Privacy Policy

1. Introduction and Scope

This Privacy Policy (the “Policy”) describes how Talk Time Academy LLC, a Florida limited liability company (“Talk Time Academy,” “we,” “us,” or “our”) collects, uses, discloses, retains, and safeguards personal information.

The Policy covers the website at talktimeacademy.org (the “Site”) and any related content, tools, and communications (collectively, the “Services”).

By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with the practices described herein, please discontinue use of the Services.

This Policy does not apply to any third-party website, platform, or service that may be linked from or referenced within the Services, including without limitation the Talk Time Academy community hosted on Skool.com. Each such third party is an independent controller of any personal information it collects and is governed by its own privacy policy.

2. Controller Identity and Contact Information

Talk Time Academy LLC, a Florida limited liability company is the controller responsible for the personal information processed under this Policy. Inquiries, rights requests, and complaints may be directed to:

Talk Time Academy LLC, a Florida limited liability company
6821 Southpoint Dr N
Jacksonville, FL 32216
growth@talktimeacademy.org

3. Categories of Personal Information Collected

3.1 Information You Provide Directly

Talk Time Academy collects the following categories of personal information only where you voluntarily submit it:

• Identifiers. Your email address, where submitted to receive educational materials, guides, or communications.
• Identifiers and customer records. Your name, email address, and the content of your message, where you contact Talk Time Academy directly.
• Quiz and form submissions. What you enter in a quiz or sign-up form, described in Section 3.4, including your child’s birth month and year and your answers about your child.

3.2 Information Collected Automatically

Talk Time Academy’s hosting provider maintains standard server logs that may record Internet Protocol (IP) addresses, browser user-agent strings, requested resource paths, and timestamps. Such logs are generated for security monitoring, abuse prevention, and technical diagnostics, are not used to build profiles of individual visitors, and are retained for no more than ninety (90) days.

Where your cookie choices allow it, an analytics service (Google Analytics) records the pages you view, how you arrived at the Site, your approximate location, and your device and browser type, and advertising pixels from Meta (Facebook and Instagram), Google (including YouTube), TikTok, Pinterest, and other advertising services we may use in the future record that you visited the Site and what you viewed. Section 9 explains these technologies and how to switch them off.

To decide which cookie choices to show you, the Site works out your country and, in some countries, your state or province, from your IP address. This is done on Talk Time Academy’s own server from a stored database, and your IP address is not sent to another company for that purpose.

3.3 Categories of Personal Information Not Collected

Talk Time Academy does not collect, and has no mechanism to collect, the following categories:

• Precise geolocation data.
• Biometric information or genetic data.
• Financial account numbers, payment card data, or credentials.
• Government identifiers, including Social Security numbers.
• A child’s last name, full date of birth, photograph, medical record, or clinical diagnosis. No field on the Site asks for them.

3.4 Quiz Responses

When you take a quiz, you answer questions about your child’s everyday behavior and development. A quiz asks for your child’s birth month and year, which sorts the questions to your child’s age, and may ask for a first name, which is optional.

Your answers, your email address, your tick of the consent box where a form has one, and the page you came from are stored by Fillout, the service that runs the quizzes and forms. Fillout passes your email address, your result, tags used to choose which follow-up emails to send you, and your child’s age to Mailchimp. Quiz answers describe behavior. They are not a diagnosis and not a medical record, and no quiz asks for either.

If you leave a quiz before the end, Fillout keeps the answers you gave, and you can pick up where you left off or start over in the same browser.

4. Sources of Personal Information

Personal information is obtained (a) directly from you, where you submit it through a form, a quiz, or written communication, and (b) automatically from your device, limited to the server-log data, the location check, and the analytics and advertising data described in Section 3.2.

5. Purposes of Processing

Talk Time Academy processes personal information for the following enumerated purposes and for no others:

1. To deliver the specific educational material, guide, or resource you requested, and to show you the result of a quiz you took.
2. To choose which follow-up emails to send you after a quiz.
3. To send periodic communications regarding new educational content, where you have consented to receive them.
4. To respond to inquiries, correspondence, and rights requests.
5. To maintain the security and operational integrity of the Services and to detect, prevent, and investigate abuse.
6. Where your cookie choices allow it, to understand how the Site is used so it can be improved, and to measure and show advertising.
7. To comply with applicable legal obligations and to establish, exercise, or defend legal claims.

Personal information is not used for automated decision-making producing legal or similarly significant effects. Advertising platforms that receive data through pixels may use it under their own policies.

6. Legal Bases for Processing

Where the General Data Protection Regulation (Regulation (EU) 2016/679) or the UK GDPR applies, Talk Time Academy relies on the following legal bases:

• Consent, Article 6(1)(a), for the sending of educational communications, for processing the answers you submit in a quiz, and for analytics and advertising cookies. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
• Legitimate interests, Article 6(1)(f), for security monitoring and abuse prevention, and for responding to correspondence you initiate.
• Compliance with a legal obligation, Article 6(1)(c), where retention or disclosure is required by law.

7. Disclosure of Personal Information

Talk Time Academy discloses personal information only as follows:

• Service providers. Fillout, which runs the quizzes and sign-up forms and stores what is submitted through them; Intuit Mailchimp, which operates as a processor for the transmission and administration of email communications; and Talk Time Academy’s website hosting provider. Each such provider is engaged under terms restricting the use of personal information to the provision of services to Talk Time Academy.
• Analytics and advertising providers. Where your cookie choices allow it, Google (Google Analytics) receives analytics data, and Meta (Facebook and Instagram), Google (including YouTube), TikTok, Pinterest, and other advertising services we may use in the future receive advertising pixel data. These providers may use that data under their own policies.
• Legal compliance. Where disclosure is required by applicable law, subpoena, court order, or other lawful process, or where necessary to protect the rights, property, or safety of Talk Time Academy or others.
• Business transfer. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to the recipient being bound by terms no less protective than this Policy.

8. Sale, Sharing, and Targeted Advertising

9. Cookies and Similar Technologies

The Site uses three kinds of cookies and similar technologies, which the Cookie Settings panel calls Essential, Performance, and Promotions.

• Essential. Cookies generated by the WordPress content management system to serve functional pages and maintain session integrity, and the record of your cookie choices, which is kept in your own browser. These are always on.
• Performance. Google Analytics, which helps Talk Time Academy understand how the Site is used.
• Promotions. Advertising pixels from Meta (Facebook and Instagram), Google (including YouTube), TikTok, Pinterest, and other advertising services we may use in the future, which measure and support advertising.

What runs before you choose depends on where you are. In Europe, the United Kingdom, and some other places, Performance and Promotions stay off until you accept them. In California, Washington, and Connecticut, Performance runs until you turn it off and Promotions stays off until you accept it. In the rest of the United States and in other English-speaking countries, both run until you turn them off.

You can change your choices at any time in Cookie Settings, in your browser settings, or by writing to the address in Section 2.

Fonts, stylesheets, and images are served from Talk Time Academy’s own infrastructure. Pages are delivered through Talk Time Academy’s hosting provider and its content delivery network, which therefore see the IP address of a visitor loading a page. When you open or use a quiz or sign-up form, your browser also connects to Fillout’s servers to display it, so Fillout receives your IP address and browser details.

10. Data Retention

How long each category of personal information is kept

Category	Retention period
Email address, subscriber list	Retained for as long as you remain subscribed, and for twenty-four (24) months following unsubscription or a deletion request, solely to honor suppression obligations under the CAN-SPAM Act.
Correspondence and message content	Retained for twenty-four (24) months from the date of receipt.
Quiz and form submissions	Kept until you ask us to remove them.
Analytics data	Kept by each provider under its own terms; Google Analytics keeps visitor-level data for up to 14 months.
Server logs	Retained for no more than ninety (90) days.

Personal information is deleted or de-identified at the conclusion of the applicable period unless a longer retention period is required to comply with a legal obligation or to establish, exercise, or defend legal claims.

11. Information Security

Talk Time Academy maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction, including transport-layer encryption for all data submitted through the Site. No method of transmission over the Internet or method of electronic storage is completely secure, and Talk Time Academy cannot guarantee absolute security.

12. Your Privacy Rights

12.1 Rights Under United States State Privacy Laws

Subject to verification and to the exemptions provided by applicable law, residents of states with comprehensive consumer privacy statutes may exercise the following rights:

• The right to know and to access the categories and specific pieces of personal information collected, the sources of that information, the purposes of processing, and the categories of third parties to which it is disclosed.
• The right to delete personal information, subject to statutory exceptions.
• The right to correct inaccurate personal information.
• The right to obtain a copy of personal information in a portable and, to the extent technically feasible, readily usable format.
• The right to opt out of the sale or sharing of personal information and of processing for targeted advertising. Section 8 explains how to use this right.
• The right to limit the use and disclosure of sensitive personal information. Some state laws may treat answers about a child’s development as sensitive. Talk Time Academy uses quiz answers only to show you your result and to choose which emails to send you, and does not sell them or use them for advertising.
• The right not to receive discriminatory treatment for exercising any of the foregoing rights.

12.2 Rights Under the GDPR and UK GDPR

Where the GDPR or UK GDPR applies, data subjects hold the rights of access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20), and objection (Article 21). Consent may be withdrawn at any time.

A data subject may also lodge a complaint with a supervisory authority. That authority is the one in the member state of their habitual residence, place of work, or place of the alleged infringement.

12.3 Exercising Your Rights

Requests may be submitted to growth@talktimeacademy.org. Talk Time Academy will acknowledge receipt within ten (10) business days and will respond substantively within forty-five (45) calendar days. That period is extendable once by a further forty-five (45) days where reasonably necessary, and notice of any extension is provided within the initial period. Requests under the GDPR will be answered within one (1) month, extendable by two (2) further months for complex requests.

Talk Time Academy will take reasonable steps to verify the identity of a requester before acting, which ordinarily requires the request to originate from, or be confirmed at, the email address to which the personal information relates. An authorized agent may submit a request on your behalf with written authorization signed by you.

12.4 Appeals

If a rights request is declined, you may appeal that decision by replying to the response or by writing to the address in Section 2 with the word “Appeal” in the subject line. Talk Time Academy will inform you in writing of the outcome of the appeal, and of the reasons for it, within forty-five (45) days. Where an appeal is denied, you may contact the Attorney General of your state to submit a complaint.

13. Children’s Privacy

The Services are directed to parents, caregivers, and other adults, and are not directed to children. Consistent with the Children’s Online Privacy Protection Act (15 U.S.C. §§ 6501–6506) and its implementing regulations at 16 C.F.R. Part 312, Talk Time Academy does not knowingly collect personal information from any child under thirteen (13) years of age.

The only information about a child that a form asks a parent for is the child’s birth month and year, answers about the child’s behavior, and, optionally, a first name. A parent or guardian who believes that a child has provided personal information may write to growth@talktimeacademy.org, and Talk Time Academy will delete the information promptly upon verification.

14. International Data Transfers

Talk Time Academy operates in the United States, and personal information is processed in the United States. The service providers named in Section 7 may also process it in other countries. Where personal information is transferred from the European Economic Area, the United Kingdom, or Switzerland, such transfer is made in reliance on your consent or on Standard Contractual Clauses adopted by the European Commission, as applicable.

15. Do Not Track and Global Privacy Control

The Site does not respond to a Do Not Track browser signal. A Global Privacy Control signal is honored as a valid opt-out request where applicable law requires it. You can also opt out at any time in Cookie Settings.

16. Changes to This Policy

Talk Time Academy may amend this Policy from time to time. The revised Policy will be posted at this address with an updated Effective Date. Where an amendment materially changes the treatment of previously collected personal information, notice will be provided by email to affected subscribers before the amendment takes effect.

17. Contact

Questions regarding this Policy, or regarding the treatment of personal information generally, may be directed to:

Talk Time Academy LLC, a Florida limited liability company
6821 Southpoint Dr N
Jacksonville, FL 32216
growth@talktimeacademy.org