Privacy Policy

Effective date: 3 August 2026 Last updated: 4 September 2026

Smalltalk Telecom Inc. ("Smalltalk", "we", "us") makes a screen-free phone for kids and a companion app for their parents. This policy explains what personal information we collect, why, where it lives, who else touches it, and the choices you have. It applies to the Smalltalk phone, the Smalltalk app, and smalltalkphone.com.

We are based in Toronto, Ontario, and this policy is written to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA).

The short version: we collect what the product needs to work and almost nothing else. No advertising, no analytics trackers, no selling or sharing data for marketing — not as a promise we added later, but as how the product is built. The longer version follows, and we have tried to keep it readable.

1. The people this policy covers

Because Smalltalk is a family product, several kinds of people show up in our records, and they deserve separate honesty:

• Parents and guardians — you create the account, and most of what we hold is yours.
• Invited callers — grandparents, relatives and close friends a guardian invites to call the family's phones through the app.
• Your child. We never ask for your child's name, age, or any profile information, and your child never interacts with Smalltalk's systems directly. But we are not going to pretend a child is invisible in a product built around their phone: if you name the phone "Maya's Phone," that name is in our records, and the phone's calling history (§3) is a record of your child's calls. You are in control of both — you choose the phone's name, and you can delete the history at any time.
• People you add as contacts. When you add someone to your child's approved contact list, you give us their name and phone number. See §5.
• Website visitors — the contact form and the wait-list.

Smalltalk accounts may only be created by adults. The service is offered in Canada, and is not currently offered in Quebec.

2. What we collect, and why

Your account. Email address and password (stored only as a secure hash), your family's display name, member names you choose to show, your timezone (so bedtime schedules run on your clock), and each member's role. Used to sign you in, run the service, and send you the notices described in §9.

Your child's phone. The phone's name (chosen by you), its internal Smalltalk number, hardware identifiers (MAC address and serial number — needed to set the phone up and keep it connected), and its live state: locked or unlocked, online or offline, on a call or not.

Calling history. For each call: who it was with (which approved contact), direction, whether it connected, how long it lasted, and when. This exists so you can see your child's activity in the app. We never record, listen to, or store the content of calls — there is no recording capability in the product at all. If someone attempts a call that the phone's rules block, we record that it was blocked and why, including a blocked attempt to dial an emergency number — because that is something a parent must be able to see.

Approved contacts. The names and phone numbers you add (§5).

Downtime schedules and the parent activity record — a log of which guardian locked the phone, changed a schedule, or added a contact, kept so that two parents can each see what the other changed. It records actions of adults, never of children.

Support conversations. If you contact us, we keep your message, our replies, your name if you gave one, and your email address. Support messages are ordinary text — please include what we need to help you, but there is no need to include anything sensitive.

Billing. Payments are processed by Stripe. We never see or store your card number; we keep Stripe's reference for your subscription, your card's brand and last four digits (so the app can show "Visa ····4242"), and your subscription's status. Because we post you a physical phone, checkout also collects your name, your phone number, and your billing and shipping addresses. We keep them to send the phone, and so a courier can reach you about the delivery; checkout accepts Canadian addresses only. If you purchase on our website before creating an account, we keep the email address you paid with until you set up the app — it is how we match your purchase to your account.

Consent records. When you tell us yes or no to receiving emails (§9), we keep a record of exactly what you were shown and when you answered. That record is evidence of your choice, which is why it is kept even if you later change your mind.

The safety-notice acknowledgment. Every guardian setting up a phone, and every invited caller using the app to call, must read and confirm the notice that Smalltalk cannot call 911 (Terms of Service §1). We record this twice, and the two records are different in kind. While your account is open, we note that the confirmation was given and when, against the phone and the person who gave it. Separately, we keep a record of the disclosure itself — the date and which version of the wording was shown — which contains no name, email address, phone number, or any other identifier, and no link to your account. That second record is the one that outlives your account (§8): it is evidence that the warning was given, not evidence about you.

Push notifications. A device token that lets us deliver notifications (a call ringing, the phone going offline) to your phone.

Website. The contact form collects your name (optional), email, and message, and delivers them to our own support system. The wait-list collects your name, email, province, and the phone number you'd like to reserve, and also goes to our own systems. Searching for an available number sends us only the number you typed. Our website sets no cookies of ours, runs no analytics, and loads no third-party scripts; our web forms use invisible spam-trap fields and rate limits instead of tracking you.

3. Your child's calling history — the 90-day rule

Your child's calling history is kept for 90 days and then deleted automatically, permanently, on a rolling basis. This window is deliberate: long enough for a parent to notice a pattern, short enough that we are not building an archive of a child's communications.

You do not have to wait 90 days. You can delete individual entries or clear a phone's entire history at any time in the app, and deletion is immediate and complete — we keep only a content-free marker that a deletion happened, which contains nothing about what was deleted.

4. What we deliberately do NOT do

These are design decisions, not aspirations, and each one is verifiable in the product:

• No advertising and no ad networks — the app and website contain no ad SDKs, pixels, or trackers of any kind.
• No analytics trackers. We do not use Google Analytics, Firebase Analytics, session recording, or any behavioural analytics product.
• No selling or renting personal information. No sharing for anyone else's marketing. Ever.
• No call recording and no access to call audio content.
• No address-book harvesting. The app never reads your phone's contact list; every approved contact is added one at a time, by you.
• No location tracking. The app asks for location permission only to read your Wi-Fi network's name during setup; it never reads, stores or sends your location.
• No profiles of children. We do not ask for, and do not want, your child's name, birthday, photo, or anything else about them.

5. Information about people you add

When you add a contact to your child's phone, you are giving us another person's name and phone number — usually a grandparent's or a family friend's. We use it for exactly one thing: connecting the calls you have approved. We never contact these people, never market to them, and never share their details.

Please only add people you know personally and have reason to believe would be comfortable being reachable by your child. If you are on someone else's contact list and want to be removed, email us (§12) and we will handle it with the account holder.

6. Service providers

We use a small number of providers to run the service. Each receives only what its job requires, and none may use your information for its own purposes:

7. Where your information lives

Your family's records — the account, contacts, schedules, calling history, support conversations — are stored in Canada. We chose a Canadian data region on the first day of the project, and it is where the product's database lives.

Some of the specialised providers above operate in the United States: calls are connected through US-based telecom infrastructure, payments are processed there, and push notifications travel through Google's and Apple's networks. Information handled by those providers may be stored or processed in the United States and may be accessible to authorities there under US law.

8. How long we keep information

When your account closes, we delete your family's records. The account owner can close the account in the app (Settings → Account & billing → Delete account); anyone else can arrange it by contacting us (§12). We may retain what the law requires us to retain (billing records), plus consent records and the safety-notice acknowledgment described in §2, which exist precisely to prove what happened.

9. Emails, and your choices about them

We separate two kinds of email and never blur them:

• Account and service notices — billing receipts, service changes, security notices, replies to your support requests. These are part of operating your service.
• Promotions and product news — only if you said yes, and you can withdraw that consent at any time in the app (Settings → Communication Preferences) or by using the unsubscribe link in any such email.

We record your choice, with the exact wording you saw, each time you make or change it.

10. Your rights

You can:

• See your information. Most of it is visible directly in the app, and you can download a copy of everything we hold (Settings → Account & billing → Download my data). For anything else, email us and we will provide it.
• Correct it — names, contacts and schedules are editable in the app.
• Delete calling history — per-entry or entirely, in the app, instantly.
• Withdraw marketing consent at any time (§9).
• Close your account and have your family's records deleted (§8).
• Complain. We would rather hear it first (§12), but you always have the right to complain to the Office of the Privacy Commissioner of Canada — priv.gc.ca or 1-800-282-1376.

We will respond to access and deletion requests within 30 days.

11. Security, honestly

Every family's records are isolated from every other family's at the database level, enforced by access rules that our automated tests verify on every change to the product. Sensitive operations run only on our servers, never in the app. Payment card numbers never touch our systems. Access to production data is limited to the founders.

One thing we will not overstate: calls on the Smalltalk network are not end-to-end encrypted. Call audio travels over standard telephone-grade infrastructure between the phone and our telecom provider. What protects a Smalltalk call is the closed network itself — only people you have approved can call your child or be called — not encryption of the audio stream. If we enable voice encryption in the future, we will say so only once it is actually running.

If we ever experience a breach that creates a real risk of significant harm to you, we will notify you and the Privacy Commissioner as PIPEDA requires.

12. Contact

Smalltalk Telecom Inc.
400-26 Wellington St E
Toronto ON M5E 1S2
Canada

Our Privacy Officer is accountable for Smalltalk's compliance with this policy and can be reached at support@smalltalkphone.com (attention: Privacy Officer). We will tell you the officer's name on request.

13. Changes to this policy

If we change this policy, we will update the date above and, for material changes, tell you in the app or by email before they take effect. We will not reduce your rights under this policy without your consent.