Effective July 1, 2026 · Last updated 16 June 2026

Terms of Service

Effective date: July 1,2026 | Last updated: 16 June 2026

These Terms of Service (the “Terms”) govern your access to and use of the websites, applications, and services provided by Talksign Ltd (“Talksign”, “we”, “us”, or “our”), a company incorporated in England and Wales with company number 17060416 and registered office at 190 Holliday Street, Birmingham B1 1FD (collectively, the “Services”). By creating an account, accessing, or using the Services, you agree to be bound by these Terms. If you do not agree, you may not use the Services.

If you are an enterprise or educational customer, the Talksign Data Processing Addendum (Part 7) applies to your use of the Services and is incorporated herein by reference.

2.1 The Services

Talksign provides AI-powered, bidirectional translation between spoken and sign languages and related tools. The Services include, without limitation:

• Communication Suite. Real-time speech-to-sign and sign-to-speech translation across mobile, desktop, web, and supported smart glasses.

• Creative Suite. Talksign Canvas, Captions, Avatars, Embed, Live, for creating and publishing sign language content.

• Marketplace. Licensable multimodal sign language datasets. Users can contribute, annotate, license, and access high-quality sign language datasets while they earn.

• Education Suite (Talksign Learn). Structured lessons, assessments, progress tracking, and professional certification.

• Enterprise Suite and API. Programmatic translation, integrations, and organizational deployment.

We may add, modify, or discontinue features at any time. Some features are available only on certain plans or platforms.

2.2 Eligibility and Accounts

• You must be at least 18 years old, or the age of majority in your jurisdiction, to create an account to use the Services. Minors under the age of 18 may access and use the Services only through an account held, managed, and supervised by a parent, legal guardian, or an authorised educational institution that accepts these Terms on their behalf.

• Where an educational institution establishes accounts for minors under 18 (such as through Talksign Learn), that institution contractually certifies that it possesses the requisite legal authority to grant institutional consent on behalf of parents or guardians under applicable child data privacy frameworks, including the US Children’s Online Privacy Protection Act (COPPA) and the UK Age Appropriate Design Code (AADC).

• You are responsible for maintaining the accuracy of your registration information and for keeping your account login credentials completely secure. You are entirely responsible for all activities, data transactions, and actions that occur under your account. You must notify us promptly at support@talksign.co of any unauthorised use of your account or any other known breach of security

2.3 Acceptable Use

Your use of the Services is also governed by our Acceptable Use Policy (Part 5), which is incorporated into these Terms. In summary, you agree not to:

• use the Services for any unlawful, harmful, fraudulent, or infringing purpose;

• misrepresent a Talksign automated translation as a certified or legally sufficient human interpretation where a qualified human interpreter is required by law;

• attempt to reverse engineer, decompile, scrape, or extract our models, datasets, or source code except to the extent this restriction is prohibited by law;

• upload content you do not have the right to use, including another person's likeness, voice, or biometric data without their consent;

• interfere with, overload, or circumvent the security, rate limits, or integrity of the Services.

2.4 Translation Accuracy and No Reliance for Critical Use

The Services utilise artificial intelligence and machine learning models, which means outputs will not always be entirely accurate or complete. Automated translation quality is highly variable and depends on multiple external factors, including background audio clarity, individual signing styles, regional sign language variations, ambient lighting, physical positioning, and situational context.

You explicitly acknowledge and agree that:

• As-Is Communication Aid: Talksign outputs are provided strictly as an aid to communication on an “as is” and “as available” basis, without any warranties of absolute accuracy.
• High-Stakes Environments: You must not rely solely or primarily on automated translations in legal, medical, financial, safety critical, or emergency settings where a qualified human interpreter is required, advisable, or otherwise necessary to ensure safety and precision.
• No Certified Substitute: Talksign is an automated tool and does not serve as a legally valid or certified substitute for a professional human sign language interpreter where one is mandated by statutory law, institutional policy, or regulatory framework.
• Mandatory Interface Acknowledgements: To ensure user safety and translation integrity in critical environments, the platform may deploy mandatory, in-app “I Agree” warning prompts and pop-up notifications when high-stakes modes are activated. You must review and formally acknowledge these prompts before proceeding with the use of the platform in those settings.

2.5 Plans, Credits, and Payment

• Credits: Paid subscription plans include a monthly credit allowance that refills automatically on your specific billing date. Unused credits roll over only up to the explicit threshold limit stated for your chosen plan tier. Credits hold no independent cash value, are non-transferable, and are not redeemable except directly for the execution of the Services.

• Top-ups: Additional top-up credit packs are available for purchase by active paid plan subscribers and are consumed dynamically according to our published platform burn rates.

• Billing and Automatic Renewal: Subscription plans renew automatically at the end of each billing cycle until formally cancelled by you through your account dashboard layout. All subscription fees are charged in advance and are strictly non-refundable, except where explicitly required by mandatory local statutory laws.

• Plan and Price Changes: We reserve the right to modify our subscription prices or core plan features upon providing reasonable advance notice to you. Any price adjustments will take effect dynamically at the start of your subsequent billing cycle.

• Statutory Cooling-Off Waiver: Under UK and EU consumer protection frameworks, consumers generally possess a statutory 14-day cooling-off period to cancel digital subscriptions and distance contracts. However, by purchasing a Premium or Pro subscription and explicitly requesting immediate operational access to Talksign’s digital service, you acknowledge and agree that you are expressly waiving your statutory right of cancellation and refund under this cooling-off framework once digital performance has commenced.

• Taxes: All listed platform prices are exclusive of value-added tax (VAT), local sales taxes, or alternative governmental duties and levies unless explicitly indicated otherwise. Applicable regional taxes will be calculated dynamically and displayed clearly at checkout based on your designated billing jurisdiction.

2.6 API and Enterprise Terms

• API access is subject to the rate limits, credit costs, and plan terms published at docs.talksign.co and any applicable order form.

• You must keep API keys confidential and are responsible for usage under your keys. We may suspend keys for abuse, security risk, or non-payment.

• Enterprise customers are governed by a separate signed agreement, order form, and where applicable a Data Processing Agreement((Part 7) which prevail over these Terms to the extent of any conflict.

• Service levels (including the published uptime SLAs) apply only as stated in the relevant plan or Enterprise agreement.

2.7 User Content and Marketplace

“User Content” means content you upload, create, generate, or publish through the Services, including avatars, captions, and recordings.

• You retain ownership of your User Content. You grant Talksign a worldwide, non-exclusive, royalty-free licence to host, process, display, and transmit your User Content solely to operate and provide the Services to you.

• No Model Training: Talksign respects your privacy and creative ownership. We will never use your private conversations, live translation data, or general User Content (such as avatars created in the Creative Suite) to train, retrain, or improve our foundational artificial intelligence models.

• Exception for Marketplace Contributions: The sole exception to this rule is content specifically submitted and paid for under the Talksign Marketplace Contributor Agreement. Because Talksign outright acquires ownership of this vetted Marketplace data for the explicit purpose of building better translation models, that specific Contributed Content will be used for AI training and development.

• You are responsible for ensuring you have all rights and consents necessary for your User Content, including any third-party likeness, voice, or biometric data.

2.8 Intellectual Property

Talksign Ownership

The Services, including our models, software, datasets, avatars provided by us, trademarks, and all related intellectual property, are owned by Talksign or our licensors and are protected by law, including under accepted patent rights. Except for the limited rights expressly granted to you, no rights are transferred. You may not use the Talksign name or marks without our prior written consent.

Third-Party Copyrights & DMCA Policy

Talksign respects the intellectual property rights of others and expects users of our Services and Marketplace to do the same. In accordance with the Digital Millennium Copyright Act (DMCA), we will respond to notices of alleged copyright infringement. If you believe that your copyrighted work has been copied or uploaded in a way that constitutes copyright infringement, please notify Talksign’s Designated Copyright Agent with the following information in writing:

• A physical or electronic signature of the copyright owner or authorised representative;
• Identification of the copyrighted work claimed to have been infringed;
• Identification of the material that is claimed to be infringing and its location on the Services;
• Your contact information, including address, telephone number, and email;
• A statement that you have a good faith belief that the use of the material is not authorised; and
• A statement, made under penalty of perjury, that the information in your notice is accurate.

Talksign’s Designated Copyright Agent:

Attn: Legal Department / Copyright Agent

Email: legal@talksign.co

Post:190 Holliday Street, Birmingham B1 1FD

2.9 Privacy

Our handling of personal data is described in the Talksign Privacy Policy (Part 3), which forms part of these Terms.

2.10 Third-Party Services and Hardware

The Services may interoperate with third-party platforms (such as video conferencing tools) and third-party hardware (such as smart glasses). We do not control and are not responsible for third-party products, and your use of them is governed by their own terms.

2.11 Suspension and Termination

• You may stop using the Services and close your account at any time.

• We may suspend or terminate your access if you breach these Terms, create risk or legal exposure, or fail to pay fees, with notice where reasonably practicable.

• On termination, your right to use the Services ends. Clauses that by their nature should survive (including IP, disclaimers, limitation of liability, and governing law) will survive.

2.12 Disclaimers

To the maximum extent permitted by law, the Services are provided “as is” and “as available” without warranties of any kind, whether express or implied, including implied warranties of merchantability, fitness for a particular purpose, accuracy, and non-infringement. We do not warrant that the Services will be uninterrupted, error-free, or that translations will be accurate or complete.

2.13 Limitation of Liability

(a) Statutory Exceptions (Uncapped Liability)

Nothing in these Terms shall limit or exclude either Party’s liability for matters which cannot be limited or excluded under applicable law. Depending on your jurisdiction, this includes, without limitation:

(i) death or personal injury caused by that Party's negligence;

(ii) fraud or fraudulent misrepresentation;

(iii) gross negligence or wilful misconduct; or

(iv) any breach of mandatory consumer rights that cannot be waived by contract.

(b) EXCLUSION OF CONSEQUENTIAL AND INDIRECT DAMAGES

SUBJECT TO SECTION 2.13(A),NEITHER TALKSIGN NOR ITS AFFILIATES, LICENSORS, OR SUPPLIERS SHALL BE LIABLE TO YOU OR ANY THIRD PARTY UNDER CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR ANY OTHER LEGAL OR EQUITABLE THEORY FOR:

(I) ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES;

(II) ANY LOSS OF PROFITS, REVENUE, BUSINESS, GOODWILL, OR ANTICIPATED SAVINGS; OR

(III) ANY LOSS, CORRUPTION, OR DESTRUCTION OF DATA, FILES, OR DIGITAL ASSETS,

REGARDLESS OF WHETHER TALKSIGN WAS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES.

(c) General Cap for Consumer Users (B2C)

Subject to Sections 2.13(a) and 2.13(b), if you are accessing or using the Services as an individual consumer, Talksign’s total aggregate liability for all claims arising out of or relating to these Terms or the use of the Services shall be strictly limited to the greater of:

(i) the total fees paid or payable by you to Talksign in the twelve (12) months immediately preceding the event giving rise to liability; or

(ii) the fixed floor amount of [£100 / $100 / ₦150,000], based on your registered billing address.

(d)General Cap for Commercial and Enterprise Users (B2B)

Subject to Sections 2.13(a) and 2.13(b), if you are utilizing the Services for commercial, institutional, educational, or business purposes (including as an Enterprise or Marketplace user), Talksign’s maximum aggregate liability for all operational, contractual, or tortious claims arising out of or in connection with this agreement shall not exceed the total fees paid by you to Talksign under the specific Order Form or account tier in the twelve (12) months immediately preceding the first incident giving rise to liability.

(e)Data Protection and Biometric Data “Super-Cap”

The Parties acknowledge that Talksign processes highly sensitive communication, audio, visual, and sign-language data that may be classified as biometric data under relevant laws (such as UK GDPR, NDPA, or US state privacy laws).

(i) Notwithstanding Section 2.13(d) but subject always to Section 2.13(a), Talksign’s total, maximum aggregate liability for any breaches of its Data Processing Addendum (DPA), data privacy laws, or claims resulting from a Data Security Incident shall be strictly capped at three times (3x) the total fees paid by you in the preceding 12 months.

(ii) Under no circumstances shall Talksign face uncapped financial exposure for data protection or biometric compliance claims, and the limit set out in this Section 2.13(e) represents your sole and exclusive monetary remedy for such breaches.

(f) Essential Allocation of Risk

The provisions of this Section 2.13 allocate the risks under these Terms between the Parties, and the Parties have relied on these limitationsin determining whether to enter into these Terms and the pricing model chosen for the Services.

2.14 Indemnity

You agree to indemnify and hold Talksign harmless from claims, losses, and reasonable costs arising from your breach of these Terms, your User Content, or your unlawful use of the Services. This clause applies to business and Enterprise users; consumer obligations apply only to the extent permitted by law.

2.15 Changes to These Terms

We may update these Terms from time to time. If we make material changes, we will provide reasonable notice (for example, by email or in-product notice). Continued use after changes take effect constitutes acceptance.

2.16 Governing Law and Disputes

(a) Informal Resolution First

Before initiating any formal legal proceeding, you and Talksign agree to try to resolve the dispute informally. You agree to notify Talksign of your claim by emailing legal@talksign.co with a written description of the dispute and your requested relief. Talksign will contact you via your registered email address. If the dispute is not resolved within thirty (30) days of the initial notification, either party may pursue formal resolution in accordance with this Section 2.16.

(b) UK, European Union, and Rest of World Users

(i) Governing Law

If you are a resident of, or an entity incorporated in, the United Kingdom, the European Union, or any jurisdiction outside of the United States and Nigeria, these Terms and any dispute arising out of them shall be governed by, and construed in accordance with, the laws of England and Wales.

(ii) Jurisdiction

Subject to Section 2.16(b)(iii), the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms.

(iii) Consumer Carve-Out

If you are an individual consumer resident in the UK or the EU, you possess the mandatory protection of the laws and local court jurisdiction of your country of residence. Nothing in these Terms affects your right as a consumer to rely on such mandatory local provisions or to bring claims in your home courts.

(c) Nigerian Users

(i) Governing Law

If you are a resident of, or an entity incorporated in, the Federal Republic of Nigeria, these Terms and any dispute or claim arising out of or in connection with them shall be governed by, and construed in accordance with, the laws of the Federal Republic of Nigeria.

(ii) Dispute Resolution

Any dispute arising out of or relating to these Terms between Talksign and a Nigerian user shall be referred to and finally resolved by the courts of the Federal Republic of Nigeria, sitting in Lagos State.

(iii) Commercial Arbitration Option
For commercial, institutional, or Enterprise users in Nigeria, either party may elect to refer any dispute to final and binding arbitration in Lagos, Nigeria, administered by the Lagos Court of Arbitration (LCA) in accordance with the Arbitration and Mediation Act 2023. The tribunal shall consist of a single arbitrator, and the language of the arbitration shall be English.

(d) United States Users (MANDATORY ARBITRATION AND CLASS ACTION WAIVER)

(i) Governing Law

If you are a resident of, or an entity incorporated in, the United States, these Terms and any dispute arising out of them shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law principles. The Federal Arbitration Act (FAA) governs the interpretation and enforcement of this Section 2.16(d).

(ii) BINDING INDIVIDUAL ARBITRATION

YOU AND TALKSIGN AGREE THAT ANY AND ALL DISPUTES, CLAIMS, OR CONTROVERSIES ARISING OUT OF OR RELATING TO THESE TERMS, THE SERVICES, OR THE MARKETPLACE SHALL BE RESOLVED EXCLUSIVELY THROUGH FINAL AND BINDING INDIVIDUAL ARBITRATION, RATHER THAN IN A COURT OF LAW, except that you may assert claims in small claims court if your claims qualify.

(iii) Arbitration Procedures

The arbitration will be administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules (for consumers) or Commercial Arbitration Rules (for business/marketplace users).

The arbitration shall be held in Wilmington, Delaware, or, for consumer convenience, may be conducted telephonically, via video conference, or in the US county where you reside. Judgment on the award rendered by the arbitrator may be entered in any court having jurisdiction.

(iv) CLASS ACTION AND JURY TRIAL WAIVER

YOU AND TALKSIGN EXPLICITLY AGREE THAT ANY PROCEEDINGS WILL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION. YOU UNDERSTAND AND AGREE THAT BY ENTERING INTO THIS AGREEMENT, YOU AND TALKSIGN ARE EACH WAIVING THE RIGHT TO A TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION.

(e) Limitation on Time to File

To the maximum extent permitted by applicable law, any cause of action or claim you may have arising out of or relating to these Terms must be commenced within one (1) year after the cause of action accrues; otherwise such cause of action or claim is permanently barred.

2.17 General

Severability: If any provision of these Terms is found to be unenforceable or invalid, the remainder of the provisions will remain in full force and effect.

No Waiver: Our failure or delay to enforce any right or provision in these Terms will not constitute a waiver of that right or provision.

Assignment: You may not assign or transfer these Terms without our prior written consent. We may assign these Terms without restriction in connection with a merger, acquisition, corporate reorganisation, or sale of assets.

Entire Agreement: These Terms, together with any applicable Enterprise agreement, the Privacy Policy, and the Acceptable Use Policy, constitute the entire, exclusive agreement between you and Talksign regarding the Services.

Effective July 1, 2026 · Last updated 20 June 2026

Privacy Policy

Effective date: July 1,2026 | Last updated: 20 June 2026

This Privacy Policy explains how Talksign Ltd (“Talksign”, “we”, “us”), company number 17060416, registered at 190 Holliday Street, Birmingham B1 1FD, collects, uses, and protects personal data when you use our Services. It should be read together with our Terms of Service (Part 2).

Our core commitment is simple: we collect as little as we can, we keep it for as short a time as we can, and we never treat your conversations as a product. We do not sell your personal data.

3.1 Who Is Responsible for Your Data

Talksign’s responsibility for your personal data depends on how you interact with our Services:

• Consumer and Self-Serve Users: Talksign Ltd acts as the Data Controller for personal data processed when you use our consumer apps and direct web services.

• Marketplace Contributors: If you upload data (such as sign language videos, facial cues, or gestures) to the Talksign Marketplace to monetise or train our AI, Talksign acts as the Data Controller for that specific biometric and content data, governing how it is verified, stored, and distributed.

• Enterprise and Institutional Customers: When you access the Services through an employer, hospital, or educational institution, that organisation is typically the Data Controller. In these instances, Talksign acts strictly as a Data Processor acting on their written instructions under a Data Processing Agreement (DPA).

Data Protection Officer (DPO) We have appointed a Data Protection Officer to oversee compliance with this privacy notice, including our handling of biometric and special category data under the UK GDPR and the Nigeria Data Protection Act (NDPA).

If you have any questions about this notice, how we handle your personal data, or if you wish to exercise your legal rights, please contact our DPO at:

Email: privacy@talksign.co

**Post:**190 Holliday Street, Birmingham B1 1FD

3.2 Information We Collect

Account, Health, and Profile Data

We collect your Name, Email Address, optional Date of Birth, optional Profile Picture, Country, Timezone, Company details, and Single Sign-On (SSO) identifiers (e.g., Google/Apple) to operate your account.

• Special Category Data (Health): You may optionally provide your hearing or disability status (e.g., Deaf, hearing, interpreter). Because this is classified as sensitive health data, we only process this specific field with your explicit, affirmative consent provided during account setup.

Conversation and translation data (Zero Media Retention)

To provide real-time translation, the Services process audio, sign/gesture, video, facial cues, and text. Where the hardware allows, this processing happens on-device. Where cloud processing is required, the data is routed transiently to our servers, currently hosted on Europe West 2 (GCP London).

• Raw Media is Discarded: We operate a strictly “Zero Media Retention” pipeline for live translations. No raw audio, raw video, or identifiable visual media is cached, logged, or stored on our servers after the translation is delivered.
• What is Kept: We retain the resulting text transcripts (for your personal history and analytics) and anonymised skeletal keypoint tracking data.

Third-Party Invite Data

If you invite a team or family member to Talksign, we collect their email address. We use this data solely to send the one time invitation and do not use it for marketing purposes unless they subsequently create an account.

Financial and Shipping Data

Payment data processing is handled entirely on Talksign's behalf by our primary sub-processor, Stripe. We do not store full payment card numbers, only Stripe tokens and invoice history. If you order physical hardware (like Talksign smart glasses), we collect your shipping address to fulfill the order.

Usage and technical data

For API customers, request history and credit consumption are processed with a 30-day retention period used strictly for billing and abuse prevention. For all users, we process device and log data (such as IP addresses, app versions, partial crash diagnostics and coarse city/country geolocation) to secure the platform, and we utilise Google Analytics to evaluate aggregate usage patterns. For Talksign smart glasses, we also log the device serial number and Bluetooth ID.

Learn and certification data

If you use Talksign Learn, we process course progress, assessment results, and certification records. For assessments incorporating automated oversight, the Education platform uses a lightweight pose and landmark detection model that only outputs numerical coordinate points.

Please note: For formal certification exams, we store student video submissions (users signing) persistently for grading, audit, and credential verification purposes.

Content you create

This includes avatars, captions, recordings, and Marketplace listings you choose to create or publish. This data is stored securely for as long as your account remains active. Upon account deletion, all associated avatars, captions, and datasets are permanently removed from our production systems after 30 days. Talksign does not use any user-generated content or custom marketplace datasets to train or improve our underlying AI models.

3.3 How and Why We Use Data

We only process your personal data when we have a valid legal basis to do so under the UK GDPR and applicable data protection laws. The table below outlines each specific purpose for which we use your data, the categories of examples involved, and the corresponding lawful basis:

3.4 Model Training

We train our models on datasets co-created with Deaf communities, educators, and researchers, designed to be transparent, representative and ethically sourced.

To protect your privacy and maintain strict operational boundaries, Talksign enforces a clear separation between your live platform data and our artificial intelligence development:

No Conversation Training: User conversation content, including real-time audio, sign language gestures, facial cues, or text transcripts, is processed strictly transiently and is never stored, logged, or used to train, retrain, or improve our AI models.

No General Content Training: We do not use your general user generated content (such as private avatars or custom captions created in the Creative Suite) for algorithmic development.

However, if you explicitly choose to participate in the Talksign Marketplace and sell sign language datasets to us under the Marketplace Contributor Agreement, that specific, vetted data is acquired and processed for the express purpose of training and improving our AI models.

3.5 How We Share Data

We do not sell personal data. We share data only with:

• Service providers (sub-processors): Cloud hosting, payment processing, and analytics vendors who process data on our instructions under contract. Our primary sub-processors include Google Cloud Platform (GCP) for cloud infrastructure, Stripe for payment data processing, and Google Analytics for aggregate site usage. A current sub-processor list is available to Enterprise customers on request.

• Enterprise customers: Where you use the Services through an organization, relevant data may be accessible to that organization as the data controller.

• Legal and safety: Where required by law, regulation, or valid legal process, or to protect rights and safety.

• Business transfers: In connection with a merger, acquisition, or sale of assets, subject to this Policy.

3.6 International Transfers

Our primary cloud computing infrastructure is securely hosted in Europe West 2 (GCP London). Because we operate across the UK, the US, and other regions, and as our product scales globally across multiple regions, your data may be processed outside your home country.

Where we transfer personal data internationally from the UK to third countries (such as to sub-processors in the US), we ensure it remains protected by implementing legally recognised safeguards. These safeguards include executing the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, alongside strict technical measures such as encryption in transit and at rest.

3.7 Data Retention

We hold your data only for as long as is necessary to fulfil the purposes outlined in this Policy. Our specific retention schedules are as follows:

• Conversation Content: Not retained. All real time audio, video, or gesture data is processed either on device or transiently in the cloud and is immediately discarded. Text transcripts and anonymised keypoints are retained for your history.

• Creative Suite & User Content: Avatars, captions, and datasets you create are stored for as long as your account remains active. Upon requesting account deletion, this data is permanently and irreversibly removed from our systems after 30 days.

• API Usage Logs: Retained for 30 days for billing and abuse prevention purposes.

• Account and Billing Records: Retained for the active life of the account and as required by law for tax and accounting record keeping.

• Learn and Certification Records: Retained as needed to maintain your valid educational credentials, or until you request deletion. Student video submissions for certification are retained securely to maintain credential validity.

3.8 Your Rights

Depending on where you live, you have specific legal rights over your personal data.

• UK and EU Rights: Under the UK GDPR and equivalent frameworks, you have the right to access, rectify, erase, restrict, port, and object to the processing of your personal data, as well as the right to withdraw your consent at any time.
• US State Rights: If you reside in the United States, you may have additional rights under state laws such as the California Consumer Privacy Act (CCPA/CPRA). These include the rights to know, delete, correct, and opt out of the sale or sharing of your personal information. Talksign does not sell personal data.

To exercise any of these rights, please contact our data protection team at privacy@talksign.co. Because we do not retain conversation content, please note that there is no historical record of your translations available for access, export, or deletion.

You also retain the right to lodge a complaint with a supervisory authority. In the United Kingdom, this is the Information Commissioner's Office (ICO).

3.9 Children

The Services are not directed to children under the age of 18(“Minors”) without the direct involvement and verified consent of a parent, guardian, or authorised educational institution. We do not knowingly collect personal data from Minors outside of these explicitly controlled environments.

• Talksign Learn & Institutional Consent: Where our Education Suite (Talksign Learn) is deployed in school or institutional environments involving students under 18, Talksign relies strictly on the school or district to provide “Institutional Consent”. This framework enables the institution to act as an agent on behalf of parents or guardians, ensuring operational compliance with the US Children’s Online Privacy Protection Act (COPPA) and the UK Age Appropriate Design Code (AADC).
• Remediation: If you are a parent or legal guardian and believe that a Minor has improperly provided personal data directly to Talksign without valid oversight, please contact us immediately at privacy@talksign.co. We will promptly take necessary measures to purge the unauthorised data and terminate the associated account structure.

3.10 Security

We protect personal data using robust technical and organisational measures, including encryption in transit (TLS 1.2 or higher) and at rest (industry-standard AES-256), least-privilege access controls, multi-factor authentication for administrative access, and strict system logging. Most importantly, we rely on a privacy by design architecture that prioritises on-device processing and minimal data retention. While no system is perfectly secure, our strict minimal retention design substantially limits the data that could ever be exposed in the event of a breach.

3.11 Cookies

Our use of cookies, software development kits (SDKs), and similar tracking technologies (including Google Analytics for performance measurement) is described in detail in our Cookie Policy.

3.12 Changes to This Policy

We may update this Privacy Policy from time to time to reflect operational, legal, or regulatory changes. If we make material changes to how we process your personal data, we will provide reasonable advance notice through the Services or by email. Continued use of the Services after these changes take effect constitutes your acknowledgement of the updated Policy. The “Last updated” date at the top of this document reflects the most current version

Effective July 1, 2026 · Last updated 16 June 2026

Cookie Policy

Effective date: July 1,2026 | Last updated: 16 June 2026

This Cookie Policy explains how Talksign Ltd uses cookies and similar technologies on our websites and applications. It should be read together with our Privacy Policy (Part 3).

4.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website or use an app. Similar technologies include pixels, local storage, and software development kits (SDKs). They help a service function, remember your preferences, keep you secure, and understand how the service is used.

4.2 Categories of Cookies We Use

• Strictly necessary: Required for the Services to work, such as authentication, security, load balancing, and remembering your cookie choices. These cannot be switched off in our systems.

• Functional: Remember your preferences and settings, such as language and accessibility options.

• Analytics and performance: We use our own in-house analytics tools to help us understand how the Services are used so we can improve them. We do not share this data with third-party advertisers. These run only where you consent.

4.3 Cookies We Set

The table below lists the main cookies and similar technologies in use.

4.4 Managing Your Choices

You can accept or reject non-essential cookies at any time through our privacy preference centre cookie banner link available in the footer of our website.

Most web browsers allow you to block or delete cookies through their native application settings, though strictly necessary cookies are required for the Talksign platform to function properly. On mobile, you can manage tracking and advertising identifiers directly through your device's operating system settings.

4.5 Third-Party Cookies

Some cookies are set by third parties we work with, such as analytics or infrastructure providers. Their use of data is governed by their own privacy and cookie policies. We list our key providers in our Privacy Policy and, and maintain transparency regarding their data integration.

4.6 Changes to This Policy

We may update this Cookie Policy from time to time as our underlying technologies or cookie utilisation changes. The “Last updated” date reflects the latest revision, and we will request renewed consent from users when material updates are deployed.

Effective July 1, 2026 · Last updated 16 June 2026

Acceptable Use Policy

Effective date: July 1,2026 | Last updated: 16 June 2026

This Acceptable Use Policy (the “AUP”) sets out the rules for using Talksign’s websites, applications, API, and services. It forms part of, and is incorporated into, our Terms of Service. By using the Services you agree to this AUP. Capitalized terms have the meaning given in the Terms of Service.

5.1 Purpose

Talksign exists to make communication accessible and inclusive. This AUP protects our users, the Deaf and hard-of-hearing communities we serve, our systems, and the integrity of our translations. We may update it as needed to address new risks.

5.2 Prohibited Content and Conduct

You must not use the Services to create, upload, share, or facilitate any of the following:

• unlawful, fraudulent, defamatory, harassing, hateful, or discriminatory content;

• content that sexualizes, endangers, or exploits children in any way;

• threats, incitement to violence, or content that promotes self-harm;

• another person’s likeness, voice, signing, or biometric data without their informed consent;

• deceptive or impersonating content, including misrepresenting an automated translation as a certified human interpretation where one is legally required;

• malware, spam, phishing, or content that infringes intellectual property or privacy rights.

5.3 Synthetic Avatars and Coincidental Likeness

To facilitate the use of our translation models, Talksign provides a library of default, pre-generated avatars (the “Default Avatars”). By using these Default Avatars, you acknowledge and agree to the following:

• AI-Generated Fictions: The Default Avatars are entirely synthetic and generated by artificial intelligence. They do not depict real, existing individuals.

• Coincidental Resemblance: Any visual resemblance between a Default Avatar and any actual person, living or deceased, is entirely accidental and purely coincidental.

• Strict Impersonation Ban: You are strictly prohibited from representing or passing off the Default Avatars as real people. You must not use these avatars to deceive third parties, create fraudulent endorsements, or suggest that a real individual is speaking or signing.

• No Exclusive Ownership: The Default Avatars remain the property of Talksign. You are granted a limited licence to use them within the platform, but you cannot claim exclusive intellectual property rights or right of publicity over any Default Avatar.

5.4 Respect for the Deaf Community

Because our Services represent and translate sign language, misuse can directly harm Deaf individuals and communities. You must not use the Services to mock, misrepresent, or produce deliberately false sign language content, or to present Talksign output as the verified statement of a real person without their consent.

5.5 Technical and Security Restrictions

• Do not attempt to reverse engineer, decompile, scrape, or extract our models, datasets, or source code, except where this restriction is prohibited by law.

• Do not probe, scan, or test the vulnerability of the Services, or breach security or authentication measures, without our prior written permission.

• Do not exceed or circumvent published rate limits, credit allowances, or quotas, or share API keys to evade limits.

• Do not use automated means to overload, disrupt, or degrade the Services.

5.6 Critical-Use Restriction

The Services are an aid to communication and are not certified for sole reliance in legal, medical, financial, safety-critical, or emergency settings where a qualified human interpreter is required. You must not deploy the Services as the sole communication method in such settings in a way that contravenes applicable law or this restriction. This mirrors section 2.4.

5.7 API and Developer Responsibilities

• If you build on the Talksign API, you are responsible for your application’s compliance with this AUP and for your end users’ conduct.

• You must present accurate information to your end users about Talksign’s role and the limits of automated translation.

• You must implement reasonable safeguards against abuse in your own application.

5.8 Reporting Abuse

To report content or conduct that violates this AUP, contact abuse@talksign.co. We review reports and may act on them, including removing content or suspending accounts.

5.9 Enforcement

Violations may result in content removal, feature or account suspension, API key revocation, or termination, with notice where reasonably practicable. Serious violations, including those that create legal exposure or risk to safety, may result in immediate action. We may report unlawful activity to the relevant authorities.

Effective July 1, 2026 · Last updated 16 June 2026

Data Processing Addendum

Effective date: July 1,2026 | Last updated: 16 June 2026

This Data Processing Addendum (“DPA”) supplements the Talksign Master Terms of Service or Enterprise Agreement (the “Agreement”) entered into by and between Talksign Ltd. ("Talksign", “Processor”) and the school, enterprise, or entity subscribing to the Services (“Customer”, “Controller”).

1. Definitions

• “Data Protection Laws” means all applicable privacy and data protection laws, including the UK GDPR, EU GDPR, US state privacy laws (e.g., CCPA), FERPA, and COPPA.
• “Personal Data” means any information relating to an identified or identifiable natural person processed by Talksign on behalf of the Customer.
• “Sub-processor” means any third party engaged by Talksign to process Personal Data.

2. Roles and Scope of Processing

• 2.1 Roles of the Parties: For the purposes of Data Protection Laws, the Customer is the Data Controller and Talksign is the Data Processor.
• 2.2 Instructions: Talksign will process Personal Data strictly in accordance with the Customer’s documented instructions as set forth in the Agreement and this DPA. Talksign will not process Personal Data for its own commercial purposes, nor will it sell, rent, or lease Personal Data.
• 2.3 AI Model Training Restriction: Talksign expressly agrees that it shall not use the Customer’s Personal Data (including audio, video, gestures, or biometric data) to train, retrain, or improve its foundational artificial intelligence models.

3. Customer Obligations and Consents (Minors & Healthcare)

• 3.1 Lawful Basis: The Customer warrants that it has a valid lawful basis to process the Personal Data and share it with Talksign.
• 3.2 Institutional Consent (Schools/Talksign Learn): Where the Customer is an educational institution processing data of minors (under 18), the Customer warrants that it has obtained all necessary parental or guardian consents required by COPPA, FERPA, the UK AADC, and applicable laws prior to allowing students to access the Services.
• 3.3 Biometric and Special Category Data: Where the Customer uses Talksign’s Services to process sign language, facial cues, or medical information, the Customer warrants it has obtained explicit consent from the Data Subject to process such biometric or health data.

4. Talksign’s Security and Processing Architecture

• 4.1 Security Measures: Talksign shall implement and maintain appropriate technical and organisational measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, or unauthorised disclosure.
• 4.2 Zero-Retention Translation (Transient Processing): For real time API translation and Talksign Learn communication features, Talksign processes audio, video, and gesture data ephemerally in the cloud. This data is deleted immediately upon the delivery of the text/audio translation and is never cached or stored on Talksign’s servers. Talksign only retains the resulting text transcripts and anonymised skeletal keypoint tracking data.
• 4.3 Confidentiality: Talksign ensures that its personnel authorised to process Personal Data are subject to strict obligations of confidentiality.

5. Sub-processors

• 5.1 Authorisation: The Customer provides general authorisation for Talksign to engage Sub-processors (such as Google Cloud Platform for hosting and infrastructure).
• 5.2 Notice of Changes: Talksign will maintain an up to date list of Sub-processors on its website. Talksign will notify the Customer of any intended changes to its Sub-processors, giving the Customer the opportunity to object.

6. Data Subject Rights

Talksign will provide reasonable assistance to the Customer in fulfilling the Customer's obligation to respond to Data Subject requests (such as requests for access, deletion, or correction), to the extent the Customer cannot resolve the request through the platform’s self-service tools.

7. Personal Data Breach

If Talksign becomes aware of a confirmed Personal Data Breach affecting the Customer’s data, Talksign will notify the Customer without undue delay (and in any event within 48 hours). Talksign will provide sufficient information to allow the Customer to meet its own regulatory reporting obligations.

8. International Data Transfers

If Talksign transfers Personal Data originating from the UK or the European Economic Area (EEA) to a country not recognised as providing an adequate level of protection, Talksign will ensure such transfers are governed by a valid transfer mechanism, such as the UK International Data Transfer Addendum or the EU Standard Contractual Clauses (SCCs).

9. Audit Rights

Upon the Customer’s written request, Talksign shall make available all information reasonably necessary to demonstrate compliance with this DPA. This audit requirement shall be primarily satisfied by Talksign providing the Customer with a copy of its most recent independent security audit report (e.g., SOC 2 Type II or ISO 27001 certification), subject to strict confidentiality obligations.

10. Deletion of Data

Upon termination or expiration of the Agreement, Talksign shall, at the Customer’s choice, delete or return all persistent Personal Data in its possession (such as user accounts or saved Creative Suite assets), unless applicable law strictly requires further storage.

Appendix A: Details of Processing

• Subject Matter and Duration: The processing of Personal Data to provide the Talksign Services, for the duration of the Agreement.
• Nature and Purpose: Transient processing of audio/video for AI sign language translation, and persistent storage of account/educational data to operate the Talksign platform.
• Categories of Data Subjects: Customer’s end-users, which may include employees, patients, or students.
• Types of Personal Data: Identification data (name, email), system usage data, and (transiently) biometric adjacent data such as audio, video, facial cues, and physical gestures required for translation. Persistent biometric data (specifically, student video submissions securely stored solely for Talksign Learn certification exams).

Effective July 1, 2026 · Last updated 22 June 2026

Web Accessibility Statement

Effective date: July 1,2026 | Last updated: 22 June 2026

Our Commitment to Inclusion

At Talksign, our core mission is to bridge communication gaps through real-time sign language translation. Because our work touches healthcare, education, and daily communication, we believe that digital inclusion is a fundamental human right, not an optional feature.

We are fully committed to ensuring that our websites, applications, and digital platforms are accessible to everyone, including individuals with visual, auditory, motor, and cognitive disabilities.

We strive to create a digital environment that embodies our guiding principle: built with, not for, the Deaf and disabled communities.

Conformance Status

The Web Content Accessibility Guidelines (WCAG) define requirements for designers and developers to improve accessibility for people with disabilities. It defines three levels of conformance: Level A, Level AA, and Level AAA.

Talksign is committed to achieving and maintaining conformance with WCAG 2.2 Level AA standards across our primary digital properties, including our web dashboard and Talksign Learn interfaces.

Measures to Support Accessibility

To ensure our platform remains accessible, Talksign takes the following internal measures:

• Accessibility by Design: We integrate accessibility checks directly into our software development lifecycle and procurement practices.
• Community Testing: We actively involve Deaf, hard of hearing, and neurodivergent users in the usability testing of our products.
• Continuous Auditing: We conduct regular internal accessibility reviews and periodic audits using both automated tools and manual screen reader testing.
• Clear Media Alternatives: Because our platform processes visual sign language, we prioritise clear, customisable text transcripts and visual indicators across our user interfaces.

Compatibility with Browsers and Assistive Technology

Talksign’s web platform is designed to be compatible with standard assistive technologies, including:

• Modern screen readers (e.g., NVDA, JAWS, VoiceOver, and TalkBack).
• Standard operating system accessibility features (e.g., high contrast modes, magnification tools).
• Major modern web browsers (Chrome, Firefox, Safari, Edge) on Windows, macOS, iOS, and Android.

Technical Specifications

The accessibility of Talksign relies on the following technologies to work with the particular combination of web browser and any assistive technologies or plugins installed on your computer:

• HTML
• WAI-ARIA
• CSS
• JavaScript

These technologies are relied upon for conformance with the accessibility standards used.

Known Limitations

Despite our best efforts to ensure the accessibility of Talksign, there may be some limitations as we continuously update our platform.

• User Generated Content: While our core interfaces are rigorously tested for accessibility, content uploaded or created by third party users in the Creative Suite or the Talksign Marketplace (such as raw video datasets or custom unedited captions) may not fully meet strict WCAG standards.

Feedback and Reporting Barriers

We welcome your feedback. If you encounter any accessibility barriers on our website, applications, or API documentation, please let us know so we can fix it.

• Email: support@talksign.co (Please include “Accessibility Barrier” in the subject line)
• Response Time: We aim to respond to accessibility feedback within two (2) business days and will work closely with you to propose a suitable workaround or permanent fix.
• Enforcement Procedure: If you are based in the UK and remain dissatisfied with our response to your accessibility complaint, you can contact the Equality Advisory and Support Service (EASS) for further guidance.

Legal Compliance

This statement affirms our ongoing commitment to fulfilling our obligations under the UK Equality Act 2010, the European Accessibility Act (EAA), and the Americans with Disabilities Act (ADA) regarding digital public accommodations.