Privacy policy

Last Updated: September 12, 2024

As a collaborative community, CallApp’s top priority will always be its relationship with the community. CallApp is firmly committed to the security and protection of the personal integrity of our users, their contacts, and CallApp’s service, as set forth herein.

 This Privacy Policy describes what personal information may be shared with CallApp and other users when activating and using CallApp’s services, how CallApp receives, collects and uses this data, and how to opt out.

CallApp Software Ltd. (“CallApp”, “we” or “us”) respects the privacy of users (“user” or “you”) of CallApp’s software (“Software”) and services (together with the Software, the “Service”) and is committed to protecting information, including Collected Information.

“Collected Information” means a user’s private, personal or personally identifying or identifiable data or information, including Content, user’s Contacts’ information (such as name, email address, telephone number or social network identifier), information which may be considered as “personal information” under the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA“), and as further defined below.

“Public Resources” means publicly available online databases and other public data resources.

The terms of this Privacy Policy are incorporated by reference into CallApp’s Terms of Service.

PLEASE READ THIS PRIVACY POLICY CAREFULLY.  BY REGISTERING, DOWNLOADING, INSTALLING, ACCESSING, ACTIVATING OR OTHERWISE USING THE SERVICE OR INTERACTING WITH US ON OUR WEBSITE, YOU ACKNOWLEDGE THE TERMS AND THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY, INCLUDING WITHOUT LIMITATION WITH RESPECT TO THE COLLECTION AND PROCESSING OF YOUR COLLECTED INFORMATION AS SET FORTH HEREIN.

The Service is not designed or intended for children under the age of eighteen (18), unless a younger age threshold has been adopted by your country (the “Eligible Age”).

We reserve the right to request proof of age at any stage to verify that minors under the Eligible Age are not using the Service. If you are under the Eligible Age, you may not download the Software or use the Service including the Software, you may not use any feature of the Service that requires registration, and you may not provide us with any Collected Information. CallApp will not knowingly collect any Collected Information concerning children under the Eligible Age where the collection and processing of the Collected Information is subject to the consent of the user. If you become aware of any minor under the Eligible Age using the Service or that any Collected Information relates to a minor under the Eligible Age, you may request to unlist their number from the Service, as further detailed in Section 7 below.

CallApp may update this Privacy Policy from time to time and such updated Privacy Policy will be effective as of the “Last Updated” date. If we make significant changes, we will make that clear on the app and/or on our website or by some other means of contact such as email, so that you can review the changes before you continue to use the Service.

  1. What Collected Information we collect

The collection of certain Collected Information mentioned below is mandatory as indicated below for the purposes described in this Policy. If you do not provide us such personal data, we will not be able to provide the Service.

Information from user or user devices.

  1. Information which is essential for the use of the Service
    When you register, download, install and access the Service, the following Collected Information will be collected and processed by CallApp:

Information regarding contacts contained in user device phone books (as detailed below) (“Contacts”), name, phone number, email, connection information, usage statistics, event information, version of the Software used (the “Essential Information“).

  1. Information which is optional and intended to improve your user experience of the Service
    When you activate or otherwise use the Service or interact with us on our website, we may collect the following information: geo-location, IP address, device ID or unique identifier, device details (including: device manufacturer and type, device model and name, device hardware and settings), keywords and meta data of incoming and outgoing calls and messages, installed apps information, ID for advertising, ad data, operating system and operator.

Furthermore, prior to using our recording call feature, which allows you to save and access certain recordings of calls and other telephone communications that you participate in, we request that you inform all participants of such recorded calls of your intended use of the recording call feature and obtain all consents and approvals for the recording of the call, as necessary or advisable under applicable law. Please note that the recordings will only be stored on your device and not on CallApp’s servers.

Information from Public Resources and other users of the Service.

We receive data from Public Resources associated with users and user Contacts, including from social networks to which users or user Contacts are registered, such as Facebook, Google+, Linkedin, Twitter, Pinterest and Foursquare (the “Third Party Social Networks“). 

If you provide us your user identifier information for Third Party Social Networks, we will use and process such information in order to enable the Service to interoperate with the Third Party Social Networks, so that the user’s identifier associated with the Third Party Social Networks (including mapped photos where applicable) may be stored and processed in conjunction with the Collected Information.

Please note that we never store any passwords to any Third Party Social Networks.

In addition, other users of the Service may provide us with complementary information in their possession about you, which has not been previously provided by you (e.g.: place of work).

Information regarding Contacts.

When you register, download, install, access and use the Service, the following Collected Information regarding the Contacts will be collected and processed by CallApp:

names, phone number, emails and information from Public Resources including Third Party Social Networks, associated with the phone number of each Contact, such as, website address.

You agree that you will exercise caution and common sense if you provide us with or let us collect or receive information, including Collected Information, about someone else e.g. someone who calls you. Please inform your Contacts and any such other person, that their information may be collected and shared with CallApp and direct them to the terms of this Privacy Policy and our Terms of Service for more information.

Information uploaded by you

You may upload and share information, including Collected Information, into the Service as content (“Content”). Content may take the form of your profile information or Contact information. All Content is available to us and to other users.

Gmail Data information

Upon your consent to access by CallApp to Gmail-originated data (“Gmail Data”), Gmail Data will be used to improve the user-facing features of the Service. For example, you will be able to see the last email subject from a Contact when you open his/her contact details.

Gmail Data, such as email body and email subject, will not be transferred to others unless that transfer is (a) necessary to provide or improve user-facing features that are prominent from the Service’s user interface, (b) to comply with applicable laws, or (c) a part of a merger, acquisition or sale of assets.

Gmail Data will not be used by CallApp to serve you advertisements. Gmail Data, such as email body and email subject, are not read by any human.

CallApp’s use and transfer to any other app of Gmail Data information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Youtube API Services

Youtube API Services will be used to improve the user-facing features of the Service. For example, you will be able to see the last YouTube video from a Contact when you open his/her contact details.

Youtube Data will not be transferred to others unless if that transfer is (a) necessary to provide or improve user-facing features that are prominent from the Service’s user interface, (b) to comply with applicable laws, or (c) a part of a merger, acquisition or sale of assets.

By using CallApp You are agreeing to be bound by the YouTube Terms of Service https://www.youtube.com/t/terms in regards to Youtube content.

  1. How we use Collected Information and on what legal basis?

We process Collected Information for specific purposes, as described in the table below. If you are in the EEA, privacy laws require us to also tell you the legal basis on which we process your Collected Information.  You will find that information in the table below.  If you would like more information about the legal basis we use, or about the “legitimate interests” referred to, please contact us at: dpo@callapp.com.

Purposes

Legal
basis

1.  Manage and provide you the Service, including without limitation: • provide you the basic features and other features of the Service that are available only to registered users of the Service • provide you with information about the Service and allow us to respond to your queries • associate data with a phone number through our name/data tagging functionality • maintain a “spam list” of phone numbers you requested to be blocked or marked as spam • develop and improve the Service and our relationship with you and other users

Performance of our contract with you to provide you the Service

 

2.   Improve your user experience

Performance of our contract with you to provide you the Service

3.  Improve your user’s experience depending on your geo-location

Consent to your geo-location

4. Create a contacts database in order to allow users to identify who
is calling and decide whether or not to take the call

When processing information about Contacts, our legitimate interests in providing, developing and improving the Service, and meeting the needs of our users (identify who is calling them)

5. Detect, prevent, address fraud, security or technical issues

Legitimate interest in preventing fraud in relation the use of the Service

6.   Respond to your requests and claims

Legitimate interest to manage your requests and claims and respond to them properly

7.   Share information with third party partners for purpose of delivery of targeted advertisements

Your consent that your data be used by our partner for targeted advertising

8.  Disclose Collected Information in connection with a merger, acquisition or sale of assets

Legitimate interests in conducting, developing and improving our business

9. Preserve our rights or ensure our defense against any dispute that may arise

Legitimate interest to ascertain, exercise and/or defend our rights and ensure our business continuity

10.  Compliance and legal process

Necessity to comply with our legal obligations pursuant to the relevant legislation
  1. Sharing Collected Information

CallApp will share and disclose your information, including Collected Information, with non-user third parties only in accordance with the terms set forth in this Privacy Policy or with your explicit consent.

CallApp may disclose your information, including Collected Information to satisfy applicable law, regulation, legal process, or governmental request.

CallApp may delegate the handling of your information, including Collected Information, to third party service providers (“Service Providers”):

  1. To ensure the provision of seamless Service, such as providers of cloud servers.
  2. To a third party examining the business of the company, or a consultant acting under a non-disclosure agreement agreed with us.

In addition, CallApp may disclose your information, including Collected Information:

  1. Where we deem it necessary to enforce this Privacy Policy or the Terms of Service, to protect any party, to detect, prevent, or otherwise address fraud, security or technical issues, or to respond to claims, including in connection with claims that unauthorized information (e.g. phone number, name, etc.) of a third-party has been retained in CallApp’s Resources (as defined in the Terms of Service) and transferred through the Service
  2. To an acquirer of CallApp or of all or part of CallApp’s business activity

Collected Information shared with third parties may be provided in hashed or encrypted form, consistent with market practices, and may be used to identify users across devices and channels for the purpose of serving targeted advertising, except where such use has been excluded by agreement with, or prohibited by, a CallApp partner (providing a Public Resources as defined above). We may be compensated for information, including Collected Information, shared with third parties. Users will not receive compensation in connection with such sharing or other use.

4.      Third Party Partners

Third party partners may engage with or be engaged by CallApp for commercialization purposes such as: using data for third party partners’ internal business needs and/ or for the provision of identity verification services and delivery of interest-based content and targeted and non-targeted advertisements to users, except where such use has been excluded by agreement with, or prohibited by, a CallApp partner (providing a Public Resources as defined above). We may share Collected Information with our partners such as name, postal address, email, or other identifier and may do so in non-human readable form. In addition, our partners may also collect information directly from user devices, such as IP address, device ID, information about browser or operating system, and depending on device settings set by the user, geographic location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the device, for purposes of delivery of interest-based content and targeted and non-targeted advertisements.

Our partners may combine such information including Collected Information with information from other sources.

5.      Third Party Sites and Privacy Policies

The Service may contain links to third-party websites. We are not responsible or liable for the privacy policies, practices, Collected Information or other content collected, received, stored, used, or shared by third-party websites. We encourage you to carefully read the privacy policies and the terms of use or service of third-party websites prior to submitting any information, including Collected Information.

Upon user information, including Collected Information, being shared with a third party, we will continue treat the user’s information according to the terms of this Privacy Policy, and the relevant third party will treat the user’s information according to the terms of its own privacy policy.

6.      Opting Out

Users may opt out of the Service by uninstalling the Software from their device, either by choosing the uninstall option on the Software, or by using the software removal option of the operating system of their device.

Upon uninstalling the Software, we will no longer collect any further information, including Collected Information, from you through the Service, nor will we provide you with the Service, including with information via the Service pertaining to your Contacts or other third parties that initiate phone calls with you.

If you would like to request the deletion of your information that was disclosed to Service Providers or to third party partners (as detailed in Sections 3 and 4 above) or any other details about the disclosure of your information, please contact us at support@callapp.com. If you are in the EEA or Brazil you have additional rights in relation to the deletion of your Collected Information. If you are a California resident, you have additional rights in relation to the deletion of your Collected Information. Please see below for more information.

7.    The Term of Retention and Use

We keep your personal data only for the time necessary for the purposes set out in this Privacy Policy and in accordance with the relevant applicable provisions.

–   We will retain and use your information, including the Collected Information as long as you are a user of the Service, and will continue to retain your information for up to 5 years from the time you unregister from the Service and/or opt-out for certain services and/or withdraw your consent to certain use (if our processing is based on your consent). Your data will then be deleted or anonymized.

–   We will retain and use Contact’s information, as long as he/she interacts with a user of the Service, unless he/she requests to be unlisted or deleted.

–  If you or any of your Contacts or any other person unlists their name and phone number made available through CallApp’s functionalities, in the form described below, we will retain their information, including Collected Information, for a period of up to 5 years from the time they unlisted from CallApp’s Service. However, users will not be able to search the CallApp platform for the unlisted name and phone number during such period. At the end of this period, their data will then be deleted or anonymized (unless they have asked to reappear on the CallApp platform).

(collectively, the “Retention Period“).

8.     Rectification and Deletion of Collected Information

If you find any of your information, including the Collected Information, to be inaccurate, you may contact us at any time by sending an email to: support@callapp.com and we will do our best to rectify your information as soon as practically possible.

If you wish to delete any of your Collected Information from our resources and/or servers, please send an email to: support@callapp.com, and we will delete such Collected Information pursuant to applicable privacy law requirements. In such event, subject to applicable privacy laws, your information will be deleted or unlisted from our database. Notwithstanding the foregoing, if we are required to maintain certain information, including Collected Information, about you, we will comply with your deletion request after fulfilling any legal requirements. In addition, a copy of your information, generated by our automated computer archival back-up systems, may remain in our archives, even after the Retention Period, provided such copy will be stored securely and will not be displayed on our active database.

If you, any of your Contacts or any other person do not wish to have their names and phone numbers made available through CallApp’s functionalities, they may unlist their number from the Service by logging onto the “Unlist” page on CallApp’s website – https://www.callapp.com/unlist. Once they are unlisted from the Service, CallApp will not search the CallApp platform for their phone number. However, their details may still be available through Public Resources.

9.   Additional Rights for EEA, Brazil and California individuals

If you are in the EEA, Brazil or if you are a California resident, applicable privacy laws grant you additional rights in relation to your Collected Information.  You can exercise any of these rights by contacting us at: support@callapp.com.

In order to process certain of your requests, we have a verification mechanism that uses email address and phone number to verify your identity. We may request additional information to verify your identity on a case-by-case basis.

9.1. For California individuals

If you are a California resident, you may also contact us by clicking here. If you are a California resident, you may use an authorized agent to submit a request on your behalf. The authorized agent may submit a request by contacting us at support@callapp.com or by clicking here. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Collected Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

If you are a California resident, you have the following rights:

  • The right to request to know what personal information, including Collected Information, we collect, use, disclose and sell. You may exercise this right twice per year, free of charge. If we are unable to  fulfill this request, we will tell you the reasons why.
  • The right to opt-out of the “sale” of your Collected Information by us, as “sale” is defined under the CCPA. Without derogating from the aforesaid as to the Eligible Age for which the Service is intended, we do not knowingly sell Collected Information of minors under 13 years old without consent from the minor’s parent or guardian, nor do we knowingly sell Collected Information of minors between 13 and 16 years old without the minor’s own consent. If you do not affirmatively opt out, and you are not a minor, your Collected Information may be sold as disclosed in this Privacy Policy.
  • The right to request deletion of your personal information, including Collected Information, collected by us. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request to delete, we will let you know the reason why.
  • The right not to receive discriminatory treatment by us for exercising your privacy rights.

The CCPA requires that we make certain disclosures about our general collection, use, disclosure, and sale of personal information over the past 12 months. Accordingly, in the past 12 months: (i) we collected the categories of personal information from the sources and for the purpose detailed in Section 1 above; and (ii) we disclosed the categories of personal information detailed in Section 1 above to the categories of third parties detailed in Sections 3 and 4 above.

In the past 12 months, we have allowed certain companies to place third-party cookies on our Service or collect certain Collected Information from user devices as described above under Sections 1 and 3, which allows those companies to receive information about your activity on CallApp that is associated with your browser or device. The companies may use that data to serve you more relevant ads on the Service or on other websites. Under the CCPA, sharing data like this may be considered a “sale” of personal information.
To exercise your right to opt-out of such sale, please click here. Except for this kind of sharing, CallApp has not sold your personal information; however, please review the disclosure below regarding how we may sell your Collected Information in the future.

We may decide to sell any Collected Information, which includes all of the information described in Section 1 above. We may choose to sell Collected Information to any of the parties described in Sections 2 or 3 of this Privacy Policy for any purpose. To exercise your right to opt-out of the sale of your Collected Information, please click here. If you do not opt-out, your Collected Information may be sold as disclosed in this Privacy Policy.

9.2. For EU and Brazil individuals

If you are in the EEA or Brazil, you have the following rights:

  • The right to be informed about how we use your Collected Information. You should be able to find the details in this policy but you can ask for more information if anything is unclear.
  • The right to access the Collected Information to confirm whether we are processing your personal information and, if so, to provide you with a copy and inform you of the characteristics of the processing.
  • The right to ask us to correct or complete any Collected Information which we hold about you that is inaccurate or incomplete.
  • The right to ask us to delete your Collected Information in certain circumstances (the data is no longer necessary for the purpose of the processing, your consent has been withdrawn, you have objected to the processing, the data has been unlawfully processed, erasure is required to comply with a legal obligation). Please note, however, that we are not required to delete Collected Information that is necessary to provide services that you request or that we need to keep to comply with applicable laws.
  • The right to restrict (i.e., to retain your personal information but not to use it). your Collected Information in certain circumstances when you dispute the accuracy of your personal information, in order to enable us to verify such accuracy; processing of your personal information is unlawful, but you do not want it to be deleted; it is necessary for you for the establishment, exercise or defense of legal claims; you have exercised your right to object and verifying the existence of overriding grounds is in progress. We may continue to use your Collected Information following a request for restriction, when we have your consent; for the establishment, exercise or defense of legal claims; or for the protection of the rights of another natural or legal person. We will suspend the processing of your Collected Information. Please note that this may affect your ability to use the Service, or in some cases, terminate the Service completely.
  • The right to object to any processing of your Collected Information based on our legitimate interest. However, please note that it may happen that we will not be able to take into account such right if we have compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the Collected Information for the establishment, exercise or defence of legal claims.
  • The right to object to marketing at any time to your Collected Information being processed for direct marketing including profiling.
  • The right to withdraw your consent, at any time, to our processing of your Collected Information if our processing is based on your consent where applicable, without compromising the lawfulness of the processing based on consent carried out prior to such withdrawal.
  • The right to request to provide you with your Collected Information in a structured, commonly used and machine-readable format, or that we transfer certain elements of your Collected Information to you or another service provider in a machine-readable format. This right applies only where the processing is based on your consent or on the performance of a contract and the processing is carried out using automated processes.
  • The digital right to legacy (only if you are a French resident). If you are located in France, you have the right to set out instructions (general or specific) about what happens to your Collected Information after your death.
  • The right to complain to your national data protection regulator.

 

10.  Security

We take commercially reasonable efforts to maintain the security of the Service and the information you submit to the Service, including your Collected Information, and preventing unauthorized access to your information, including your Collected Information, through the use of industry-standard technologies and reasonable internal procedures, including transmitting your data using modern security measures such as encryption.

In addition, we enable the display of CallApp’s data only based on a phone number which has already been obtained by a user, e.g.: by an incoming call.

 We make good faith efforts to store your information in a secure operating environment. However, we cannot guarantee security. We cannot be responsible for the acts of those who gain unauthorized access to or abuse our Service, and we make no warranty, express, implied or otherwise, that we will prevent such access. You understand that all information, including Collected Information, collected through our website or in connection with the Service is at your own risk and is subject to the provisions, disclaimers, and limitations of liability in both this Privacy Policy and our Terms of Service.

In the event that we become aware of any accidental or unauthorized access to your information, we will use commercially reasonable efforts to notify you of such.

11.  Transfer of Information to a Different Jurisdiction

Collected Information is stored in the USA.

We or our infrastructure providers may transfer Collected Information to a different jurisdiction , provided that such jurisdiction ensures adequate level of protection of the Collected Information or that such transfer meets any other applicable data protection requirements (such as the implementation of (i) appropriate data transfer agreements based on Standard Contractual Clauses adopted by the European Commission or binding corporate rules or other valid transfer mechanisms and (ii) a data transfer impact assessment with the implementation of supplementary measures (contractual, technical, or organizational) if required to ensure the validity of the transfer.

You can ask us for more information about how we meet such requirements and notably on the transfer mechanism in place.

In addition, we or our infrastructure providers may transfer Collected Information to a different jurisdiction, if necessary and required in accordance with applicable data protection laws.

12.  Law and Jurisdiction

This Privacy Policy shall be construed and governed in accordance with the laws of the State of Israel, regardless of its conflict of laws rules. The courts of Tel Aviv, Israel, shall have sole and exclusive jurisdiction over any dispute under this Privacy Policy or otherwise related to the Service.

13.  Updates to this Privacy Policy

CallApp reserves the right to update this Privacy Policy from time to time. In our sole discretion we may post updates to CallApp’s website.

Updates to this Privacy Policy are effective as of the “Last Updated” date. If we make significant changes, we will make that clear on the app and/or on our website or by some other means of contact such as email, so that you can review the changes before you continue to use the Service. 

14.  Inquiries or Complaints

If you have an inquiry or complaint about this Privacy Policy or our information collection practices, please contact CallApp’s Data Protection Officer, who has been appointed to deal with your inquiries and complaints. You may reach him/ her at: dpo@callapp.com.

If you are unsatisfied with our Data Protection Officer’s treatment of your inquiry, you may lodge a complaint with the supervisory authority in your country.

Our representative in Europe may be contacted at: eurep@callapp.com.

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