Privacy Policy

Introduction

We are TALKPOINT LTD, doing business as Tipi ("Company," "we," "us," or "our"). We operate the Tipi mobile application (the "App"), a location-based ephemeral chat platform that connects users nearby, as well as any related products and services that refer or link to this legal term (collectively, the "Services").

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy or our practices with regards to your personal information, please contact us at privacy@tipi.zone.

This privacy policy describes how we might use your information if you:

• Download and use our mobile application (Tipi)
• Engage with us in other related ways ― including any sales, marketing, or events

In this privacy policy, if we refer to:

• "Personal Information," we mean any information that identifies or relates to you.
• "Services," we mean our App and other related services.

Please read this privacy policy carefully, as it will help you understand what we do with the information that we collect. By using Tipi, you acknowledge and consent to the practices described in this policy.

1. What Information Do We Collect?

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

Information Collected

• Phone Number: Required for account creation and verification via SMS. We do not use this for marketing purposes without your explicit consent.
• Profile Data: Username, bio, and profile picture (if you choose to upload one).
• Location Data: We collect approximate location data (radius-based) to show you relevant chat rooms nearby. We presume this is essential for the functionality of Tipi. We only collect this with your explicit permission. You can revoke this permission at any time in your device settings.
• Contacts (Hashed): If you choose to engage in "Friend Discovery," we access your contact list to find friends on Tipi. We do not store your contacts. We hash phone numbers using HMAC-SHA256 to compare them with existing users. This ensures your contacts' privacy is preserved. We do NOT send invites or messages to your contacts.
• Sensory Data (User Content): Photos, audio, or video you send in chats.
• Device Data: Device ID, model, and OS version for analytics and debugging.

Information We DO NOT Collect

• Biometric Data: We do not collect or store biometric identifiers such as fingerprints or facial recognition data.
• Precise Continuous Tracking: We do not track your location in the background for marketing or surveillance. Location is used to provide the service (finding nearby rooms).

2. How Do We Use Your Information?

We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use the information we collect or receive:

• To facilitate account creation and logon process: (Contractual Necessity) To verify your identity via SMS.
• To provide the requested service: (Contractual Necessity) To show you nearby rooms and deliver your messages.
• To improve our Services: (Legitimate Interest) We use Firebase Analytics to understand how users interact with our app and to identify bugs or crashes (via Crashlytics).
• To ensure safety and prevent fraud: (Legitimate Interest) To detect and prevent abuse, spam, and fraudulent activity.
• For Marketing: We do not use your phone number for marketing SMS. We do not sell your personal data.
• Future Monetization: Tipi is currently free and ad-free. If we introduce advertising or premium features in the future, we will update this policy and, where required, obtain your consent for data usage related to personalized ads.

3. Who Do We Share Your Information With?

We do not sell your personal information. We only share information with the following categories of third parties:

• Service Providers: We may share data with trusted third-party vendors who perform services for us, under strict confidentiality agreements. These include:
  • Cloud Hosting: Google Firebase (Data storage and backend).
  • Analytics & Performance: Firebase Analytics, Firebase Crashlytics.
  • Communications: SMS providers (e.g., Twilio or Firebase Auth) for verification codes.
• Google Maps: Our location features integrate Google Maps. By using these features, you agree to be bound by Google's Terms of Service and Privacy Policy. Google may receive location coordinates to display maps.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.
• Advertising: If we ever display ads, we may share limited device or location information with trusted ad partners to deliver relevant ads. We will not share your identity or contacts without consent.

4. Do We Use Cookies and Tracking Technologies?

We do not use browser cookies, as Tipi is a mobile application. However, we use mobile tracking technologies such as:

• Mobile Device Identifiers: To recognize your device for security and preferences.
• Analytics SDKs: We use Firebase Analytics to collect aggregate data on app usage.

Opt-Out: You can opt-out of certain analytics tracking by adjusting your device settings (e.g., "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android), or through available in-app privacy settings.

5. Where Is Your Data Stored?

Our servers are located in the United States. However, TALKPOINT LTD is located in Israel.

• International Transfers: Information we collect may be transferred to, stored, and processed in the United States or any other country where we or our service providers maintain facilities.
• Legal Basis: Israel is recognized by the European Commission as providing an adequate level of data protection. For transfers to the U.S., we rely on Standard Contractual Clauses (SCCs) and other mechanisms to ensure your data is protected.
• By using Tipi, you consent to the transfer of your information to Israel and the United States.

6. How Long Do We Keep Your Information?

We prioritize ephemerality.

• Chat Content: Messages and room content are automatically deleted from our live systems after they expire (typically between 30 minutes and 7 days, depending on the room settings). We do not maintain permanent historical records of your conversations.
• Account Data: We keep your profile information (phone number, username) as long as your account is active. You can delete your account at any time.
• Backups: Please note that while content is deleted from our live databases, residual copies may persist for a short period in secure, access-restricted backup archives for disaster recovery purposes. These are eventually overwritten.
• Legal Compliance: We may retain certain information for longer periods if required by law (e.g., for fraud prevention or legal compliance).

7. How Do We Keep Your Information Safe?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process.

• Encryption: We use encryption in transit and at rest for sensitive data.
• Hashing: Contact lists are hashed using HMAC-SHA256 and are not stored in raw form.
• Access Controls: Access to personal data is strictly limited to authorized personnel.

Breach Notification: In the event of a data breach that compromises your personal information, we will notify you and appropriate regulatory authorities as required by applicable law.

8. Your Privacy Rights

Depending on your location, you may have the following rights:

European Economic Area (EEA) and UK

• Right to Access: Request copies of your personal data.
• Right to Rectification: Request correction of inaccurate data.
• Right to Erasure: Request deletion of your data.
• Right to Restrict Processing: Ask us to limit how we use your data.
• Right to Object: Object to processing based on legitimate interests.
• Right to Withdraw Consent: Revoke consent at any time (e.g., for location or contacts).
• Right to Data Portability: Request your data in a structured, commonly used, and machine-readable format.

United States (California, Virginia, etc.)

• Right to Know: Request details about the categories and specific pieces of personal information we collect.
• Right to Delete: Request deletion of your personal information.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out: You have the right to opt-out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising. Tipi does not sell your personal data.
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

How to Exercise Your Rights

The fastest way to exercise your rights (such as deletion) is through the Settings menu in the Tipi app, where you can Delete Account instantly.

For other requests, contact us at privacy@tipi.zone. We may need to verify your identity before processing your request. We aim to respond to verified requests typically within 30 days.

9. Updates to This Policy

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Last Updated" date.

Notification: For material changes that affect your rights, we will notify you prominently within the app (e.g., via a pop-up) or via email/SMS. We may require you to review and accept the updated policy to continue using the App.

10. Children's Privacy (COPPA Compliance)

• Under 13: We do not knowingly collect personal information from children under 13. If you are under 13, you may NOT create an account or use Tipi.
• Ages 13-17: Users between 13 and 17 may use Tipi with parental or guardian consent. We may apply additional restrictions to protect minor users, such as limiting certain features or content visibility.
• Parental Rights: Parents or guardians may request to review, delete, or stop the collection of their child's personal information by contacting us at support@tipi.zone.

If we learn that we have collected personal information from a child under 13, we will promptly delete such information and terminate the associated account.