Last Updated: January 20, 2017
We have detailed below which data is processed, how we process and use your data, but before, we would like to explain the lawful basis for which we do so:
When you register, we process a your Personal Information (as defined below) in order to perform our contract with you;
When visitors access our website, we may collect certain Online Identifiers which we have a legitimate interest in processing, some of this data is processed by our third party partners, all as detailed below;
We process Personal Data you voluntarily share with us, such as your contact list, or when you contact us for support, we process this data subject to your consent.
(I) The type of information we collect
The first type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via your use of the Services (“Non-personal Information”). Such Non-Personal Information may include:
Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name from which you linked to the Services; etc.).
Analytics information: We, or third parties on our behalf (i.e., Google Analytic), collect information about your use of the Services log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, installs, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information may include:
Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself, such as your email address and name. You may register to our Services through your social network account or directly through our Apps. When you register or sign-in to the Services via your social network account (e.g. Facebook; Google, etc.), we will have access to basic information from your social network account, such as your name, email address, profile picture, as well as any other information you made publicly available on such account or agreed to share with us. At all times, we will abide by the terms, conditions and restrictions of the social platform.
Contacts: to enable the Service and manage your contacts, you will need to share with us your full contact list (i.e. address book) (“Contacts”), your phone number, details you save under your contact application next to your own details (“Contact Information”). When you provide us with access to your Contacts, you acknowledge and agree that we may use such information as part of the Services. Please note that at any time, you or any of your Contacts can choose to opt-out from having their Contact Information enhanced, managed or shared by us, by following the instructions below (under “Opt-out options”).
Call logs. Solely if you use our caller ID we will have access to your call logs, we will use this solely in real time to identify the call, and this data is not stored or used by us.
Backup: To back up your Contacts and enable you to sync and backed up your Contacts between several devices you own, the Contact Information we collect will be stored in our database. If you do not want us to keep this data on our servers, please opt-out by.
Voluntary information: We collect information which you provide us voluntarily. For example, when you respond to communications from us, performing a purchase through our App, communicate with us via email or the website or share additional information about yourself or about others through your use of the Services.
Online Identifiers: We may also collect Personal Information from your device. Such information includes IP address, cookies or agents (“Online Identifiers”).
(II) How we collect information
There are four main methods we may use to collect information about you:
We collect information automatically through your use of the Services. In other words, when you are using our Services, we are aware of it and may gather the information relating to such usage (e.g. your and Contacts).
We collect information which you provide us voluntarily. For example, we collect Personal Information which you provide when you register, perform an in-app purchase, interact with our customer support; etc.)
(III) Cookies and SDKs we use
We use Google Analytics and Fabric to collect information about online usage activities across our website and Services, this data may include IP address. To learn more how Google uses data from our use of Google Analytics Cookie we recommend you review Google’s policies located at: www.google.com/policies/privacy/partners and https://policies.google.com/technologies/partner-sites . We also encourage you to review the Google Analytics' currently available opt-outs for the web tool available at: https://tools.google.com/dlpage/gaoptout/.
(IV) How do we use the information we collect?
We use and share Personal Information to enhance and provide the Service.
(V) With whom we share the information we collect
We do not share your Personal Information with third parties except:
The Services are based on contact management and Caller ID (if applicable), therefore, we will use your number and contact for this purpose. This disclosure is also important to individuals that are not our users which may be identified by the caller ID. We enable an easy opt-out in the event you no longer wish to be identified, for more information see the User Right section below.
We may also share Personal Information with (i) our subsidiaries and business partners if needed; (ii) subcontractors and other third party service providers (e.g. payment processors, server, cloud management, etc.); and (iii) any potential purchasers or investors of the Company.
We may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
(VI) For how long we retain the information we collect?
Please note that we may retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements, unless required otherwise by law or by you. Please note, some of the information collected was made public by you, thus, in some cases, you may encounter your details again after the request for removal, in case they were re-collected over the web, contributed by other partners or in other means. We will make best efforts to ensure this doesn’t happen but the risk exists.
(VII) What are your rights?
Individuals (either our users, partners, associates, or other individuals we identify through the caller ID, etc.) have the right to control the Personal Information processed by us, these rights include without limitations: the right to know what information we hold about them, access the Personal Information, receive a copy or to opt-out at any time as detailed here.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the information we collect from you, which may also apply.
Where we are not able to provide you with the information 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.
If you wish to exercise your right, please contact. Some rights may be executed without the need to contact us, as follows:
Browser & Cookies Opt-out: you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using.
Sharing Contacts: You may choose to opt out from sharing your contacts by changing your preference through the App, for more information please see here.
Phone Number: if you wish to remove your Contact Information from our servers please click here.
(VIII) How do we safeguard and transfer your information?
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information, and prevent unauthorized use of any such information. For more information please see our Security Policy. Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union, in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the European Union.
The Services are not intended for children, accordingly, we do not use the Service to knowingly solicit data from children as defined under applicable law (e.g. thirteen (13) regarding US individuals and sixteen (16) regarding European Economic Area ("EEA") individuals). We request that children do not provide Personal Information through our Services. If you become aware or have any reason to believe that a child has shared any Personal Information with us, please contact us and we take reasonable steps to ensure that such information is deleted from our files.
Simpler Apps Inc.
540 President Street, 3rd Floor
Brooklyn, NY, US, 11215
Individuals from the EU may contact our EU representative according to Art. 27 GDPR regarding all requests related to data protection and privacy:
Attn: Simpler Apps Inc.