Privacy Policy
1. Introduction and Scope
This Privacy Policy (the “Policy”) describes how Talk Time Academy (“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 is the controller responsible for the personal information processed under this Policy. Inquiries, rights requests, and complaints may be directed to:
Talk Time Academy6821 South Point Dr N
Jacksonville, FL 32216
Myfirstwords@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.
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.
3.3 Categories of Personal Information Not Collected
Talk Time Academy does not collect, and has no mechanism to collect, the following categories:
- Analytics, behavioral, or usage-measurement data. No analytics service is deployed on the Site.
- Advertising identifiers, cross-context behavioral advertising data, or targeted advertising data.
- Precise geolocation data.
- Biometric information or genetic data.
- Financial account numbers, payment card data, or credentials.
- Government identifiers, including Social Security numbers.
- Any identifying information concerning a child, including a child’s name, date of birth, photograph, medical record, or clinical diagnosis. No field on the Site solicits such information.
4. Sources of Personal Information
Personal information is obtained (a) directly from you, where you submit it through a form or written communication, and (b) automatically from your device, limited to the server-log 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:
- To deliver the specific educational material, guide, or resource you requested.
- To send periodic communications regarding new educational content, where you have consented to receive them.
- To respond to inquiries, correspondence, and rights requests.
- To maintain the security and operational integrity of the Services and to detect, prevent, and investigate abuse.
- 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, and is not used for profiling.
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. 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. 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.
- 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. No Sale or Sharing of Personal Information
Talk Time Academy does not sell personal information, and does not share personal information for cross-context behavioral advertising. Those terms carry the meaning given them by the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (Cal. Civ. Code §§ 1798.100 et seq.).
Talk Time Academy likewise does not sell personal data, and does not process personal data for targeted advertising, within the meaning of the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, or any comparable state statute.
Talk Time Academy has not sold or shared personal information in the twelve (12) months preceding the Effective Date stated above. Talk Time Academy does not sell or share the personal information of consumers it knows to be under sixteen (16) years of age.
9. Cookies and Similar Technologies
The Site sets only strictly necessary cookies generated by the WordPress content management system for the purpose of serving functional pages and maintaining session integrity. No advertising cookies, analytics cookies, or cross-site tracking technologies are deployed.
All fonts, scripts, stylesheets, and images are served from Talk Time Academy’s own infrastructure. No third-party content delivery network is invoked in the ordinary rendering of a page, and consequently no visitor IP address is transmitted to a third party by the act of loading a page.
10. Data Retention
| 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. |
| 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. As stated in Section 8, no such processing occurs.
- The right to limit the use and disclosure of sensitive personal information. Talk Time Academy collects no sensitive personal information.
- 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 Myfirstwords@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.
No field within the Services requests information identifying a child. A parent or guardian who believes that a child has provided personal information may write to Myfirstwords@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 and stored on servers located in the United States. 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 deploy tracking technologies and therefore has no tracking behavior to alter in response to a Do Not Track browser signal. A Global Privacy Control signal is honored as a valid opt-out request where applicable law requires, notwithstanding that no sale or sharing of personal information occurs.
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 Academy6821 South Point Dr N
Jacksonville, FL 32216
Myfirstwords@talktimeacademy.org