HUGH Privacy Policy

HUGH is an app managed and operated by TalkLife Ltd.

At TalkLife, respect for your privacy is foundational to everything we do. Since we started TalkLife we have strived to build our Services with a strong set of privacy principles in mind.

This Privacy Policy describes how TalkLife collects, uses and discloses information, and what choices you have with respect to the information. We are committed to protecting and respecting your privacy. We recommend you read this privacy policy and contact us without hesitation if you have additional questions.

When we refer to “TalkLife”, “we”, “our”, “us”, we mean TalkLife Limited of Runway East Building, 1 Victoria Street, Bristol, United Kingdom that acts as the controller or processor of your information, as explained in more detail in the “Our Legal Bases For Processing Information” below.

This policy outlines how any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Information We Collect And Receive

TalkLife must receive or collect some information to operate, provide, improve, understand, customise, support, and market our Services, including when you install, access, or use our Services. The types of information we receive and collect depend on how you use our Services.

We may collect and process the following data about you:

Information that you provide by filling in forms on our site https://www.talklifeworkplace.com/ and our mobile application HUGH (“our app”). This includes information provided at the time of registering to use our app, downloading and sharing data via our app, subscribing to our service, posting material on forums and on your profile, posts and comments, or requesting further services. We may also ask you for information when you report a problem with our site.

The information which you provide us may include:

• Username and password, date of birth, gender, e-mail address;
• Your name and phone number;
• Profile photo and any additional photos which you upload to our app;
• Your employer;
• Information you may provide about your wellbeing, mood, or experiences within the app;
• Any information you choose to share within your profile.

Your Messages

We collect and process the messages you send and receive on HUGH, including their content, to help maintain a safe and supportive community. Messages may be analysed by moderation systems, including Artificial Intelligence (AI), to detect potentially harmful or policy-violating content. In limited cases, authorised team members may review message content where required by law, or to investigate reports of serious risk or harm. We apply strict safeguards and access controls to protect your privacy.

Customer Support

You may provide us with information related to your use of our services, including copies of messages, posts or comments, and how to contact you so that we can provide you with customer support. For example, you may send us an email with information relating to our app performance or other issues. If you contact us, we may keep a record of that correspondence.

Special Category Data

Some information you share on HUGH may reveal details about your health or wellbeing - for example, when you talk about how you feel or describe personal experiences. This information is considered “special category data” under data protection law.

We only process this type of information where:

• you choose to share it and give your explicit consent;
• it’s necessary to protect your vital interests or those of another person (for example, in cases of serious or imminent harm); or
• it’s permitted by law in the substantial public interest, such as safeguarding vulnerable people.

We apply extra safeguards to protect this data, including strict access controls, encryption, and data minimisation. You can withdraw your consent at any time by deleting your information, adjusting your privacy settings, or contacting us.

Age Verification

In certain regions, we may be required by law to verify your age before allowing access to our platform or specific features. These checks are performed on our behalf by a trusted third-party provider, and access to the verification shared with HUGH is strictly limited and provided solely for the purpose of validating the results. Information collected is handled securely and in compliance with applicable data protection laws.

Surveys

We may also collect information that you provide through participation in surveys or questionnaires, which may include demographic data, preferences, and other feedback related to our services.

Automatically Collected Information

Usage and Log Information

We collect information about your activity on our services, like service-related, diagnostic and performance information. This includes information about your activity (including how you use the service, your service settings, how you interact with others using our services, and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website and performance logs and reports. This also includes information about when you registered to use our services, the features you are using on HUGH like our messaging, diary, posts, bio information, and when you last used our service, and when you last updated your information.

Device and Connection Information

We collect device and connection specific information when you install, access or use our services. This includes information like the type of mobile device you use, a unique device identifier (sometimes referred to as a device ID or token), mobile network information, your mobile operating system and the type and version of mobile software which you use, information stored on your device, such as login information, photos, videos or other digital content; General, aggregated, demographic, and non-personal data (such as aggregated anonymous information about website usage and other forms of analytical data). It will not be linked to any of your personal data, through cookies or other means, without your consent; Details of transactions you carry out through our site; and details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise, and the resources that you access.

IP addresses and cookies

We use cookies to operate and provide our services, including to improve your experiences, understand how our services are being used and customise our services. We may collect information about your mobile phone, including details of your mobile handset and mobile software, for system administration and to collate aggregate information. This is statistical data about our users' browsing actions and patterns and the use of our app, and does not identify any individual.

Where we store your personal data

We may use third-party vendors, such as Amazon and Google, to store your data. Your data may be transferred to and stored in locations outside the European Economic Area (“EEA”), including but not limited to the United States and the United Kingdom. It may also be processed by staff operating outside the EEA who work for us or for a third-party vendor. By submitting your personal data, you agree to this transfer, storing or processing to jurisdictions outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How We Use Information

We use the information we have (subject to choices you make) to operate, provide, improve, understand, customise, support and market our Services. Here’s how:

Our Services

We use the information we have to operate and provide our Services, including providing customer support, and improving, fixing and customising our services. We understand how people use our Services and analyse and use the information we have to evaluate and improve our Services, research, develop and test new services and features, and conduct troubleshooting activities. We also use your information to respond when you contact us.

Safety And Security

We verify accounts and activity, and promote safety and security on and off our Services, such as by investigating suspicious activity or violations of our Terms or Community Guidelines, and to ensure our Services are being used legally.

Please also note that information we hold and information that you share may be passed to your employer, the appropriate authorities or regulators where: this is required or requested by the authorities or by law; we have concerns that any individual is likely to cause harm to themselves or other people; or there is an actual or suspected case of cyber bullying and we are requested by appropriate authorities to provide such information or cooperate with their investigation.

Use of Artificial Intelligence (AI)

We may use Artificial Intelligence (AI) technologies, including tools provided by third-party service providers, to help maintain a safe and accessible community. For example, AI may assist in detecting policy-violating material, and in translating content into different languages. These systems are used only to support our community guidelines and improve user experience, while human moderators oversee any AI-assisted decisions.

E-mail Marketing and Newsletters

We may use your personal data from time to time to contact you (via electronic means) with our internal newsletters and details of new blog posts and other communications or services that we are available on our site or our app, where we think these may be of interest to you. Our emails will contain links which enable you to “unsubscribe” to such communications at any point. Our site and our app may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Information You And We Share

You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customise, support and market our services.

Information You Share Socially

Our sites and our app allow you to connect and share your actions, comments, content, and information publicly or with friends. Please be mindful of your own privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.

For example: When you submit a post or comment to the Services, visitors to and users of our Services will be able to see the content of your posts and comments, the username associated with your posts or comments, and the date and time you originally submitted the post or comment. Although some parts of the Services may be private or quarantined, they may become public (e.g., if content you have shared in a one-to-one conversation is shared by another member without your consent) and you should take that into consideration before posting to the services.

When users view your profile they will be able to see information about your activities on the Services, such as your username, prior posts and comments, HUGH ranks, Your help or needing help status, your biography information and how long you have been a member of the Services.

Please note that, even when you delete your account, the posts, comments and messages you submit through the Services may still be viewable or available on our servers. See “Managing and Deleting Your Information”.

Third-Party Processors

We work with trusted third-party service providers who process information on our behalf to help us operate, secure, and improve our services. These providers are bound by strict data protection and security obligations and only process information as instructed by HUGH. Where data is transferred outside the UK or European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Government and the European Commission.

Analytics Partners

We may partner with third-party analytics providers to better understand your use of the Services. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device. We use analytics partners (such as Google Analytics) to help analyse usage and traffic for our Services. As an example, we may use analytics partners to analyse and measure, in the aggregate, the number of unique visitors to our Services.

Assignment, Change Of Control, And Transfer

All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner.

If TalkLife Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (including responding to requests from law enforcement authorities both inside and outside the EEA), or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, or that of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction, and may require us to transfer your personal data outside of the EEA.

How the General Data Protection Regulation Applies To Our European Region Users

The General Data Protection Regulation (2016/679 EU) (EU GDPR) is the governing legislation for collecting and processing personal data in the EU. Following the end of the Brexit transition period on 31 December 2020, most of the EU GDPR was retained in UK law by the European Union (Withdrawal) Act 2018. The retained GDPR is known as the “UK GDPR”. The UK GDPR is supplemented by the Data Protection Act 2018. As a UK based company, all TalkLife activities therefore comply with UK GDPR and the Data Protection Act 2018.

Our Legal Bases For Processing Information

We process your information under a number of different legal bases, depending on the type of processing:

Contractual necessity. We use your information as necessary to provide our services under our Terms of Service - for example, creating and managing your account, providing access to the platform, and delivering the features you request (such as messaging, rooms, or translation).

Consent. In some cases, we rely on your consent - for example, where you agree to optional uses like receiving marketing communications. You may withdraw consent at any time through your settings or by contacting us.

Legal obligations. We may process and share information where required by law, such as responding to lawful requests from authorities or complying with record-keeping obligations.

Vital interests. In rare circumstances, we may process information to protect your life or the life of another person - for example, when escalating serious self-harm risks to emergency services.

Public interest. In limited cases, we may process information for reasons of substantial public interest, such as safeguarding vulnerable people.

Legitimate interests. We use your information where necessary for our own (or others’) legitimate interests, provided those interests are not overridden by your rights and freedoms. This includes:

• keeping the platform safe and secure (e.g. moderation, fraud detection, abuse prevention);
• improving and innovating our services (e.g. developing new features, AI-assisted moderation and translation);
• operating a sustainable business (e.g. analytics, service optimisation, ensuring platform profitability).

How You Exercise Your Rights

Under the UK GDPR or other applicable local laws, you have the right to access, rectify, port, erase your information and lodge a complaint with a supervisory authority, as well as the right to restrict and object to certain processing of your information. This includes the right to object to our processing of your information for direct marketing and the right to object to our processing of your information where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise your rights at any stage by emailing dpo@talklife.co or through in-app settings. We will respond to all rights requests without undue delay and in any event within one month of receiving the request, in line with UK GDPR and EU GDPR requirements. Where a request is complex or numerous, we may extend this period and will inform you of any such extension and the reasons for it. You can access tools to rectify, update, and erase your information directly in-app as described in the Managing and Deleting Your Information section.

If we process your information based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. You can also object to our processing of your information. For marketing communications, we will always seek your opt in consent. Where we use your information for direct marketing for our own Services, you can always object and opt out of future marketing messages using the unsubscribe link in such communications.

Managing And Deleting Your Information

We store information until it is no longer necessary to provide our services, or until your account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, and relevant legal or operational retention needs.

If you would like to manage, change, limit, or delete your information, we allow you to do that through the following tools:

Services Settings. You can remove posts, comments and photos shared on HUGH by the deletion tool provided on each post, comment or photo. You can also remove posts via your profile and the Previous Posts feature. You can also use our block feature to manage the users with whom you communicate.

Deleting Your Account. You may delete your HUGH account at any time (including if you want to revoke your consent to our use of your information) using our in-app delete account feature. When you delete your HUGH account, your undelivered messages are deleted from our servers as well as any of your other information we no longer need to operate and provide our Services. Be mindful that if you only delete our Services from your device without using our in-app delete account feature, your information may be stored with us for a longer period. Please remember that when you delete your account, it does not affect the information other users have relating to you, such as their copy of comments, posts or messages that you may have sent to them. We endeavour to remove your information from all of our servers within 14 days of deletion. If you sign into your HUGH account at any stage during that period, your account will reactivate and you will need to use our in-app deletion tool again to remove your information.

You may also request the removal or rectification of your details by emailing TalkLife's Data Protection Officer - dpo@talklife.co. Please note that we withhold the right to keep a record of any users that have previously been banned from our platform for breaking our terms of service if we deem them a future threat to other users.

Inactive Accounts. Inactive accounts are kept on record for 6 years for the exercise or defence of legal claims.

Our Policies Concerning Minors

Age Requirements. Although we welcome users from all walks of life, HUGH is not intended or directed at individuals under the age of 16 years of age. Therefore, individuals under the age of 16 may not create an account. We do not knowingly collect information from children under the age of 16 and if you are under this age you must not use our Services. Please take your privacy seriously and do not provide false information regarding your age when you register. If we become aware that you are under 16 and using our app or our site, we may terminate your user account and issue bans to your device.

Law And Protection

We collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law or regulations, to legal process, or to government requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our users, TalkLife Limited, or others, including to prevent death or imminent bodily harm.

Our Global Operations

TalkLife shares information globally, both internally, and externally with our partners and with those you communicate with around the world in accordance with this Privacy Policy. Information controlled by TalkLife Limited will be transferred or transmitted to, or stored and processed, in the United Kingdom or other countries outside of where you live for the purposes as described in this Privacy Policy. These data transfers are necessary to provide the Services set forth in our Terms and globally to operate and provide our Services to you. We utilise standard contract clauses approved by the European Commission, and may rely on adequacy regulations (the UK equivalent to the European Commission’s adequacy decisions) about certain countries, as applicable, for data transfers from the United Kingdom to the European Economic Area and other countries.

Changes to our privacy policy

This privacy policy is reviewed annually. We will also occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the “Last Updated” date at the top of this Privacy Policy and the revised Privacy Policy will come into effect on the date it was posted to our site or our app or as otherwise notified by us. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by prominently posting notice of the changes on our sites and/or our app and, where appropriate, notifying you by email. We recommend that you check this page from time to time to inform yourself of any changes in this Privacy Policy. By continuing to use our site or our app after we have posted a revised Privacy Policy you acknowledge that you have consented to the revised Privacy Policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to The Data Protection Officer for TalkLife Limited – dpo@talklife.co