Topics Chat Portugal, Lda. is committed to protecting the privacy and personal data of users of the Topics Chat platform.
This Privacy Policy explains what personal data we collect, how we use it, which legal bases apply, how long we keep it, with whom we may share it, what security measures we adopt and what rights users have under applicable law, including the General Data Protection Regulation, GDPR.
This Policy must be read together with the Topics Chat Terms and Conditions, especially in matters relating to accounts, Rooms, communities, creators, subscriptions, Stripe Connect, informative wallet, payments, moderation, reports, appeals, monetisation features and adult-only features, if and when such features are made available.
By using the Platform, the User acknowledges that their personal data will be processed in accordance with this Policy. Where processing depends on consent, consent will be requested specifically and separately whenever applicable.
1. Identification of the Controller
The entity responsible for processing personal data collected through the Platform is Topics Chat Portugal, Lda., NIPC 518288714, Rua Dr. Joaquim Pires de Lima, n.º 271, 4200-350 Porto, Portugal, telephone +351 938 369 617, email support@topicschat.com.
For legal matters, authority requests, illegal content, moderation decisions or DSA matters, support@topicschat.com may be used.
In certain payment, financial verification, KYC, anti-fraud or settlement operations, payment providers such as Stripe may act as independent controllers or joint controllers under their own terms and privacy policies.
2. Scope of this Policy
This Policy applies to the processing of personal data carried out through the Topics Chat application, associated websites, support channels, Platform features, communities, Rooms, chats, groups, subscription tabs, paid services, creator features, moderation systems, notifications and other services made available by Topics Chat.
This Policy applies to Users, Creators, Professional Users, community administrators, Room participants, subscribers, payers, payment beneficiaries, persons contacting support and persons whose data is processed in the Platform context.
This Policy does not apply to third-party websites, applications, platforms, app stores, payment systems, social networks, cloud services, analytics services or other third-party services that have their own privacy policies.
The use of cookies and trackers on www.topicschat.com is detailed in a separate Cookie Policy, which may be made available through Iubenda or an equivalent provider.
3. Essential concepts
Personal data means any information relating to an identified or identifiable natural person.
Processing means any operation performed on personal data, including collection, recording, organisation, storage, consultation, use, transmission, disclosure, restriction, erasure or destruction.
Controller means the entity that determines the purposes and means of processing. Processor means an entity that processes personal data on behalf of the controller.
4. Processing principles
Topics Chat processes personal data according to the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and accountability.
We collect only the data necessary to provide the Platform, ensure security, comply with legal obligations, process payments, enable monetisation, manage reports, respond to requests and improve the Services.
We do not sell personal data to third parties.
5. Categories of personal data processed
We may process account and identification data, optional profile data, technical and usage data, Content and communication data, Room and community data, support data, transaction and billing data, Creator and Professional User data, informative wallet data, security and moderation data, consent and versioning data, notification and communication data, and inferred or derived data within legally permitted limits.
Age verification and adult-only feature data may be processed only where such features are actually available and operationally supported by the Platform.
6. How we collect data
We collect data directly from the User, automatically during Platform use, through third-party service providers when necessary, and from other Users where they report Content, mention a User, send invitations or communicate incidents.
The User must not provide third-party personal data without an appropriate legal basis or authorisation, especially sensitive data, data relating to minors, financial data, health data, intimate data or private communications.
7. Purposes and legal bases
We process data for account management, authentication, provision of Platform features, monetisation, subscriptions, payments, verification of Creators, age and adult-only features where available, moderation, security, abuse prevention, reports, appeals, DSA compliance, support, service communications, promotional communications, analytics, improvement, tax and regulatory compliance, and defence of rights.
The legal bases may include performance of a contract, compliance with legal obligations, legitimate interest and consent or explicit consent where required.
8. Account, profile and social use data
Account data is necessary to create and maintain a functional identity within the Platform.
The username, profile photograph, description, badges, public communities, Rooms created or visible participation may be shown to other Users according to Platform settings and the nature of the feature.
Some records may be retained after account deletion where necessary for legal obligations, security, moderation, payments, defence of rights or abuse prevention.
9. Rooms, communities, chats and User Content
We process data associated with Rooms, communities, groups, channels, private chats and tabs to enable communication, organise conversations, display Content, apply moderation rules, manage reports and protect users.
Where a User reports a message, Room, profile or community, Topics Chat may process the reported Content, context, participants, relevant history and technical information necessary to assess the report.
10. Creators, monetisation, Stripe Connect and informative wallet
To enable monetisation, we process additional data relating to identity, age, eligibility, taxation, payments, transactions, commissions, compliance and risk.
Payments are processed by authorised providers, including Stripe Connect or equivalent entities, which may collect and process data directly under their own policies.
The wallet shown in the application is merely informative and Topics Chat does not maintain a payment account, usable balance or electronic money on behalf of the Creator.
11. Adult-only features, age verification and sensitive data
Topics Chat does not treat adult-only features as active by default. Any future availability of sensual content, artistic nudity or non-explicit adult content will depend on operational mechanisms for age verification, classification, access restriction, moderation and compatibility with legal, app store and payment provider requirements.
Users must not publish or send sensitive data, intimate data, health data, third-party documents, intimate images, sexual information about third parties or data relating to minors unless there is an appropriate legal basis and authorisation.
12. Moderation, reports, appeals and security
We process data to apply the Terms and Conditions, manage reports, analyse Content, respond to appeals, protect users, prevent abuse and comply with legal obligations.
Where manifestly illegal content, exploitation of minors, threat to life, violence, abuse, serious fraud or security risk is involved, Topics Chat may preserve data and communicate information to competent authorities in accordance with the law.
13. Automated systems, AI and decisions with impact
Topics Chat may use automated systems, AI, classifiers, security rules, risk models and anti-fraud tools to support moderation, security, content classification, spam prevention, abuse detection, protection of minors and Platform integrity.
Where an automated decision produces legal or similarly significant effects on the User, the User may request human intervention, express their point of view and contest the decision, in accordance with applicable law.
14. Cookies, trackers, SDKs and similar technologies
The Platform and www.topicschat.com may use cookies, trackers, SDKs, device identifiers, local storage, scripts, monitoring tools, analytics, push notifications and similar technologies.
Topics Chat maintains a separate Cookie Policy for www.topicschat.com, hosted through Iubenda, identifying categories of trackers, purposes, third parties, duration and preference management.
Cloudflare may be used for distribution, protection, traffic optimisation, security and abuse mitigation. PostHog may be used for product analytics, usage measurement and, where applicable, session replay, according to configuration and applicable law.
Where the law requires consent for non-essential technologies, Topics Chat will seek to obtain such consent through an appropriate mechanism.
15. Notifications and communications
Topics Chat may send service notifications relating to account, security, payments, subscriptions, messages, Rooms, communities, Terms changes, support, reports, appeals and Platform operation.
Promotional communications will be sent on the basis of consent or another valid legal basis, and the User may withdraw consent or object.
16. Sharing data with third parties
We may share personal data with processors and service providers who help us make the Platform available, including Cloudflare, Neon, Stripe, Twilio, PostHog, Sentry, Expo, Iubenda and providers of hosting, infrastructure, databases, payments, authentication, notifications, SMS, email, analytics, error monitoring, support, consent management, legal policy hosting, security and compliance.
We may share data with authorities, courts, regulators or other competent entities where required by law, valid order or necessary to protect rights, security and Platform integrity.
We do not sell personal data to third parties.
17. Third-party services and User responsibility
The Platform may allow access to third-party services. Processing by those third parties is governed by their own privacy policies and terms.
When sharing Content with third parties, the User is responsible for ensuring the legality, reliability, authorisation and security of that sharing.
18. International data transfers
Topics Chat seeks to process and store personal data preferably within the European Economic Area.
Where international transfers occur, we will adopt appropriate mechanisms such as adequacy decisions, standard contractual clauses, supplementary measures or other lawful instruments.
19. Data retention
We retain personal data only for the period necessary to fulfil the relevant purposes, unless a longer period is required or permitted.
Account data is retained while the account is active and afterwards as necessary for security, legal defence, legal compliance, abuse prevention or disputes. Support data may be retained for up to 24 months. Technical and security logs may be retained for up to 12 months. Billing and tax data may be retained for up to 10 years. Moderation data may be retained for up to 24 months or longer where necessary.
Third-party providers may apply their own retention periods according to their policies and applicable law.
20. Data security
Topics Chat adopts appropriate technical and organisational measures, including TLS encryption, encryption at rest where applicable, access controls, permission management, security logs, monitoring, authentication, backups, reviews and internal procedures.
No system is entirely secure, but Topics Chat undertakes to act diligently to prevent and respond to risks.
21. User rights
Under the GDPR, the User may exercise rights of access, rectification, erasure, restriction, objection, portability, withdrawal of consent and the right not to be subject to solely automated decisions producing legal or similarly significant effects.
Exercise of rights may be subject to identity verification, protection of third parties, legal limitations, trade secrets, security, abuse prevention and retention necessary for legal compliance or legal defence.
22. How to exercise rights
The User may exercise rights by email to support@topicschat.com or by post to the address indicated in this Policy.
Topics Chat will respond within legally applicable timeframes and may request additional information where necessary.
23. Complaint to the supervisory authority
The User has the right to lodge a complaint with the competent supervisory authority. In Portugal, the authority is the Comissão Nacional de Proteção de Dados, CNPD, www.cnpd.pt, Av. D. Carlos I, 134, 1.º, 1200-651 Lisbon, Portugal.
24. Privacy of minors
The Platform is intended for Users who are at least 13 years old, without prejudice to the minimum age, parental consent requirements and other legal conditions applicable in the User's country of residence.
We do not knowingly collect personal data from minors below the minimum age applicable in their jurisdiction.
Users under 18 may not access adult content, adult-only features, adult-only monetisation features or areas reserved for adults, if such features are made available.
25. Sensitive data and third-party information
We ask Users not to publish or send sensitive data unless strictly necessary and legally permitted.
It is prohibited to publish personal data of third parties without a legal basis. Topics Chat may remove, limit, retain as evidence or communicate such data to authorities where necessary.
26. Anonymised and aggregated data
Topics Chat may use anonymised, aggregated or statistical data for analysis, reports, product improvement, internal research, institutional communication, security and business metrics.
27. Changes to this Policy
Topics Chat may update this Policy to reflect legal, technical, operational, commercial, product, security or data processing changes.
Relevant changes may be communicated through the application, email, notifications, banners or other appropriate means.
28. Contacts
For privacy, data protection or rights matters, the User may contact support@topicschat.com.
Address: Topics Chat Portugal, Lda., Rua Dr. Joaquim Pires de Lima, n.º 271, 4200-350 Porto, Portugal.