OnTopic Privacy Policy

1. Introduction

This Privacy Policy sets out how we, OnTopic LLC. (“OnTopic”), use and protect your personal data that you provide to us, or that is otherwise obtained or generated by us, in connection with your use of our cloud-based messaging services (the “Services”). For the purposes of this Privacy Policy, ‘we’, ‘us’ and ‘our’ refers to OnTopic, and ‘you’ refers to you, the user of the Services.

1.1. Terms of Service

This Privacy Policy forms part of our Terms of Service, which describes the terms under which you use our Services and which are available here. This Privacy Policy should therefore be read in conjunction with those terms.

1.2. EEA Representative

If you live in a country in the European Economic Area (EEA), the Services are provided by OnTopic, which for the purposes of applicable data protection legislation is the data controller responsible for your personal data when you use our Services. You can forward GDPR related inquiries to support@OnTopic-app.com

2. Legal Ground for Processing Your Personal Data

We process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (1) providing effective and innovative Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.

3. What Personal Data We Use

3.1. Basic Account Data

OnTopic is a communication service. You provide basic account data (which may include profile name, profile picture and about information) to create a OnTopic account.

To make it easier for your contacts and other people to reach you and recognize who you are, the display name you choose, your profile pictures, and your username on OnTopic are always public. We do not require your display name to be your real name.

3.2. Your Email Address

In order to facilitate account recovery and login flows, we ask for an email address at sign up. This address will only be used to send you a login code. Your email address will not be used for marketing purposes or shared with third parties without your prior consent.

3.3. Your Messages

OnTopic uses end-to-end encryption to protect the privacy of its users. This means that all messages, question answers, and media within a OnTopic are encrypted with a key that only you and the other members of the group know. There is no way for us or anybody else without direct access to a group member’s device or to learn what content is being sent in those messages. End to end encryption does not apply to every aspect of a OnTopic. Only messages, media (including images and video), and question answers are end to end encrypted. Some elements that are not end to end encrypted include:

• Your profile picture
• “Reactions” sent to messages or question answers
• The text of questions being asked within the group chat
• The log of who is sending messages and uploading media

When you send photos, videos or files via OnTopic, before being uploaded, each item is encrypted with the group's encryption key, not known to the server. Your recipients can then download and decipher the file. This means that the file is technically on one of OnTopic’s servers, but it is impossible to read or view to everyone except for you and the members of the group chat. We may periodically purge this random data from our servers to save disk space.

3.4. Cookies

The only cookies we use are those to operate and provide our Services on the web. We do not use cookies for profiling or advertising. The cookies we use are small text files that allow us to provide and customize our Services, and in doing so provide you with an enhanced user experience. Your browser should allow you to control these cookies, including whether or not to accept them and how to remove them.

4. Keeping Your Personal Data Safe

4.1. Storing Data

If you signed up for OnTopic from the UK or the EEA, your data is stored in data centers in the Netherlands. These are third-party provided data centers in which OnTopic rents a designated space. However, the servers and networks that sit inside these data centers and on which your personal data is stored are owned by OnTopic. As such, we do not share your personal data with such data centers. All data is stored heavily encrypted so that local OnTopic engineers or physical intruders cannot get access.

4.2. End-to-End Encrypted Data

Your messages, media and files from secret chats are processed only on your device and on the device of your recipients. Before this data reaches our servers, it is encrypted with a key known only to you and the recipient. While OnTopic servers will handle this end-to-end encrypted data to deliver it to the recipient we have no ways of deciphering the actual information. In this case, we neither store nor process your personal data, rather we store and process random sequences of symbols that have no meaning without the keys which we don’t have.

4.3. Retention

Unless stated otherwise in this Privacy Policy, the personal data that you provide us will only be stored for as long as it is necessary for us to fulfill our obligations in respect of the provision of the Services.

5. Processing Your Personal Data

5.1. Our Services

OnTopic is a cloud service. We will process your data to deliver your cloud chat history, including messages, media and files, to any devices of your choosing without a need for you to use third-party backups or cloud storage.

5.2. Safety and Security

To improve the security of your account, as well as to prevent spam, abuse, and other violations of our Terms of Service, we may collect metadata such as your IP address, devices and OnTopic apps you've used, history of username changes, etc.

5.3. Spam and Abuse

To prevent phishing, spam and other kinds of abuse and violations of OnTopic’s Terms of Service, our moderators may check messages that were reported to them by their recipients. If a spam report on a message you sent is confirmed by our moderators, your account may be limited from using the service – temporarily or permanently. You can send an appeal by emailing spam@OnTopic.app. We may also use automated algorithms to analyze messages in cloud chats to stop spam and phishing.

6. Who Your Personal Data May Be Shared With

6.1. Other OnTopic Users

Other users of our Services with whom you choose to communicate with and share certain information, who may be located outside the EEA. Note that by entering into the Terms of Service and choosing to communicate with such other users of OnTopic, you are instructing us to transfer your personal data, on your behalf, to those users in accordance with this Privacy Policy. We employ all appropriate technical and organizational measures (including encryption of your personal data) to ensure a level of security for your personal data that is appropriate to the risk.

6.2. Law Enforcement Authorities

If OnTopic receives a court order that compels us to release your metadata and usage information we will comply. So far, this has never happened.

7. Your Rights Regarding the Personal Data You Provide to Us

7.1. Your Rights

Under applicable data protection legislation, in certain circumstances, you have rights concerning your personal data. You have a right to: (1) request a copy of all your personal data that we store and to transmit that copy to another data controller; (2) delete (see section 10 below) or amend your personal data; (3) restrict, or object to, the processing of your personal data; (4) correct any inaccurate or incomplete personal data we hold on you; and (5)lodge a complaint with national data protection authorities regarding our processing of your personal data.

7.2. Exercising Your Rights

If you wish to exercise any of these rights, email support@OnTopic.app.

8. Deleting data

If you would like to delete your account, see https://www.ontopic.app/delete-account.

9. Child Safety: Abuse and Exploitation Prevention Policy

OnTopic is committed to creating a safe platform and strictly adheres to policies that prevent abuse, exploitation, and harm. While our app does not allow children under the age of 18, we take further measures to ensure compliance with child safety requirements and Google Play’s policies. Below are the key elements of our approach:

9.1 Age Restriction

OnTopic is age-gated on the Google Play Store, making it inaccessible to users under 18 during app installation. Our Terms of Use explicitly prohibit minors from using the app. Users agree to these terms during account creation. If we become aware that a user is under the age of 18, we will promptly suspend their account and delete any associated data in accordance with our privacy policy.

9.2. Content Moderation and Encryption

All content shared within OnTopic is end-to-end encrypted to prioritize user privacy. As a result, OnTopic does not have access to user-generated messages or media for moderation purposes.To address inappropriate behavior or abuse, we rely on user reports to identify violations of our policies. Users can report inappropriate groups directly via the group’s settings page, and such reports are reviewed promptly by our moderation team.

9.3. Reporting Mechanism

Users can report content, groups, or behavior they believe violates our policies. Reporting options are accessible within the app to ensure ease of use.Reports concerning child abuse or exploitation are prioritized and escalated as necessary to appropriate law enforcement authorities, in compliance with applicable laws.

9.4. Moderation of Public Topics

OnTopic allows users to submit conversation starters or topics to a public topic database. All submissions undergo a rigorous moderation process to ensure compliance with our child safety policies before being made publicly available. Content promoting or facilitating child exploitation, abuse, or harm is strictly prohibited and will not be approved for publication.

9.5. Cooperation with Authorities

In cases where child exploitation or abuse is reported or suspected, OnTopic cooperates fully with law enforcement agencies by providing relevant data in compliance with applicable laws and our privacy policy.

9.6. Policy Updates and User Education

We regularly update our policies and practices to align with child safety laws and evolving industry standards. Users are encouraged to familiarize themselves with our Terms of Use and Privacy Policy to understand their responsibilities and the protections in place.

By implementing these measures, OnTopic ensures compliance with child safety requirements while respecting user privacy through end-to-end encryption.

If you have questions or need to report any issues related to child safety, please contact us at support@ontopic.app.

10. Changes to this Privacy Policy

We will review and may update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on this page https://www.ontopic.app/privacy. Please check our website frequently to see any updates or changes to our Privacy Policy, a summary of which we will set out below.