Privacy Policy

Topics Chat Portugal, LDA is committed to protecting the privacy and personal data of users of the Topics Chat application (“Application” or “Platform”).

This Privacy Policy explains what personal data we collect, how we use it, the legal bases that justify its processing, how long we retain it, with whom it may be shared, and the rights of users under applicable legislation, including the General Data Protection Regulation (GDPR).

1. Identification of the Data Controller

Entity: Topics Chat Portugal, LDA
Tax Identification Number (NIPC): 518288714

Address:
Rua Dr. Joaquim Pires de Lima, no. 271
4200-350 Porto
Portugal

Phone: +351 938 369 617
Email (privacy and support): support@topicschat.com

Topics Chat Portugal, LDA is the entity responsible for the processing of personal data collected through the Topics Chat application.

2. Scope of this Policy

This Policy applies to the processing of personal data carried out through:

• the Topics Chat application

• associated support channels

• functionalities available on the Platform

This policy does not apply to third-party websites, applications, or services that may be linked to the application. Such services are governed by their own privacy policies.

3. What Personal Data Is

Personal data is any information relating to an identified or identifiable natural person.

A person is considered identifiable when they can be identified directly or indirectly, in particular through identifiers such as:

• name

• username

• email address

• phone number

• IP address

• device identifiers

4. Categories of Data Processed

We may process different categories of personal data, including:

Account and Identification Data

• username or user name

• email address

• phone number

• profile picture (if added by the user)

• internal account identifier

Technical and Usage Data

• IP address

• device type

• operating system

• technical device identifiers

• access logs

• interactions with application features

Support and Communication Data

• messages sent to support

• content or attachments sent in support requests

• history of tickets or communications

Transaction and Billing Data

• purchase history within the application

• payment identifiers

• data required for billing or compliance with tax obligations

Security and Moderation Signals

• content reports

• records related to content moderation

• security logs and abuse-prevention records

Optional Profile Data

• biography

• interests or preferences defined by the user

• other optional information added to the profile

5. Purposes and Legal Bases for Processing

We process personal data only when a valid legal basis exists.

Main purposes include:

Account Management and Platform Operation

To allow the creation, management, and use of an account within the application.
Legal basis: contract performance.

Provision of the Service and Application Features

To ensure the functioning of the platform, including communities, messaging, and other features.
Legal basis: contract performance.

Platform Security and Abuse Prevention

To detect fraudulent activity, platform abuse, or violations of community rules.
Legal basis: legitimate interest in ensuring the security and integrity of the service.

User Support Management

To respond to support requests and resolve technical issues.
Legal basis: legitimate interest.

Compliance with Legal Obligations

To comply with legal, tax, or regulatory obligations.
Legal basis: legal obligation.

Communications and Notifications

To send communications related to the operation of the application or service updates.
Legal basis: contract performance or consent, where applicable.

6. How We Collect Data

Personal data may be collected:

Directly from the User

When the user:

• creates an account

• uses application features

• fills in profile information

• contacts support

Automatically

During the use of the application through:

• technical logs

• device identifiers

• usage information

Through Service Providers

When we use external services necessary for the operation of the application (for example cloud infrastructure or payment services).

7. Cookies and Similar Technologies

The application may use technologies such as:

• analytics SDKs

• error monitoring tools

• push notifications

• security technologies

These technologies are used to:

• ensure proper functioning of the application

• improve the user experience

• monitor stability and performance

• prevent fraud or abuse

Where applicable, users may manage preferences through their device or application settings.

8. Data Security

We implement appropriate technical and organizational measures to protect personal data, including:

• TLS encryption for communications

• internal access controls

• security monitoring

• logging of security events

Data is stored in secure cloud infrastructure located in the European Economic Area (EEA), including AWS servers.

9. Data Retention Periods

We retain data only for as long as necessary for the purposes of processing.

In general:

• Account data: while the account remains active

• Support data: up to 24 months after request resolution

• Security logs: up to 12 months

• Billing data: up to 10 years (tax obligation)

• Moderation data: up to 24 months

After these periods, data may be deleted or anonymized.

10. Data Sharing with Third Parties

We may share personal data with:

Processors (Subcontractors)

Service providers who process data on our behalf, such as:

• cloud infrastructure providers

• payment services

• technical support tools

• analytics and monitoring services

All processors are subject to contractual data protection obligations.

Public Authorities

When required by law or by order of a competent authority.

Corporate Transactions

In case of merger, acquisition, or corporate restructuring.

We never sell personal data to third parties.

11. International Data Transfers

Data is preferably processed within the European Economic Area (EEA).

If transfers occur outside the EEA, we ensure appropriate legal safeguards are applied, such as:

• European Commission adequacy decisions

• EU-approved Standard Contractual Clauses.

12. Users’ Rights (GDPR)

Users have the following rights:

• Right of access

• Right to rectification

• Right to erasure (“right to be forgotten”)

• Right to restriction of processing

• Right to object

• Right to data portability

• Right to withdraw consent (where applicable)

Users also have the right to lodge a complaint with the competent supervisory authority:

CNPD – Comissão Nacional de Proteção de Dados
www.cnpd.pt

13. How to Exercise Your Rights

Rights may be exercised through:

Email: support@topicschat.com

Or by post to:

Topics Chat Portugal, LDA
Rua Dr. Joaquim Pires de Lima, no. 271
4200-350 Porto
Portugal

Some information may also be managed directly in the account settings within the application.

14. Children’s Privacy

The application is intended for users aged 13 years or older.

We do not intentionally collect personal data from children under 13.

If we become aware of such a situation, we will delete the data and may close the account.

15. Sensitive Data

Users are asked not to send sensitive personal data, such as:

• racial or ethnic origin

• political opinions

• religious beliefs

• health data

• biometric data

• sexual orientation

If such data is received inadvertently, it will be deleted unless there is a legal obligation to retain it.

16. Changes to the Privacy Policy

We may update this Policy periodically.

Whenever relevant changes occur, they may be communicated through:

• the application

• notifications

• or other appropriate means.

17. Contact

For any questions related to privacy or data protection:

Email: support@topicschat.com

Address:
Rua Dr. Joaquim Pires de Lima, no. 271
4200-350 Porto
Portugal