In order to use the App, we will ask you to enter your telephone number and to provide access to your contacts, incoming and outcoming call numbers. We also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID , Facebook ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the app, to serve ads.
For improving the app and serving ads, we may share this data with third parties. Such parties include Facebook, Apple, Appsflyer, Amplitude, Firebase. As a result of sharing this data with third parties we (1) analyze different interactions (e.g. how often users make subscriptions, what calls do users record more often – incoming or outcoming); (2) serve ads (and show them only to a particular group of users, for example, to subscribers).
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European Union and the European Economic Area.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
TABLE OF CONTENTS
- PERSONAL DATA CONTROLLER
- CATEGORIES OF PERSONAL DATA WE COLLECT
- FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
- UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
- WITH WHOM WE SHARE YOUR PERSONAL DATA
- HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
- AGE LIMITATION
- INTERNATIONAL DATA TRANSFERS
- CALIFORNIA PRIVACY RIGHTS
- DATA RETENTION
- HOW “DO NOT TRACK” REQUESTS ARE HANDLED
- CONTACT US
PERSONAL DATA CONTROLLER
VPN MobApps Limited, a company registered in Malta (with mailing address at Regus, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta), will be the controller of your personal data.
CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, phone number). We also collect data automatically (for example, your IP address).
Data you give us
We may ask you to provide information about yourself when you register for and/or use the Service. This information includes: your telephone number, access to your contacts, incoming and outcoming call numbers, call recordings.
We are applying all security measures necessary to ensure that your call recordings will be kept safe, in particular, HTTP basic auth enforced with access media using AccountSid and Authentication token.
Sometimes you may also need to provide us with an email address and some other information during the communication with our Support Team in order to fulfill your request.
Data we collect automatically:
Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
Device and Location data.
We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
We record how you interact with our Service. For example, we log with what features, and content you interact, how often you use the App, how long you are in the App, what sections you use, and your subscription orders.
We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
- Data about how you found us
- Data you give us
FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
To host personal data and enable our App to operate and be distributed we use Amazon Web Services, which is hosting and backend service.
To customize your experience
We process your personal data to adjust the content of the Service and make offers tailored to your personal preferences.
To manage your account and provide you with customer support
To communicate with you regarding your use of our Service
We communicate with you by push notifications. These may include information on special offers or other information about the App. As a result, you may, for example, receive a push notification offering you to check our new feature. To opt out of receiving push notifications, you need to change the settings on your device.
The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our App’s users, as well as when they interacted with it, such as by clicking on links included in the message.
To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the App and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of the App our users like more, what categories of users use our App. As a consequence, we often decide how to improve the App based on the results obtained from this processing. For example, if we discover that users more frequently record incoming calls, we may focus on improving functionality of such call recordings.
To send you marketing communications
We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as for example, special offers. We may show you advertisements in our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device as described in section 3.4. above.
To personalize our ads
We and our partners, such as Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products, for example, in your Facebook’s feed.
How to opt out or influence personalized advertising
iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.
Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).
To learn even more about how to affect advertising choices on various devices, please look at the information available here.
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
- Network Advertising Initiative – http://optout.networkadvertising.org/
- Digital Advertising Alliance – http://optout.aboutads.info/
- Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
- Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
- DAA AppChoices page – http://www.aboutads.info/appchoices
We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the App (for example, installed it). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.
Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our App (for example, show our ads to users who have purchased a subscription). Some other examples of events that may be used for tailoring ads include, in particular, installing our App, finishing a free trial. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
- To provide our Service
UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose please refer to Section 2. This section applies only to EEA-based users.
We process your personal data under the following legal bases:
- your consent;
to perform our contract with you;
Under this legal basis we:
- Provide our Service (in accordance with our Terms and Conditions of Use)
- Customize your experience
- Manage your account and provide you with customer support
- Communicate with you regarding your use of our Service
for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
- to communicate with you regarding your use of our Service
This includes, for example, sending you push notifications reminding you to turn on call recording during conversation. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.
- to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).
- to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.
- to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
- to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
- to comply with legal obligations.
WITH WHOM WE SHARE YOUR PERSONAL DATA
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
- cloud storage providers (Amazon)
- data analytics providers (Facebook, Appsflyer, Firebase, Amplitude)
- marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google)
- call recording functionality provider (Twilio)
Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
- Service providers
HOW YOU CAN EXERCISE YOUR RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change some of your personal data by sending us an email at firstname.lastname@example.org.
You may also request a copy of your personal data collected during your use of the App at email@example.com.
Deleting your personal data. You can request erasure of your personal data by sending us an email at firstname.lastname@example.org.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at email@example.com.
Additional information for EEA-based users
If you are based in the EEA, you have the following rights in addition to the above:
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at firstname.lastname@example.org.
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at email@example.com.
INTERNATIONAL DATA TRANSFERS
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).
CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to firstname.lastname@example.org which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Effective as of: