This privacy policy describes our policies and procedures on the collection, use and disclosure of your information when you use the TeamTalkers & Friends app. The privacy policy tells you about your privacy rights and how the law protects you. We use your personal data to provide and improve the service. By using the service, you agree to the collection and use of information in accordance with this privacy policy.




  • Service means the TeamTalkers social platform and Friends mobile application operated by Dividis LLC

Personal Data

  • Personal Data is any information that relates to an identified or identifiable

Usage Data

  • Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).


  • Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

  • Data Controller means the natural or legal person who (either alone or jointly with other parties) determines the purposes for


which and the manner in which any personal information are, or are to be processed.

  • For the purpose of this Privacy Policy, we are a Data Controller of your Personal

Data Processors (or Service Providers)

  • Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data
  • We may use the services of various Service Providers in order to process your data more

Data Subject (or User)

  • Data Subject is any living individual who is using our Service and is the subject of Personal


Information Collection and Use


We collect several different types of information for various purposes to provide and improve our Service to you.

T ypes of Data Collected


Personal Data


While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Cookies and Usage Data
  • Phone number


We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you in order to continuously optimize and personalize those services and send you personal updates about new offerings which we believe you will find relevant. You may opt out of receiving any, or all of these forms of communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.



Usage Data


We may also collect information that your mobile phone sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your phone’s Internet Protocol address (e.g. IP address), type, version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. You can also make additional choices on your phone’s settings by changing our Service’s sensitive data permissions such as location sharing, access to contact list, camera and microphone.

Location Data


We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information in order to learn more about how people use our Service.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and are stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

To enable the advertisements on our service, we may share a unique advertising identifier with our third party partners, and advertising service providers (such as Google). This includes partners managing their advertising placements and also advertisers themselves and their agencies or third parties managing their advertising demands.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some functionalities of our Service.

Examples of Cookies we use:

  • Session We use Session Cookies to operate our Service.
  • Preference We use Preference Cookies to remember your preferences and various settings.
  • Security We use Security Cookies for security purposes

required to prevent fraudulent activity and improve security.

Use of Data

We collect personal data to provide better services to the users. We believe it is important to offer the right programs, services, advertising and other content to our users, at any time and any place. In this way we get to know our users better on the basis of a number of personal details, so that we can adjust our services where possible to the needs of our users. We may also contact you on the basis of your personal information in order to provide you with advertisements and other content tailored to your preferences.

Dividis LLC uses the collected data for various purposes:


  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are


similar to those that you have already purchased or enquired about unless you have opted not to receive such information

  • To manage your account
  • To verify the user’s identity


We use your Registration and Account information to register you for the Service and create your User Account; create your profile and make it visible; process payments; give you information about your account, and respond to your requests; personalize your experience by providing content in the Service, including targeted advertising by third party services that we believe may be of most interest to you.


Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), the legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Dividis LLC may process your Personal Data because:


  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it’s not overridden by your rights
  • For payment processing purposes
  • To comply with the law


Retention of Data


Dividis LLC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Dividis LLC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.


Transfer of Data


Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States or Europe and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and Europe and process it there.


Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Dividis LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information as well as having a lawful basis for the data transfer.



Lawful Bases for data transfer and processing include:


  • Subject’s specific consent to do so – this one is required in data sell agreements or in any transfer that is not covered by the other bases;
  • Processing (transfer) is necessary for the performance of a contract with the data subject – this one is suitable for the controller-processor relationships and does not require additional consent;
  • Legitimate interest of the company – The data transfer under the legitimate interest can only be deemed if the data subject can really expect such transfer;

Processing (transfer) is necessary for company’s legal obligations;

  • Processing (transfer) is necessary for protection of the subject’s vital interests;
  • Public interest or competent authority’s

Disclosure of Data

Your personal data is protected with us, but we do share this information with secured third parties we trust in order to provide you with our Services.


With Service Providers


We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites after You visited our Service or for payment processing.


With Affiliates

We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

With Business partners

We may share Your information with Our business partners to offer You certain products, services or promotions.


With other users

When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users registered in our Service. Do not forget this information is public on our Services and depending on your privacy settings it may be publicly distributed outside. If You interact with other users within our Service others may see Your name, profile, pictures and description of Your activity based on the privacy settings you have chosen within the Service community. Similarly, other users will be able to view descriptions of Your activity, communicate with You, view Your profile and share different content with you.


Business Transaction


If Dividis LLC is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement


Under certain circumstances,Dividis LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements


Dividis LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Dividis LLC
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability


Security of Data


The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic  storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.


Fraud & Spam Prevention


Prevent Fraud & Spam; We want our Service to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms and Conditions.

“Do Not Track” Signals Under California Online Privacy Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. Residents of the State of California can request a list of all third-parties to which our App has disclosed certain personal information (as defined by California law) during the preceding year for those third-parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at

p rivacy@teamtalkers.com. You need to attest to the fact that you are a

California resident and provide a current California address for our response. Please note that requests via the telephone or post mail are not acceptable means and we do not carry responsibility for notices that are not labeled or sent properly, or that do not have complete information.

You can enable or disable ¨Do Not Track¨ by visiting the Preferences or Settings page of your web browser.

California Consumer Privacy Act (CCPA) requires disclosing the collection of personal information by reference to specific categories listed in the statute. The categories of information that we may collect directly from you include “identifiers” and “protected characteristics”. The categories of


information that we may automatically collect from you through the use of cookies and similar technologies include “identifiers”, “geolocation data”, “commercial information”, “audio, electronic, visual, or similar information”, and “internet or other electronic network activity information”.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Dividis LLC will take all reasonable steps  to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:


  • The right to access, update or to delete the information we have about Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal
  • The right of You have the right to request that we restrict the processing of your personal information.


  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used
  • The right to withdraw You also have the right to withdraw your consent at any time where Dividis LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).


We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to Cookies and Tracking Technologies or when we process accurate location data for purposes other than performing the service). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy policy or by changing your setting within the Service or by changing the setting within the Service. We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to


perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We have put in place appropriate safeguards (such as contractual agreements) in accordance with applicable legal requirements to ensure that your data is adequately protected.

To provide our services, we do rely on a number of independent companies or service providers, such as providing a number of infrastructure or IT services, executing payment transactions through our services, conducting surveys, and so on. It is possible that such companies will have access to certain data and information as part of their assignment. We allow this to the extent that this is necessary for the performance of the task and these companies offer the necessary guarantees with regard to the access and possible use of this data and information.



Our Service uses Google Analytics and Firebase Analytics services. Google Analytics uses “cookies”, which are text files placed on your computer, to help the service analyse how users use it and Firebase provides numerous options to measure events taking place within our Service and set out parameters based on the activity of users. For more information about the usage and types of cookies please refer to the section “Tracking and Cookies Data”.

The information generated by the cookie about your use of the Service (including your IP address) will be transmitted to and stored by Google on servers in the United States.


Google will use this information to evaluate your use of the Service, compiling reports on user activity for operators and providing other services related to traffic activity and internet usage.


Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with other data held by Google.


Additionally, some Firebase services could be used to send notifications to users. This form of communication requires the user’s consent before contacting them in such a way. If you have provided your consent to be contacted but wish to opt out after the consent has been given, you have the right to be “Forgotten” by clicking on the unsubscribe link in the communication email sent to you by us.


For more information, please visit Google’s official privacy policy and terms at the links set out below:



By using our Service, you consent to process data about you in the manner and for the purposes set out above.

You can prevent the collection of your data by Google and Firebase Analytics by contacting us at privacy@teamtalkers.com. An opt-out cookie will be set to prevent your data from being collected. However

please have in mind that you may not be able to utilise some of the features of our Service.



We may provide paid products and/or services within the Service. In that case, we use secured third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:


  • S tripe
  • Their Privacy Policy can be accessed at


  • P ayPal
  • Their Privacy Policy can be accessed at


Links to Other Sites


Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


Children’s Privacy


Our Service does not address anyone under the age of 18 (“Children”).


We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.


If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Changes to This Privacy Policy


We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions or comments or if you no longer wish to use our services and / or products, please contact us at


By email: office@teamtalkers.com By visiting this page on our website:


By phone number: 00359 87 77 87 819