TalkLine Privacy Policy

Date of issuance: December 03, 2021

Date of effectiveness: December 03, 2021

Thank you for using TalkLine!

This Privacy Policy ('Policy') describes and defines how we collect, store, use, protect, transfer, and share your personal information when you sign up and use our Services, as well as your rights to your personal information.

Before using our Services, you must carefully read, fully understand, and accept this Policy, especially the content highlighted in bold or bold underscore.Please note that we shall review and update this Policy from time to time to account for changes in our collection and/or use of personal information. To keep aware of the latest version of this Policy, you may access this page regularly.

By using or continuing to use TalkLine, you acknowledge and consent that we can collect, use, store, and share your information according to this Policy.

This Policy covers the following topics:

1. The personal information we collect

2. How we store personal information

3. How we protect personal information

4. How we use personal information

5. How we share and disclose personal information

6. Your rights regarding your personal information

7. How we transfer your personal information globally

8. The emails and information we may send to you

9. How we process personal information of minors

10. Changes to this Policy

11. How to contact us

Terms and definitions:

TalkLine is a cloud video conferencing software for individuals and enterprises worldwide developed by Shenzhen ZEGO Technology Co., Ltd. ('ZEGO', 'we', 'us', or 'our'). Our products and services related to TalkLine include TalkLine Official website (https://www.talkline.cn) TalkLine Official website (https://www.talkline.cn)， TalkLine Administration Console (https://console.talkline.cn) TalkLine Administration Console (https://console.talkline.cn)， TalkLine Mini-Programand TalkLine client applications for different operating systems (including Windows, macOS, iOS, Android, and others). Collectively, we refer to these TalkLine related products and services as 'our Services'.

Enterprise Super Administrator: A TalkLine Enterprise User who is granted by ZEGO the privileges to operate the TalkLine Administration Console. Enterprise Super Administrators have the authority to invite and authorize individual users to join their organization in TalkLine, and to authorize individual users to become Enterprise General Administrators of their organization in TalkLine.

Enterprise General Administrator: A TalkLine Enterprise User who is granted by an Enterprise Super Administrator the privileges to operate the TalkLine Administration Console. Enterprise General Administrators have the authority to invite and authorize individual users to join their organization in TalkLine.

Personal User: Any individual who users our Services for their personal use.

1. The Personal Information We Collect

In order to provide our Services to you, optimize our Services, and protect the security of your account, we collect the information you voluntarily provide, authorize or generate when you register or use our Services, including the following:

1) Information collected during account registration

When you sign up to use our Services, we shall collect the following information from you:a)Your mobile phone number (may be used to allow other TalkLine users to find your account by searching for your mobile phone number in TalkLine);b)Your email address;c)Your WeChat account information;d)Other information that is necessary to register or log in to your TalkLine account.The above information is necessary for the use of our Services. If you do not provide such information, you will not be able to use our Services normally. If you provide information of any other individual, you must obtain consent from the relevant individual.In accordance with relevant laws and regulations, you may be required to verify your real name before you can use certain features and services. In order to meet these legal and regulatory requirements, we will collect your real name verification information.

2) Information collected while you are using our Services

To provide you with our Services, maintain the normal operation of our Services, improve and optimize our Services, and protect your account security, we shall collect the following information from you when you use our Services:

1. Device information: We shall collect information about the devices you use to access our Services according to the device model and the permissions you grant during your installation and use of our Services, including the device model, the operating system and its version, screen size, device serial number, MAC address, unique device identifier (IMEI, Android ID, IDFA, OpenUDID, IMSI of the SIM card), time zone, system language setting, and the version number of the TalkLine application.
2. Permissions to access the microphone and/or camera: When you use TalkLine's audio/video conferencing features, you need to grant TalkLine permissions to access the microphone and/or camera on your device If you do not grant such permissions, you will not be able to use any features that require access to the camera or microphone. When you use TalkLine's screen sharing or whiteboard sharing feature, TalkLine needs to capture audio/video data from the screen and/or any file you choose to share. While you are doing screen/whiteboard sharing using TalkLine, you can annotate on the screen and take screenshots (including whiteboard content being share), and such screenshots will only be saved locally on your device. When you use the QR code scanning feature, you need to grant TalkLine permission to access the camera; otherwise, TalkLine will not be able to scan the code and provide the result.
3. Permission to access the calendar: When you choose to add a TalkLine meeting to your calendar, we need to obtain read and write access to your calendar , otherwise, we will not be able to add the meeting schedule to your calendar.
4. Permission to access the photo album: When you choose to use TalkLine's custom virtual background feature, you will need to upload a photo or a video from your device as your personal virtual background, and TalkLine will request access to your device's photo album. If you do not provide the required information or refuse to grant album access, you will not be able to use the custom virtual background feature.
5. Permission to access device storage: When you use TalkLine's file sharing, meeting recording, uploading, and downloading services, you will need to grant TalkLine read and write access to your device's storage; otherwise, you will not be able to use such services.
6. Permission to read the phone state: When you use TalkLine's features such as meeting reminders and dial-in, TalkLine needs to get your phone's current state for making/receiving calls.
7. Log information: When you use our Services, we may automatically collect log information through web cookies, web beacons, and similar technologies, including the following:
   1. Activities of your account during your use of our Services, such as the meetings you attend and how you join them, login information, and others.
   2. Information about the meetings you schedule or live streaming sessions you create using our Services, such as the user accounts used to hold the meetings or live streaming sessions, and the associated data and time duration.
   3. Information (metadata) contained in the content you share through our Services, such as the shared files and recordings that you upload.
   4. Data about your media traffic while you are using our Services, which we collect for traffic monitoring purposes.
8. Get the software installation list: When you use TalkLine to log in WeChat or share the created meeting to WeChat or WeCom, we need to confirm the installation status of the above software for quickly switch between them and ensure the use of functions.

3) Information Collected by Third-Party SDKs (see Appendix I for details)

Please understand that the features and services we provide to you are constantly being updated. If a feature or service needs to collect information from you but is not included in the preceding description, we will separately explain the content, scope, and purpose of the information required through page prompts, interactive processes, website announcements, etc., and obtain your consent to our collection of such information.

4) Features for clearing cache and uploading logs

The following two features are provided in the Auxiliary tab of the TalkLine Settings window: a) Cache clearing: to clear the cached files generated from file sharing and audio/video downloads during your use of TalkLine; b) Log upload: to upload the logs (information about account activities, meeting information, uploaded files, media data, etc.) of the TalkLine app, which will be used to troubleshoot issues and optimize our services.

5) Application permission application and usage description (see Appendix II for details)

We may apply for or use the relevant permissions of the operating system to ensure the functions of TalkLine products and safe and stable operation; In order to protect your right to know, we display the relevant operating system permissions that may be applied for and used by the product through the list. You can manage the relevant permissions according to your actual needs; According to the product upgrade, the type and purpose of application and use permission may change. We will adjust the list in time according to these changes to ensure that you know the application and use of permission in time.

2. How We Store Personal Information

We use the information we collect for the following purposes in strict compliance with the laws and regulations and our agreements with our users. If we use your information for purposes other than the ones listed below, we will explain to you and ask for your consent.

1) Where the information is stored

In accordance with laws and regulations, the personal information we collect within the territory of the People's Republic of China will be saved in Shanghai, China.

For example, your personal information including phone number, email address, WeChat profile pictures, WeChat nicknames, region, gender, meeting information, shared files, media data, activities of your account, device model, device operating system, unique device identifier, and others will be stored in Alibaba Cloud's data center in Shanghai.

2) Retention of personal information

We retain your personal information only for as long as necessary to provide you with our Services and as described in this Policy. For example, the retention period of the device information and log information we collect from you is 6 months, and your account registration information will be retained until you cancel your account. After the retention period expires, we will delete your personal information accordingly, unless otherwise is required by laws and regulations.

In the case of discontinuation of our products or services, we will notify you by push notification, announcement, and other means, delete or anonymize your personal information within a reasonable period of time, and immediately stop the collection of personal information, as well as close the interfaces with third-party services to avoid the collection and continued use of personal information by third-party services.

3. How We Protect Personal Information

1) Proper and secure use of information

We strive to safeguard the security of our users' information to prevent loss, misuse, unauthorized access or disclosure.

2) Encryption technologies

We will use various security protections within a reasonable security level to keep information secure. For example, we use encryption technologies (e.g., SSL /TLS), anonymization processes, and other methods to protect your personal information.

3) Security certification

We have achieved multi-level protection scheme (MLPS) Level III certification in China.

4) Management system and process

We have established a dedicated management system, process, and organization to safeguard information security. For example, we strictly limit the scope of people who have access to information, require them to comply with confidentiality obligations, and conduct audits.

5) Remedial measures

In the event of personal information leakage and other information security incidents, we will start the emergency plan to prevent the incident from deteriorating, and inform you of the incident, the possible impact of the incident on you, and the remedial measures we will take by push notifications, announcements, and other means. We will also report our handling of such personal information security incidents in accordance with laws and regulations.

4. How We Use Personal Information

We collect information about you and your use of our Services in order to provide better services to our users. We may use the information we collect for the following purposes:

1) To safeguard information security

To protect the security of your information and that of all our users, we use relevant information to help us improve the security and reliability of our Services, including detecting, preventing, and responding to fraud, abuse of the system, illegal activities, security risks, and technical issues that could cause harm to TalkLine, our users or the public.

2) To communicate with you

We may use the information we collect from you (e.g., the email address, cell phone number, etc.) to communicate with you directly. For example, we may inform you about upcoming changes or upcoming improvements to TalkLine. We may use such information to gain more knowledge about how you access and use our Services so that we can manage and upgrade our Services to meet your needs in a more targeted way. We may also contact you to get your feedback on our Services.

3) To comply with laws and regulations

1. In accordance with the requirements of relevant laws, regulations, and government orders, we will not use your personal information for user profiling, personalized recommendations, or advertising purposes. If we need to use your personal information for purposes other than those stated at the time of collection and the directly or indirectly related purposes, we will inform you about such use of your personal information and obtain your explicit consent before using it.
2. In accordance with relevant laws and regulations and national standards, we may collect and use your personal information without your authorization under the following circumstances:
   1. Directly related to national security, national defense, and other national interests; Directly related to public safety, public health, public's right to know, and other significant public interests;
   2. Directly related to criminal investigations, prosecutions, trial, and sentence enforcement;
   3. For the purpose of safeguarding your or another individual's life, property, or other significant legal rights and interests, but it is difficult to obtain your consent;
   4. The personal information collected is disclosed by you to the public at your own discretion;
   5. Personal information collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, and other sources;
   6. Necessary for the signing and perform the contract according to your requirements;
   7. Necessary for maintaining the safe and stable operation of our Services, such as the detection and handling of faults in our Service;
   8. Other circumstances stipulated by laws and regulations.

5. How We Share and Disclose Personal Information

1) With your consent

We do not share or transfer your personal information to third parties, except for the following:

1. We have obtained your prior consent to do so. The personal information has been de-identified before being shared and cannot be re-identified by third parties.
2. For the purpose of external processing.We may share your personal information with our affiliates or other third-party partners (third-party service providers, contractors, agents, application developers, etc.) to allow them to process such information for us in accordance with our instructions, privacy policy, and other relevant confidentiality and security measures, and to use it to provide our services to you for the purposes described in the 'How We Use Personal Information' section in this Policy. If we share your information with the aforementioned affiliates or third parties, we will protect data security by conducting strict security monitoring on the software tool development kits (SDKs) and application program interfaces (APIs) through which our affiliates or third-party partners obtain the information. We also use encryption, anonymization processing, and other means to protect the security of your information. For example, the information we collect from you, including your mobile phone number, QQ number, email address, WeChat profile picture, WeChat nickname, region, gender, meeting information, shared files, media data, account activities, device model, device operating system, unique device identifier, and other information, will be stored in our database on Alibaba Cloud. We keep your account registration information until you cancel your account, after which we will delete it accordingly. Your device information and log information will be stored for 6 months.
3. When required to provide your personal information in accordance with relevant laws, rules, regulations, other regulatory documents, mandatory administrative law enforcement, or judicial requirements, we may disclose your personal information to the administrative law enforcement agencies, or judicial agencies according to the requested type of personal information and manner of disclosure. When we receive a request for information disclosure, we require legal documentation to support the request, subject to compliance with laws and regulations. We only provide data that law enforcement agencies and judicial agencies have the legal authority to obtain for specific investigative purposes. To the extent permitted by laws and regulations, the documents we disclose are protected by encryption measures.

2) As decided and managed by enterprises

We do not disclose the personal information we collect to the public. If we must disclose it to the public, we will inform you of the purpose of the disclosure, the type of information to be disclosed, and the sensitivity of the information that may be involved, and obtain your explicit consent. For our enterprise customers, it is up to the enterprises to decide and manage how the personal information of their individual members is disclosed in TalkLine or shared with the public.

3) To comply with law enforcement requirements

We may disclose your personal information as required by laws or in response to law enforcement requests from relevant authorities.

6. Your Rights to Your Personal Information

In accordance with the relevant Chinese laws, regulations, and standards, as well as the common practices of other countries and regions, you have the following rights to your personal information:

1) Access your personal information

You have the right to access your personal information, except for exceptions stipulated by laws and regulations. If you wish to exercise your right to access your personal information, you can do so yourself in the following ways:

1. Access the profile information of your TalkLine account.
   You can access or edit the profile information of your TalkLine account in the TalkLine client apps and the TalkLine Administrator Console.Via TalkLine apps: Home > Click your profile picture > Select Personal Settings
   Via TalkLine Administration Console: Home > User Management > User List > Detailed information of individual users
2. Access the meeting information of your TalkLine account.
   Via TalkLine apps: Home > Today's Meetings or All Meetings
   Via TalkLine Administration Console: Home > Meeting Management > Upcoming Meetings or Ended Meetings;Home > User Management > User List > Meeting information of individual users.

If you are unable to access your personal information as described above, you may contact us using the contact information provided in this Policy. We will respond to your requests within 15 business days.

For other personal information generated during your use of our Services, we can provide it to you as long as it does not require us to put in excessive resources to do so. If you have any issues accessing your personal information in our Services, you may contact us using the contact information provided in this Policy.

2) Update your personal information

If there is any incorrect personal information about you in our service, you have the right to request us to correct it.

You can update your personal information as described in the section 'Access your personal information' above. If you are unable to do so, you may contact us using the contact information provided in this Policy. We will respond to your requests within 15 business days.

3) Delete your personal information

You may request us to delete your personal information from our Services in the following cases:

1. If our process of your personal information violates laws and regulations.
2. If we collect and use your personal information without obtaining your consent.
3. If our process of your personal information violates our agreement with you.
4. If you no longer use our Services, or if you cancel your account.
5. If we no longer provide our Services to you.

If we, upon your request, delete your personal information, we will also request the entities who get your personal information from us to delete your personal information in a timely manner, unless otherwise required by law or regulation, or such entities have your independent authorization to keep your personal information.

When your personal information is deleted from our Services, we may not immediately delete the corresponding information from our backup system, but we will delete it when the backup is updated.

4) Change the scope of your consent

Each business function requires some basic personal information to work correctly (see the 'The Personal Information We Collect' section in this policy). For the collection and use of additional personal information, you may give or withdraw your consent at any time. You may contact us using the contact information provided in this Policy. After verifying your identity, we will act on your request and respond to you in 15 business days.

When you withdraw your consent, we will no longer process the corresponding part of your personal information. However, your decision to withdraw your consent shall not affect the previous processing of your personal data based on your original consent.

5) Cancel your account

You can cancel your registered account at any time. If you want to cancel your account:

you can send us a request using the contact information provided in this Policy. After verifying your identity, we will act on your request and respond to you in 15 business days.

After canceling your account upon your request, we will stop providing our Services to you and delete your personal information, unless otherwise stipulated by laws and regulations.

6) Our response to your requests mentioned above

For security reasons, you may need to provide supporting documentation (or by other means) to prove your identity before we can process your request.

We will respond to you within 15 business days. If you are not satisfied with our response, you can file a complaint or report to the regulatory authorities of the Internet, telecommunications, public security, and industry and commerce.

In principle, we do not charge a fee for your reasonable requests, but we will charge a fee at cost, as appropriate, for repeated requests that exceed reasonable limits. We may deny requests that are unnecessarily repetitive, require excessive technical measures (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tapes).

We may not process your request in the following cases:

1. Related to the fulfillment of our legal and regulatory obligations;
2. Directly related to national security and national defense;
3. Directly related to public safety, public health, and other significant public interests;
4. Directly related to criminal investigations, prosecutions, trial, and sentence enforcement;
5. Where there is sufficient evidence that you have subjective malice or abuse of rights;
6. For the purpose of protecting your or another individual's life, property, or other significant legal rights and interests, but it is difficult to obtain consent from you;
7. When our processing of your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
8. Involving commercial secrets.

7. How We Transfer Your Personal Information Globally

In principle, the personal information we collect and generate in the People's Republic of China will be stored in the People's Republic of China.

Because we provide our Services through network resources and servers located around the world, this means that, with your consent, your personal information may be transferred to, or accessed from, jurisdictions outside the country in which you use our Services.

Such jurisdictions may have different data protection laws or even no such laws. In such cases, we will ensure that your personal information is adequately protected to the same extent as it is in the People's Republic of China. For example, we may request your consent for cross-border transfers of your personal information or implement security measures such as data de-identification prior to cross-border data transfers.

8. The Emails and Information We May Send to Your

1) Emails and push notifications

When you use our Services, we may use your information to send you product surveys, satisfaction surveys, and promotional emails to inform you of other products or services offered by us or third parties. If you do not wish to receive such information, you may choose to unsubscribe by following our relevant instructions.

2) Announcements related to our Services

We may send you correspondence related to our Services, such as welcome letters, payment notices, information about technical and service issues, security notices, announcements about the suspension of a service due to system maintenance, and other service-related announcements. You may not be able to cancel these service-related announcements that are not promotional in nature.

9. How we process personal information of minors

1) We expect that minors use our Services under the supervision and guidance of their parents or guardians

If you are a minor under the age of 18, you shall read and agree to this Policy under the supervision and guidance of your parents or other guardians before using our Services.

2) We take the protection of the personal information of minors very seriously

We protect the personal information of minors in accordance with the relevant national laws and regulations. For personal information collected from minors with parental consent, we will use, share or publicly disclose such information only as permitted by laws, with the explicit consent of their parents or guardians, or as necessary to protect the minors.

3) We conduct self-review and receive feedback

If we find that we have collected personal information from a minor without prior verifiable parental consent, we will make efforts to delete such information as soon as possible. If you are the guardian of a minor, please contact us using the contact information provided in this Policy if you have any questions regarding the personal information of a minor in your custody.

10. Changes to this Policy

We may revise this Policy from time to time and notify you via pop-up notice. By continuing to use our Services after any changes are made to this Policy, you agree to be bound by the revised version of this Policy. If you do not agree to the revised version of this Policy, you must stop accessing or using our Services.

11. How to Contact Us

If you have any complaints, suggestions, or issues related to the personal information of minors, please email us at TalkLine@zego.im, or write to us at the addresses below:
38th Floor, One Excellence Tower 3, 5033 Menghai Road, Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone Shenzhen, Guangdong, China
Post Code: 518000
We will respond to you within 15 business days after verifying your user status.

Appendix I: Information Collected by Third-Party SDKs

Appendix II: Application permission application and usage description