Privacy and Cookie Policy

Last updated: March 2025

Who are Talkblue?

Talkblue is an initiative by Highway11, based in the Netherlands. Where we decide the means or purpose of processing your personal data, we are the data “controller.”

How to contact us:

Write us: talkblue@ruudniew.com

What are your rights?

You have the following rights, although these rights may be limited in some circumstances:

1. Ask us to send a copy of data to you or someone else
2. Ask us to restrict, stop processing, or delete your data
3. Object to our processing of your data
4. Object to use of your personal data for direct marketing
5. Ask us to correct inaccuracies

If we rely on consent to process data, or send direct marketing, you can withdraw consent by contacting us via the email address above.

Your personal data and how we use it

Enquiry data

When you contact us with an enquiry, we collect your name, email address, and any other information you provide. We use this data to respond to your enquiry. We keep enquiry data for five years from when our relationship with you ends.

We process this information in accordance with the terms of our contract with you or to take steps at your request prior to entering into a contract. We also use this to pursue our legitimate interests in responding to enquiries, and in order to understand our customers and improve our services. You may be required to provide us with certain information in order for us to respond to your enquiries. We collect this information from you, and we will not share it with third parties, unless required by law or required to provide our services to you.

Platform data

At the moment of writing, Talkblue doesn't offer account creations or logins. We may collect the following data:

• Usage data and telemetry
• IP address
• Browser and device information
• Your feedback and survey responses
• Conversation data. Conversation data is never directly stored by Scaleway. Scaleway only sends conversation data to AI models to generate responses. Internet searches by the model are processed by Qwant, our search engine provider and routed through a European proxy by Oxylabs. Though we try to avoid it, data may sporadically end up in our logs and telemetry systems, but without a direct link to your identity. We use logs to improve, protect and maintain our services.

We keep your data for up to 5 years after our relationship with you ends. We use this data internally to improve, protect, maintain and provide our services. We may process this information using Scaleway (our cloud services provider) or Mollie (our payment provider). These organizations may access your data. All data remains within the EU, and we have agreements in place to ensure your data is protected.

Analytics data

Talkblue currently does not use any analytics platforms like Google Analytics. In the future we might use European based, GDPR compliant analytics services, such as Plausible or Fathom. We will update this policy when we start using these services.

Cookies and local storage

Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they’re essential for our sites, apps or services.

Storage, transfers and disclosure

Any personal data that we store is securely stored in the EU. We do not use data processors outside of the European Economic Area, and no personal data is transferred to countries that do not provide adequate levels of protection.

We may disclose your personal data:

• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
• With members of our corporate group, insurers, advisers, suppliers and subcontractors, as necessary for the purposes set out in this policy.
• With our service providers and subcontractors, provided that they only use that personal data on our instructions and not for their own independent purposes.
• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

Subprocessors

Under the GDPR, a subprocessor is any business or contractor customer data may pass through as a side effect of using Talkblue’s service. This definition is very broad and includes things some might simply consider “hardware”, like cloud infrastructure. We use partners for some business processes that are not core to our expertise but are critical to our customers having a quality experience. Here is a current list of subprocessors:

• Scaleway (Paris, France): Cloud Infrastructure Provider
• Mollie (Amsterdam, Netherlands): Payment provider
• Oxylabs (Vilnius, Lithuania):Proxy Provider
• Qwant (Paris, France):Search Engine Provider

Data storage locations

• Scaleway, France