Privacy Policy Talksome B.V.

1. Responsibility and Scope

This privacy statement applies to the data processing of Talksome B.V., located at: Security Delta (HSD), Wilhelmina van Pruisenweg 104, The Hague. It applies to all users of Talksome services and products and to all visitors of our website.

2. Personal data we process

We process your personal data because you use our services, visit our website and/or because you provide this data to us yourself. Depending on the services you use or your activities on our website, different personal data is processed. In this privacy statement we explain which data is processed in which situation. We make a distinction between the following types of data:

2.1 Contact details

This is data which is used to identify or contact any (natural) person. This information consists of name, address, telephone number, e-mail address, the name of the company or organization you work for, usernames and passwords, and other (contact) details that we obtain directly from you.

2.2 Usage data

When using our services, all kinds of technical data are processed about how it is used. This is the data needed to set up connections and related technical data. Examples of this type of data are your own telephone number and the telephone number of the person you are calling, the date, time, and duration of a connection. Also the number of users per partner are monitored monthly.

2.3 Content data

One of our core activities is to transport the content of communications that take place through our services. This processing is limited to the automated processing by our infrastructure. We will not listen to, view, or share the content of your communication with others (unless we are required to do so, for example if a tap is placed in connection with a criminal investigation).

3. When is personal data processed?

3.1 When you contact Talksome

If you contact us, we will process certain data about you. Those are contact details. This can happen if you want to become a partner, if you contact us with a question, to receive support or to report a malfunction. In these cases, data is processed in a support and / or relationship management system. Your question and your contact details are recorded to be able to answer them or to propose the right solution.

3.2 When you make use of our Services

3.2.1 Compass Core platform, API and Compass Web Interface

If you use Compass (our Cloud PBX), content data is primarily processed. After all, the communication takes place via Compass.

Compass also offers several functionalities, such as being able to make dial plans and manage voicemail boxes. Related to this, contact and usage data is processed, for example to link a user to a telephone number and voicemail box. Compass also processes usage data. We register your IP address, your number, the number of the person you are calling, the date and time and the duration of the call.

3.2.2 Compass Apps: Navigator, Bridge, Wall Display

Our apps always work together with the core platform described in the previous paragraph. No extra logging or usage data is being collected when using these apps. When using Bridge via the webinterface Matomo is used (see 3.3. When you visit our Website)

3.2.3 Compass Demo account

If you create a Compass Demo account the same data is collected as mentioned in paragraph 3.2.1 and 3.2.2. The data retention periods are the same as stated in paragraph 7.

3.2.4 Calling

When you make or receive calls the content of the communication is transferred via our network and therefore processed by our infrastructure. Compass does not however have a SIP trunk of its own and always work in conjunction with a certified SIP trunk of a third party. Please refer to the Privacy Statement of your SIP trunk provider for more information.

3.2.5 Release Notes, Service Disruptions and Newsletter

We use Mailchimp to send out release notes about impact and new features of new Compass Releases, Service Disruptions and PIR’s (Post Incident Reports) and Newsletters to our Partners and other interested Organisations. We only send these to the relevant Contact Persons that should be informed. During this process we use the contact details to register the opening and click-through rate. There is always an opt-out link if you think these mailings do not apply to you.

3.3. When you visit our Website

To keep track of usage statistics on our website, we use the open-source software Matomo. With this we place two analytical (first party) cookies:

  • _pk_id: Generates a unique number to distinguish a visitor from other visitors. Retention period: 14 days after your last visit to our site.
  • _pk_ref: registers the site from which a visitor comes to our site. Retention period: 30 minutes after your last visit to our site.

We have taken the following privacy protection measures:

  1. We mask the last five hextets of the IPv6 addresses and the last two octets of the IPv4 addresses we collect from visitors (for example, 2001:db8:7bb:: or
  2. We store the collected data on our own servers that we manage ourselves and which are located in the Netherlands.
  3. The visitor logs (with the data below) are not kept for longer than 32 days.
  4. Cookies or other trackers from third parties will never be loaded via our website(s).
  5. We respect Do Not Track headers, in fact we encourage their use and cookie blockers.

With the help of Matomo and these analytical cookies we collect the following data:

  • The unique number associated with the cookie _pk_id (see above).
  • IP address (masked).
  • Pages visited (title and URL) and date and time they were visited.
  • The URL of the page that led to our website (Referrer URL).
  • Links used on our website that refer to external websites (Outlink).
  • Downloaded files.
  • Approximate location: country, region, city (we do not collect the exact geolocation).
  • Other data: screen resolution, visitor's local time, website speed, browser language.
  • Browser user agent: browser used, operating system, type of device (computer, smartphone, etc.).

We process this data to the extent necessary to analyze the use and functioning of our website(s). Due to the privacy-protective measures we take, the impact on your privacy is limited and we do not ask for your permission separately.

4. What do we process data for?

A legal basis is required for lawful processing of personal data. The foundations on which we rely are:

• Permission • Legitimate interest • Necessary for the execution of the agreement

A more specific elaboration can be found below.

4.1 Delivery of Products and Services

We process personal data in order to provide our services. The processing of personal data is necessary for establishing connections, carrying out administrative processes such as invoicing and handling questions.

4.2 Service Improvement

We always try to improve our services. Your data can be used for this, for example to make statistical analyzes of network use based on usage data from all our users. We use the information we obtain from these analyzes to assess and adjust our products, services and processes on the basis of new developments.

4.3 Network Management and Security

We are responsible for our part of the telephony network over which telephone and internet traffic takes place. This means that we maintain, improve and manage this part of the network. We route communication traffic, resolve disruptions, monitor the load and, if necessary, adapt the network with new technologies. To properly perform these tasks, it is necessary to analyze network usage. Usage data is processed for these technical and statistical analyses. The results of these analyzes are anonymized and cannot be traced back to individual persons. For the security of the connections use different techniques for protection against security breaches. Connections are scanned to protect your connection and our network against security breaches or fraud.

4.4 Marketing and Sales Activities

Personal data is also processed by us to inform Partners and other interested entities. If you have given permission for this, we can, for example, inform you by e-mail about new services, products or promotions. We use the data about viewing and clicking behavior on our website that we process to measure the effectiveness of the website or certain marketing campaigns. See 3.3 and 3.4 for more details. If you have requested or created a Compass demo account, your phone number and/or email address can be used to contact you.

5. Who do we share data with?

5.1 Suppliers

We use suppliers to provide our services. Some of these suppliers require usage data in order to properly provide their service to us. To the extent necessary, suppliers in such cases have access to your usage data when performing their services. We have taken the necessary contractual and organizational measures with our suppliers to ensure that your data is only processed for the above purposes.

5.2 Partners and Resellers who purchase our services for resale

We sell our products and services through Partners. For this we share contact details and usage data with these partners. If you use such a service from a third party, we will process the above-mentioned data. In those cases, we only process this data to enable your provider to provide its service.

5.3 Competent Authorities

In certain cases, we are legally obliged to share data with third parties. In such cases, we may disclose this information to third parties without your knowledge, without your consent and without notifying you. Furthermore, under the Telecommunications Act, we are obliged to make the contact details of our customers available for the purpose of criminal investigations.

5.4 Emergency call forwarding

When calling the emergency number 112, your telephone number is always sent, even if you have blocked the caller ID or if you have chosen a 'secret number'. We are legally obliged to send your telephone number. The emergency center also has the contact details associated with the number.

6. How do we secure the data?

We take the protection of your data seriously and have taken appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. These measures consist of all kinds of technical and organizational solutions that depend on the services or products. These solutions can include password protection, encryption, firewalls, antivirus, intrusion detection and access controls for our employees.

All Talksome employees are actively involved in ensuring and enhancing the level of information security across all Talksome work processes. Talksome uses an access list for being able to access certain data. Not everyone can see everything and that is strictly controlled. If you feel that your data is not properly secured or there are indications of misuse, please contact our customer service or via

7. How long do we keep data?

We do not store your data for longer than is legally permitted and necessary for the purposes for which we use your data. How long certain data is kept depends on the nature of the data and what we process it for. The retention period can therefore differ per purpose.

If you have a contract with us for the provision of services, your contact details will in any case be kept during the term of your subscription.

Type of Data Duration
Amount of companies / users in Compass (monthly check) Duration of the contract (with Partner)
Call recordings None. (they are directly sent by email)
Voicemails 90 days
CDR’s (Call Detail Records) 90 days

8. What are your rights?

You have the right to view, correct or delete your personal data. Partners can alter their information with us, End Users via our Partners. In addition, you have the right to withdraw your consent to the data processing or to object to the processing of your personal data by us and you have the right to data portability. This means that you can submit a request to us to send the personal data we have about you in a computer file to you or another organization mentioned by you.

You can send a request for access, correction, deletion, data transfer of your personal data or request for withdrawal of your consent or objection to the processing of your personal data to To ensure that the request comes from you, we may ask you to provide further information that allows us to identify you.

9. Questions and Contact

If you have any comments or questions about this privacy statement, please contact us. You can call our Service Desk: +31 88 555 2111. You can also send an email to

Requests regarding the exercise of your rights, such as access, correction, or deletion, can be submitted to us by normal mail:

Talksome B.V.
HSD, Wilhelmina van Pruisenweg 104
2595 AN The Hague
The Netherlands