Privacy Policy
1. Who we are
TruTalk is operated by [ENTITY DESCRIPTION — placeholder, e.g. “an independent founder based in …” or a registered company]. For the purposes of the EU General Data Protection Regulation (Regulation 2016/679, "GDPR") and any applicable local data-protection law in [JURISDICTION — placeholder], we are the data controller of any personal data described in this policy.
Contact:
[LEGAL ENTITY / OWNER NAME — placeholder, e.g. “TruTalk” or a registered company name]
[REGISTERED ADDRESS — placeholder]
[JURISDICTION / COUNTRY OF REGISTRATION — placeholder, e.g. Italy]
Email: [CONTACT EMAIL — placeholder, e.g. hello@letstrutalk.com]
2. What data we collect
We collect only what is necessary for the service to function and to respond to you. Specifically:
Data you give us directly
- Contact form submissions, name, email address, and the contents of your message. Submitted only when you choose to send us a message via the form on our homepage.
- Email correspondence, if you email us at hello@letstrutalk.com, we receive your email address and message contents.
Data collected automatically
- Server logs, our hosting provider (Netlify) automatically logs basic technical information when you visit the site, including your IP address, browser type, referring URL, and timestamp. These logs are retained for short periods for security and abuse-prevention purposes.
- Anti-spam protection, Netlify Forms uses an invisible honeypot field and may use Akismet-style spam detection to filter out automated submissions.
- Analytics, only if you accept via our cookie banner, we use Google Analytics 4 (GA4) to understand aggregate traffic — pages viewed, session duration, approximate location derived from IP, device/browser type, and referring site. We do not use GA4 for advertising, and Google Signals / ads personalization features are not enabled.
We do not collect: Conversation content from the TruTalk web app (app.letstrutalk.com), location data, payment information (Stripe handles this directly), social-media identifiers, advertising IDs, or biometric data.
3. Why we collect it
- To respond to inquiries, we use the name and email from your contact form submission only to reply to your message.
- To operate the website, server logs help us prevent abuse and diagnose technical issues.
- To improve the service, aggregate analytics (Google Analytics 4, loaded only with consent) help us understand which pages people read and how the site performs.
- To comply with the law, we may process data to meet legal obligations, such as responding to a binding court order.
4. Lawful basis for processing (GDPR Art. 6)
- Consent (Art. 6(1)(a)), for analytics cookies, and for any optional newsletter sign-ups.
- Performance of a contract or pre-contractual steps (Art. 6(1)(b)), when you contact us with a business inquiry.
- Legitimate interest (Art. 6(1)(f)), for security logging, abuse prevention, and replying to general inquiries. We always balance this against your privacy rights.
- Legal obligation (Art. 6(1)(c)), to comply with applicable law.
5. Who we share it with
We never sell or rent your personal data. We share it only with the following sub-processors who help us run the service:
- Netlify, Inc. (USA), hosting and form handling. Privacy policy
- Google LLC (USA), acts as our data processor for Google Analytics 4 (with consent); Gmail receives forwarded contact-form submissions; Google Fonts loads the Inter typeface. Privacy policy · Data Processing Terms
- Cloudflare, Inc. (USA), content delivery for our app, if applicable. Privacy policy
- Stripe, Inc. (USA / Ireland), payment processing for TruTalk+ subscriptions. We never see or store your full card details. Privacy policy
We may add or change sub-processors over time. Material changes will be noted here.
6. How long we keep it
- Contact-form submissions: retained for up to 24 months from your last interaction, then deleted, unless we are required to keep them for legal reasons.
- Server logs: retained for up to 30 days by Netlify.
- Google Analytics 4 data: retained for [GA4 DATA-RETENTION SETTING — placeholder, e.g. “14 months”, as configured in GA4 Admin → Data Settings → Data Retention], then automatically deleted by Google.
- Subscription records: retained for as long as you have an active account, plus 10 years for accounting/tax purposes as required by Italian law.
7. Cookies, analytics & consent
We use cookies and similar technologies only where strictly necessary and, where required by law, only with your prior, freely-given consent. We use Google Consent Mode v2: analytics cookies default to denied on every visit until you actively choose otherwise.
Strictly necessary (no consent required)
- Cookie-preference storage (browser local storage), remembers your Accept/Reject choice so we don't ask again on every visit.
Optional, consent-based
- Google Analytics 4 (
_ga,_ga_*cookies), loaded only after you click “Accept” in the cookie banner. Provided by Google LLC, used to measure aggregate site usage.
_ga cookies already set. Clicking Accept grants analytics storage for this browser going forward. You can change your mind at any time via the Cookie settings link available on every page — no need to clear your browser.
Legal basis & withdrawal
Analytics cookies are processed on the basis of your consent (GDPR Art. 6(1)(a) and Art. 7). You may withdraw consent at any time, as easily as you gave it, via the Cookie settings link in the footer of any page; withdrawal does not affect the lawfulness of processing before it was withdrawn.
8. Your rights under GDPR
You have the following rights regarding your personal data. To exercise any of them, email us at [CONTACT EMAIL — placeholder]. We will respond within one month.
- Right of access (Art. 15), request a copy of the personal data we hold about you.
- Right to rectification (Art. 16), ask us to correct inaccurate or incomplete data.
- Right to erasure ("right to be forgotten", Art. 17), ask us to delete your data.
- Right to restrict processing (Art. 18), ask us to pause processing in certain cases.
- Right to data portability (Art. 20), receive your data in a portable format.
- Right to object (Art. 21), object to processing based on legitimate interests.
- Right to withdraw consent (Art. 7), at any time, for processing based on consent.
- Right to lodge a complaint, with your local data-protection supervisory authority, e.g. [SUPERVISORY AUTHORITY — placeholder, based on JURISDICTION above].
9. International data transfers
Some of our sub-processors (Netlify, Google, Stripe, Cloudflare) are based in the United States. When personal data — including Google Analytics 4 data, where you've consented — is transferred outside the European Economic Area, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, incorporated into Google's and our other processors' data processing terms, and additional safeguards where required, to ensure your data remains protected at a standard equivalent to GDPR.
10. Children
TruTalk is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.
11. Changes to this policy
We may update this policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you by email or by an in-product notice. Continued use of the site after a change means you accept the updated policy.
12. Contact us
For any privacy-related question, including requests to exercise your rights, please contact:
[LEGAL ENTITY / OWNER NAME — placeholder]
[REGISTERED ADDRESS — placeholder]
Email: [CONTACT EMAIL — placeholder]
This privacy notice has been drafted to reflect the requirements of Regulation (EU) 2016/679 (GDPR) and applicable Italian law. It is provided in good faith but does not constitute legal advice. We recommend periodic review with qualified counsel.