Privacy Policy - Contacts app

Privacy Policy - Contacts app

This Privacy Policy (the "policy") describes how we collect, store, use and disclose your information that could identify an individual ("Personal Data"), and what choices you ("you, "your") have with respect to the information when you use our mobile applications, our services, our sites. Any mobile applications that hyperlink to this Policy and are available for download in the Google Play Store or any other third-party app store, or are pre-installed on third-party devices (the "Application" or "Applications"), the related services we provide ("Services") or any other websites ("Sites"), pages, features, or content owned or operated by Contacts.

Highlights
When you use or interact with our website, mobile applications and other related services, we and third parties may obtain certain information about you. In this Highlights section, we provide an overview of our privacy practices related to the Services. Please review our full Privacy Policy below for a detailed explanation of our practices.

This Service is provided by the Contacts is intended for use as is. This Privacy Policy (the "Policy") describes how "Contacts" and its affiliates. This document, the "Privacy Policy", explains how your personal data is collected and processed by Contacts when you use all applications published in Contacts, Google Play and Apple App Store.


We collect several different types of information for various purposes to provide and improve our Service to you.


You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of "personal" and "non-personal" data, and how it is technically processed.

Non-Personal Data

During your interaction with our website and Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services ("Non-Personal Data "). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc.

Personal Data

We may also collect from you, directly or indirectly, during your access or interaction with the website or Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual ("Personal Data"). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified in the table below.

We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation ("Special Categories of Personal Data").

The below details the processing of Personal Data, the purpose, lawful basis, and processing operations:

Push Notifications:
We may store Firebase Cloud Messages token. If you wish to stop getting push notifications, you may do so simply by disabling push notifications on your device’s settings or uninstall the app.

- This information will be processed to allow us to send push notifications to users from our server.
- As the token is Non-Personal Data it does not require a lawful basis.

In-App Payment Information:
When you make a payment through our App and offered Services, all payments are in-app payments and are subject to the applicable App Store terms and privacy policy.

Google Terms of Service
https://policies.google.com/terms

Google Privacy Policy
https://policies.google.com/privacy

App Store Terms of Use
https://www.apple.com/uk/store

App Store Privacy Policy
https://www.apple.com/legal/privacy/en-ww/



We use in app payment processors; the registration and payment information are solely processed by the applicable app store provider. We do not store nor process any Personal Data when you process the payment.
We receive an order number which is connected to a user ID which was generated when installing the app (non identifiable).

The Payment Information is processed to perform our contract with you to provide you our Services..



Log Data and Unique Identifiers:
In case of an error in the App we collect data and information (through third-party service providers) such as "Log Data" or "Crash Data". This data may include information such as your device Internet Protocol ("IP") address, device name, operating system version, the configuration of the App when utilizing our Service, the time and date of your use of the Service, and other statistics.

In most cases, this data will not include Personal Data, however we treat this information as Personal Data as we may be able to reasonably identify you.

We process this data set for our legitimate Interest of protecting our App and Services and optimizing the App and Services.

Profiling Data:
When you use our App we may display advertisements, our partners, the advertisers may place an SDK (as detailed below) and collect certain data on you for the purpose of displaying advertisement.
If you wish to prevent the display of advertisements or other identifiers for interest-based advertising, you may change your device settings to reset such advertisement or opt-out of such advertising (typically, this is available under the "Privacy" or "Ads" section in your device settings).
Please note that if you reset your advertising settings or opt-out of interest based advertising, you may still see advertisements in our App, but those ads will not be targeted for you. Please note that such actions may result in a less enjoyable user experience.

Our partners will process this data to manage and deliver advertisements more effectively and personally, including contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners and advertisers, including for re-targeting purposes.

We process this information based on your consent as required under your jurisdiction provided through our cookie manager or similar technologies.

Photos and Videos:
if you use our designated feature in the applicable App in order to provide you with our Services, we will ask you to provide us with photos of you (collectively "Content") for set as dialer image. While we cannot prevent you from doing so, we still do not use Personal Data from photos for purposes other than providing our Service.	We process such data to provide you with the Services.
Further we wish to clarify that we do not store any of your photos and videos on our servers and any processing activity shall be done solely on your device. We process this information based on your consent provided through the organic in-app permissions in order to execute our contract with you and provide you with our services.


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 a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The 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.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.

HOW WE COLLECT YOUR INFORMATION:
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

Automatically, We process this information based on your consent provided through the organic in-app permissions in order to execute our contract with you and provide you with our services..
When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.
Provided from third-parties.

SDK & TRACKING TECHNOLOGIES:
Our Services and some of our Service Providers utilize "cookies" or "software development kits ("SDK")" anonymous identifiers and other tracking technologies (collectively, "Tracking Technologies") which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps and Services as a whole.

The specific SDK we currently use, the purpose of the SDK, their privacy policy and opt-out controls are set forth in the table below:


Google Play
In-app billing
Google Play Privacy Policy: https://play.google.com/about/privacy-security-deception
https://policies.google.com/privacy?hl=en

Firebase
• Remote Config- data
• storage and processing location
• Crashlytics- data
• Cloud Messaging
• data encryption
• security purpose
• a/b testing
• in-app messaging
• predictions
• analytics

Firebase Privacy Policy: https://firebase.google.com/support/privacy


Advertisers:
• AdMob
• AdColony
• Applovin
• Chocolate Platform
• Facebook Audience Network
• Index Exchange
• Media.net
• Mobfox
• OpenX
• PubMatic
• Rubicon
• Sharethrough
• Yieldmo

And as may be updated from time to time (collectively "Advertisers").

The Advertisers are advertising Service Providers. Their targeted advertising SDKs collect information about your browsing activity across multiple websites and online services in order to provide you with relevant advertisements on the App and Services of third parties. The information collected using these advertising SDK does not disclose your identity, and helps us analyze the effectiveness of our advertising.


• AdColony: https://www.adcolony.com/privacy-policy/
• AdMob: https://policies.google.com/privacy?hl=en
• Applovin: https://www.applovin.com/privacy/
• Chocolate Platform: https://chocolateplatform.com/privacy-policy/
• Facebook Audience Network: https://www.facebook.com/about/privacy/
• Index Exchange: https://www.indexexchange.com/privacy/
• Media.net: https://www.media.net/privacy-policy/
• Mobfox: https://www.mobfox.com/privacy-policy/
• OpenX: https://www.openx.com/legal/privacy-policy/
• PubMatic: https://pubmatic.com/legal/privacy/
• Rubicon: https://www.rubicon.com/privacy-policy/
• Sharethrough: https://www.sharethrough.com/privacy-center
• Yieldmo: https://yieldmo.com/privacy-policy/



DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your data with third parties, including our partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.

CATEGORY OF RECIPIENT
1. Advertisers
- Online Identifiers	
Display ads or content that best suit such application, as a part of our Services.

2. Service Providers
We may disclose Personal Data to our service providers, contractors and third parties, including, but not limited to, our cloud and hosting provider, analytics and marketing providers, payment processors (in app payments), fraud prevention and analytic tools, tracking tools, the service providers are limited by contracts which limit their use of the data, and requires implementing security measures. The service providers process the data solely to provide the needed services. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.

3. Any acquirer of our business	
We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.

4. Governmental agencies, or authorized third parties.	
We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.


When we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

G. DATA RETENTION:
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.

Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

H. SECURITY MEASURES:
We take great care in implementing physical, technical, and administrative security measures for the services that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) if we discover a security incident related to your Personal Data.


I. USER RIGHTS
According to data protection and privacy laws may grant you with certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and (vii) withdraw consent (to the extent applicable). If you wish to submit a request to exercise your rights, please fill out the Data Subject Request Form ("DSR") available here and send it to our email at: mohitdhameliya5@gmail.com

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint.

For additional rights under various jurisdictions, please refer to Section ‎II "JURISDICTION-SPECIFIC NOTICES" herein below.

J. OPT OUT OPTIONS
Interest-Based Advertising ("IBA"): We do not sell your Personal Data. Some of our Apps may include providing you with advertisements therefor we may "share" your Personal Data with third parties for personalized advertising purposes. If you wish to opt-out from the sharing of your personal data with third parties for the purpose of cross-contextual interest-based advertising there are many way to do so, as further detailed below. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.

For IBA opt out options on desktop and mobile websites, please visit:

Digital Advertising Alliance (US) https://www.aboutads.info/choices/
Digital Advertising Alliance (Canada) https://youradchoices.ca/en/tools
Digital Advertising Alliance (EU) https://www.youronlinechoices.com/
Network Advertising Initiative https://optout.networkadvertising.org/?c=1
Additional information on opt-out rights and means are available through our CCPA Privacy Notice page link and DSR form: link.


ELIGIBILITY AND CHILDREN PRIVACY:
The Services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a "child" immediately upon discovering that such a user shared information with us. Please contact us at: mohitdhameliya5@gmail.com if you have reason to believe that a child has shared any information with us.

II. JURISDICTION-SPECIFIC NOTICES:
A. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 ("CCPA") effective November 2020, and as amended by the CPRA, effective January 1, 2023.

Please see the CCPA Privacy Notice: link which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.

B. ADDITIONAL NOTICE TO COLORADO RESIDENTS
Under the Colorado Privacy Act ("CPA") if you are a resident of Colorado, acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your personal data are described below.

"Personal Data" as defined in the CPA means: "information that is linked or reasonably linkable to an identified or identifiable individual" and does not include any of the following: publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- "Confidentiality Of Substance Use Disorder Patient Records", Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.

Sensitive Data includes (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. We do not process or collect any sensitive data.

Section ‎‎I.C "DATA SETS WE COLLECT AND FOR WHAT PURPOSE" of the Privacy Policy, we describe our collection and processing of personal data, the categories of personal data that are collected or processed, and the purposes. Additionally, in Section ‎I.F"DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH" details the categories of third-parties the controller shares for business purposes. ###

1. YOUR RIGHTS UNDER CPA:
Here in below, we will detail how consumers can exercise their rights, and appeal such decision, or if we sell the personal data, or sells the personal data for advertising and how to opt-out.


Right to Access/ Right to Know	
You have the right to confirm whether and know the Personal Data we collected on you	

Right to Correction	
You have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.	

Right to Deletion	
You have the right to delete the Personal Data, this right is not absolute and in certain circumstances we may deny such request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) Debug products to identify and repair errors that impair existing intended functionality; (4) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) Comply with the law or legal obligation; (6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action.	

Right to Portability	
You have the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.	

Right to opt out from selling Personal Data	
You have the right to opt out of the sale of your Personal Data for the purposes of targeted advertising, sale to a third party for monetary gain, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer.
You may authorize another person acting on your behalf to opt out, including by broad technical tools, such as DAA, NAI, etc.	
We does not sell your personal information, so we do not offer an opt out. We may "share" personal information with third parties for personalized advertising purposes. You may indicate your choice to opt-out of the sharing of your personal data with third parties for personalized advertising on third party sites as detailed in Section ‎I.K OPT OUT OPTIONS.
To opt out from the use of cookies on our website, please click the "do not sell or share my personal information" in the footer of the website which will enable you to customize the use of cookies on our website.	

Right to opt out from Targeted Advertising	
You have the right to opt out of the sale of your Personal Data for the purposes of targeted advertising, sale to a third party for monetary gain, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer.
You may authorize another person acting on your behalf to opt out, including by broad technical tools, such as DAA, NAI, etc.	
We does not sell your personal information, so we do not offer an opt out. We may "share" personal information with third parties for personalized advertising purposes. You may indicate your choice to opt-out of the sharing of your personal data with third parties for personalized advertising on third party sites as detailed in Section ‎I.K OPT OUT OPTIONS.
To opt out from the use of cookies on our website, please click the "do not sell or share my personal information" in the footer of the website which will enable you to customize the use of cookies on our website.	

Right to opt out from Profiling	
You have the right to opt out of the sale of your Personal Data for the purposes of targeted advertising, sale to a third party for monetary gain, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer.
You may authorize another person acting on your behalf to opt out, including by broad technical tools, such as DAA, NAI, etc.	
We do not profile you, thus we do not need to provide an opt-out.	



Children's Privacy Protection Act Compliance
We'll comply with local laws regarding children's right protection applicable to our product and service (such as Children's Online Privacy Protection Act of the USA). These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, We immediately delete this from our servers. 

If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions. We are in compliance with the requirements of COPPA, we do not collect any personal information from anyone under 13 years and above of age.

Security
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it.

Changes to the Privacy Policy : may, in its sole discretion, change this Privacy Policy from time to time, any and all changes will be reflected here and the date new versions are posted will be stated at the top of this Privacy Policy, so please review it periodically.
We may use the information: we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested.

- Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning. We do not use an SSL certificate- We only provide articles and information. We never ask for personal or private information like email addresses, or credit card numbers.

Cookies
Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your device internal memory.

For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.– Understand and save user's preferences for future visits.
Third-party analytics services
Mods Network Privacy Policy and Cookie Policy: This Privacy Policy illustrates what personal information a user may share with Mods Network ApS,when installing, running and using Mods Network's applications and Caller ID technology (collectively "Services"). It also describes how the Company receives, collects and uses this data. In reference to all data received from the identified persons using the Services ("User"), the Company will diligently respect the User's fundamental legal right to data protection and privacy.
 
Mods Network End User License Agreement: This End User License Agreement ("Agreement") governs your use of the Caller Identification Service ("Service") owned and operated by Mods Network ApS.

This app uses third-party addons that collect varied data, which may include device identifiers, location, mobile network coverage and performance, installed apps list and usage stats.

With the user's consent, this data will be collected and shared with those third-parties for analysis and measurement purposes. The user can change his mind at any time by changing the consent.


Advertising
3rd party ad serving systems allow user data to be utilized for advertising communication purposes displayed in the form of advertisements on Contacts, possibly based on user interests.

We use Google Admob SDK and Facebook SDK for advertisements in our applications. Remember, though, there could be errors in the programming, and sometime programming errors may cause unwanted side effects.

Third - Party Services
We use 3rd party services in our apps. These services collect usage data in compliance with their Privacy Policies. The services are described below.

When this app is in use (or running in the background) we collect and share with our business partners the following device and location data: Precise location data of the device, WiFi signals or Bluetooth Low Energy devices in your proximity, device-based advertising identifiers, app names and/or identifiers, and information about your mobile device such as type of device, operating system version and type, device settings, time zone, carrier, and IP address.

That data may be used for the following purposes:
(a) to customize and measure ads in apps and other advertising;
(b) for app and user analytics;
(c) for disease prevention, and cybersecurity;
(d) for market, civic / government or other research regarding aggregated human foot and traffic patterns, and
(e) to generate proprietary pseudonymized identifiers tied to the information collected for the above purposes.

The information we collect, including device data and identifiers and precise location data, may be shared with third parties including advertising and data companies, brands, and analytics, non-profit, financial, government and research organizations and other businesses that do location-based analytics (and their service providers)."

This Policy applies to Contacts's all Apps. It is our right to change, add, modify, or remove portions of this Privacy Policy at any time for any reason. In case of any changes made in the Privacy Policy, we will update the same on the Website. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes and the amended Privacy Policy.

Contacts is very concerned about safeguarding the confidentiality of your information Please be aware that no security measures that we take to protect your information is absolutely guaranteed to avoid unauthorized access or use of your Non-Personal Information which is impenetrable. We haven't any Intention to Copy or use Others Product use and Access in company's Application.

If you do not agree with the terms, do not download & install & use Contacts's app or any other aspect of Contacts.
If you have any questions and privacy practices, please contact us at mohitdhameliya5@gmail.com
Thank You.