Privacy Policy

1. Introduction

EaseTalk ("we," "our," or "us") is committed to protecting your privacy and meeting applicable data protection obligations, including the General Data Protection Regulation (GDPR), Digital Services Act (DSA), and App Store guidelines where they apply.

This Privacy Policy explains how we collect, use, process, and protect your personal information when you use our mobile application and related services.

2. Data Controller Information

Data Controller: EaseTalk
Contact: easetalkai@gmail.com
Location: Cork, Ireland (EU)
DPO Contact: Available upon request

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

• Consent (Art. 6(1)(a)): For optional features like analytics and marketing communications
• Contract Performance (Art. 6(1)(b)): To provide our speech practice services
• Legitimate Interest (Art. 6(1)(f)): For app improvement and security
• Special Category Data (Art. 9): Where information is sensitive or health-related, we rely on an appropriate Article 9 condition, such as explicit consent where required

4. Information We Collect

4.1 Personal Information

• Account information (email, name, age range)
• Profile preferences and settings
• Therapist connection data (if applicable)

4.2 Speech and Health Data

• Speech activity data, transcripts where required, and speech-related feedback data
• Speech pattern analysis, fluency signals, and practice metrics where used by the service
• Progress tracking and mood logs
• Practice session history and performance data

Depending on how EaseTalk is used, some information may be sensitive or health-related. We handle such information with additional care and limit collection to what is necessary for the service. EaseTalk does not routinely store raw audio recordings as part of its standard platform design. Where speech is processed to provide platform functionality, we aim to minimise retention and store only the data necessary to provide the service, such as activity records, reflections, transcripts where required, and therapist-assigned activity data.

4.3 Technical Data

• Device information and operating system
• App usage analytics and crash reports
• IP address and general location (country level)
• Analytics data, anonymised or pseudonymised where appropriate

4.4 Therapist Integration Data

• Therapist-assigned exercises and goals
• Shared progress reports and session summaries
• Communication logs between user and therapist

5. How We Use Your Information

5.1 Core App Functionality

• Provide personalized speech practice sessions
• Generate personalized feedback and recommendations
• Track your progress and improvement over time
• Enable therapist collaboration features

5.2 Service Improvement

• Analyze usage patterns to improve app features
• Improve AI-assisted speech features without using identifiable user data to train AI models
• Identify and fix technical issues
• Conduct research for speech and language therapy advancement

5.3 Communication

• Send important service updates and notifications
• Provide customer support
• Share relevant educational content (with consent)

6. Data Storage and Security

6.3 Data Retention

• Account Data: Retained while account is active + 30 days after deletion
• Raw Audio: Not routinely stored as part of the standard platform design; where temporary processing is needed, retention is minimised
• Progress Data: Retained for 2 years for continuity of care
• Analytics Data: Anonymised or pseudonymised where appropriate and retained only as long as needed for service improvement

Some data may remain personal data where it can be linked to an account, therapist, or user. We avoid describing data as anonymous unless it has been anonymised so that individuals are no longer identifiable.

7. Data Sharing and Third Parties

7.1 We DO NOT sell your personal data

EaseTalk will never sell, rent, or trade your personal information to third parties for marketing purposes.

7.2 Limited Sharing Scenarios

• Therapist Integration: When therapists use EaseTalk to monitor client progress, they may act as independent data controllers for their therapeutic relationship. EaseTalk may process relevant data as a service provider or processor depending on the arrangement. Progress data is shared with connected therapists only with appropriate permission or another valid legal basis.
• Service Providers: We use approved service providers for EU storage, hosting, authentication, analytics, communications, and support. We maintain appropriate contractual, technical, and organisational safeguards with those providers, including data processing terms where required.
• Legal Requirements: When required by law or to protect user safety
• Business Transfers: In case of merger/acquisition (with user notification)

7.3 International Transfers

EaseTalk is designed so that personal data is stored in the EU. If any personal data must be transferred outside the EU or EEA, we use appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Explicit user consent where required

8. Your Rights Under GDPR

Depending on where you live and the legal basis for processing, you may have the following rights over your personal data:

8.4 Exercising Your Rights

To exercise any of these rights, contact us at easetalkai@gmail.com. We will respond within 30 days and may request identity verification for security purposes.

9. Children's Privacy

EaseTalk is designed for users aged 13 and above. We do not knowingly collect personal information from children under 13. If we discover such data has been collected, we will delete it immediately.

For users aged 13-16 in the EU, parental consent may be required in accordance with local GDPR implementations.

10. Cookies and Tracking

Our mobile app uses minimal tracking technologies:

• Essential Cookies: Required for app functionality (no consent needed)
• Analytics Cookies: Optional analytics cookies or similar technologies, used with consent where required
• Performance Cookies: Crash reporting and performance monitoring

You can manage cookie preferences in the app settings.

11. AI and Automated Decision Making

EaseTalk uses AI-assisted features for:

• Speech pattern analysis and feedback: AI outputs may be imperfect and do not create solely automated decisions with legal or similarly significant effects
• Personalized exercise recommendations: User and therapist controls remain available for exercise selection
• Progress summaries: AI does not diagnose or make treatment decisions

You have the right to:

• Request human review: Request human review of AI-generated outputs where available
• Contest AI-generated feedback: Challenge or correct AI-generated results that you disagree with
• Understand AI logic: Request explanations of how AI analyzes your speech data and the decision criteria used
• Not be subject to automated decisions: You will not be subject to decisions based solely on automated processing that produce legal or similarly significant effects

12. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify the relevant supervisory authority within 72 hours
• Inform affected users without undue delay
• Provide clear information about the breach and our response
• Take immediate steps to contain and remedy the breach

13. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will:

• Notify users of material changes via email or in-app notification
• Provide 30 days notice before changes take effect
• Maintain previous versions for reference
• Seek new consent where required by law

14. Supervisory Authority

You have the right to lodge a complaint with your local data protection authority. In Ireland, this is:

Data Protection Commission (DPC)
Website: www.dataprotection.ie
Phone: +353 57 868 4757
Email: info@dataprotection.ie

15. Pilot Program Notice

EaseTalk is currently in pilot/beta phase. During this period:

• Features may change based on user feedback and clinical insights
• We collect additional usage data to improve the service and validate effectiveness
• Participation is voluntary; you may withdraw anytime without penalty
• Enhanced support available for pilot participants
• Your feedback helps shape the final product and contributes to research

16. App Store Compliance

This privacy policy is designed to reflect applicable requirements and guidance, including:

• Apple App Store Review Guidelines
• Google Play Store Developer Policy
• EU Digital Services Act (DSA)
• General Data Protection Regulation (GDPR)
• ePrivacy Directive