Privacy Policy

App and Website Privacy Notice
Last Updated: 30th January 2024

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This section will detail our privacy policy. It will explain how we collect, use and store personal information provided by users. It will also cover the steps we take to protect user privacy.

BeneTalk LTD. (“BeneTalk”, “us”, “we”, or “our”) is dedicated to upholding your privacy rights and ensuring the secure use of our services. This commitment aligns with legal frameworks and policies including the UK Data Protection Act (DPA) and EU General Data Protection Regulation (GDPR) designed to safeguard your privacy while interacting with our website(s) - www.benetalk.com, www.superpenguin.com (“Websites”) - and applications (“Apps”) named “BeneTalk,” “Penguin,” and “SuperPenguin.” Our Apps and Websites are collectively referred to as (“Products”). Your personal data, held by us, is treated with utmost care, adhering to data protection principles:

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• Lawful, Fair, and Transparent Processing: We process your data in strict compliance with applicable laws. We commit to fair and transparent use of your data, ensuring that you are fully informed about how your data is used. Our processing activities are always based on lawful grounds such as consent, contract, legal obligations, or legitimate interests.
• Purpose Specification and Limitation: Data is collected solely for explicit, legitimate, and specified purposes, as outlined in our privacy policy. We guarantee that your data will not be used in any manner incompatible with these purposes. Any changes to these purposes will be communicated to you and will be subject to your consent where required by law.
• Data Minimisation, Relevance, and Accuracy: The data we collect is limited to what is necessary in relation to the purposes for which it is processed. We are committed to ensuring that the data we hold is accurate, relevant, and up to date.
• Storage Limitation: Personal data is retained only for as long as necessary for the purposes we have disclosed to you. The maximum duration of retention will not exceed 7 years unless a different retention period is required or permitted by law. We regularly review our data retention policies to ensure compliance with all applicable laws and regulations.
• Data Security and Integrity: We employ robust security measures to protect your data, including appropriate anonymization and encryption techniques, as well as physical, technical, and administrative safeguards. These measures are designed to protect data from unauthorised access, disclosure, alteration, and destruction, in compliance with international data protection standards.

For clarity, our definitions and terms mentioned above are broken down here:

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“App(s)”

BeneTalk”, “Penguin”, “SuperPenguin”, our mobile applications.

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“Personal Data”

Any information relating to an identified or identifiable individual and any information listed here.

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“Privacy Policy”

This privacy policy.

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“Products”

Our Website and App(s)

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“Terms and Conditions”

Our terms and conditions are located here

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“Website(s)”

“www.benetalk.com”, “www.superpenguin.com”, our websites.

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“BeneTalk,” “we,” “us,” or “our”

BeneTalk Ltd

Personal data is considered to be any information that may be able to identify you. For example, we may collect or process the following Personal Data (“Personal Data”) about you:

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A) Category

• Specific types of personal data.

B) Personal Identifiers

• First name and surname, email address.

C) Internet or Other Electronic Network Activity Information

• Internet Protocol (IP) address, device ID, device language, operating system, device type and model, carrier.

D) Geolocation Data:

• Approximate location including country and city.

We collect Personal Data from what you provide to us directly, and Personal Data we automatically collect when interacting with our products. This includes:

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• ‍Direct Submissions: When you complete contact forms on our products including onboarding on our apps.-
• ‍Device information: From your mobile device.

We also collect information automatically by using our products. We use the following technologies to automatically collect data:

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• ‍Cookies: Small text files sent from your browser to your device. BeneTalk uses cookies to collect data and improve our customer service. You can use the “Help” function on most browsers to accept or disable cookies or to be notified when a cookie is being sent. If you disable all cookies, you may not be able to use some features of our website.
• Amplitude Analytics: Measures how users interact with our products. Amplitude Analytics records information about page views and uses first-party cookies to remember what you have done on previous interactions with our products. Our apps send lots of information about the users and what they are doing in the app to Amplitude. This includes personal details like: name, email address, device id, device type, brand and model, operating system version, carrier, language, rough location (country and city). We do not record audio or use an Ad ID or track the users for advertisement purposes. Amplitude privacy policy can be found here.
• Firebase: We use these services for our cloud database, user authentication, storage, and crash analysis. The privacy policy can be found here.
• Other Third Party Tools: We may use tools which allow us to track the performance of our products. These tools identify errors, and provide information about our products’ performance.

We may use your personal data for the following purposes:

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• To operate, maintain and enhance our products including troubleshooting and system administration, testing and system maintenance, usability and accessibility assessment and improvement, technical support and reporting.
• To improve our products to ensure that content is presented in the most effective manner for you and your device.
• To promote or market our products and products, which may include using your email address to send you newsletters or offer promotions. You are able to opt out of receiving these emails.
• To contact you in response to a request.
• To provide you with information that you request from us.
• To notify you of any changes to our products or products including changes to our privacy policy and terms and conditions.
• Inviting you to participate in further research and development.
• We also may use your data to conduct research. We do this by administering questionnaires and surveys throughout our apps. We only conduct research on aggregated, anonymous or de-identified data from Personal Data by masking data which can be personally identifiable to you (“De-Identified Data”).
• To use de-identified data for analytics and reporting purposes.

We may share personal data with third parties in certain circumstances or for specific purposes including:

For Business Purposes:

We may share your Personal Data with service providers including data hosting and data storage partners including Google, analytics providers, CRM providers including Close, technology services and support. Privacy policy included here.

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For Research:

For the purposes of increasing research and improving the care provided to people with speech and language difficulties, we may pass de-identified data to third parties such as universities and research centres for the purposes of completing scientific research. Therefore, research articles may be published containing this de-identifiable data. All research carried out by approved third parties is required to have ethical approval from an independent research ethics board.

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To improve our products:

We may use your personal data for internal testing, research, analysis, and product development including improvements to our website and apps.

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Third Party Analytics:

We use Amplitude to evaluate how users interact with our products and services.

We understand the importance of protecting, managing, and storing your personal data. Here are our measures:

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Secure servers:

Your personal data is stored on secure servers, with anonymisation applied where feasible to enhance privacy protection. This approach aligns with global data security standards and practices.

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Data Retention:

We retain personal data no longer than is necessary for the purpose for which it is processed, in compliance with GDPR and other relevant data protection laws. The maximum retention period is up to 7 years, unless a different duration is mandated by specific legal requirements.

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Safeguards:

We implement physical, electronic, and procedural safeguards for data collection, storage, and disclosure.

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Encryption:

We encrypt your information during transmission.

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Computer Safeguards:

We employ robust computer security measures including firewalls and data encryption to prevent unauthorised access and ensure data integrity.

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Access Control:

Access to personal data is strictly limited to employees who require it for their work responsibilities. Regular training and strict internal policies enforce this access control.

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System Monitoring:

Regular monitoring of our systems for vulnerabilities and potential attacks is conducted. This includes periodic penetration testing to assess the effectiveness of our security measures.

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Breach Procedures:

In the event of a suspected data breach, we have in place detailed procedures to promptly address the situation. If a breach occurs that poses a risk to your rights and freedoms, we will notify you and the relevant authorities as required by law.

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Updates to This Privacy Notice:

We reserve the right to update this privacy notice to reflect changes in our data processing practices or in response to legislative changes. All significant changes will be communicated to you in advance, ensuring transparency and compliance with data protection regulations.

If you have any questions about BeneTalk's privacy policy, the data we hold on you, or if you would like to exercise one of your data protection rights, please do not hesitate to contact us by emailing speak@benetalk.com.