Talk Town Privacy Policy

This Privacy Policy (Policy) applies to your use of Talk Town. Talk Town is a game app for your mobile, tablet or similar device that aims to help deaf children learn skills to communicate and engage with others.

Talk Town Limited (“we”, “our” or “us”) take our obligations in regards to privacy seriously. In this Policy, “you” and “your” means the individual providing Personal Information to us, and may include the individual’s parent or legal guardian where the context so requires.

This Policy provides information in relation to the basis on which we collect, hold, use and disclose your Personal Information. “Personal Information” has the same meaning as in the Privacy Act 1993, being information about an identifiable individual.

By using Talk Town you agree to the terms of this Policy and you agree that information is subject to New Zealand law, including the Privacy Act 1993 and any applicable codes.

Updates to this Policy
1. We will review this Policy from time to time to make sure it takes into account new laws and technology, and any changes to how we operate.
2. Should we decide to change our Policy we will post all changes on our website so that you are always kept up to date.
3. Use and disclosure of Personal Information collected from you is subject to this Policy in effect at the time such Personal Information is collected, unless otherwise agreed.
Collection of Personal Information
1. We collect Personal Information when you set up an account for Talk Town, when you provide it to us through Talk Town’s interface, and through playing Talk Town.
2. The Personal Information we collect and hold when you set up an account includes (but is not limited to): your username, email address, and account password.
3. We also collect and hold information relating to your use of Talk Town (including the preferences set for the character you create and your progress in playing the game) and your confidence engaging in social circumstances. This is done through your responses to a series of questions asked at the start and end of the game and from the actions you take when playing Talk Town.
4. Your Personal Information may also be collected and held in any other circumstances noted in this Policy and as permitted by the Privacy Act.
5. If Personal Information that is required to be entered during the account set up process is not provided you may not be able to play Talk Town. If you do not respond to questions asked by Talk Town or the situations arising when playing Talk Town then you may not be able to progress through Talk Town or otherwise get the full benefits of Talk Town.
Purposes for which we collect and use your Personal Information
1. We may collect and use your Personal Information for the following purposes:
  1. to enable you to play Talk Town, including backing up your data and resetting your password;
  2. to enhance and customise your gaming experience and otherwise to improve Talk Town;
  3. to research Talk Town’s impact on building social and self advocacy skills;
  4. to provide our marketing material to you, including newsletters and updates on future developments with Talk Town (where you have signed up to receive these marketing communications);
  5. to communicate with you, which includes responding to any message or enquiry you send us and identifying you when you want to communicate with us;
  6. to meet our respective obligations under the Terms and Conditions; and
  7. any other purpose made known to you when collecting the Personal Information or which is subsequently agreed with us.
Disclosure of Personal Information
1. If you are under 18 years of age, we may disclose your Personal Information to your parent or guardian where required for the Talk Town Terms and Conditions or this Policy, or where it is requested by your parent or guardian.
2. We do not otherwise share your Personal Information without your consent, except where permitted by the Privacy Act, unless we believe it is necessary:
  1. to enforce the Talk Town Terms and Conditions, or where it is legally required to do so;
  2. for us or other authorised agencies to detect, investigate, prevent or address security or technical issues;
  3. to otherwise protect our property, legal rights, or that of others; or
  4. for the purposes of carrying out the matters noted in the section below on the Management of Personal Information.
3. We may undertake research or statistical analysis in relation to the use of Talk Town by participants. We may also disclose data arising from that research and statistical analysis to third parties, such as medical researchers. However, we will not disclose any identifying information to those third parties and any disclosed data will be anonymised.
Social Media and Advertising
1. We do not place third party advertisements or links to social media on Talk Town. We believe you should not be targeted by marketing efforts during your educational experience.
Management of Personal Information
1. Except as otherwise stated in this Policy, your Personal Information we collect is held by us.
2. Personal Information collected through your use of Talk Town is stored on your device, and backed-up to a third party provider to hold the information on our behalf. We engage a third party provider to manage this process. We will not authorise any third party provider to use the information for their own purposes.
3. While we do not currently send any marketing communications we may do so in the future (where you have signed up to receive them). Any marketing communication would be sent to you separately and not through Talk Town. Where we do send marketing communications, we may engage a third party to assist us to send them to you. In such a case:
  1. We would need to provide those third parties with your name and email to enable the marketing communications to be sent. Such third parties may be offshore and may be in countries that do not have privacy laws as comprehensive as in New Zealand.
  2. We may use these third parties to collect information about your interaction with the marketing communication, such as whether you opened the email, the links you clicked on, the webpages viewed and the dates and times of such access and activity. Information about the device used to access the marketing communication may also be collected. In such a case, the third party would provide or make available this information to us for the various purposes outlined in this Policy. They may also hold this information on our behalf.
  3. We may also engage these third parties on the basis that they may use the information that we provide them and which is collected from your interaction with our marketing communications for their legitimate business interests, such as to provide, support and improve the services they provide and to undertake data analytics projects. However, we would not permit them to use your Personal Information to market their or any other person’s services to you.
4. You may unsubscribe from receiving marketing communications from us by contacting us in accordance with the Your Rights section below or in accordance with the unsubscribe facility in any email sending you marketing communications. We will not be able to provide marketing communications to you if you unsubscribe.
5. In accordance with the Privacy Act we take reasonable steps to protect the security of Personal Information that we hold.
6. Where we no longer require your Personal Information for a permitted purpose under the Privacy Act, we will take reasonable steps to destroy it.
Your Rights
1. You have the right of access to, and correction of, your Personal Information. To access or correct any of your Personal Information, please contact us as follows:

Email: mayor@talktowngame.net

Address: Talk Town Limited

P.O. Box 37439

Christchurch 8245

New Zealand

We endeavour to ensure that the Personal Information we hold is accurate, complete and up-to-date. If any of the Personal Information that you have provided to us changes we encourage you to contact us to update that Personal Information.
Given that Talk Town is aimed at children and young adults, if you are a parent or a legal guardian of a child who is under 18 and has signed up to play Talk Town without your consent and you do not wish for them to participate in Talk Town, please contact us to have the information removed from our database.
If a dispute arises between us and we cannot resolve it with you, then you may wish to contact the Office of the Privacy Commissioner on investigations@privacy.org.nz.
Talk Town Privacy Policy
This Privacy Policy (Policy) applies to your use of Talk Town. Talk Town is a game app for your mobile, tablet or similar device that aims to help deaf children learn skills to communicate and engage with others.
Talk Town Limited (“we”, “our” or “us”) take our obligations in regards to privacy seriously. In this Policy, “you” and “your” means the individual providing Personal Information to us, and may include the individual’s parent or legal guardian where the context so requires.
This Policy provides information in relation to the basis on which we collect, hold, use and disclose your Personal Information. “Personal Information” has the same meaning as in the Privacy Act 1993, being information about an identifiable individual.
By using Talk Town you agree to the terms of this Policy and you agree that information is subject to New Zealand law, including the Privacy Act 1993 and any applicable codes.
Updates to this Policy
1. We will review this Policy from time to time to make sure it takes into account new laws and technology, and any changes to how we operate.
2. Should we decide to change our Policy we will post all changes on our website so that you are always kept up to date.
3. Use and disclosure of Personal Information collected from you is subject to this Policy in effect at the time such Personal Information is collected, unless otherwise agreed.
Collection of Personal Information
1. We collect Personal Information when you set up an account for Talk Town, when you provide it to us through Talk Town’s interface, and through playing Talk Town.
2. The Personal Information we collect and hold when you set up an account includes (but is not limited to): your username, email address, and account password.
3. We also collect and hold information relating to your use of Talk Town (including the preferences set for the character you create and your progress in playing the game) and your confidence engaging in social circumstances. This is done through your responses to a series of questions asked at the start and end of the game and from the actions you take when playing Talk Town.
4. Your Personal Information may also be collected and held in any other circumstances noted in this Policy and as permitted by the Privacy Act.
5. If Personal Information that is required to be entered during the account set up process is not provided you may not be able to play Talk Town. If you do not respond to questions asked by Talk Town or the situations arising when playing Talk Town then you may not be able to progress through Talk Town or otherwise get the full benefits of Talk Town.
Purposes for which we collect and use your Personal Information
1. We may collect and use your Personal Information for the following purposes:
  1. to enable you to play Talk Town, including backing up your data and resetting your password;
  2. to enhance and customise your gaming experience and otherwise to improve Talk Town;
  3. to research Talk Town’s impact on building social and self advocacy skills;
  4. to provide our marketing material to you, including newsletters and updates on future developments with Talk Town (where you have signed up to receive these marketing communications);
  5. to communicate with you, which includes responding to any message or enquiry you send us and identifying you when you want to communicate with us;
  6. to meet our respective obligations under the Terms and Conditions; and
  7. any other purpose made known to you when collecting the Personal Information or which is subsequently agreed with us.
Disclosure of Personal Information
1. If you are under 18 years of age, we may disclose your Personal Information to your parent or guardian where required for the Talk Town Terms and Conditions or this Policy, or where it is requested by your parent or guardian.
2. We do not otherwise share your Personal Information without your consent, except where permitted by the Privacy Act, unless we believe it is necessary:
  1. to enforce the Talk Town Terms and Conditions, or where it is legally required to do so;
  2. for us or other authorised agencies to detect, investigate, prevent or address security or technical issues;
  3. to otherwise protect our property, legal rights, or that of others; or
  4. for the purposes of carrying out the matters noted in the section below on the Management of Personal Information.
3. We may undertake research or statistical analysis in relation to the use of Talk Town by participants. We may also disclose data arising from that research and statistical analysis to third parties, such as medical researchers. However, we will not disclose any identifying information to those third parties and any disclosed data will be anonymised.
Social Media and Advertising
1. We do not place third party advertisements or links to social media on Talk Town. We believe you should not be targeted by marketing efforts during your educational experience.
Management of Personal Information
1. Except as otherwise stated in this Policy, your Personal Information we collect is held by us.
2. Personal Information collected through your use of Talk Town is stored on your device, and backed-up to a third party provider to hold the information on our behalf. We engage a third party provider to manage this process. We will not authorise any third party provider to use the information for their own purposes.
3. While we do not currently send any marketing communications we may do so in the future (where you have signed up to receive them). Any marketing communication would be sent to you separately and not through Talk Town. Where we do send marketing communications, we may engage a third party to assist us to send them to you. In such a case:
  1. We would need to provide those third parties with your name and email to enable the marketing communications to be sent. Such third parties may be offshore and may be in countries that do not have privacy laws as comprehensive as in New Zealand.
  2. We may use these third parties to collect information about your interaction with the marketing communication, such as whether you opened the email, the links you clicked on, the webpages viewed and the dates and times of such access and activity. Information about the device used to access the marketing communication may also be collected. In such a case, the third party would provide or make available this information to us for the various purposes outlined in this Policy. They may also hold this information on our behalf.
  3. We may also engage these third parties on the basis that they may use the information that we provide them and which is collected from your interaction with our marketing communications for their legitimate business interests, such as to provide, support and improve the services they provide and to undertake data analytics projects. However, we would not permit them to use your Personal Information to market their or any other person’s services to you.
4. You may unsubscribe from receiving marketing communications from us by contacting us in accordance with the Your Rights section below or in accordance with the unsubscribe facility in any email sending you marketing communications. We will not be able to provide marketing communications to you if you unsubscribe.
5. In accordance with the Privacy Act we take reasonable steps to protect the security of Personal Information that we hold.
6. Where we no longer require your Personal Information for a permitted purpose under the Privacy Act, we will take reasonable steps to destroy it.
Your Rights
1. You have the right of access to, and correction of, your Personal Information. To access or correct any of your Personal Information, please contact us as follows:
Email: mayor@talktowngame.net
Address: Talk Town Limited
P.O. Box 37439
Christchurch 8245
New Zealand
We endeavour to ensure that the Personal Information we hold is accurate, complete and up-to-date. If any of the Personal Information that you have provided to us changes we encourage you to contact us to update that Personal Information.
Given that Talk Town is aimed at children and young adults, if you are a parent or a legal guardian of a child who is under 18 and has signed up to play Talk Town without your consent and you do not wish for them to participate in Talk Town, please contact us to have the information removed from our database.
If a dispute arises between us and we cannot resolve it with you, then you may wish to contact the Office of the Privacy Commissioner on investigations@privacy.org.nz.

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