[Last Updated: May 16, 2022]
“End User(s)”: end users that install one of our apps: "Simpler Caller ID - Contacts and Dialer" available on Google Play, "Dialer, Phone, Call Block & Contacts by Simpler" available on Google Play, "Easy Backup - Contacts Transfer and Restore" available on Google Play, "Cleaner - Merge Duplicate Contacts" available on Google Play, "Simpler - Contacts Manager" available on iOS, "Easy Backup Pro" available on iOS. (each and collectively shall be defined as "App(s)");
TYPES OF DATA WE COLLECT AND HOW WE USE IT
The first type of data we collect is aggregated, non-identifiable, non-personal data, which may be processed via your use of the Service (“Non-Personal Data”).
The second type of data is individually identifiable data, namely data that identifies an individual, or may with reasonable effort identify an individual (“Personal Data”).
In the event that we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data for as long as it remains combined.
The data sets we collect and process including how we process such data sets, for what purpose and what is our lawful basis to such processing activates is as follows:
From our App's End Users
Online Identifiers - When you use our App, we (either directly or through our service providers will collect your IP address. We use this data to enable us to audit and detect fraud.
Account Data - If you wish to be granted with access to our App and to use our Services you will be requested to create an account by signing - in through your Facebook, Apple or Google account. The Account will be used as a unique identifier which is required in order to identify you in our database.
Contact Information - If you voluntarily contact us for support or other inquiries, you may be required to provide us with certain information such as your name and email address. We will use this data to provide you with the support you requested or to respond to your inquiry.
Contact List - In order to provide our services, you will need to share your full contact list with us. Our services include the enrichment, management, backup, verification, deletion of duplication of your contact list address book. In order to provide you with such services we will have to collect and store your contact list in our database (for back up services) and to compare your contact list with our and our third party's contact information databases. For this reason, we will share your contact list with our service providers as detailed below.
Call Log - If you wish to use our caller ID function we will be required to collect and process your "call log". Our services include identifying calls. Therefor we will need to compare your call log with our databases to enable identity verification and fraud prevention.
Permissions - Our App's operations require the permissions to access certain settings of your Android device. Certain features of our Apps require the following access permissions:
Appear on Top permission is used in order to able our "caller" to identify incoming calls.
Storage Access permission is used in order to access your phone bock and to provide you with the identification and back up features.
To access these Permissions, you will need to affirmatively enable them through in-app permission or the mobile settings. You may disable the Permissions at any time, but depending on the Permission you disable, a feature or all features may not function properly.
Non-User Data We Collect from Contacts
Our services include the management, backup, verification, and deletion of duplication of our end-users contact list address book. In order to provide our end-users with such services we will have to store our end-user contact list in our database (for back up services) and to compare the contact list with ours and third party's contact information database. Therefor when the End User uses our services we process and retain certain data from their Contacts including: the Contact's full Name, email address, phone number, job title, geographical location (including home and/or company address), company name or other organization that the Contact is a part of, social media links to their accounts (e.g. LinkedIn, Facebook etc.), websites that the Contact owns or operates, and any other information that the End User has saved for that particular Contact (Contact dependent). We will not collect or process picture of Contacts.
A Contact may opt-out at the following link: https://www.simplercontacts.com/opt-out
The lawful basis for processing the information detailed above is as follows
Online Identifiers - legitimate interest in connection with our processing of this data for the purpose of fraud detection and prevention
Contact Information - r our legitimate interest in order to respond to your inquiry
Contact List - r your affirmative and active consent which will be displayed as a pop notice when using the App
Call Log - your affirmative and active consent, which will be displayed as a pop notice when using the App.
Permissions - your affirmative and active consent, which will be displayed as a pop notice when using the App.
Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of personal data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above.
HOW WE COLLECT DATA
Depending on the nature of your interaction, we may collect your information by using one or more of the following methods:
Automatically - we may use APIs software developer kit ("SDK") and other technologic measures to gather some of your data automatically.
Permissions – in case you are End User using Android device certain features of our Apps require the following access permissions: (i) Appear on Top which is used in order to able our "caller" to identify incoming calls; and (ii) Storage access which is used in order to access your phone bock and to provide you with the enrichment and back up features. To access these permissions, you will need to affirmatively enable them through an in-app permission or the mobile settings. You may disable the Permissions at any time, but depending on the Permission you disable, a feature or all features may not function properly.
We may share information solely in the following events:
(i) Third Party Service Providers:
We may disclose or share certain information with our third-party service providers for the purpose of providing us with services with are required in order for us to provide our Services to you.
(ii) Legal Requirement
We may share information in order to protect legal rights (including intellectual property rights) or to comply with any applicable law, regulation, legal process or governmental request.
(iii) Affiliate Company
We may disclose or share certain information with our parent company, any subsidiaries, joint ventures, or other companies under common control with the Company ("Affiliated Companies"). We share information for the purpose of enhancing our Services to you. You may request we do not share any of your information by submitting a data subject request herein.
Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Data that we hold (depending on your jurisdiction). Please review our User Rights Policy for more information regarding your privacy choices and the rights you may have under the relevant data protection and privacy laws in your jurisdiction.
If you wish to exercise any or all of the above rights, please fill out the Data Subject Request Form (“DSR”) available here.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.
DATA RETENTION & DELETION
We retain the data that we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual requests that we delete his or her Personal Data. We may, at our sole discretion, delete or amend information from our systems, without providing any prior notice to you, once we deem it is no longer necessary for such purposes.
You may request us to delete the data we collect from you. Such request shall be according to your engagement with us and the type of deletion you as detailed below:
Contact - you may request us to delete your information from any of our, and our Service Providers databases by submitting a request https://www.simplercontacts.com/opt-out. In such case we will add your data to our “do-not collect” which should assist us to comply with your request and not to collect the Contact data even if provided by any our End User.
End-User - you may request us to Opt-Out (as detailed below) or to delete your information. In case you request us to delete your information we will delete your data as detailed above including the Contact collected from you and request our service providers to delete such data.
NOTE THAT DELETING THE APP FROM YOUR DEVICE WILL NOT RESOLVED IN DELETING YOUR DATA COLLECTED FROM YOU.
In addition, please note that in case you are an end-user requesting us to stop the collection of your data (“Opt-Out”) by either contacting us through or by switching off the collection toggles in our app, we will stop the collection of your data from the date of such request, but we will use and process the data collected from you prior to submitting the request in order to provide our services. If you wish us to delete the processing of the data collected prior to the said opt-out request, please follow the instructions above.
Additionally, in the event of a security incident in which we discover your Personal Data may have been at risk, we will take reasonable efforts to notify you and the applicable authority (if required to do so, subject to applicable laws).
If you become aware or have any reason to believe that a Child has shared any information with us, please contact us (as detailed below) and we will take reasonable steps to ensure that such information is immediately deleted from our databases.
Our databases are currently located in Ireland and certain processing activities are conducted from the HQ offices in Israel.
Simpler Apps Inc.
540 President Street, 3rd Floor
Brooklyn, NY, US, 11215