other form.
  • Purchase a product or service from us or from one of our vendors, suppliers or other agents.
  • Sign-up to receive email newsletters or other correspondence.
  • Request materials from us.
  • Request e-mail, mail or telephone support or services.
You will be informed on what information is required and what information is optional at the time of your submission including, but not limited to, your registration and/or contact us submissions to us.
5.2 Passive Collection.As you use our Services, we may passively collect (that is, gathered without you actively providing the information) non-personal identifiable information and/or use the following technologies which collect such information on our behalf:
Browser and/or Device Information
Certain information is collected from most browsers, such as your IP address, your media access control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, internet browser type and version. We also may collect information about any mobile device used to access our Services, such as a unique device identifier and type if you access our Services through a mobile device. Your IP address is a number that is automatically assigned to your computer or device by your Internet Service Provider. An IP address is identified and logged automatically in our server log files whenever a user accesses our Services, along with the time and date of the visit and/or use and the page(s) and/or features that are visited and/or used. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites and/or services.
Services Usage Data
When you access our Services, we and our service providers may track and collect application and/or Services usage data, such as date and time that your devices access our servers and what information and files have been downloaded and/or uploaded to our Services on your device number.
The Services use cookies (including Flash cookies).
A cookie is a small, removable data file that is stored by your web browser or application on your computer and/or device. Cookies allow us to collect various information including, but not limited to, browser type, time spent on our Services, features and pages visited, and language preferences. We and our service providers use this information for security purposes, to facilitate navigation, display information more effectively, serve you with more tailored information, facilitate your ongoing access to and use of our Services and to personalize your experience while using our Services. We also use cookies to recognize your computer and/or device, which makes your use of our Services easier, such as to help you log into our Services.
You can choose to have your computer and/or device warn you each time a cookie is being sent to your computer and/or device or you can choose to turn off all cookies. You do this through your computer and/or device settings. If you turn cookies off, you will not have access to many features that make your use of our Services more efficient and enjoyable, and in some cases, some of our Services will not function or will function with limited capability.
Pixel Tags, web beacons, clear GIFs and other similar technologies.
We and our service providers may use pixel tags, web beacons, clear GIFs and other similar technologies in connection with some of our Services (including email messages) to, among other things, analyze our users’ behavior and information about them, track the actions of the users of our Services and/or recipients of our emails, and compile statistics about our Services usage and response rates.
6. Sharing information and disclosure
We disclose your personal information collected from you though our Services to third parties in the following manner and for the following reasons:
  • To your Community Administrator, so that you can access and use the Services.
  • If you have consented to such disclosures.
  • If there are special circumstances, including, but not limited to, any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or membership interest (including in connection with a bankruptcy, liquidation or similar proceeding) and the due diligence related to such circumstances.
  • If the third party is our service provider who provides services to us in connection with our Services including, but not limited to, website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer services, email and direct mail delivery services, credit card processing, auditing services and other services.
  • If the party is our affiliate, in which case we are the party responsible (or data controller) for the management of the jointly used personal information.
  • Upon request by the government (including, but not limited to, the investigatory and enforcement powers of the Federal Trade Commission and other administrative bodies).
  • As permitted by applicable law.
  • In response to a court order or other legal process.
  • When required by law or when we believe in good faith is required by law.
  • To enforce our Privacy Policy, Terms of Service or other agreements and polices applicable to our Platform.
  • To protect our operations, rights, privacy, safety and/or property.
  • To contact, identify or bring legal action against someone who may be causing injury to or interference with our or others’ rights or property including, but not limited to, claims for infringement of intellectual property, invasions of privacy or situations involving threats or alleged threats to the physical safety of a person’s property; or companies assisting in fraud protection or investigation.
We also may provide aggregated, non-personally identifiable information to third parties for any legal purposes whatsoever.
7. Protecting your information
We use commercially reasonable efforts to safeguard and secure your personal information while stored on our computer systems and/or transmitted to or from our computer systems. Regardless of these efforts by us, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform. If you have reason to believe that your interaction, stored data and/or transmissions to and with us are no longer secure (for example, if you feel that the security of any account that you have with us has been comprised), please immediately notify us of the problem by contacting us immediately at privacy@realtalk.dog.
Some features of our Services may require you to set up a user ID and password. We recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited telephone call or email. If you suspect you have received a fraudulent communication from us or any of our affiliates, please contact us immediately at privacy@realtalk.dog.
Do not provide your personal or financial information in response to an email request or after clicking on a link from an email. We do not ask for this type of information through an email or any communication.
To help protect your computer and personal information, make sure you have current anti-virus and firewall software installed on your computer and update such software on a regular basis. Also, please review your credit card statements carefully and verify that all transactions are authorized and report any discrepancies immediately to your credit card company.
8. Children’s online privacy
The Community Administrator is responsible for ensuring that all Users are either over the age of 13 or have a parent’s permission. We do not knowingly collect personal information from children under the age of 13 without a parent’s permission. The Services are not intended to solicit information of any kind from children under the age of 13, and we have made commercially reasonable efforts to design the Services to prevent our knowing acceptance of any such information.
It is possible that by fraud, deception or error, we may receive information pertaining to children under the age of 13. If we are notified of this, as soon as we verify the information, we will immediately obtain parental consent or otherwise delete the information from our servers. If you want to notify us of our receipt of personal information belonging to a child under the age of 13, please do so at privacy@realtalk.dog.
9. Cross-Border Transfer
The Platform is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your personal information may be stored and processed in any country where we have facilities or service providers, and by using the Platform or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including the United States, which may provide for different data protection rules than in your country. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards or obtain your consent. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
10. California Privacy Rights
If you are a resident of the State of California, you may exercise the rights described below. By choosing to exercise your rights as described below, you are declaring that you are a California resident as defined in the California Consumer Privacy Act of 2018, Civil Code Section 1798.100 (“CCPA”).
Your RightsDescription
Disclosure of Personal Information We Collect About You
You have the right to know what personal information we collect.
  • The categories of personal information we have collected about you, including sensitive personal information
  • The categories of sources from which the personal information is collected
  • The categories of third parties to whom we disclose personal information, if any –and–
  • The specific pieces of personal information we have collected about you
Please note that we are not required to:
  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–
  • The categories of third parties to whom we disclose personal information, if any –and–
  • The specific pieces of personal information we have collected about you
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose
While we are required to provide this notice, we do not sell any personal information.
In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
  • The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–
  • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose
You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.
To opt-out of the sale or sharing of your personal information, privacy@realtalk.dog.
Right to Limit Use of Sensitive Personal Information
You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
  • Perform the Services or provide the goods reasonably expected by an average consumer who requests those goods or Services
  • To perform the following Services: (1) Helping to ensure security and integrity to the extent the use of the User's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a User's current interaction with the business, provided that the User's personal information is not disclosed to another third party and is not used to build a profile about the User or otherwise alter the User's experience outside the current interaction with the business; (3) Performing Services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–
  • As authorized by further regulations
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
To limit the use of your sensitive personal information, please email privacy@realtalk.dog.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
  • Delete your personal information from our records –and–
  • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort
Please note that we may not delete your personal information if it is reasonably necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us
  • Help to ensure security and integrity to the extent the use of the User's personal information is reasonably necessary and proportionate for those purposes
  • Debug to identify and repair errors that impair existing intended functionality
  • Exercise free speech, ensure the right of another User to exercise his or her right of free speech, or exercise another right provided for by law
  • Comply with the California Electronic Communications Privacy Act
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
Right of Correction
If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation
You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
  • Deny goods or services to you
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
  • Provide a different level or quality of goods or services to you –or–
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Please note that we may charge a different price or rate or provide a different level or quality of Services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Exercising your Rights. If you wish to exercise one of these rights, please contact us as described herein or email us at privacy@realtalk.dog. Please include your name and email address with your request. Before we can process any such request, we will need to verify your identity through the email address or telephone number associated with your use of our Platform or your account with us and confirm your request prior to fulfilling any such request and reserve the right to deny a request where we are unable to satisfactorily complete this process. If you authorize someone to make a request on your behalf, we may also deny your request if we are unable to verify that the individual making the request is authorized to act on your behalf.
You can also submit a complaint to the California Office of the Attorney General. For more information on the California Consumer Privacy Act please visit https://www.oag.ca.gov/privacy/ccpa.
11. GDPR Privacy Rights
If you are a resident of the European Union or the United Kingdom, you may exercise the rights described below.
Your RightsDescription
Right to Be Informed
The right to know or be notified about the collection and use of your personal information.
Right to Access
The right to be provided with a copy of your personal information (the right of access)
Right to Rectification
The right to require us to correct any mistakes in your personal information
Right to be Forgotten
The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability
The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object
The right to object:
  • At any time to your personal information being processed for direct marketing (including profiling)
  • In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.
If you wish to exercise one of these rights, please contact us as described herein or email us at privacy@realtalk.dog. Please include your name and email address with your request. Before we can process any such request, we will need to verify your identity through the email address or telephone number associated with your use of our Platform or your account with us and confirm your request prior to fulfilling any such request and reserve the right to deny a request where we are unable to satisfactorily complete this process. If you authorize someone to make a request on your behalf, we may also deny your request if we are unable to verify that the individual making the request is authorized to act on your behalf.
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority can be found here (https://edpb.europa.eu/about-edpb/about-edpb/members_en).
12. Your rights with respect to personal data
  • You can review and change your personal information by logging into the Platform and visiting your account settings page.
  • You may also send us an email at privacy@realtalk.dog to request access to, correct, or delete any personal information free of charge that you have provided to us. We cannot delete your personal information except by also deleting your user account.
  • We will respond to a request to access, correct, or delete any data within 30 days of the date we receive the request.
  • We may not accommodate a request to change information if we believe the change would violate or breach any law or legal requirement or cause the information to be incorrect.
  • If on your request, we refuse to amend, correct, or delete your personal information, we will set out our reasons for not doing so and provide you with details of how you may complain about our refusal.
  • If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Contributions, is governed by our Terms of Service.
13. How long is personal data kept?
We will only retain personal data for as long as is reasonably necessary. Upon deletion of an account, all personal data will be removed as soon as possible, and always within 90 days of the deletion.
14. Do not track disclosure
Third parties such as advertising networks, analytics providers, and widget providers may collect information about your online activities over time and across different websites when you access or use our Services.
15. Changes to our privacy policy
It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Platform home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Platform home page. Please take a look at the “LAST UPDATED” legend on the top of this page to see when this Privacy Policy was last revised. Any such change shall be effective immediately upon posting of the revised Privacy Policy within our Platform. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this privacy policy to check for any changes.
16. Contact us with questions and feedback
We welcome your questions, comments, and concerns about this Privacy Policy and our privacy practices. Please email us at: privacy@realtalk.dog.
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