Terms of Service &
Privacy Policy

Last updated: Aug 27th, 2026
Effective Date: Aug 27th, 2026

These Terms of Service and this Privacy Policy together form a single agreement between you and URL RND, LLC. Please read both. If you do not agree to them, do not use Talkuccino.

Quick summary — the things that matter most

Talkuccino connects you, anonymously, to another adult for a live voice conversation.
You must be 18 or older. There are no exceptions.
We do not record, transcribe, or listen to conversations between users. Neither may you.
We never reveal your phone number to the person you speak with, and we never reveal theirs to you.
Talkuccino cannot be used to call emergency services.
The only personal information we require to open an account is an email address and a phone number.
You can delete your account, and everything attached to it, from inside the App at any time.
We have zero tolerance for abusive users and objectionable conduct.

This summary is for convenience only. The full terms below govern.

PART A — TERMS OF SERVICE

1. Who we are, and what this agreement covers

Talkuccino is provided by URL RND, LLC, a limited liability company organised under the laws of the State of Delaware, United States, with its business address at 4 Thatcher Rd., Tenafly, New Jersey 07670, United States ("Talkuccino", the "Company", "we", "us", "our").

"Service" means the Talkuccino mobile application (the "App"), the local access telephone numbers we make available, the call-matching and call-bridging service, our customer support channels, and the website at talkuccino.com (the "Website"). The Website is informational only; you cannot hold a conversation through it.

"You" means the individual using the Service. By creating an account or using the Service, you enter into a binding agreement with us on these Terms.

2. What Talkuccino is — and what it is not

2.1 How the Service works

Talkuccino matches adults who want to have a conversation with someone they do not know.

You create an account in the App using an email address and a phone number.
When you want to talk, you dial the Talkuccino local access number for your country from your own telephone. You place the call: the Service never telephones you to start a conversation, and never calls anyone else on your behalf. The only messages we send to your number are one-time verification codes, by SMS or automated voice call, when you register or re-verify your account, and occasional service messages about your account or a security issue. We never call or text you for marketing.
Your call is answered by our conference bridge and you are placed on hold in a waiting queue.
When another user is waiting, and you have each accepted the connection, the bridge connects the two of you for a live, two-way voice conversation.
Either of you may end the call at any time, for any reason or none.

The two participants are never told each other's telephone number, email address, name, or location, and the Service does not disclose them.

2.2 What Talkuccino is not — please read this carefully

(a) Talkuccino is not a telephone service and cannot be used to call emergency services.

Talkuccino is not a telephone company, is not a telecommunications carrier, is not an interconnected VoIP service, and is not a substitute for your ordinary telephone service. You cannot dial 911, 999, 112, 000, 111, 100, or any other emergency, police, ambulance, fire, or crisis number through Talkuccino. The Service permits you to reach exactly one number — the Talkuccino access number — and to be connected to one anonymous other user.

If you need emergency assistance, hang up and call your local emergency number directly from your telephone. You must maintain your own means of reaching emergency services at all times.

(b) Talkuccino does not let you call a person of your choosing. You cannot use the Service to reach a specific individual, a specific number, or anyone who has not independently chosen to use Talkuccino and is waiting in the queue at the same time as you.

(c) Talkuccino is not a counselling, crisis, medical, legal, financial, or professional advice service. The people you speak with are members of the public. They are not screened, vetted, trained, qualified, licensed, or supervised by us, and we make no representation about who they are or what they will say. Nothing you hear on a Talkuccino call is advice from us or endorsed by us.

(d) Talkuccino is not a dating, matchmaking, introduction, or escort service.

(e) We do not listen to conversations. Because we do not record, transcribe, or listen to user conversations (see clause 6), we cannot screen or supervise what is said on a call in real time. We rely instead on the safeguards in clause 5: the rules of conduct you accept when you register, the ability to block anyone at the end of any call, and the removal of accounts that many different users independently block. You are speaking to a stranger and you should conduct yourself accordingly.

(f) Talkuccino is not a moderated or sanitised service. Adults talk to adults, unscripted and unsupervised. People will disagree with you, be blunt with you, swear, and hold views you dislike. That is not misconduct, and we do not remove people for it. Clause 5.1 sets out the conduct we prohibit; clause 5.3 explains what we actually act on. If you simply do not want to speak with someone again, block them — that is what blocking is for.

2.3 Your telephone charges

You dial into the Service using your own telephone service. Your telephone or mobile provider's call charges, plan minutes, roaming charges, and data rates apply and are your responsibility. We are not responsible for any charge levied by your provider, including where you dial an access number outside your own country or while roaming.

Important — call cost. The app access numbers are local to each country, some are non-geographic numbers that might be charged at a different rate than your standard local call rate. The number to dial will be shown by the App. Please check the rates with your provider before you continue to dial.

2.4 What the Service does not carry

The only thing a user can send another user through the Service is live speech, in real time, one-to-one.

There is no text chat and no messaging between users.
There is no profile visible to other users.
There are no images, no video, no voice notes, and no file transfer.
Nothing you write in the App is ever shown to another user.
Conversation-topic and language preferences are chosen from a fixed list, are used only to route your call, and are never displayed to the other participant.
Live speech between users is never recorded (clause 6.1).

Accordingly, the only user-generated content the Service enables is one-to-one live aural communication within the meaning of section 55(5) of the United Kingdom's Online Safety Act 2023, and the Service is an exempt user-to-user service under paragraph 3 of Schedule 1 to that Act.

3. Eligibility — you must be 18 or over

The Service is for adults only. You must be at least 18 years of age to create an account or use the Service. There is no exception, and there is no parental-consent route: we do not permit anyone under 18 to use Talkuccino under any circumstances.

By creating an account you represent and warrant that you are 18 years of age or older and that you have the legal capacity to enter into this agreement.

How we apply the age limit

We ask for your date of birth when you register. Once your age is confirmed we replace it with a simple "over 18" flag.
We request and act on the age category your app store provides, including Apple's Declared Age Range API, as required by the app-store accountability laws of Texas, Utah, Louisiana, and California, and by our agreement with Apple.
If the signal indicates that you are under 18, or if it is unavailable and we have reason to doubt your declared age, we refuse or restrict access.
The App carries an 18+ app-store age rating, and availability may be further restricted by the age-verification requirements of your country or app store.

If we discover that a user is under 18, we will suspend the account immediately, terminate it without refund, and delete the associated personal data promptly. You may report a suspected under-18 user to support@talkuccino.com.

You must not permit any other person to use your account, and you must not use the Service on behalf of, or in the presence of, a person under 18.

4. Your account

4.1 Accuracy. You must provide a valid email address and a valid telephone number that you control, and keep them up to date. We use the phone number to identify your calls into the Service and to verify your account; we do not use it to call or text you for marketing.

4.2 One account per person. Accounts are personal to you. You may not sell, transfer, share, or licence your account, and you may not create a new account to evade a suspension or ban. Bans are recorded against the verified telephone number, and we may refuse re-registration.

4.3 Security. You are responsible for keeping your account credentials and your registered telephone confidential. Tell us promptly at support@talkuccino.com if you believe your account has been accessed without your authorisation.

4.4 Deleting your account.

You can delete your account, and all the personal data attached to it, from inside the App at any time — open Settings, then Account, then Delete Account. You do not need to email us, telephone us, or visit a website.
This is available to every user, in every country. It is a permanent deletion, not a deactivation or a suspension.
Deletion removes your email address, telephone number, age flag, preferences, call history, and support correspondence. We complete deletion within 30 days, and we confirm to you when it is done.
What we keep, and why. If your account was terminated for breach of clause 5, we retain your telephone number and an account identifier for 36 months solely to enforce the ban and prevent re-registration. We also retain anything we are legally required to keep, or that relates to an open investigation or legal claim. Nothing else is retained.
Deleting your account does not cancel your subscription. Apple bills you, not us. You must cancel separately in your Apple Account settings before you delete your account, or billing will continue. See clause 8.5.

5. Acceptable use — zero tolerance

The Service depends on people treating each other decently. We have no tolerance for objectionable conduct or abusive users. You accept a short code of conduct before every call. Any breach of this clause may result in immediate and permanent termination without refund, and we may report serious matters to law enforcement.

5.1 On a call, or otherwise through the Service, you must not:

harass, threaten, intimidate, stalk, bully, or abuse another user;
make sexual advances, sexual propositions, or sexually explicit remarks to a user who has not indicated they welcome them, or continue after a user has objected or asked you to stop;
expose another user to sexual content involving, or presented as involving, a minor — we report this to the authorities in every case;
direct hatred at, or degrade, any person or group by reference to race, ethnicity, national origin, religion, disability, sex, sexual orientation, gender identity, age, or any comparable characteristic;
encourage, glorify, or provide instruction in suicide, self-harm, disordered eating, violence, terrorism, or any criminal act;
attempt to obtain another user's real name, telephone number, address, workplace, financial details, passwords, or other personal information, or pressure them to disclose it;
give out your own contact details in order to move the conversation off the Service;
impersonate any person or organisation, including any representative of Talkuccino;
solicit money, gifts, cryptocurrency, investments, donations, or financial assistance, or run any confidence trick, romance scam, or fraud;
advertise, market, or promote any product, service, cause, campaign, or organisation;
record, transcribe, broadcast, stream, or otherwise capture a call — see clause 6;
engage in conduct that is unlawful where you are, or where the other user is.

5.2 In relation to the Service, you must not:

use the Service for any commercial purpose, including operating a call centre, telemarketing, market research, recruitment, or any bulk or automated calling operation;
use auto-dialers, predictive dialers, robocalling equipment, call-forwarding into multi-line systems, bots, scripts, or any automated means to access the Service;
reverse engineer, decompile, disassemble, modify, or create derivative works of the App, except to the extent this restriction is prohibited by law;
probe, scan, penetration-test, overload, or interfere with the Service or its infrastructure, or attempt to gain unauthorised access to any account, system, or data;
circumvent any usage limit, queue mechanism, geographic restriction, age restriction, suspension, or ban;
use the Service in a way that materially degrades service quality for others;
misrepresent your affiliation with us, or use our name, logo, or trade marks without our prior written permission.

5.3 Reporting, blocking, and what we do about it

Blocking. When a call ends, the App offers you the option to block the other participant. Blocking is immediate, permanent, and mutual: we will not match the two of you again. You do not have to give a reason, and we never tell the other person that you have blocked them.
Telling us why. After you block, we optionally ask why. You choose from a short fixed list, or you skip. There is no free-text box. Whichever you choose, the block has already taken effect and nothing you select can undo it.
What we do with it. We do not judge what was said on a call, because we do not record calls and cannot know. A single block, with or without a reason, does not remove anyone from the Service. People are entitled to find each other tiresome, blunt, or dull, and that is not misconduct. We act on patterns: where an account is blocked by many different users who have no connection to one another, we may suspend it, or remove it permanently and without refund.
When we act immediately. We act at once, without waiting for a pattern and within 24 hours, where a block reason indicates conduct involving a person under 18, or a credible threat of violence.
How we investigate. Because we do not record calls, we cannot review what was said. We work from connection metadata, the account history of the users involved, the number and independence of the users who have blocked an account, and behavioural signals such as repeated very short calls.
Serious harm. Where a report discloses an imminent risk to life, or apparent child sexual exploitation, we report it to the appropriate authority, including — as required by 18 U.S.C. §2258A — to the National Center for Missing & Exploited Children.
You can also email us at support@talkuccino.com at any time. Tell us the approximate date, time, and access number you dialled, so that we can identify the call from our connection records.
If you are the victim of a crime, report it to your local police. We respond to lawful requests from law enforcement in accordance with Part B, clause 5.

6. Calls are not recorded — a mutual commitment

6.1 Our commitment. We do not record, transcribe, store, listen to, monitor, analyse, or process the audio content of conversations between users. We do not use conversation audio to train, fine-tune, or evaluate any artificial-intelligence system. This is a design commitment, not merely a policy: the Service is built so that user-to-user call audio is bridged in real time and is never captured.

6.2 Your commitment.You must not record, transcribe, stream, broadcast, or otherwise capture any part of a Talkuccino conversation, by any means — including a second device, a recording app, call-recording features of your handset or carrier, or any accessibility or transcription tool. You must not publish, share, or distribute any recording, transcript, or excerpt of a conversation.

This is not merely a contractual restriction:

In several U.S. states — including California, Connecticut, Delaware, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania, and Washington — recording a telephone conversation without the consent of every participant is a criminal offence, a civil wrong, or both.
In the European Economic Area and the United Kingdom, recording a call in which you take part may be lawful for purely personal use, but publishing, sharing, or otherwise disclosing that recording, or any transcript or excerpt of it, without the other participant's consent is unlawful under data-protection, confidentiality and, in some countries, criminal law.

You are solely responsible for your compliance with the law that applies to you. Recording or sharing a call is a serious breach of these Terms and will result in permanent termination.

6.3 The one exception — our support line. Calls to our customer support line are recorded, and may be transcribed, for quality, training, and dispute-resolution purposes. You hear a spoken announcement to that effect at the start of the call, before any recording begins. If you do not wish to be recorded, hang up and contact us by email at support@talkuccino.com instead — email support is always available and is never recorded. Support recordings are covered by Part B, clause 2.4.

7. Content you provide

7.1 Your content. "Your Content" means anything you submit to us that is not the live audio of a call — for example your settings, conversation-topic or language preferences, feedback, support messages, and abuse reports. It does not include the content of your conversations, which we do not capture.

7.2 Ownership and licence. You keep ownership of Your Content. You grant us a limited, non-exclusive, worldwide, royalty-free, revocable licence to host, store, reproduce, and use Your Content solely to operate, support, secure, and improve the Service. This licence ends when you delete the relevant content or close your account, except for copies we must retain to comply with law, resolve a dispute, or enforce these Terms.

7.3 Your responsibility. You are solely responsible for Your Content and warrant that you have the right to provide it and that it does not infringe anyone's rights.

7.4 Our intellectual property. The App, the Website, the Talkuccino name and logo, and all software, designs, and materials we provide are owned by us or our licensors and are protected by intellectual property law. We grant you a personal, limited, non-exclusive, non-transferable, revocable licence to use the App for your own non-commercial use, on Apple-branded devices you own or control, in accordance with these Terms and with clause 17.7(b). All rights not expressly granted are reserved.

7.5 Copyright complaints (DMCA). If you believe material on the Website or in the App infringes your copyright, send a notice to our designated agent: Copyright Agent, URL RND, LLC, 4 Thatcher Rd., Tenafly, New Jersey 07670, United States; support@talkuccino.com, subject "DMCA Notice" (registered with the U.S. Copyright Office).

Your notice must include, as required by 17 U.S.C. §512(c)(3):

your physical or electronic signature;
identification of the copyrighted work claimed to be infringed;
identification of the material claimed to be infringing, and information reasonably sufficient to let us locate it;
your address, telephone number, and email address;
a statement that you have a good-faith belief that the use is not authorised by the copyright owner, its agent, or the law; and
a statement, made under penalty of perjury, that the information in the notice is accurate and that you are the copyright owner or authorised to act on the owner's behalf.

If we remove material in response to a notice, we will notify the person who provided it, who may submit a counter-notification under 17 U.S.C. §512(g). Repeat infringers. We terminate, in appropriate circumstances, the accounts of users who are repeat infringers.

8. Subscriptions, payment, and cancellation

8.1 Free and paid access. Some features of the Service are free. Others require a paid subscription. The name, duration, price, and contents of each subscription, and any free-trial terms, are shown in the App before you purchase.

8.2 All payment is through Apple.Talkuccino subscriptions are sold exclusively as in-app purchases through the Apple App Store. Apple, not Talkuccino, is the merchant of record and processes your payment. We never see, receive, or store your card number, bank details, or billing address. Your purchase is also subject to Apple's Media Services Terms and Conditions, which govern the payment relationship between you and Apple. We offer no other way to purchase the Service.

8.3 Auto-renewal.Paid subscriptions renew automatically and continue until you cancel.

Before you subscribe we show you, clearly and prominently and before any billing information is collected: the subscription name, the length of the renewal period, what the subscription includes during that period, the full renewal price, the price per unit where we quote one, that the subscription renews automatically at that price for successive periods until cancelled, and how to cancel.
You give your consent to these automatic-renewal terms separately from your consent to the purchase itself.
Unless you cancel, your Apple account is charged the then-current price within 24 hours before the end of the current period.
Your renewal date and price are visible at any time in your Apple Account subscription settings.
Existing subscribers can sign in or restore purchases from the subscription screen in the App.

8.4 Reminders. We will send you an email reminder:

between 3 and 21 days before a free trial or introductory-price period longer than 31 days converts into a paid subscription; and
between 15 and 45 days before each renewal of any subscription with a term of one year or longer.

Each reminder states the price, the renewal date, and how to cancel.

8.5 Free trials. Where a free trial is offered, its length and terms are stated at the point of purchase. If you do not cancel before the trial ends, the trial converts automatically into a paid subscription and you will be charged. Any unused portion of a free trial is forfeited if you purchase a subscription during the trial period.

8.6 How to cancel.You cancel through your Apple Account, not through us — we cannot cancel an Apple subscription on your behalf.

Open Settings on your device, tap your name, tap Subscriptions, select Talkuccino, and tap Cancel.
You must cancel at least 24 hours before the end of the current billing period to avoid being charged for the next one.
Cancelling stops future renewals. Your access continues until the end of the period you have already paid for.
Deleting the App, or deleting your Talkuccino account, does not cancel your subscription.

8.7 Refunds. Because Apple is the merchant of record, refund requests must be made to Apple, through Apple's "Report a Problem" process at reportaproblem.apple.com. Apple's refund policy applies. We have no ability to issue refunds for App Store purchases. If you believe you have been charged in error, contact us at support@talkuccino.com and we will assist you with Apple where we can.

8.8 Price changes. We may change subscription prices. Any price increase applies only from your next billing period, and we will give you notice, and the opportunity to cancel, before it takes effect, in accordance with Apple's requirements and applicable law.

8.9 Merchant of record and your statutory rights. Apple processes your payment as merchant of record. That does not reduce our own obligations to you under automatic-renewal and consumer-protection law, including the California Automatic Renewal Law (Cal. Bus. & Prof. Code §17600 et seq.) and the Restore Online Shoppers' Confidence Act (15 U.S.C. §8401 et seq.).

8.10 Consumers in the European Economic Area and the United Kingdom. Your subscription is sold to you by Apple as merchant of record, and your statutory cancellation and withdrawal rights in respect of that sale are exercised against Apple under Apple's Media Services Terms and Conditions.

Where a right of withdrawal from a distance contract for digital services applies, it lasts 14 days from the conclusion of the contract. If you ask us or Apple to begin supplying the service during that period, you may still withdraw within the 14 days, and you will be charged only for the proportion of the service supplied up to the point of withdrawal. The right is lost only once the service has been fully performed — see Article 16(a) of Directive 2011/83/EU and, in the United Kingdom, regulation 36 of the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013. Nothing in this clause affects your statutory rights under Directive (EU) 2019/770, Directive 2011/83/EU as implemented locally, or the Consumer Rights Act 2015.

8.11 Consumers in Australia and New Zealand. Our services come with guarantees that cannot be excluded under the Australian Consumer Law and the New Zealand Consumer Guarantees Act 1993. Nothing in these Terms excludes, restricts, or modifies those guarantees. For a major failure with the service, you are entitled to cancel your service contract with us and to a refund for the unused portion, or to compensation for its reduced value. You are also entitled to be compensated for any other reasonably foreseeable loss or damage. If the failure does not amount to a major failure, you are entitled to have the problem rectified in a reasonable time and, if this is not done, to cancel and obtain a refund for the unused portion.

9. Availability, changes, and termination

9.1 Availability. We aim to keep the Service available but we do not guarantee it. The Service may be unavailable because of maintenance, upgrades, failures in telephone networks or third-party infrastructure, or events outside our control. The Service depends on public telephone networks that we do not own or operate.

9.2 Matching is not guaranteed. Whether and how quickly you are matched depends on how many other users are waiting at that moment. We do not guarantee that you will be matched, that you will be matched within any period, or that any particular conversation will occur.

9.3 Changes to the Service. We may change, add, or remove features. Where a change materially reduces the Service and you hold a paid subscription, we will give you at least 30 days' notice, except where a shorter period is required to comply with law, protect security, or address an urgent risk.

9.4 Suspension and termination by us. We may suspend or terminate your access immediately and without notice if we reasonably believe you have breached clause 3 (age), clause 5 (acceptable use), or clause 6.2 (recording), or that your use presents a risk to other users, to us, or to the Service, or where we are required to do so by law. In other cases we will give you reasonable notice. Where we terminate for breach, no refund is due, subject to your non-excludable statutory rights.

9.5 Termination by you. You may stop using the Service and delete your account at any time (clause 4.4). Remember to cancel your subscription separately through Apple (clause 8.6).

9.6 Withdrawal from a country. We may cease to offer the Service in any country. Where we do so, we will give affected users reasonable notice where practicable.

9.7 Survival. Clauses 2.2, 6.2, 7, 8.7, 11, 12, 13, 14, 15, 16, and 17 survive termination.

10. AI-assisted customer support

10.1 We use third-party generative artificial intelligence tools, including large language models operated by OpenAI and Google, to help handle customer support enquiries. We do not use AI on the content of user conversations, which we do not capture.

10.2 You are told at the start of a support interaction if AI tools may be involved. You can always ask for a human — reply "HUMAN AGENT" in a support chat, or email support@talkuccino.com — and we will route you to a person.

10.3 AI-generated responses can be inaccurate, incomplete, out of date, or inconsistent with our policies or with the law. AI-generated responses are not guaranteed to be accurate, complete, or up to date, are not professional advice of any kind, and should be independently verified before you act on them. If an AI response appears wrong or harmful, tell us by asking to "Report a Problem" during the interaction, or by emailing support@talkuccino.com.

10.4 Decisions that materially affect your account — suspension, termination, billing outcomes, and the handling of abuse reports — are subject to human review. We do not make decisions producing legal or similarly significant effects about you by automated means alone.

10.5 Please do not send government identification numbers, financial account or card numbers, passwords, health information, biometric data, or other sensitive information to our support channels. See Part B, clause 20.

11. Disclaimers

11.1THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT WARRANTY OF ANY KIND. To the fullest extent permitted by law, we disclaim all warranties, express, implied, or statutory, including any implied warranty of merchantability, fitness for a particular purpose, title, non-infringement, accuracy, and any warranty arising from course of dealing or usage of trade.

11.2 Without limiting clause 11.1, we do not warrant that the Service will be uninterrupted, timely, secure, or error-free; that you will be matched with anyone; that any other user is who or what they claim to be, is of good character, is truthful, or will behave lawfully or decently; or that any information you receive on a call is accurate or reliable.

11.3 We are not responsible for the conduct of other users. You interact with other users at your own risk. We do not screen, vet, background-check, or verify users beyond applying the age limit in clause 3, and we do not listen to conversations.

11.4 Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot lawfully be excluded or limited. If you are a consumer, these Terms do not affect your non-excludable statutory rights, including under the laws of the European Economic Area, the United Kingdom, Australia, New Zealand, Israel, and applicable U.S. state law.

New Jersey residents: the disclaimer of implied warranties in clause 11.1 is enforceable in New Jersey to the extent permitted by N.J.S.A. 12A:2-316, and does not limit any right you have under the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 et seq. Residents of other U.S. states: some states do not permit the exclusion of implied warranties; where your state does not, clause 11.1 does not apply to you.

12. Limitation of liability

PLEASE READ THIS CLAUSE CAREFULLY. IT LIMITS WHAT YOU CAN RECOVER FROM US.

12.1 Excluded losses. To the fullest extent permitted by applicable law, neither the Company nor any of its members, managers, officers, directors, employees, contractors, agents, affiliates, licensors, or suppliers will be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, business, goodwill, opportunity, anticipated savings, or data, however caused and on any theory of liability, whether in contract, tort (including negligence), strict liability, or otherwise, and whether or not we have been advised of the possibility of such damages.

12.2 Cap on liability. To the fullest extent permitted by applicable law, the total aggregate liability of the Company and the persons listed in clause 12.1, arising out of or relating to the Service or these Terms, will not exceed the greater of (a) the total amount you paid us for the Service in the twelve months immediately before the event giving rise to the claim, or (b) one hundred United States dollars (US$100).

This cap does not apply to any liability for compensation for a breach of data-protection law, including under Article 82 of the GDPR or the UK GDPR, the New Zealand Privacy Act 2020, or the Privacy Act 1988 (Cth), which is governed by that law and is not limited by these Terms.

12.3 Specific exclusions. To the fullest extent permitted by applicable law, we are not liable for:

the acts, omissions, statements, or conduct of any other user;
any harm arising from a conversation, including anything said to you;
any failure or delay of any telephone or mobile network;
any inability to reach emergency services (see clause 2.2(a));
charges levied by your telephone or mobile provider;
any recording made by another user in breach of clause 6.2; or
any unauthorised access to your account resulting from your failure to keep your credentials secure.

12.4 Owners and personnel. You agree that any claim you may have arising out of or relating to the Service or these Terms may be brought only against the Company, and not against any member, manager, officer, director, employee, contractor, or agent of the Company personally. The protections in clauses 11 and 12 are given for the benefit of those persons as well as the Company, and each of them may rely on them.

12.5 Allocation of risk. You acknowledge that the limitations in clauses 11 and 12 are a fundamental basis of the bargain between us and reflect the price of the Service, and that we would not provide the Service without them.

12.6 Consumers. If you are a consumer, clauses 12.1 to 12.3 apply only to the extent permitted by the law of your country of residence, and nothing in this clause 12 limits any liability that cannot lawfully be limited, including liability for death or personal injury caused by negligence, for fraud, or under the Australian Consumer Law, the New Zealand Consumer Guarantees Act 1993, the UK Consumer Rights Act 2015, or mandatory consumer-protection law in the European Economic Area.

New Jersey residents: clauses 12.1 to 12.3 are enforceable in New Jersey except that they do not limit liability for (i) death or personal injury caused by our negligence, (ii) fraud, (iii) any claim under the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 et seq., or (iv) any liability that N.J.S.A. 12A:2-719 or other New Jersey law prohibits us from limiting. Residents of other U.S. states: where your state does not permit the limitation of incidental or consequential damages, clause 12.1 does not apply to you.

13. Indemnity

This clause applies only where you use the Service other than as a consumer, or where your use is commercial or in breach of clause 5.

Subject to that, and to the fullest extent permitted by law, you will indemnify and hold harmless the Company and the persons listed in clause 12.1 from any third-party claim, demand, loss, liability, damage, cost, or expense (including reasonable legal fees) arising out of: your breach of these Terms; your violation of any law or of any third party's rights; or any recording you make in breach of clause 6.2.

This clause does not require you to indemnify us against any claim caused by our own negligence, wilful misconduct, or breach of these Terms, and it does not apply to consumers resident in the European Economic Area, the United Kingdom, Australia, New Zealand, or Israel.

14. Disputes

14.1 Talk to us first. Most problems can be resolved quickly. Before starting any formal proceeding, please contact us at support@talkuccino.com with the subject "Dispute" and give us 30 days to try to resolve it.

14.2 Users in the United States — binding arbitration and class-action waiver.

THIS CLAUSE AFFECTS YOUR LEGAL RIGHTS. IT REQUIRES MOST DISPUTES TO BE RESOLVED BY INDIVIDUAL ARBITRATION RATHER THAN IN COURT, AND WAIVES YOUR RIGHT TO A JURY TRIAL AND TO PARTICIPATE IN A CLASS ACTION.

If you are resident in the United States, you and we agree that any dispute, claim, or controversy arising out of or relating to the Service or these Terms will be resolved by final and binding individual arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules, before a single arbitrator, seated in Bergen County, New Jersey — or, at your election, by telephone, videoconference, on documents only, or in the county of your residence. The Federal Arbitration Act governs this clause.

Class-action waiver.You and we each agree to bring claims only in an individual capacity, and not as a plaintiff or class member in any purported class, collective, consolidated, or representative proceeding. The arbitrator may not consolidate claims or preside over any form of representative proceeding. If this waiver is held unenforceable as to a particular claim, that claim — and only that claim — will proceed in court.
Exceptions. Either of us may bring an individual claim in small-claims court, and either of us may seek injunctive relief in court to protect intellectual property or to address unauthorised access to the Service.
Your right to opt out.You may opt out of this arbitration agreement by emailing support@talkuccino.com with the subject "Arbitration Opt-Out" within 30 days of first accepting these Terms, stating your name and the email address on your account. Opting out does not affect any other part of these Terms and will not disadvantage you in any way.
Costs. We will pay all AAA filing, administration, and arbitrator fees for any claim of US$10,000 or less, other than the portion of the filing fee that the AAA Consumer Arbitration Rules require you to pay.
Pre-arbitration notice. Neither of us may commence arbitration until 30 days after sending a notice of dispute under clause 14.1. Sending that notice suspends any applicable limitation period until 30 days after it is sent.
Coordinated filings. If 25 or more substantially similar demands for arbitration are filed by or with the assistance of the same counsel within a 60-day period, the AAA's Mass Arbitration Supplementary Rules and fee schedule apply.

14.3 Users outside the United States. Clause 14.2 does not apply to you. If you are a consumer, you may bring proceedings in the courts of the country where you are resident, and you retain the benefit of the mandatory consumer-protection law of that country. Consumers in the European Union may contact their national European Consumer Centre for free assistance with a cross-border complaint — the directory is at ec.europa.eu/consumers/ecc. We are not obliged to use, and do not currently participate in, any alternative dispute resolution scheme. Consumers in the United Kingdom may bring proceedings in the courts of England and Wales, Scotland, or Northern Ireland as applicable.

14.4 Time limit. To the extent permitted by law, any claim arising out of or relating to the Service or these Terms must be brought within one year after it arises. This limit does not apply to, and does not shorten, any period fixed by law that cannot be varied by agreement — including claims under the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 et seq., or any other consumer-protection, personal-injury, or statutory claim under the law of your state or country of residence, for which the ordinary statutory period applies.

15. Governing law

These Terms are governed by the laws of the State of New Jersey, United States, without regard to its conflict-of-laws rules, and the United Nations Convention on Contracts for the International Sale of Goods does not apply.

If you are a consumer, this choice of law does not deprive you of the protection of any mandatory provision of the law of the country in which you are habitually resident. Consumers in the European Economic Area, the United Kingdom, Australia, New Zealand, and Israel retain the full benefit of their local consumer-protection and data-protection law.

16. Changes to these Terms

We may change these Terms. For material changes we will give you at least 30 days' notice before they take effect, by email to your registered address, by in-app notice, or both, and we will post the updated version at talkuccino.com/terms with a new "Last updated" date.

If you do not agree to a change, you may delete your account before it takes effect; continued use after that date means you accept the change. For changes that are not material — corrections, clarifications, and changes required by law — we may act with shorter or no notice.

We keep previous versions of these Terms; email support@talkuccino.com if you would like a copy.

17. General

17.1 Entire agreement. These Terms and the Privacy Policy are the entire agreement between you and us about the Service and replace any earlier understanding.

17.2 Severability. If any provision is held invalid or unenforceable, it will be modified to the minimum extent necessary to make it enforceable, or severed if it cannot be, and the rest of the Terms will remain in effect.

17.3 No waiver. Our failure to enforce any provision is not a waiver of it.

17.4 Assignment. You may not assign or transfer these Terms. We may assign them to an affiliate or in connection with a merger, acquisition, or sale of assets, on notice to you.

17.5 Force majeure. We are not liable for any failure or delay caused by events beyond our reasonable control, including network or carrier failure, power failure, natural disaster, epidemic, war, civil unrest, industrial action, or governmental action.

17.6 No third-party rights. Except for the persons named in clauses 11, 12, and 13, and Apple and its subsidiaries under clause 17.7, each of whom may enforce the clauses expressed to be for their benefit, no one other than you and us has any right to enforce these Terms.

17.7 Apple. You acknowledge and agree that:

(a) Acknowledgement. These Terms are concluded between you and us only, and not with Apple. We, not Apple, are solely responsible for the App and its content.

(b) Scope of licence. The licence granted to you in clause 7.4 is a non-transferable licence to use the App on any Apple-branded product that you own or control, and as permitted by the Usage Rules set out in the Apple Media Services Terms and Conditions, except that the App may be accessed and used by other accounts associated with you via Family Sharing or volume purchasing.

(c) Maintenance and support. We are solely responsible for providing any maintenance and support services for the App. Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the App.

(d) Warranty. We are solely responsible for any product warranties, whether express or implied by law, to the extent not effectively disclaimed. In the event of any failure of the App to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the App to you; and, to the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the App. As between us and Apple, any other claims, losses, liabilities, damages, costs, or expenses attributable to any failure to conform to any warranty will be our sole responsibility.

(e) Product claims. We, not Apple, are responsible for addressing any claims by you or any third party relating to the App or your possession and use of the App, including: (i) product liability claims; (ii) any claim that the App fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection, privacy, or similar legislation.

(f) Intellectual property rights. In the event of any third-party claim that the App or your possession and use of the App infringes that third party's intellectual property rights, we, not Apple, will be solely responsible for the investigation, defence, settlement, and discharge of any such intellectual property infringement claim.

(g) Legal compliance. You represent and warrant that (i) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a "terrorist supporting" country; and (ii) you are not listed on any U.S. Government list of prohibited or restricted parties.

(h) Developer name and address. Our name and address, and the contact information to which any questions, complaints, or claims with respect to the App should be directed, are set out in clause 19.

(i) Third-party terms of agreement. You must comply with applicable third-party terms of agreement when using the App, including the terms of your telephone or mobile service plan.

(j) Third-party beneficiary.Apple and Apple's subsidiaries are third-party beneficiaries of these Terms, and upon your acceptance of these Terms Apple will have the right — and will be deemed to have accepted the right — to enforce these Terms against you as a third-party beneficiary of these Terms.

17.8 Language. These Terms are drawn up in English. Where we provide a translation, it is for convenience only, and the English version governs to the extent of any conflict, except where the mandatory law of your country of residence provides otherwise.

17.9 Notices. We will send notices to the email address on your account. You should send notices to support@talkuccino.com or to URL RND, LLC, 4 Thatcher Rd., Tenafly, New Jersey 07670, United States.

18. European Union — Digital Services Act

To the extent that the Digital Services Act (Regulation (EU) 2022/2065) applies to the Service:

18.1 Point of contact. Our single point of contact for Member State authorities, the European Commission, and the European Board for Digital Services, and for recipients of the Service, is support@talkuccino.com. You may write in English or in the official language of your Member State. Contact by this route is handled by a person; it is not solely automated.

18.3 Restrictions and moderation. The restrictions we impose on your use of the Service are set out in clause 5. We moderate conduct, not conversation content: because we do not record or listen to calls (clause 6.1), we cannot and do not apply automated content analysis to them. We act on user reports (clause 5.3) using connection metadata and account history. Every suspension or termination decision is taken by a person, not by an automated tool.

18.4 Contesting a decision. If we suspend or terminate your account we will tell you why. You may contest the decision by emailing support@talkuccino.com with the subject "Account Decision Review"; we will review it internally and reply within 14 days. You may also seek redress before a court or, where available, before an out-of-court dispute settlement body certified under Article 21 DSA.

19. Contact

Email: support@talkuccino.com
Post: URL RND, LLC, 4 Thatcher Rd., Tenafly, New Jersey 07670, United States
Telephone: +1 (760) 820-4611

PART B — PRIVACY POLICY

1. Who we are and what this covers

URL RND, LLC, a Delaware limited liability company with its business address at 4 Thatcher Rd., Tenafly, New Jersey 07670, United States, is the controller of the personal data described in this policy. Where the term "business" is used under United States state privacy law, we are the business.

This policy explains what personal data we collect when you use the Talkuccino App, our telephone access numbers, our support channels, and the talkuccino.com website; how we collect it; every purpose we use it for; who we share it with; how long we keep it; how you can delete it; and what rights you have.

We collect as little as we reasonably can. The only personal data we require to open an account is an email address and a telephone number.

Contact for privacy matters:

Email: support@talkuccino.com (please put "Privacy" in the subject line)
Post: Privacy Contact, URL RND, LLC, 4 Thatcher Rd., Tenafly, New Jersey 07670, United States
Telephone: +1 (760) 820-4611

We aim to acknowledge privacy enquiries within 48 hours.

2. What we collect, and how

2.1 Information you give us directly

Email address — collected from you at registration. Used to create and identify your account, to send you service messages, and to let you recover access. Required.
Telephone number — collected from you at registration. Used to recognise your call when you dial in, to verify your account, and to enforce bans. Required.
Date of birth — collected from you at registration. Used to apply the 18+ age limit. Replaced with a simple "over 18" flag once verified. Required.
One-time verification codes — sent to your number by SMS or automated voice call, and entered by you. Used to confirm you control the number and to prevent abuse. Required.
Conversation preferences — spoken language, and topics of interest, chosen by you from a fixed list. Used to match you with someone you can talk to. Optional.
Support messages and abuse reports — collected from you when you contact us. Used to answer you and to investigate reports.
Marketing preference — collected from you if you opt in. Used to send promotional messages. Optional, and off by default.
Block records — created when you block someone at the end of a call. Records that the two accounts must not be matched again. Used to enforce the block. Required in order to block.
Block reasons — the reason you choose from our fixed list, if you choose one. Used to identify accounts that many unconnected users have blocked. Optional — you can always skip it.

We do not ask for your name, your address, your photograph, your gender, your sexual orientation, your religion, your political views, your health, or any other special-category or sensitive information, and you should not send them to us.

2.2 Information we receive from Apple

An age-range signal, where you agree to share it, used to apply our 18+ limit.
Your subscription status, tier, renewal date, and a pseudonymous transaction identifier, used to manage your subscription.

We do not collect or store payment information. Subscriptions are sold through the Apple App Store and Apple is the merchant of record. We never see your card number, bank details, or billing address.

2.3 Call connection data (call metadata)

When you dial into the Service, our telephony providers and our systems generate connection records. These consist of:

the access number you dialled;
your calling telephone number;
the date and time the call started and ended, and its duration;
the identifier of the conference bridge; and
the fact that two accounts were connected to each other.

These records describe that a call happened. They do not contain any part of what was said.

2.4 Support call recordings

Calls to our customer support line are recorded and may be transcribed. You hear a spoken announcement before recording begins, and you may hang up and email us instead if you prefer not to be recorded. This is the only audio we ever capture.

2.5 Information collected automatically

Device and app data — device model, operating system version, App version, language and region settings, and a device or installation identifier.
Diagnostics — crash reports, error logs, and performance data.
Log data — IP address, and the date, time, and nature of requests your App makes to our servers. We use your IP address to derive an approximate country, for security and to show you the correct local access number. We do not collect precise or GPS location.
Website data — if you visit talkuccino.com, standard web analytics. See clause 16.

2.6 What we do not collect — and cannot give you

Because it matters, we will state it plainly:

We do not record, transcribe, listen to, monitor, or store the audio of conversations between users. We could not produce a recording of your conversation if asked, because none exists.
We do not use conversation audio to train or evaluate artificial-intelligence systems.
We do not disclose your telephone number, email address, or any other identifier to the person you speak with, and we do not disclose theirs to you. We make no attempt to identify anonymous users to one another, and we do not permit anyone else to.
We do not collect precise location, contacts, photographs, microphone audio outside a support call, biometric data, or health data.
We do not sell, rent, trade, or share your personal data for money or for cross-context behavioral advertising, and we never have.
We run no advertising in the App or on the Website; we operate no advertising or social-media tracking pixels, and we do not track you across other companies' apps or websites.
No paid feature depends on you granting any device permission. You do not have to enable push notifications, location services, contacts access, or tracking in order to use or pay for the Service.

3. Why we process your data, and our lawful basis

For users in the European Economic Area, the United Kingdom, and other jurisdictions applying a lawful-basis framework:

Creating and maintaining your account — email, phone number. Performance of a contract, Art. 6(1)(b).
Connecting and matching your calls — phone number, call metadata, conversation preferences. Performance of a contract, Art. 6(1)(b).
Verifying that you are 18 or over — date of birth, app-store age signal. Legal obligation, Art. 6(1)(c); and legitimate interests in protecting minors, Art. 6(1)(f).
Managing your subscription — transaction identifier, subscription status. Performance of a contract, Art. 6(1)(b).
Customer support, including support-call recordings — support messages, recordings, account data. Performance of a contract, Art. 6(1)(b); legitimate interests in quality and training, Art. 6(1)(f).
Preventing fraud, abuse, harassment, and misuse, and enforcing bans — phone number, call metadata, reports, device data. Legitimate interests in protecting our users and our service, Art. 6(1)(f).
Security, diagnostics, and keeping the Service working — log data, crash reports, device data. Legitimate interests in a secure and reliable service, Art. 6(1)(f).
Understanding how the Service is used, in aggregate — aggregated and de-identified usage data. Legitimate interests in improving the Service, Art. 6(1)(f).
Marketing messages — email address. Consent, Art. 6(1)(a). You may withdraw it at any time.
Complying with law and responding to lawful requests — whatever is relevant. Legal obligation, Art. 6(1)(c).
Establishing, exercising, or defending legal claims — whatever is relevant. Legitimate interests, Art. 6(1)(f).

Where we rely on legitimate interests, we have balanced those interests against your rights. You may object to any processing based on legitimate interests — see clause 9.

Withdrawing consent. Where we rely on your consent, you may withdraw it at any time — turn marketing off in the App's settings, click unsubscribe in any marketing email, or email support@talkuccino.com. Withdrawing consent does not affect processing already carried out, and it never affects your ability to use the Service.

We do not repurpose your data. Data collected for one purpose is not used for a new, incompatible purpose without your further consent, unless the law expressly permits it.

4. Confidentiality of your communications

We treat the fact and the content of your communications as confidential. We do not intercept, listen to, tap, or store conversations between users, and we do not permit our providers to do so. Call metadata is kept only for as long as we need it for the purposes in clause 3, and is then deleted or aggregated — see clause 7.

We treat call metadata as traffic data and apply the standards of confidentiality and traffic-data minimisation set out in Articles 5 and 6 of the ePrivacy Directive (2002/58/EC) as implemented in your country, whether or not those Articles apply to us as a matter of law, because we consider that to be the right standard for a voice service.

5. Who we share your data with

We do not sell your personal data and we do not share it for advertising. We disclose it only as follows.

5.1 Service providers acting on our instructions

Every provider named below is bound by a written contract requiring it to process personal data only as we instruct, to keep it secure and confidential, to provide the same or equal protection of your personal data as is stated in this policy, and to delete or return it when we ask. The same applies to any parent, subsidiary, or related entity of ours that has access to user data.

Amazon Web Services — cloud hosting and storage. Receives account data, call metadata, and logs.
Phone.com Inc. — supplies the local access telephone numbers. Receives call signaling and connection data.
TurboBridge — Advanced Communications Solutions LLC, d/b/a “TurboBridge” operates the conference bridge that connects calls. Receives call signaling and connection data. Does not record call audio for us.
Apple — app distribution and payment as merchant of record. Receives purchase and subscription data. Apple's own privacy policy applies to your Apple Account.
RevenueCat — subscription status management. Receives a pseudonymous transaction identifier and your subscription status.
Google Firebase / Crashlytics — crash reporting and app diagnostics. Receives device data, crash reports, and an installation identifier.
OpenAI and Google (Gemini) — third-party artificial-intelligence services used to assist customer support. Receive only what you type into a support conversation, and the minimum account context needed to answer it. See clause 20.
Squarespace — hosts the informational website. Receives website visitor data only, and has no access to App or account data.

We keep this list current. If you would like the identity of the provider handling a particular category of data, ask us.

5.2 Legal and safety disclosures

We may disclose personal data where we are required to by law, or where we believe in good faith that disclosure is reasonably necessary to comply with legal process, to enforce our Terms, to detect or prevent fraud or a security issue, or to protect the rights, property, or safety of our users, of any person, or of us.

We review every request, we require valid legal process, and we disclose no more than the request properly requires. Where we are permitted to tell you about a request affecting you, we will.

Note for law enforcement: we hold no recordings or transcripts of user conversations. On valid legal process we can provide account registration data and call connection records within our retention periods.

5.3 Business transfers

If we are involved in a merger, acquisition, financing, reorganisation, or sale of assets, personal data may be transferred as part of that transaction. We will notify you before your data becomes subject to a materially different privacy policy, and the acquirer will be bound by this policy until you are notified and given a choice.

5.4 What we never share

We never disclose your telephone number or email address to another user, and we never disclose your personal data to any third party for that third party's own marketing.

6. International transfers

We are based in the United States and our servers are located there. If you use the Service from outside the United States, your personal data will be transferred to and processed in the United States, which may not provide the same level of legal protection as your own country.

Where we transfer personal data out of the European Economic Area, we rely on the Standard Contractual Clauses approved by the European Commission, supplemented by the technical and organisational measures in clause 8. We carry out transfer impact assessments where required.
For the United Kingdom, we rely on the ICO's International Data Transfer Agreement, or the International Data Transfer Addendum to the EU Standard Contractual Clauses.
For Australia, we take reasonable steps under Australian Privacy Principle 8 to ensure overseas recipients handle your personal information consistently with the Australian Privacy Principles.
For New Zealand, we comply with Information Privacy Principle 12 of the Privacy Act 2020 by ensuring recipients are subject to comparable safeguards by contract.

You may ask us for information about the safeguards we use by writing to support@talkuccino.com.

7. How long we keep your data

Account data (email, phone number, preferences) — for as long as your account is open, then deleted within 30 days of deletion, except for the ban record below.
Date of birth — replaced with an "over 18: yes/no" flag within 24 hours of successful age verification. The flag is deleted with your account.
Call connection metadata — 90 days, then deleted or irreversibly aggregated.
Block records — for as long as both accounts exist, because a block is permanent. Deleted when either account is deleted.
Block reasons — 24 months, then deleted or irreversibly aggregated.
Call metadata relating to an open abuse report or investigation — until the investigation closes, then for a further 12 months.
Support messages and email correspondence — 24 months from the last message.
Support call recordings and transcripts — 90 days, unless retained for a specific dispute or investigation.
Crash reports and diagnostic logs — 90 days.
Ban records (telephone number and account identifier only, to prevent re-registration by a user terminated for breach) — 36 months.
Marketing consent records — until you withdraw consent, plus 24 months as proof that consent was given.
Subscription and transaction records — as long as required by tax and accounting law. Apple, not we, holds the payment records.
Anything subject to a legal hold or a live legal claim — until the matter concludes.

When a retention period ends we delete the data, or irreversibly de-identify it so that it can no longer be linked to you.

You do not have to wait for these periods to expire. You can delete your account and its data at any time from inside the App — see clause 9 and Part A, clause 4.4.

8. Security

8.1 What we do.

Data in transit between the App and our servers is protected with TLS 1.2 or higher.
Data at rest is encrypted with AES-256 or equivalent.
We apply role-based access controls and multi-factor authentication for administrative access.
We carry out network monitoring, regular review of access rights and configuration, and vendor security assessments.
We train staff on data protection and maintain a documented incident-response process.
We design for data minimisation. The strongest protection for your conversations is that we never capture them.

8.2 What we cannot promise — please read this.The voice leg of your call travels over the public telephone network. You dial in from your own telephone or mobile, and that part of the call is carried by telephone carriers using the ordinary protections of the telephone network. It is not end-to-end encrypted, and we do not claim that it is. We do not record it and our providers do not record it for us, but we cannot control the security of public telephone networks and we make no representation about them.

8.3 No system is completely secure. We cannot guarantee the absolute security of your data, and you send it to us at your own risk.

9. Your rights

Depending on where you live, you have some or all of the following rights. Exercising them is free, and we will not treat you differently for doing so.

Access — to be told whether we hold personal data about you, and to receive a copy.
Rectification — to have inaccurate data corrected and incomplete data completed.
Erasure — to have your data deleted, subject to limited exceptions such as legal retention duties and open investigations.
Restriction — to have processing paused while a dispute about it is resolved.
Portability — to receive the data you gave us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible.
Objection — to object to processing based on legitimate interests. You may object to direct marketing at any time and we will stop, without exception.
Withdraw consent — at any time, without affecting processing already carried out.
Not to be subject to a decision based solely on automated processing producing legal or similarly significant effects. See clause 19.
Complain to your data protection authority. See clause 22.

The fastest route — delete it yourself. You can delete your account and all associated personal data from inside the App at any time: Settings, then Account, then Delete Account. This works in every country and requires no request to us. See Part A, clause 4.4.

How to exercise the other rights. Use the privacy controls in the App, or email support@talkuccino.com with the subject line "Privacy Request". Tell us what you want and which account it concerns.

Verification. We may ask you to confirm control of the email address or telephone number on the account. We ask for no more than we need, and we do not collect identity documents for this purpose.

Timing. We respond within:

one month — European Economic Area, United Kingdom;
45 days — United States, extendable once by a further 45 days where necessary, with notice to you;
30 days — Australia and Israel;
20 working days — New Zealand;
15 business days — opt-out requests under U.S. state law.

Where a request is complex we will tell you within the original period and explain the delay.

Authorised agents. You may use an authorised agent where the law of your state or country allows it. We will ask for proof of authorisation.

10. If you are in the European Economic Area

This clause covers Ireland, the Netherlands, Belgium, Sweden, Denmark, Romania, and Norway. The GDPR applies to our processing of your personal data, and the rights in clause 9 apply in full.

Who we are. URL RND, LLC is a company incorporated in Delaware, United States, with its business address in New Jersey. We are the controller of your personal data. We have no offices, staff, or servers in the European Economic Area, and all of our processing takes place in the United States.

How to reach us.

Email: support@talkuccino.com, subject line "Privacy Request". Monitored on business days. We acknowledge within 48 hours and respond substantively within one month, as required by Article 12(3) GDPR.
Post: URL RND, LLC, 4 Thatcher Rd., Tenafly, New Jersey 07670, United States.

You may write to us in English, Dutch, Swedish, Danish, Romanian, French, or Norwegian, and we will respond in the same language.

Your right to complain.You may complain to the supervisory authority in the country where you live or work, or where you think a problem occurred, without contacting us first. Contact details are in clause 22. You also have the right to an effective judicial remedy.

Transfers. See clause 6. Our transfers to the United States are made under the European Commission's Standard Contractual Clauses.

[DROP-IN — insert once an Article 27 representative is appointed, then delete this note]Our representative in the European Union. We have appointed [name], of [street address, city, Member State], as our representative in the European Union under Article 27 of the GDPR. You may contact our representative on any matter relating to our processing of your personal data, in addition to or instead of contacting us, at [email address] or at the postal address above.

11. If you are in the United Kingdom

The UK GDPR and the Data Protection Act 2018 apply, and the rights in clause 9 apply in full. Transfers to the United States are made under the ICO's International Data Transfer Agreement, or the International Data Transfer Addendum to the EU Standard Contractual Clauses.

You may complain to the Information Commissioner's Office — Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; telephone 0303 123 1113; ico.org.uk. You may complain to the ICO without contacting us first.

Our representative in the United Kingdom. We have appointed Ophr Levi, of 31 Holders Hill Drive, London NW4 1NL, United Kingdom, as our representative in the United Kingdom under Article 27 of the UK GDPR. You may contact them at ophir.garion@gmail.com.

12. If you are in the United States

We apply a single national standard, built to the strictest requirement in any state, so that every user in the United States receives the same treatment.

We do not sell your personal information, we do not share it for cross-context behavioural advertising, and we do not process it for targeted advertising. We have never done so. Because of this, opt-out rights relating to sale, sharing, and targeted advertising have nothing to operate on — but you may still exercise them, and we will confirm our position in writing.

Your rights, in every state:

to know what we collect and why;
to access a copy;
to correct inaccuracies;
to delete;
to portability;
to opt out of sale, sharing, targeted advertising, and profiling with legal or similarly significant effects;
to limit the use of sensitive personal information; and
not to be discriminated against for exercising any of them.

Global Privacy Control. We recognise the Global Privacy Control browser signal as a valid opt-out request. Since we do not sell or share personal information, honouring it changes nothing — but we honour it.

Acknowledgement. We confirm receipt of every request within 10 business days and tell you how we will handle it.

Appeals. If we decline a request, we will tell you why and how to appeal. To appeal, reply to our decision or email support@talkuccino.com with the subject "Privacy Appeal". We respond to appeals within 45 days — the shortest period any state requires — even where your state allows us up to 60. If we deny your appeal, we will give you a method to complain to your state Attorney General.

How to exercise your rights: email support@talkuccino.com, subject "US Privacy Request", or telephone +1 (760) 820-4611.

12.1 Additional information for California residents

Under the California Consumer Privacy Act as amended, these are the categories of personal information we have collected in the last 12 months, with the source, purpose, and recipients of each.

Identifiers — email address, telephone number, IP address, device identifier. Collected from you, and automatically. Used for account creation, call connection, and security. Disclosed to service providers only.
Personal information under Cal. Civ. Code §1798.80 — telephone number. Collected from you. Used for call connection and verification. Disclosed to service providers only.
Protected classification characteristics — age, in the form of an "over 18" flag. Collected from you. Used to apply the legal age restriction. Disclosed to service providers only.
Commercial information — subscription status and a transaction identifier. Received from Apple. Used to manage your subscription. Disclosed to service providers only.
Internet or network activity — App usage and crash logs. Collected automatically. Used for diagnostics, security, and service improvement. Disclosed to service providers only.
Geolocation data — approximate country only, derived from IP address. Collected automatically. Used to show the correct local access number, and for security. Disclosed to service providers only.We do not collect precise geolocation.
Audio information — support calls only. We do not record, transcribe, or store conversations between users. The only audio we hold is a recording of a call you place to our customer support line, made after a spoken announcement. Collected from you, only if you telephone support. Used for quality, training, and dispute resolution. Disclosed to service providers only.
Professional, education, biometric, or genetic information — not collected.
Sensitive personal information — not collected.
Inferences drawn to create a profile — not collected. We do not profile users.

We have not sold or shared any personal information in the preceding 12 months, and we have not disclosed personal information to any third party for that third party's direct marketing purposes. This is also our response for the purposes of California's "Shine the Light" law, Cal. Civ. Code §1798.83.

We do not collect or process sensitive personal information, so the right to limit its use and disclosure does not apply to us.

Response times: 45 days for requests to know, delete, and correct, extendable once by 45 days; 15 business days for opt-out requests. Requests: support@talkuccino.com, subject "California Privacy Request", or +1 (760) 820-4611.

12.2 Other states

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Minnesota, Maryland, Tennessee, Indiana, Kentucky, Rhode Island, and every other state with a comprehensive privacy law have the rights set out at the start of clause 12, including the right to appeal. Use the same contact route.

Nevada residents may submit a verified request that we not sell covered information. We do not sell it.

13. If you are in Australia

The Privacy Act 1988 (Cth) and the Australian Privacy Principles apply.

Overseas disclosure (APP 8). Your personal information is disclosed to and stored by our service providers in the United States. We take reasonable steps to ensure they handle it consistently with the APPs.
Access and correction (APPs 12 and 13). Email support@talkuccino.com. We respond within 30 days, and we do not charge for access.
Anonymity (APP 2). The Service is anonymous between users by design. We cannot provide it without an email address and telephone number.
Complaints. Complain to us first at support@talkuccino.com, subject "Privacy Complaint". If you are not satisfied within 30 days, complain to the Office of the Australian Information Commissioner — oaic.gov.au; telephone 1300 363 992; GPO Box 5288, Sydney NSW 2001.
Data breaches. We comply with the Notifiable Data Breaches scheme and will notify the OAIC and affected individuals of any eligible data breach.

14. If you are in New Zealand

The Privacy Act 2020 applies, including the Information Privacy Principles.

IPP 12 — overseas disclosure. We disclose personal information to service providers in the United States, relying on contractual protections requiring comparable safeguards to those in the Privacy Act.
IPP 3A — information we collect about you from someone else. Most of the information we hold comes directly from you. We also receive a small amount about you from Apple: an age-range signal used to apply our 18+ limit, and your subscription status and a pseudonymous transaction identifier used to manage your subscription. We collect this to verify your eligibility and to operate your subscription; it is held as described in clause 7; and you may access and correct it by emailing support@talkuccino.com. This notice is given for the purposes of Information Privacy Principle 3A. We do not build profiles from third-party sources.
Access and correction (IPPs 6 and 7). Email support@talkuccino.com. We respond within 20 working days.
Complaints. Complain to us first, then to the Office of the Privacy Commissioner — privacy.org.nz; telephone 0800 803 909; PO Box 10094, Wellington 6143.
Breaches. We notify the Privacy Commissioner and affected individuals of any privacy breach likely to cause serious harm.

15. If you are in Israel

The Protection of Privacy Law, 5741-1981, as amended — including by Amendment 13, in force from 14 August 2025 — applies to our processing of the personal data of Israeli residents.

You have the right to inspect the information we hold about you and to request its correction or deletion. Email support@talkuccino.com; we respond within 30 days, as required by the Protection of Privacy Regulations (Conditions for Inspecting Information and Procedures for Appeal against a Refusal to Grant a Request for Inspection), 5741-1981. We do not currently operate a Hebrew-language interface; you may write to us in English.

We notify the Privacy Protection Authority, and where instructed by it, the affected individuals, of severe security incidents as required by the Protection of Privacy (Data Security) Regulations, 5777-2017. You may complain to the Privacy Protection Authority at gov.il.

16. Cookies and the website

The App does not use cookies for advertising, and we operate no advertising or social-media pixels anywhere.

The talkuccino.com website is informational and is hosted by Squarespace. It uses:

Strictly necessary cookies — for security, load balancing, and basic function. These do not require your consent.
Analytics cookies — to count visits and understand which pages are used. In the EEA, the UK, and everywhere else where consent is required, these are set only after you consent. You can refuse as easily as you can accept, change your mind at any time through the cookie settings link in the website footer, or use your browser's cookie controls.

We honour the Global Privacy Control signal. We do not act on the legacy "Do Not Track" browser header, which is no longer a supported standard; we do not need to, because we set no advertising or tracking cookies.

Inside the App we use local storage and a device or installation identifier for authentication and for crash reporting. This is necessary to provide the Service you have asked for.

17. Age of users

The Service is for adults. You must be 18 or over.

We ask for your date of birth at registration. Once your age is verified we replace it with a simple "over 18" flag.
We request and act on the age category your app store provides, including Apple's Declared Age Range API, as required by the app-store accountability laws of Texas, Utah, Louisiana, and California.
The App carries an 18+ app-store age rating.

We do not knowingly collect personal data from anyone under 18. If we learn that we have, we delete the account and the associated data promptly. If you believe a person under 18 has an account, tell us at support@talkuccino.com and we will investigate.

We do not profile users, and we make no automated decisions with legal or similarly significant effects about anyone.

18. Data breaches

We maintain an incident-response process and an internal breach register.

EEA and UK — we notify the competent supervisory authority within 72 hours of becoming aware of a personal data breach where required by Article 33 GDPR / UK GDPR, and we notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms (Article 34).
Australia — we notify the OAIC and affected individuals of eligible data breaches under the Notifiable Data Breaches scheme.
New Zealand — we notify the Privacy Commissioner and affected individuals of notifiable privacy breaches.
United States — we notify individuals and regulators as required by applicable state breach-notification law.
Israel — we notify the Privacy Protection Authority of severe security incidents.

Notifications to you will describe, in plain language, what happened, what data was affected, what we are doing, and what you can do.

19. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you by automated means alone.

Matching is not a decision about you: it connects whoever is waiting, taking account of the language and topic preferences you choose. It does not evaluate, score, rank, or profile you.

Decisions that materially affect your account — suspension, termination, and the outcome of an abuse report — involve human review. If such a decision is taken about you, you may ask us to explain it and to reconsider it: email support@talkuccino.com with the subject "Account Decision Review".

20. AI tools in customer support

20.1 What we use them for. We use third-party generative AI, currently including OpenAI's models and Google's Gemini, to help draft and triage customer support responses. We do not apply AI to conversations between users, because we do not capture them. You are told at the start of a support interaction if AI may be involved, and you may decline.

20.2 What is sent. Only the content of your support conversation, and the minimum account context needed to answer it. Please do not send us: government identification or social-security numbers; card, bank, or account numbers; passwords; health or medical information; biometric data; information about criminal records; immigration status; or any special-category data under Article 9 GDPR.

20.3 Lawful basis and your right to object. For users in the EEA and the UK we rely on legitimate interests, Article 6(1)(f), in providing efficient support. You may object at any time — email support@talkuccino.com with the subject "AI Processing Objection" — and we will handle your inquiry without AI assistance.

20.4 California. If you would prefer that your support interaction is not processed using third-party AI tools, email support@talkuccino.com with the subject "California AI Opt-Out". We action these within 15 business days.

20.5 Transfers and retention. These providers are located primarily in the United States; transfers are covered by the Standard Contractual Clauses (clause 6). Support records containing AI interactions are retained in line with clause 7. Each provider's own privacy policy also applies — openai.com/policies/privacy-policy and policies.google.com/privacy.

20.6 Human oversight. See clause 19 and Part A, clause 10.

20.7 EU AI Act. We deploy third-party general-purpose AI systems to assist our support team. We are a deployer, not a provider, of those systems, and we do not use AI for emotion recognition, biometric categorisation, or the generation of synthetic audio, image, or video content. Consistent with the transparency principle in Article 50 of Regulation (EU) 2024/1689, which has applied since 2 August 2026, we tell you at the start of a support interaction when an AI system is involved, and you may always ask for a human. We use no AI system prohibited under Article 5, and none of our uses is high-risk under Annex III.

21. Changes to this policy

We may update this policy. For material changes we will give at least 30 days' notice by email, in-app notice, or both, and we will post the updated version at talkuccino.com/terms with a new "Last updated" date.

Material changes include new purposes of processing, new categories of recipient, a change of lawful basis, new tracking technology, and any reduction of your rights.

Previous versions are available on request from support@talkuccino.com.

22. Contact us, and how to complain

Privacy contact

Email: support@talkuccino.com (subject line: "Privacy")
Post: Privacy Contact, URL RND, LLC, 4 Thatcher Rd., Tenafly, New Jersey 07670, United States
Telephone: +1 (760) 820-4611

We acknowledge privacy inquiries within 48 hours.

You may complain to your data protection authority at any time, and you do not have to contact us first.

Belgium — Autorité de protection des données / Gegevensbeschermingsautoriteit, autoriteprotectiondonnees.be
Denmark — Datatilsynet, datatilsynet.dk
Ireland — Data Protection Commission, dataprotection.ie
Netherlands — Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl
Norway — Datatilsynet, datatilsynet.no
Romania — ANSPDCP, dataprotection.ro
Sweden — Integritetsskyddsmyndigheten (IMY), imy.se
United Kingdom — Information Commissioner's Office, ico.org.uk
Australia — Office of the Australian Information Commissioner, oaic.gov.au
New Zealand — Office of the Privacy Commissioner, privacy.org.nz
Israel — Privacy Protection Authority, gov.il
United States — your state Attorney General

A directory of all European Economic Area supervisory authorities is at edpb.europa.eu/about-edpb/about-edpb/members_en.

Schedule 1 — Local access numbers

Dial the LOCAL number for your country that will be displayed by the APP. Your provider's call charges apply.

These numbers displayed connect you only to the Talkuccino service. They cannot be used to reach emergency services, and they cannot be used to call any other person. Numbers may change.

Terms of Service & Privacy Policy