Last updated November 7, 2024

Thank you for using Townhall!

Townhall is a social network based on voice. Our products include our iOS and Android apps and our website (our “Products”). Among other things, our Products allow you to use your voice to interact with others in real-time through “Conversations” (what we call the different types of audio conversations, including “Chats,” “Live Rooms,” and “VMs,” you can have using our Products), and to share recordings of those interactions for others to enjoy (or participate in) later.

When you use our Products, you provide personal information to us. We wrote this privacy policy (the “Privacy Policy” or “Policy”) to help you understand what personal information we collect, how we use it and disclose it, how long we retain it, and what choices you have about it. This Policy does not cover information that does not identify you. Nor does it cover the practices of Townhall users. Users who listen to you speak on Townhall, or view information you share on Townhall, might save that information outside of our Products using other tools.

You may have specific privacy rights in your state or region. In the United States, residents of California and other states have specific privacy rights. Residents of the European Economic Area (“EEA”), the UK, Brazil, the Republic of Korea, and other jurisdictions also have specific rights:

Residents of California can find our California Consumer Privacy Act disclosures.
Residents of the EEA, the UK, and Brazil can find our Notice to EEA, UK, and Brazilian Data Subjects.
Residents of Europe who are not Townhall users can find our Non-User Data Notice.

1. Information We Collect

A. Information You Provide

When you use Townhall, we collect personal information that you provide to us. This includes:

Account Information

When you set up an account, we may ask you to provide information about yourself, including your name, phone number, email address, and date of birth. If you use our Products as a guest without setting up an account, we may ask you to provide your name, phone number or other information.

Biographical Information

We may also ask you to provide us with some additional personal information about you that will be visible in our Products, such as topics that interest you (“Interests”), a profile picture, and a bio in your profile to tell others more about you. When you change your profile picture we store a copy of the new picture you upload and retain all profile pictures you uploaded previously for trust and safety purposes and in accordance with our data retention policies.

Social Media And Contact Information

You may choose to connect your other social media accounts, or sync your contacts.

B. Information We Get When You Use Our Products

When you use our Products, we collect additional personal information based on your activity and other personal information you might choose to provide. This includes:

Audio Conversations

Chats. Chats are audio conversations you can have on Townhall that occur asynchronously with other users, and which may also contain attachments like links or images. With Chats, the content you create can be shared with groups of users or user networks more publicly. (As detailed in our Terms of Service). Chats will appear in other users’ “feeds” and in other parts of the app, and in some cases may be shared by other users outside of Townhall. Chats are shared with others according to the privacy settings of the user that created the Chat (the “Chat Creator”). This means you can share Chats you create with other users. We retain your Chats indefinitely, unless you delete them, so that they can be played back by other users. A full Chat conversation may be deleted by the Chat Creator, or a specific audio comment (a section of an audio Chat or VM) within a conversation may be deleted by the person who created it. A “House” is a community you can join with users, where you can participate in Chats and Live Rooms, and interact in different ways.
Voice Messages (“Messages” or “VMs” ). Direct voice messages, which we call “Messages” or “VMs” are voice conversations allowing you to send audio content directly to one person or a group of people (unlike Chats, which are voice conversations that you may share in your feed to groups of users, such as your friends, friends-of-friends, or other House members ). These conversations may also contain attachments like links or images. For VMs, content is recorded and remains available unless a conversation participant deletes a specific item of content (such as a segment) they have created. If you start a VM, or participate in a VM with one or more users, those users may appear in the “Recently Chatting With” section of your profile, which will be displayed to your friends. Friends who visit your profile may press on a user’s photo (or group of user photos) that is displayed in the “Recently Chatting With” section to start a separate, new group conversation with you and the other user(s).
Live conversations (“Live Rooms”). Live Rooms are conversations where you interact with other users in real time using your voice and other features provided within Live Rooms.
- We record all Live Rooms so that we can investigate any complaints regarding violations of our Community Guidelines or our Terms of Service, or otherwise illegal or illicit activity. This is part of our commitment to users under our Terms of Service to work to provide a safe space for their Conversations and combat illegal and harmful conduct and content. If we receive a complaint while the Room is live, we will review the recording to determine whether a violation has occurred. We will retain the recording as long as reasonably necessary to identify and investigate potential violations.
- In Live Rooms that are open to all users, we may also generate transcripts of the Conversation to analyze the contents of the Conversation and use that information to personalize our Products (“Transcripts”).
Replays. We record conversations that occur in Live Rooms and make them available to other users where the Room creator instructs us to do so by enabling the “Replay” feature. When Replays are enabled, the recording will be stored by Townhall and may be made available to other users on Townhall at the Room creator’s instruction. Replays may also be available outside of Townhall.

Usage And Activity Information

We collect information about when and how you use our Products. Among other things, this includes Transcripts of Conversations; information about Conversations; Conversations you create; Conversations you participate in; Conversations you join; and Replays you create. It also includes who you follow, what Houses or communities you create or join, web pages you visit, links you share, content you share to other platforms through integrations (i.e. social sharing), queries you submit, and what kind of content you’re interested in.

Text Messages

We store text-based messages you send to and receive from other users and information about those messages, including the messages you send via Room Chat or other messaging features in the Products, including historical Backchannel conversations. We review the contents of these messages if a user reports, or we otherwise detect, a potential trust and safety violation or potentially illegal or illicit activity.

Other Communications

We collect information about the messages you send us when you contact us with questions or feedback, including the contents of those messages.

Contacts

If you give us permission to sync your contacts, we will store identifiers known as hash values derived from the phone numbers of your contacts, and we will update your contacts periodically. Similarly, if you invite somebody to join Townhall, we will store a hash value derived from the phone number you provide. We do not collect names, email addresses, or any other information associated with your contacts.

Voice Samples And Text-To-Speech Functions

We may offer a text-to-speech function that lets you convert text into speech to share in Conversations. If you enable this function, we may ask you to provide voice samples, which we will collect and store to create a “Custom Voice” associated with your profile. Depending on your location, applicable laws may define the data used to create your Custom Voice as a biometric identifier or biometric information.

Log Data And Device Information

We may collect information from and about the devices you use. In particular, we may collect information about log-in authentication attempts and successful authentications, your hardware and software, such as the hardware model, operating system version, device memory, unique application identifiers, apps installed, unique device identifiers, browser type, and information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.

Cookie Information

We use cookies (small text files sent by your computer each time you visit our website, unique to your Townhall account or your browser) to get log data. Some of these cookies are used to help us understand how you use our Products, how many people use our service, and how they use it. Other cookies are used to help us track the efficiency of our advertising campaigns on other platforms. For more detailed information about cookies, please see our Cookie Policy.

Web and Logged-out Activity

If you visit any web pages on Townhall, with or without being logged into an account; or, if you participate in Townhall features or create content as a guest (i.e., where we do not require you to log in or have a registered account), we may collect and retain information associated with you, including identifiers such as your name or phone number, device information, session information, details of your activity, cookies, or other information.

Information From Third Parties

Social Media Information

If you link your Townhall account to X (Twitter), Instagram, or any other social media services, we may receive information from those other services. The information we receive will depend on the privacy settings on those other services.

Service Providers

We may also receive information about you from our service providers.

Information About Guests

We may allow you to use our Products to a limited extent without opening an account, such as by allowing you to join a Conversation (which may include a Chat or a Live Room) or a House for a limited amount of time using a link, contributing audio content to a Conversation, or accepting invitations for Conversations scheduled for a future date. By choosing to use our Product without an account, you agree that you will comply with our Terms of Service Community Guidelines, and any other policies Townhall makes available in order to maintain the safety of our Products. We will only allow you to do so if you agree to our Terms like any other user must. Similarly, all provisions of our Terms, our Privacy Policy, and our Community Guidelines apply to you the same as they do for any other user.

Information About Non-Users

Townhall users may sync their contact lists to Townhall in order to help Townhall connect them to existing users, invite new users, and to connect users and their contacts with one another on Townhall. Similarly, users may send people invitations through various methods, including manually entering a telephone number, posting an invitation, and sharing a link. In either case, the only information Townhall stores is a hash value derived from the phone number. Townhall does not collect names or any other information associated with your contacts, and we do not share the hash values we collect or make them available to others.

How We Use The Information We Collect

We use the personal information we collect to provide our Products to you and to improve them. Specifically, we use the data we collect to:

Register your account, verify your identity (e.g., checking that your phone number belongs to you), and verify the accuracy of your information.
Develop, operate, improve, maintain, and protect our Products.
Personalize our Products.We personalize our Products in a number of ways. For example, we may suggest Conversations for you to join, other content you may want to engage with, or users to follow. For more information on personalization, see our Personalization FAQ.
Send you communications. For example, we may use email, text messages, or app-based notifications to respond to support inquiries, share information about our Products, and tell you what’s happening on Townhall.
Verify and enhance the safety and security of our Products.
Verify and analyze user engagement, trends, and usage.
Assess the efficiency of our advertising campaigns on other platforms.
Handle and record user rights requests, including opt-ins and opt-outs.
Prevent fraud or other unauthorized or illegal activity.
Enforce, investigate, and report conduct violating our Terms of Service Community Guidelines, or other policies.
Respond to requests from law enforcement agencies or other government agencies, and comply with legal or regulatory requirements.

How We Disclose The Information We Collect

We do not sell personal information about our users. We may, however, disclose that information to:

Other online services you connect to your Townhall account.

If you choose to link your Townhall account to X (Twitter), Instagram, or any other services, we may disclose information to those other services at your direction when using our Products.

Services we use to market Townhall

When we market our Products we may disclose information to the websites and apps we use to market our Products, including Facebook, Google, X (Twitter), Microsoft, LinkedIn, Trade Desk, or others.

Service providers and other third parties

We employ third parties to process information on our behalf based on our instructions and for the purposes described in this Privacy Policy, including providers of services relating to cloud computing, analytics, security, enforcement of content policies (including our Community Guidelines), and user support.

Law enforcement or governmental or non-governmental organizations

If we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights or property of the public, any person or Townhall; or to detect, prevent or otherwise address illegal conduct, fraud, security or technical issues, we may disclose information to law enforcement agencies, other governmental agencies, or private parties as needed.

Our wholly owned subsidiaries and affiliates

If we were to engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy, we would disclose your information to parties involved in such a process (for example, a purchaser).

How Long We Keep Information

We keep your personal information only for as long as we reasonably need it to provide our Products to you and fulfill the purposes described in this Policy. This is also the case for anyone that we disclose your personal information to and who carries out services on our behalf. In general, this means we will retain your personal information for as long as you have a Townhall account.

For users located in the EEA, the UK or Brazil, you’ll find specific data retention periods for the different purposes of processing under Justifications for Data Processing in the Notice to European and Brazilian Data Subjects.

We may delete some personal information earlier based on changes to your account settings, such as if you instruct us to delete your Contacts. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll remove any information that can identify you from our systems.

As explained above, we record conversations in Live Rooms so that we can investigate any complaints we might receive relating to violations of our Community Guidelines, our Terms of Service, or otherwise illegal or illicit activity. We will retain the recording as long as reasonably necessary to identify and investigate potential violations. When we generate Transcripts for Live Rooms that are open to all users, we will retain those Transcripts for as long as we need them to personalize our Products.

We also record Conversations and make them available to other users where the creator instructs us to do so. For Chats, content is recorded and remains available to other users according to the Chat creator’s preferences, unless the Chat creator deletes the entire Chat conversation, or a conversation participant deletes a specific item of content (i.e., an audio comment) they have created. For VMs, content is recorded and remains available unless a conversation participant deletes a specific item of content (i.e., an audio comment) they have created. For Live Rooms, the Room creator can opt to record the content of the Room by enabling the “Replay” feature. When Replays are enabled, the recording will be stored by Townhall and may be made available to other users on Townhall or other people outside of Townhall. Replays are created and saved at the direction of Room creators, and remain available unless the Room creator instructs us to remove the Replay.

If an item of content is deleted by its creator, we may retain a copy of it temporarily in storage, but will delete it from our backups within a reasonable amount of time.

Managing Your Information – There are a variety of ways you can manage the personal information we have about you. Specifically, you can:

Request access to the information we collect and hold about you. We’ll aim to provide this to you within 30 days after you submit your request.
Have your information corrected or deleted. You can update your information in your profile, delete individual Chats you have created, delete Chat and VM audio comments you created within Conversations, and delete Replays you have created. You can delete your information within our Products, by deleting your account in your account settings, or by making a written request to our team, depending on the type of information you are requesting to delete. Because Townhall involves people creating audio together, the details of this are helpful to understand.
Change your profile settings. If you want to restrict the availability of certain information in your Townhall profile, you can do so in your account settings page.
Disconnect social media accounts. When you connect your social media accounts to Townhall, we notify those platforms. You may disconnect your social media accounts directly within the Products at any time via your account settings page.
Delete your contacts. If you chose to sync your contacts, you can always change your mind by disabling contact sync in your account settings page.
Opt out of push notifications. If you opt in to receive push notifications within the Products, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the Products, or deleting the Townhall app from your iOS or Android device.
Pause or reduce notifications. If you want to pause notifications for a while, or reduce the number of notifications Townhall sends you, you can do so in your account settings page.
Disable optional recording features. Creators of a Room or moderators of a Room may disable Replays.
Revoke consent you have given or object to us processing your information. You can revoke any consent you have given us by adjusting your settings, or object to processing personal information in certain circumstances.

Transferring Information – While our Products are offered worldwide, we are based in the United States and rely on cloud storage providers that store user data on our behalf in the United States. When you use our Products, your personal information may be transferred and stored outside your home country, including in the United States, for the purposes described in this Policy. The privacy protections and the rights of authorities to access your personal information in such countries may not be equivalent to those of your home country.

Revisions – We may change this Policy from time to time. If we do, we’ll post any changes on this page. We will provide a more prominent notice or get your consent where required by law.

Contact Us – Global Turner Limited (doing business as “Townhall”) is responsible for your information. You can contact Townhall at Novel Techpark, Hosapalya, Bengaluru – 560068, India

California Consumer Privacy Act Disclosures

Last Modified: January 2, 2025

The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties to whom we disclose it, which we have explained above. This notice supplements information contained in our Privacy Policy and applies solely to residents of the State of California (“consumers” or “you”).

Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”) have the same meaning when used in this notice and policy. This notice and policy does not reflect our collection, use, or disclosure of California residents’ personal information, or data subject rights, where an exception under the CCPA applies.

1. Your Rights To Access And Deletion

Access. You have the right to request a copy of the personal information we collect, use, or disclose about you. You can submit a request for this information via our Privacy Center.

Deletion. You also have the right to request the deletion of personal information. You can submit a request for the deletion of personal information using this form.

Correction. You can ask us to correct the personal information that we hold about you. You can submit a request for correction using this form.

Verification. Townhall may ask you to provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Townhall will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

Exceptions. In accordance with the CCPA, Townhall will not provide the following information in response to access requests for the following reasons:

Account data such as account passwords and identity verification codes, unmasked phone numbers, or email addresses, because of the sensitive nature of the information.
Other users’ and employees’ personal information, including the names and account information of individuals who may have invited you to the app, other users’ feedback, and employees’ comments because the information belongs to other individuals and disclosing it may impact their rights.
Internal proprietary attributes that enable us to provide various aspects of our app, including channel and room customization, suspension decisions, and content suggestions, because the information is protected by federal and state trade secret law.
Server logs that are older than 30 days because we use these to ensure the security and integrity of our app.

Townhall does not sell the personal information of its users. When a business sells your personal information, you have a right to opt out. Townhall does not sell, and in the preceding 12 months did not sell, California residents’ personal information. Townhall does not have actual knowledge that it sells the personal information of minors under 16 years of age. All users under 18 are defaulted into a “private profile.”

2. Personal Information Handling Practices

Below you will find a list of the categories of personal information we collect about California residents and have collected in the preceding 12 months. For each category of personal information we have collected, we reference the category or categories of personal information in the CCPA that most closely describe the personal information.

Personal Information Handling Practices

CCPA Category	Category Of Personal Information We Collect	Type of Third Party to Which Disclosed
Identifiers	Name, username, telephone number, e-mail address, IP address, profile picture, purchase or transaction history, information provided in user’s profile or bio	Third parties and service providers Government regulatory authorities
Categories listed in the California Customer Records Act (Cal. Civ. Code § 1798.80(e))	Name, username, age, telephone number, e-mail address, IP address, profile picture, purchase or transaction history, preferred language, interests, app usage and activity information, friend lists, contact lists (hashed telephone numbers only), information from user’s other social media accounts (if user chooses to connect them), messages sent and received from other Townhall users, questions or feedback sent to Townhall	Third parties and service providers Other online services connected to Townhall Government regulatory authorities
Characteristics of protected classifications under California or federal law	Age	Third parties and service providers
Commercial information	Purchase, transaction, and payment history, interests, app usage and activity information, Friend lists, contact lists (hashed telephone numbers only), questions or feedback sent to Townhall	Third parties and service providers Other online services connected to Townhall Government regulatory authorities
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web website, application, or advertisement	IP address, domain name, browsing history, browser type and settings, operating system, network information, service provider, signal strength, device type, device memory, device’s call log data, unique application identifier, unique device identifier, apps installed on device, time of visit, duration of visit, date and time stamps of actions	Third parties and service providers Government regulatory authorities
Geolocation data	IP address	Third parties and service providers
Audio, electronic, visual, thermal, olfactory, or similar information	Audio information, including voice recordings from conversations when users use our Products; visual information, including profile photos; voice sample(s) we may use to create a custom voice; and supplemental information generated from audio or visual information, such as captions, transcripts, and conversation summaries	Third parties and service providers Government regulatory authorities
Sensitive personal information, such as:- data generated when you interact with others on the services, such as the content of your audio or text messages to others- any sensitive biographical information you provide publicly, such as information about your race or ethnicity	Information that may be provided to us when interacting on the services, such as in audio conversations or in user’s bio	Third parties and service providers Government regulatory authorities
Professional or Employment related information	Information that may be supplied in user’s bio	Third parties and service providers
Education Information	Information that may be supplied in user’s bio	Third parties and service providers
Inferences drawn from the information above	Information about user activity and the contents of communications used to personalize recommendations regarding conversations or Houses a user might join, people a user might know, or other content a user might want to enjoy or create on Townhall.	Third parties and service providers

Townhall collects this personal information from the following sources:

Information Provided By You. When you use Townhall, we collect personal information that you provide to us. When you set up an account, we may ask you to provide information about yourself, including your name, phone number, email address, and age (“Account Data”). We may also ask you to provide us with some additional personal information that will be publicly visible in our Products, such as a profile picture, a bio in your profile to tell other Townhall users more about you, and topics you’re interested in. You may also choose to connect your other social media accounts, sync your contacts.
Information We Get From You When You Use Our Products. When you use our Products, we collect additional personal information based on your activity and other personal information you might choose to disclose. As discussed in our Privacy Policy, this may include usage and activity information, audio information from Conversations, messages, other communications, transaction data, contacts, log data and device information, and cookie data. Townhall may collect information from the computer, tablet, phone, or other device that you install our mobile application on, that you use to access our Products, or that you use to open an email or click on an advertisement from Townhall. Townhall does not respond to “do not track signals.”
Information From Third Parties. If you link your Townhall account to X (Twitter), Instagram, or any other social media services, we may receive information from those other services. The information we receive will depend on the privacy settings on those other services. We may also receive information about you from our service providers.

Townhall collects, uses, retains, and discloses this personal information for the following purposes:

Register your account, verify your identity, and verify the accuracy of your information.
Develop, operate, improve, deliver, maintain, and protect our Products.
Personalize our Products by suggesting Live Rooms, Houses, and other content we think you might be interested in, or by prompting you to create content or Conversations. We also use this information to (i) suggest users you might like to follow; and (ii) suggest your profile to other users.
Send you communications via email or text message. For example, we may use email or text messages to respond to support inquiries, disclose information about our Products, highlight content we think you might like, tell you about features we think you might like to hear about, or suggest ways to improve your Townhall experience.
Verify and enhance the safety and security of our Products
Verify and analyze user engagement, trends, and usage
Assess the efficiency of our advertising campaigns on other platforms
Handle and record consumer rights requests, including opt-ins and opt-outs
Prevent fraud or other unauthorized or illegal activity
Enforce, investigate, and report conduct violating our Terms of Service, Community Guidelines, or other policies
Respond to requests from law enforcement agencies or other government agencies, and comply with legal or regulatory requirements.

3. Disclosure Of Personal Information

In the preceding 12 months, Townhall disclosed the above categories of personal information to the following categories of third parties for a business purpose, in some cases as directed by you:

Third parties and service providers that provide products or services to us. In particular, companies that help us support our Products or provide services to you. Townhall may use third parties or service providers to process information on our behalf based on our instructions and for the purposes described in the Privacy Policy, audit interactions and transactions with you, address security, fix errors, maintain accounts and provide customer service, assist with our internal research, and verify service quality or safety.
Other online services you connect to your Townhall account. If you link your Townhall account to X (Twitter), Instagram, or any other services, we may disclose your information to those other services at your direction when using our Products.
Government regulatory authorities. We may disclose your personal information to relevant government regulatory authorities if we believe the disclosure is reasonably necessary to comply with a law, regulation; protect the safety, rights or property of the public, or any person or Townhall; or to detect, prevent or otherwise address illegal conduct, fraud, technical or security issues.

4. Non-Discrimination

Townhall will not discriminate against you if you exercise your privacy rights.

5. Authorized Agent

In addition to exercising your rights yourself, you may also designate an authorized agent to make these requests under the CCPA on your behalf. In order to do this, we may ask you to verify the request directly using the phone number or email address connected to your account, or via other means. The information Townhall asks you to provide to verify your identity may depend on your prior interactions with us and the sensitivity of the personal information at issue.

6. Contact Information

If you have any questions or comments about this notice and policy, the ways in which we collect and use your personal information, or your choices and rights regarding such use, please do not hesitate to contact us at the following address:

Global Turner Limited

Novel Tech Park

Hosapalya, Bengaluru – 560068

India

Thank you for using Townhall!