Last Updated: March 24, 2021.
We may provide additional privacy notices to you at the time we collect your data. This type of an “in-time” notice will govern how we may process the information you provide at that time.
California residents may click here for Your California Privacy Rights
1. Information We Collect
We may obtain information about you in a variety of ways, including through your use of our Services, when you call, email or otherwise communicate with us, or when you participate in events or other promotions.
Categories of personal information that we may collect or obtain (including from third party providers), include the following:
|Telephone number, unique online identifier (UUID, Advertising ID, IDFA), IP Address
|B. Commercial information.
|Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
|C. Internet or other similar network activity.
|Information on a consumer’s interaction with a website, application, or advertisement. See Information collected by Automated Means in Section 2 below for additional details.
|D. Sensory data.
|Audio Recordings (call recordings)
In addition to the above, we may also collect the following types of information:
- Transcripts Call Recordings. We may make transcripts of call recordings available to you. We may use a third-party provider to help us provide transcription services to you.
- Call Recordings. We store the recordings, and if applicable, transcripts with our cloud storage or telecom provider. We do not otherwise share these recordings or transcripts with third parties.
2. Sources of Information and Purposes of Use
Information collected from you:
The following are examples of the types of information we may collect directly from you:
- Telephone number.We require your phone number for the technical provision of our Services to you.
- Call Recordings and Transcripts.We store the recordings, and if applicable transcripts of recordings you make using the Service. We do not otherwise share these recordings or transcripts with third parties.
- Phone Contacts. We may have sustained access to the phone numbers in your contacts to make it easier for you to make calls. We do not save or share this information.
Automated Information includes information such as:
- Hardware and software information
- While we do not track AdvertisingID (such as Google’s AdvertisingID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’s settings), we may use third party providers and tools (such as and by way of example Adjust, Firebase, and RevenueCat) in efforts to make improvements to the app, for tracking purposes, transcription, and such third party providers may utilize AdvertisingID, Apple IDFA or other methods when providing services to us.
- Adjust ID (this identifier lets us know where our users found our Services online, record user app events and optimize our advertising efforts)
- Subscription Data
This Automated Information is generally used for the following purposes:
- for the technical provision of our Services in order to be able to provide you with a functioning user-friendly experience
- to uncover insights about your use of our mobile applications in order to improve our Services and features, including developing new products and features
- to facilitate your access to our mobile application
- to customize our Services for you
- to help us better understand our current and potential customers and optimize the marketing of our Services accordingly
- events and usage data are captured for our internal business analytics in order to understand how our users interact with our mobile applications and use our Services. For example, we may capture when a user visits a screen, taps a button, permits notifications, upgrades, or otherwise interacts with the app.
3. How We May Use Your Personal Information
In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following:
- Performing Our Services
- Maintaining or servicing accounts, providing customer service, operating mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments
- Internal Research
- Understanding and evaluating how our Services and features perform with our users
- Uncovering insights about usage in order to improve the Services and provide customers with enhanced features as well as inform our development of new features and products.
- Auditing Interactions with Consumers
- measuring usage mobile applications
- measuring our advertising and marketing activity (e.g., measuring how a user was acquired)
- identification and repair of impairments to intended, existing functionality of our Services
- Understanding our customer in order to more effectively market our Services
- Quality and Safety Maintenance and Verification
- activities related to improving the quality of the Services we provide, including upgrade or enhancement of the Services
- Complying with legal or regulatory requirements, judicial process, industry standards, and our company policies
- Other purposes that may be described at the time you choose to provide personal information to us
We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose, and otherwise process such information for our own legitimate business purposes — including historical and statistical analysis and business planning — without restriction.
4. How We May Share Information about You with Others
Third-Party Service Providers
We may share information about you with the following categories of third-party providers for a variety of business purposes:
- Internal Business Insights Platforms.Our third-party internal business analytics platform provides us with the tools to help us understand app usage and interactions and uncover insights that allow us to improve our product and features as well as optimize our marketing. We may share or make available unique user identifiers, IDFA, deviceID, IP address, Adjust ID and app usage and events (such as when you subscribed to our services) with these providers for the following business purposes: performing services that allow us to (i) monitor and understand usage in order to enhance existing Services or develop new products and features and (ii) better understand our customers in order to market our products more effectively.
- Measurement and Attribution.These service providers offer tools that allow us to measure and attribute the source of new subscription sign-ups and that allows us to uncover insights about usage and app events. We may use unique user identifiers made available to us from these third-party providers to help us measure the effectiveness of our ads (e.g., where and how a user is acquired) and to uncover information about how our customers are using our apps in order to improve their quality and safety. We may also share and/or store unique user identifiers, device IDs, IDFA, or IP addresses with these providers for the same purpose.
- Telecom Providers.Our telecom providers allow us to make our services available to you. We may share and/or store phone numbers, SMS, MMS, call recordings, and transcriptions with our telecom service providers as necessary to provide our Services to you.
- Other technology providers necessary to provide our services(including cloud storage and web hosting providers). We store user-provided and Automated Information and/or aggregate or non-personally identifiable information with our cloud storage providers. We also may make certain Automated Information available for various purposes such as monitoring network traffic to detect malicious actors and to protect against malware, fraud, or other unlawful uses or activity. Additionally, we may use a third-party provider to assist us in providing transcription services.
- Marketing providers.We, or the third-party service providers we use to assist us with marketing our own products to you, may use the information we collect from you to provide advertisements and offers for our other products. For example, we may share information (usually a unique online identifier) with our marketing service provider that enables them to serve you an ad for Call Recorder. We may share this information with companies like Facebook, Pinterest or Snapchat that allows us to create Custom or Lookalike Audiences. Learn more about Facebook Lookalike Audiences, Pinterest Audiences, and Snapchat Audiences. Additionally, we may share certain information, including app events, with Facebook or other advertising partners that provide us with optimization services for our advertising. You can learn more about how to opt-out of having such activity sent to Facebook here and about Off-Facebook activity generally here. You can also visit your Pinterest Settings and Snapchat Advertising Preferences to learn more about your privacy options on those platforms. We also use Google Ads to advertise our products. When you view or click on an ad on a website or app, tracking technology may be set by Google to help better provide advertisements that may be of interest to you. You may opt-out of the use of this tracking technology by visiting Google’s Advertising and Privacy
Legal, Regulatory, Compliance, and Similar reasons.
5. Information for Individuals in the European Economic Area (EEA)
Your Choices and Rights
As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:
- Access: you may request access to your personal information and receive copies of it;
- Correction: you may have inaccurate/incomplete personal information corrected and updated;
- Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;
- Deletion: in certain circumstances, you can request a right “to be forgotten” (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;
- Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider); and
- Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.
Legal basis for processing data
International data transfers
- Countries that the European Commissions has deemed to adequately safeguard personal information,
- Pursuant to the recipient’s compliance with standard contractual clauses (also known as Model Clauses), EU-US Privacy Shield, or Binding Corporate Rules,
- Pursuant to the consent of the individual to whom the personal information pertains, or
- As otherwise permitted by applicable EEA requirements.
6. Information for Residents of California: Your California Privacy Rights
Access to Information and Data Portability Rights
- The categories of personal information we have collected about you.
- The categories of sources from which we collected your personal information.
- The business or commercial purposes for our collecting or selling your personal information.
- The categories of third parties to whom we have shared your personal information.
- The specific pieces of personal information we have collected about you.
- A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
- A list of the categories of personal information sold about you in the prior 12 months, or that no sale occurred. If we sell your personal information, we will explain:
- The categories of your personal information we have sold.
- The categories of third parties to which we sold personal information, by categories of personal information sold for each third party.
Data Deletion Rights
Exercising Your Rights
- Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative. You agree that in order to accommodate certain requests by you, we may require you to verify your ownership of an account by responding to a text message sent to the phone number on the account and/or by requesting reasonable documentation to show your ownership of the number and account.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We do not knowingly “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether our use of certain tracking technologies may constitute a “sale” of your PI as defined by the CCPA. See section regarding Online Privacy Choices and Rights to learn more about the choices that are available to you.
7. Online Privacy Choices and Rights
Access, Edit and Delete Your Information
Notice to Nevada users
8. Data Retention & Deletion
9. How We Protect Personal Information
If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you. We may also post a conspicuous notice on our site or notify you through the mobile application. You consent to our use of text message, and/or notification through the app as a means of such notification. If you prefer for us to use the postal service to notify you in this situation, please let us know by submitting your request at the appropriate contact email in the How to Contact Us section. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information.