Privacy Policy

Effective as of 1 July 2025

Talky GmbH ("Talky", "we", "our" or "us") is committed to protecting your privacy and the privacy of children using the Talky App.

This Privacy Policy explains what personal data we collect, why we collect it, how we process it, and what rights you have under the General Data Protection Regulation (GDPR).

The Talky App is intended for children aged 8 to 16 and may only be used by children under 16 with the consent of a parent or legal guardian.

1. Data Controller

Talky GmbH
Französische Str. 20
10117 Berlin, Germany
Commercial Register: HRB 249285B
Email: support@talky.tech

2. What Data We Collect

Parent or Legal Guardian
During registration we collect your email address, used solely to complete parental verification and to communicate with parents where necessary.

Child
While using the App we process:

• a pseudonym or in-app username (if chosen)
• learning progress and gameplay progress
• language learning interactions
• voice recordings and speech transcriptions generated from voice recordings
• technical information required to operate the App (such as device information, crash reports and diagnostic information)

We do not require children to provide their real name.

3. Why We Process Your Data

We process personal data only where necessary to provide the Talky App. This includes:

• providing language learning functionality;
• analysing spoken language to generate speech transcriptions and learning feedback;
• personalising the learning experience based on interactions with the App;
• saving learning progress across sessions;
• improving the reliability, security and performance of the App;
• complying with applicable legal obligations.

We do not use voice recordings or personal data to train artificial intelligence models. We do not sell personal data. We do not use children's personal data for advertising.

4. Voice Processing

Voice recordings are an essential part of the Talky learning experience. When a child speaks within the App, voice recordings are securely transmitted to OpenAI's Whisper API for speech-to-text processing. The resulting transcription is used to provide the language learning functionality of the App.

Voice recordings are stored within the child's pseudonymised profile so that learning progress can be maintained. Voice recordings are not used by Talky to train artificial intelligence models.

5. Third-Party Service Providers

To operate the Talky App we use trusted service providers. All providers are bound by data processing agreements and are only permitted to process personal data as instructed by us.

Amazon Web Services (AWS)

AWS provides our cloud infrastructure and secure data storage. Personal data is stored exclusively on servers located within the European Union.

OpenAI

We use the OpenAI Whisper API to convert spoken language into text. Only the data required to perform speech recognition is transmitted. Data submitted through the OpenAI API is not used to train OpenAI's models.

6. Legal Basis

Where children under the age of 16 use the App, processing is based on the consent of their parent or legal guardian in accordance with Articles 6(1)(a) and 8 GDPR.

Processing necessary to provide the App and maintain its security is additionally based on Article 6(1)(b) and, where applicable, Article 6(1)(f) GDPR.

7. Data Storage and Retention

Personal data is stored only for as long as necessary to provide the App or until it is deleted by the parent or legal guardian. Parents and legal guardians can delete their child's personal data directly within the App at any time. Once deleted, personal data is removed from our systems unless we are legally required to retain certain information.

8. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or disclosure. These measures include:

• encrypted data transmission;
• encrypted data storage where appropriate;
• strict access controls;
• regular security monitoring.

9. International Data Transfers

Our primary data storage is located within the European Union.

For speech recognition, voice recordings are transmitted to OpenAI through its API. OpenAI is a US-based company.

Where personal data is transferred outside the European Economic Area, we ensure that appropriate safeguards are in place, including standard contractual clauses approved by the European Commission where required under the GDPR.

10. Your Rights

Under the GDPR you have the right to:

• access your personal data;
• correct inaccurate data;
• request deletion of your personal data;
• restrict processing;
• object to certain processing activities;
• receive a copy of your data where applicable;
• withdraw consent at any time.

To exercise any of these rights, please contact: support@talky.tech

You also have the right to lodge a complaint with your local data protection authority.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Where required by law, or where changes materially affect your rights, we will notify you through the App or by email. The latest version will always be available within the App and on our website.

12. Contact

If you have any questions regarding this Privacy Policy or the processing of personal data, please contact us at: support@talky.tech