What This Policy Covers
This policy explains, in plain terms, what TalkWay does and does not do with your information when you use the app from the Apple App Store and Google Play Store. Two riders create or join a short-lived room and talk to each other over the internet while they ride. One rider can be on iOS and the other on Android. TalkWay does not play music itself.
TalkWay is operated by POLPROG, the data controller. We run our own backend, so your data is processed on infrastructure we control rather than handed to a third-party platform.
Last updated: June 21, 2026
Who We Are
- App: TalkWay
- Provider: POLPROG [to be completed: full registered legal entity name, if any]
- Address: [to be completed]
- Contact: [email protected]
We have not appointed a Data Protection Officer, as there is no obligation to do so under Article 37 GDPR for this processing.
The Data We Do Not Collect
TalkWay is built so that there is almost nothing to collect. Specifically, we do not collect, request, or store any of the following:
- No account, sign-up, login, password, or email address
- No name, date of birth, gender, or any profile
- No camera or photos. The app never requests camera access
- No location. The app never requests location access and does not use GPS
- No contacts, calendar, or address book
- No advertising identifier, device fingerprint, or cross-app tracking
- No analytics, crash reporting, or usage telemetry SDKs
- No cookies or web tracking technologies
TalkWay contains no analytics, advertising, or tracking software of any kind.
The Microphone
The microphone is the only device permission TalkWay requests.
- On iOS the permission is described as: "TalkWay uses the microphone so you can talk to your riding partner." (NSMicrophoneUsageDescription)
- On Android the permission is RECORD_AUDIO, used together with a foreground microphone service so the call keeps working while you ride with the screen off or another app in front
The microphone is used for one purpose only: to capture your voice and send it, live, to the one other rider in your room. Your voice is streamed peer to peer through the real-time media layer (LiveKit and WebRTC) and is never recorded, never written to disk, and never stored by the app or by us. When the call ends, the audio is gone.
The Room Code and Your Display Name
To connect two riders, TalkWay uses a short room code.
- A room code is a random six-character code (for example K7P2QM), generated on our server with a cryptographically secure random generator. It is not derived from you or your device and contains no personal data
- Room codes are ephemeral. A created but unused room is valid for a short window (30 minutes by default) and an active room is torn down a few minutes after the last rider leaves (5 minutes by default). After that the code is gone
- You may optionally enter a short display name so your partner sees who is talking. It is free text, not verified, not required, and not tied to any account
Our server holds only this ephemeral, short-lived room state. There is no database of users and no record of who talked to whom.
Network Information
To carry your voice, the app and our server exchange the minimum technical information any internet service needs:
- Your device's IP address is processed transiently by our server and the real-time media infrastructure to route the connection and to apply abuse protections such as rate limiting. We do not use it to build a profile of you and we do not retain it as part of any user record
- Standard, minimal request logs may be kept briefly for security and reliability and do not contain room codes in request bodies
How Your Voice Travels
The live audio and the signaling that sets up each call are handled by LiveKit, the real-time communication infrastructure TalkWay is built on. Audio is routed between the two riders; it is not recorded or stored. Depending on the deployment, LiveKit may run on infrastructure we operate or on LiveKit Cloud.
Sub-processor: [to be completed: LiveKit Cloud, or your self-hosted deployment details]. Scope: real-time audio routing and call signaling only. We use no other third parties for analytics, advertising, or tracking, because the app does none of those.
Legal Bases (GDPR)
Where the GDPR applies, our legal bases are:
- Microphone capture and live voice transmission, room creation and joining: Article 6(1)(b), performance of the service you ask for
- Transient processing of IP address and minimal logs for security, abuse prevention, and reliability: Article 6(1)(f), legitimate interests in keeping the service safe and available
There is no consent-based tracking, because there is no tracking.
Retention
- Voice audio: not retained. It is streamed live and never stored
- Room codes and room state: ephemeral, removed automatically on the timeouts above (minutes, not days)
- IP address and minimal request logs: processed transiently and not kept as part of any user record
Because there are no accounts and no stored personal data, there is nothing to delete on request and nothing to export. Uninstalling the app removes the only local state, which is a small amount of app preference data on your own device (for example your last used display name), stored only on the device and not transmitted to us.
Children's Privacy
TalkWay is a general-audience cycling utility and is not directed at children. It collects no personal data from anyone, including children.
International Transfers
Where any transfer outside the EEA occurs (for example if a LiveKit Cloud region outside the EEA is used), it is covered by an adequacy decision or Standard Contractual Clauses. [to be completed: confirm the LiveKit region and transfer mechanism for your deployment.]
Your Privacy Rights
Even though we hold no personal data tied to you, where the GDPR or similar laws apply you have rights of access, rectification, erasure, restriction, objection, and portability. To exercise them, or for any privacy question, contact us at the address above. We will respond as required by law, and you may also complain to your local data protection authority.
Changes to This Policy
If we change how TalkWay works in a way that affects this policy, we will post the new version at this URL with a revised date, and material changes will be reflected in the store listing before they take effect.