At Telefonco, we recognize that privacy is important. We respect your privacy and believe that we should clearly and transparently disclose our privacy practices to you as the user. The Telefonco application, software, design, servers, data, user input, content, website located at www.Telefonco.com (“Website”), and associated services (collectively “Services” or “App”) are owned and operated by Telefonco OU.
1 : COLLECTION OF INFORMATION
1.1 : The Telefonco App allows you to input information about you directly into the App and collects certain information programmatically when you register for our Services, when you install and use the App on your device, and when you use the Services as described in more detail below. Such information may contain personal or personally identifiable information.
1.2 : Personally Identifiable Information (“PII”) is information that can be used to uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single individual. Telefonco collects PII from you when you voluntarily provide it to us, in instances in which you must provide such information to use features of the Services, programmatically when you install the App, and when you visit websites of our partners. Telefonco may collect this PII from you through various channels, including through your voluntary submission of information to the Services, through requests initiated by you through the Services, and through communication with third-parties.
1.3 : We do not collect sensitive personal information (also known as special categories) such as healthcare information, sexual orientation, political views, racial or linguistic data through the Website or the Services, unless required by the provisions of any applicable laws, rules, regulations, or norms.
1.4 : The PII that Telefonco may collect from you is as follows:
A : Information that you voluntarily submit/input to the Services
We collect and store any information that you knowingly provide to us. This includes: (a) your name; (b) your email address(es); (c) mobile or other phone numbers; and (d) your preferences. When you install the App, you’ll also be asked to allow us access to your mobile device’s address book, call logs and location data to enable us to provide you our Services If you use our customer support service or interact with us via email or any other medium, we may keep a record of that interaction, including copies of your emails and your email address.
Whenever you utilize the Services, there is certain information that is collected and recorded automatically, such as usage data and other information automatically collected from your browser or mobile device This includes: (a) your mobile device information, including, without limitation, device type, ID, model number, operating system, application, and related information; (b) your MAC and/or IP address (c) global positioning and geolocation data; (d) details of the specific page or feature you requested; (e) default language and user preferences; and (f) length of time of visit and the number of times the user may use the Services; (g) details of the calls made on Telefonco and (g) Log files, diagnostics, performance logs and reports. We may assign each user one or more unique identifiers to help keep track of future visits.
Telefonco uses Google Play Billing to process payments. Therefore Telefonco does not store any payment related information such as credit/debit card details and/or bank details.
Telefonco works with third party service providers that help us operate, provide, improve, understand, customise, support and market our Services. We may combine information about you that we have with information we obtain from other sources to provide you a better experience or to improve the quality of our Services. Examples of information we may receive from other sources includes location information which we use for marketing purposes, customer support or enrolment information, page view, and identity information which we may use to detect fraud. Please note that we use Google Analytics Solutions for the purpose of analytics and measurement, so as to get a better idea of how our Services are used. For example, we may use the data gathered from your usage of the Platform by Google Analytics Solutions to design new products or services, or to make our existing offerings under the Services more user friendly.
2 : USE OF INFORMATION
2.1 : Telefonco uses your PII and other information to provide you with and bill you for the Services, to communicate with you, to identify and fix problems with the Services, to update you on changes to the Services, to communicate with you concerning your account, if applicable, and to update you on Telefonco’s services offered through the Services or the services of third-parties. We use this information to make the Services easier for you to use, for example, by eliminating the need for you to repeatedly enter the same information. We also use this information for auditing, research and analysis purposes so that we are able to maintain, protect, and improve the Services and ensure the technical functioning of our network.
2.2 : You authorize Telefonco to use the information collected from you for the following uses:
A : Enable your use of the Services;
B : Process payment and verify payment information;
C : Improve algorithms;
D : Measure service usage;
E : Publish summaries online or offline;
F : Develop new features and services;
G : Contact and communicate with you, whether through email, phone, push notifications or messages within the Services;
H : Customize and/or tailor the Services and your user experience, which may include targeted selection and display of third-party advertisements within the Services (i.e. behavioural advertising);
I : Display limited profile information to other users, including your name, email address and phone number and to display any other content you post to the Services which is meant for public consumption;
J : Advertise and provide you with information about products, benefits, and services of Telefonco;
K : Provide you with information or services that may be of interest to you;
L : Transmit and process your information and actions within the Services;
M : Provide statistical information, and include you in the same, where applicable;
N : Provide you with technical service and support, including updates;
O : Understand your needs and requests;
P : Communicate promotions or other offers;
R : Protect Telefonco’s rights and property, including intellectual property, and the same of our users;
S : Combine your PII with information from other Telefonco applications and/or services;
T : Promote mobile applications Telefonco develops for other related apps;
U : Facilitate your use of the Services, its upgrades, or its replacements;
V : Provide the information to third-parties performing services in support of our delivery of Services to you;
W : Personalize your experience with our Services;
X : Respond to legal requirements, exercise our legal rights or defend against legal claims, to protect our interests, fight fraud or illegal activity, to enforce our policies, or to protect third-party rights, property, or safety.
2.3 : Telefonco does not process data through any means of automated decision making, including profiling, that may have significant consequences for you.
3 : LEGAL BASIS FOR PROCESSING INFORMATION UNDER THE GDPR FOR USERS IN THE EUROPEAN UNION (“EU”)
3.1 : Telefonco processes information of users in the European Union in accordance with European laws and regulations such as the General Data Protection Regulation (“GDPR”). The GDPR governs how Telefonco may process your information, and the rights that EU users have in relation to their information. This means that Telefonco will collect and use your information only where:
B : The collection and use of your information is justified because of a legitimate interest such as for research and development or marketing the Services (but only where our legitimate interest isn’t overridden by your interest in protecting your information);
D : The collection and use of your information is necessary for compliance with our legal obligations;
3.2 : You may withdraw your consent for using your information at any time. Depending on the situation you can either withdraw your consent by writing to firstname.lastname@example.org. Where we are using your information because of a legitimate interest to do so, you have the right to object to that use. However, if you do so, you may not be able to continue using the functionalities of the Website and/or the Services.
4 : STORAGE OF INFORMATION
4.1 : Telefonco’s infrastructure consists of servers deployed at multiple data centers that are owned and operated by third party companies or us. (by third party/vendor)All information collected in connection with the Services resides on this network of servers and/or on your device. Much of your information is stored on your device and is subject to the security and privacy policies of your device and storage providers. If Telefonco is using a vendor, all data storage by the vendor is consistent with the vendor’s policies.
4.2 : If you are a user outside the EU, all data storage by Telefonco of your PII or other information may be stored and processed on computers located outside of your country, and through your use of the Services you unequivocally consent to the processing and storage of your information outside of your own jurisdiction. You understand and agree that Telefonco may continue to store your information after you cease use of the Services or disable your use of, access to, or otherwise of the App.
4.3 : In the event that we transfer information of users in the EU to a third-party service provider located outside the EU and/or is not subject to an adequacy decision by the EU commission, we will ensure that we obtain your prior consent for such transfer and ensure that such third- party service providers have appropriate safeguards for your information by way of entering into a binding agreement that provides for the same.
4.4 : In order to improve usability and experience, Telefonco may store your private information on your personal device for subsequent retrieval. Telefonco takes commercially reasonable care to encrypt this information on your device with passwords or other secrets supplied by you. Such information stored on your personal device is subject to security offered by your device, operating systems and other components. You understand and agree that Telefonco cannot be held responsible for any compromise of access to your personal device, for loss of information, theft or for any exploits or logic attacks on your device through malware or other software or hardware that is outside the control of Telefonco’s Services.
4.6 : Though we undertake commercially reasonable efforts to protect your personal and personally identifiable information, no software or service is completely safe. Accordingly, you provide all such personal or personally identifiable information at your own risk.
5 : SHARING INFORMATION
5.1 : Telefonco may share your information with third-parties in the following circumstances:
A : where Telefonco has obtained your consent, including when you choose to register a user account, use the Services, and otherwise share your information with Telefonco, other users and/or other third-parties;
B : where sharing or disclosure of your personal or personally identifiable information is necessary to provide you with the Services;
D : where Telefonco has been purchased by a third-party; where sharing or disclosure of your personal or personally identifiable information is necessary to respond to requests by government authorities; where your personal or personally identifiable information is demanded by a court order or subpoena; where sharing or disclosure of your personal or personally identifiable information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of Telefonco; where sharing or disclosure of your personal or personally identifiable information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty; and
5.2 : The following categories of recipients will most likely receive your data in order for us to provide services to you.
A : Google Firebase
B : Google Play
C : Telinta, Inc.
E : Google Fabric.io
5.7 : We may occasionally ask you information on your feedback on using the App or other parts of the Services, that we shall use to improve the quality of the Services. You are under no obligation to provide any such information.
5.8 : We will never sell your PII to unaffiliated third-parties without your approval at the time of collection. You agree to inform us of any changes to your PII, and to protect the security of your username, password and PII.
5.9 : We have a strict No-Spam Policy prohibiting the use of any data collected to send spam communications. We will not sell any contact information to third-parties.
6 : INFORMATION RETENTION
6.1 : If you are a user from non-EU countries, on receiving a request to deactivate your account, Telefonco will deactivate your account and archive your PII. Archived information will be retained by Telefonco indefinitely in its secure database for the purpose of our records. Non-personally identifiable information of users from non-EU countries is retained indefinitely for analytics. However, your sensitive personal information, collected by us, if any, will be destroyed upon deactivation of your account.
6.2 : If you are a User in the EU, on receiving a request to deactivate your account, Telefonco will deactivate your account and all PII and Sensitive Personal Information, collected by us, if any, will be destroyed. Non-personally identifiable information of users in the EU may be retained indefinitely for analytics subject to the same being kept separate from other information including but not limited to unique identifiers, that, in combination with such non-personally identifiable information of the users, may render the same personally identifiable.
6.3 : We collect and retain certain data that is required for our detection, investigation and prevention of fraud, cheating and other violations of our terms and applicable laws ("Breach(es)"). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on such Breaches and stored only for the minimum amount of time needed for the purpose of dealing with such Breaches. If the data indicates that such a Breach has occurred, we will further store the data for the establishment, exercise or defence of legal claims, until a legal case related to it has been resolved, or such legal claim no longer exists due to the expiry of relevant limitation periods. Please note that the specific data stored for dealing with Breaches may not be disclosed to you if such disclosure will compromise Telefonco’s legal rights as well as the mechanism through which we detect, investigate and prevent such Breaches.
7 : YOUR RIGHTS IN RESPECT OF YOUR INFORMATION
7.1 : The laws of some countries grant particular rights in respect of personal information. If you are a user situated in the European Union, you may have the right to:
A : Request a copy of your information and data portability- This right entitles users to know whether we hold any PII about them and, if we do, to obtain information on and a copy of such PII(in a structured, commonly used and machine-readable format).
B : Request that we correct inaccuracies relating to your information- This right entitles users to have PII be corrected if it is inaccurate or incomplete;
C : Request that your information is deleted - This right entitles users to request the erasure of PII, including where such PII would no longer be necessary to achieve the purposes;
D : Request the restriction of the processing of PII: This right entitles users to request that we only process PII in limited circumstances, including with consent;
E : Object to our use of your information- This right entitles users to request that we no longer process their PII;
7.2 : Should you wish to make a request in respect of your personal information, please contact us at email@example.com.
7.3 : If, at any time, you prefer not to receive communications from us, simply follow the unsubscribe options at the bottom of each such communication or contact us directly. We will make commercially reasonable efforts to implement your opt-out requests promptly, but you may still receive our emails for up to ten (10) business days as we process your request.
7.4 : In some circumstances, we may not be able to comply with a request that you make in respect of your personal information. For example, we may not be able to provide a copy of your information where it infringes on the rights of another user. We may also be required to retain certain information that you ask us to delete for various reasons, such as where there is a legal requirement to do so.
7.5 : If we are unable to resolve your request, or if you are concerned about a potential violation, you may be entitled to report the issue or make a complaint to the data protection authority in your jurisdiction.
8 : CHILDREN'S ONLINE PRIVACY PROTECTION POLICY
The Services are not intended for or directed to users under the age of thirteen (13), and Telefonco does not knowingly or intentionally collect personally identifiable information from children under the age of thirteen (13) or other minors. Where appropriate, Telefonco takes reasonable measures to determine that users are adults of legal age and to inform minors not to submit such information to the Services or in response to advertisements. If you are concerned that personal information may have been inadvertently provided to or collected by Telefonco, please contact us immediately so appropriate steps may be taken to remove such information from our database.
10 : CONTACT AND NOTICES
We fully cooperate with police and lawyers. However, to protect our users, all requests for personal information must be accompanied with:
1 : A Subpoena
2 : Phone Number
3 : Approx Time Called
We encourage all users to act responsibly and considerately. In the occassion that a user does violate a law, we are fully open and compliant with local and national authorities. Please contact us by email at firstname.lastname@example.org with the request for information.
The legal department will only respond to attorneys or law enforcement.