Smalltalk Privacy Policy

Effective Date: January 1, 2018

At SmallTalk (“SmallTalk”, “We” or “Us”), your privacy is important to us. We respect your privacy and take reasonable measures to protect it. This Privacy Policy applies to the SmallTalk website (www.smalltalk.agency) (the “Site”) and any services offered on the Site. This Site is structured so that, in general, you can visit without revealing any personal information. However, if you choose to provide us with personal information, you may be assured that it will only be used in accordance with the principles set forth in this document.

By accessing or using the Site, you agree and consent to our use of your personal information as described in this Privacy Policy. If you do not agree to any of the terms and conditions in this policy, you should not use this Site or any of the services.

WHAT INFORMATION WE COLLECT

Information Collected Automatically. We collect certain data when you visit most pages on the Site. Your visit may automatically provide us with data about your computer, such as your IP (Internet Protocol) address, browser type, operating system, domain name, access times, and any referring web site addresses. As further described below, some parts of the Site may use embedded cookies or other technologies to track and facilitate your use of the Site.

Personal Information You Provide Voluntarily. On some pages of the Site, We provide online forms for the purposes of contacting us, subscribing to communications, registering for a webinar, downloading information resources such as whitepapers, and engaging in promotional events or other purposes. Personal information collected may include name, phone number, mailing address and email address. We may also ask you to voluntarily provide us with information regarding your personal or professional interests, demographics, experience with our products, and contact preferences.

We do not collect any personal information from you on this Site unless you provide it to us. For example, if you email us or answer questions we have placed on the Site, you are voluntarily releasing that information to Us for use as set forth in this policy. Please do not submit personal information to Us if you do not want us to have this information. We also do not collect any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership).

PERFORMANCE AND TRACKING INFORMATION

We may track and record your interactions with our advertisements, our web sites, emails or other applications we provide using clickstream data and cookies. Clickstream data is a recording of what you click on while browsing the Site. This data can tell Us the type of computer and browsing software you use and the address of the web site from which you linked to the Site. Cookies are small text files that are placed on your computer by a web site for the purpose of facilitating and enhancing your communication and interaction with that web site, such as remembering your preferences and collecting aggregate (i.e., not personal) information. Many web sites, including ours, use cookies for these purposes. For example, We use Google Analytics to help use measure the performance of the Site and improve your online experience. Our agreements with these service providers do not permit them to use the information collected on our behalf except to help us conduct and improve our business. You may stop or restrict the placement of cookies on your computer or delete them from your browser by adjusting your web browser preferences and browser plug-in settings, in which case you may still use the Site, but it may interfere with some of its functionality. If you wish to find out more about cookies, or how to refuse cookies for your browser, please visit the Interactive Advertising Bureau’s web site at www.allaboutcookies.org.

In the future We may enable online behavioral advertising when you access the Site, which may use third-party cookies or other tracking technologies to serve you advertisements about goods and services on our Site that may be of interest to you. These advertising companies and networks use certain non-personal information about your access and use of the Site and other websites you have visited to provide tailored advertisements.

If you would like more information about online behavioral advertising and to know what your choices are, including how to opt-out of having your online information used for online behavioral advertising, please see the following industry websites:

Be advised, however, that opting out of online behavioral advertising does not mean that you will not see advertising when you are online. It means only that the advertising you do see on our Site or other websites will be less relevant to your interests and choices.

Social Media. When users connect to the Site from a social media website, such as Facebook or LinkedIn, we collect the personal information you have provided to that particular social media website in accordance with the social media website’s privacy practices, and we add the information to your profile and to manage your account, if any.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to understand your needs and provide better products and services, personalize your web site experience, and tailor future communications. Occasionally, We may use your personal information, such as an email you have provided, to contact you for market research or to provide you with marketing promotion or offer that may be of particular interest to you. However, you may opt out of receiving these marketing or promotional messages at any time by contacting Us as provided below or clicking on the “Unsubscribe” function embedded in these messages. However, you cannot unsubscribe to transactional or administrative email messages about the status of your account, if any, or any product or service that you have requested.

SmallTalk will not use or share personal information provided to us online for purposes unrelated to the ones described in this policy without letting you know and offering you a choice.

HOW WE MAY SHARE YOUR PERSONAL INFORMATION

We may share the personal information you provide with other SmallTalk divisions or affiliates, provided that, such other divisions or affiliates have privacy practices that are no less robust than those set forth in this policy.

SmallTalk may permit its vendors and subcontractors to access your personal information, but they are only permitted to do so in connection with services they are performing on our behalf and in accordance with their contractual obligations with us. They are not authorized by SmallTalk to use your personal information for their own benefit or in ways inconsistent for the services they are providing to Us. We do not provide any personal information to third parties for their marketing purposes.

We may use third-party payment processors when, for example, you register for a training course or purchase any other product or service provided on the Site. Financial information you provide to a payment processor is subject to that third party’s terms and policies. We do not have access to this information at any time.

We may disclose personal information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for the web site. In addition, SmallTalk may disclose personally identifiable information as required by law or legal process.

In the event of a sale, merger, liquidation, dissolution, reorganization or acquisition of SmallTalk, or a business unit, personal information We have collected about you may be sold or otherwise transferred. However, this will only happen if the party acquiring the information agrees to use personal information in a manner which is substantially similar to the uses described in this policy.

We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Site. Participation is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details.

LINKS TO OTHER SITES

This Site may contain links to other web sites and services. This can include clicking “Register” to take you to the web sites of various third-party retailers. We do not control such third-party web sites and services and are not responsible for their actions or privacy practices. The existence of a link on our web site does not mean that we endorse or have vetted such third-party web site or service. You are encouraged to carefully review the policies and practices of every web site and service that you visit. While posted, third-party links may include special promotions or offers, the Site does not implement Online Behavioral Advertising features.

SECURITY

SmallTalk has implemented reasonable and appropriate security measures to ensure the security of the personal and information we collect. Procedures to protect the personal information that you provide to Us. Any third-party service providers with whom We may share personal information are contractually obligated to implement security measures no less robust and comprehensive. However, be advised that no method of transmitting or storing electronic data is ever completely secure, and We cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this policy.

If We provide you a direct means for maintaining your personal information in our databases, such as through an online account or profile application, you are responsible for taking reasonable precautions to protect your login data, such as your ID and password. SmallTalk will not be responsible for breach that results from a lost or stolen login.

NON-CONFIDENTIAL

Any communication or material you transmit to Us by email or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, non-confidential and nonproprietary. Except to the extent expressly covered by this policy, anything you transmit or post may be used by Us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. You expressly agree that We are free to use any ideas, concepts, know-how, or techniques contained in any communication you send to Us without compensation and for any purpose whatsoever, including but not limited to, developing, manufacturing and marketing products and services using such information. Furthermore, you confirm that any media files you submit to Us (e.g., pictures, videos, etc.) are your property and you have permission of anyone depicted in these files to transfer rights to SmallTalk.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits users of our Site who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@smalltalk.agency or via our Contact Form. We currently do not honor browser-based Do Not Track signals.

ACCESS TO AND CORRECTION OF INFORMATION / OPT-OUT

We retain your personal information for as long as needed to provide you the requested services or information. However, SmallTalk will maintain reasonable procedures for individuals to gain access to their personal information and preferences. If you wish for us to cease using your personal information and delete it from our list of active users, please contact us at info@smalltalk.agency or via our Contact Form and including sufficient details to enable Us to complete your request. We will process and honor such requests within a reasonable period of time after receipt.

Keep in mind, however, that there may be residual information that will remain within our databases, access logs and other records, which may or may not contain personal information. The residual information will not be used for commercial purposes, but we may retain and use it as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

CHILDREN’S PRIVACY

Protecting the privacy of the very young is especially important. SmallTalk does not collect or maintain information on the Site from persons We know to be under age 13, and no part of our Site is designed to attract anyone under age 13. Please do not communicate with or contact Us if you are under age 13. If a child under the age of 13 has provided SmallTalk with their personal information, we ask that a parent or guardian of the child contact us using our Contact Us page to inform us of that fact. SmallTalk will use reasonable efforts to delete such information from our database.

LOCATED IN THE UNITED STATES

SmallTalk is located in the United States and the Site is maintained in the United States. Your personal and other information will be stored, processed and accessed in the United States. You understand and agree that SmallTalk may collect, use, disclose, and otherwise process the personal information you provide as described in this Privacy Policy even if you are from an area outside the United States. This Privacy Policy is governed by the data privacy laws of the United States, which laws may not as protective as such laws in other countries.

CHANGES TO PRIVACY POLICY

From time to time we may modify this Privacy Policy. We will notify you of any material change by sending a notice to the e-mail address you provided to us or by placing a prominent notice on our Site. You can view the most recent version of the Privacy Policy at any time by clicking the “Privacy Policy” link at the bottom of each page on the Site. Your continued use of the Site after any modification indicates your agreement to the new terms and conditions.

COMMENT AND QUESTIONS

If you have comments or questions about our privacy policy or your personal information, you may email us at info@smalltalk.agency or via our Contact Form.

SmallTalk
143 Santa Rita Avenue
Palo Alto CA 94301
415.813.1060