Privacy Policy for Flexspeak, Inc.
Last Updated: April 21, 2023

California residents – please refer to the “Privacy Notice for California Residents” below.

Flexspeak, Inc. is committed to ensuring that your privacy is protected. If we ask you to provide certain information when using our websites, services, or products ("Services"), it will only be used in accordance with this Privacy Policy, unless stated otherwise in connection with a specific Service.

This Privacy Policy outlines how Flexspeak, Inc. generally handles your personal data. For certain Services, we may provide more specific information and ask for your consent before processing your personal data. At the end of this policy, you’ll find contact information for any questions or clarifications.

This policy only covers Flexspeak, Inc.’s use of personal data. If another company uses our technology as part of their service offering, please refer to their privacy policies.

1. What We Collect

Depending on the Services you use, we may process different types of information.

1.1 Personal Data You Provide to Us:

• Information provided during registration (e.g., name, email address, phone number).
• User profile information (e.g., details added after registration).
• Purchase information (e.g., payment details, order history).
• Communication data (e.g., your email address when contacting us).
• Health-related data (e.g., eye information or disability details if submitted).

1.2 Automatically Collected Data:

• Device and usage information (e.g., operating system, browser, and device performance).
• Interaction data (e.g., feature usage statistics, data from third-party services).
• Social media data (e.g., information shared via social media profiles).

1.3 Data from Third-Party Companies:

• We may share your personal data within Flexspeak, Inc. to improve products and services (anonymized where possible).
• Information shared when using social media accounts for access.

2. How We Use Your Personal Data

We use the information collected to provide, personalize, and enhance our Services.

2.1 Providing and Personalizing Services:

• Creating accounts and user profiles.
• Providing technical support and communicating about our Services.
• Customizing your experience based on usage.

2.2 Improving Our Services:

• Analyzing feedback and technical issues.
• Conducting research to understand user behavior.
• Enhancing third-party content and integrations.

2.3 Marketing and Promotions:

• Sending promotional messages (opt-out available in each message).
• Measuring response to marketing efforts.

2.4 Safety and Security:

• Investigating suspicious activity.
• Protecting users, Flexspeak, Inc., and third parties.

3. Minors

Flexspeak, Inc. recognizes the importance of protecting the privacy of minors. Our applications may be used by minors who require augmentative and alternative communication (AAC). We have implemented measures to ensure data protection for minors, including:

• Control by Service Providers: We allow the service provider (e.g., caregiver, clinician, or administrator) to control the collection and use of data for minors using Flexspeak's Services. The service provider is responsible for entering and managing data and selecting with whom it may be shared.
• Limiting Data Collection: We limit the collection and processing of personal data for minors to what is necessary to provide core features of the Services.
• Compliance with Institutions: When our Services are used by schools, clinics, or other service providers, we act as a data processor and follow the instructions provided by the institution.

4. Sharing of Personal Data

We share your information as necessary to support our Services.

4.1 Third-Party Developers and Content Providers:

• Information shared with partners providing content or experiences through our Services.

4.2 Service Providers:

• Data shared with vendors (e.g., hosting, payment processing, customer service).

4.3 Business Transactions:

• Data may be transferred in case of a merger, acquisition, or bankruptcy.

4.4 Legal Requests:

• Data shared with law enforcement when required by law.

4.5 De-Identified Data:

• We may share aggregated or de-identified data that does not identify individuals.

5. Data Retention and Deletion

We retain your data as long as it is necessary to fulfill the purposes outlined in this policy, such as providing Services, meeting legal obligations, or resolving disputes.

• When you delete your account, we will delete or anonymize the personal data you provided and the data collected during your use of the Services.
• Certain data may be retained for legal or accounting purposes even after account deletion.

6. Legal Requests and Minimizing Harm

We may access, preserve, and share your data when:

• Responding to legal requests or compliance requirements.
• Protecting the safety and security of our users and Services.

7. Global Data Transfers

Flexspeak, Inc. operates globally, and your data may be transferred to and processed in countries outside of where you live, including the United States and China. We ensure that any data transfers comply with applicable data protection laws.

8. Changes to This Privacy Policy

We may update this Privacy Policy periodically. If we make significant changes, we will notify you through email or via a notice on our Services.

For questions, contact our Data Protection Officer at:
Email: team@flexspeak.com
Address: Flexspeak, Inc., 15400 Belgrade St. #137, Westminster, CA 92683

9. Legal Basis for Processing Data

Our legal basis for processing your personal data may include:

• Fulfilling our contract with you.
• Obtaining your consent (which can be withdrawn at any time).
• Complying with legal obligations.
• Protecting vital interests.
• Serving our legitimate business interests.

10. Exercising Your Rights (GDPR)

Under GDPR, you have rights to:

• Access Your Data: Request a copy of your personal data.
• Rectify Your Data: Correct any inaccurate or incomplete data.
• Port Your Data: Receive your data in a machine-readable format.
• Erase Your Data: Request deletion of your data when it is no longer needed.
• Restrict Processing: Limit how we use your data in certain circumstances.

To exercise these rights, contact us at team@flexspeak.com.

11. Privacy Notice for California Residents

Please refer to the “Privacy Notice for California Residents” below for specific information about your rights under the CCPA.

Contact Information

For any inquiries about this Privacy Policy or to exercise your rights, please contact:

Website: www.flexspeak.com
Email: team@flexspeak.com
Address: 15400 Belgrade St. #137, Westminster, CA 92683
Attn: Data Protection Officer

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