True Directory - Caller ID & Call Blocker, Privacy Policy

Last Revised: April 10, 2019

True Directory - Caller ID & Call Blocker. (Company, we, our or us) respects the privacy of the users of our mobile application (App), and is fully committed to protect the personal information that users share with it in connection with the use of our App.

This Privacy Policy (the Privacy Policy) is intended to describe our practices regarding the information we may collect from you (the User or you) when you use our App, the manners in which we may use such information, and the options and rights available to you.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our End User License Agreement (the EULA), available at End User License Agreement which this Privacy Policy is incorporated thereto by reference.

 

1.        Your Consent – please read carefully.

By downloading, installing, accessing and/or using the App you agree to the terms and conditions set forth in this Privacy Policy, including to the collection and processing of your Personal Information (as defined below). If you disagree to any term hereof, you may not download, install, access or use the App, and must promptly and permanently remove the App and any part thereof from your systems and devices, and cease any and all use thereof.

Please note: you are not obligated by law to provide us with any Personal Information. You hereby acknowledge and agree that you are providing us with Personal Information at your own free will, for the purposes described herein, and that we may retain such Personal Information in accordance with this Privacy Policy and any applicable laws and regulations.

 

2.        Which information we may collect on our Users?

We may collect two types of data and information from our Users:

(i)    Non-personal Information, which is non-identifying and non-identifiable information, without particular reference to the identity of the User from which such information was collected; and

(ii)  Personal Information, which is individually identifiable information that identifies an individual, or may with reasonable effort identify an individual, either alone or in combination with other information, or may be of private or sensitive nature.

For the avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

Personal and Non-personal Information which is being gathered in connection with the App may consist of the following:

·       We may automatically collect and the User may automatically provide us with certain technical Non-personal Information and aggregated usage information, such as the User's mobile device brand and model, operating system type and version, country code, which Third Party Services’ applications are installed on the User’s device and User’s uses thereof through the App, the User's manual configurations, 'click-stream', interactions and activities on the App, the period of time the User used the App and related time stamps, crash and error logs, etc.

·       When registering to the App, the User will be asked to provide his/her phone number, which will be used in order to allow us to provide the Users with the App's services and experience.

·       For the App to provide the Advanced Search Functionality and the Matching Functionality, as such terms are defined in the EULA, it may require certain access permissions to information stored on User's device regarding the User’s contacts (Contact Information). Such information may also include Contact Information stored locally by the User relating to certain third-party applications installed on the device (e.g., Skype, WhatsApp, Viber etc.), as well as such contacts social networks IDs. Such Contact Information may be utilized in order to use additional features of the App reliant upon such permissions. If you provide us with personal information about someone else, you confirm that they are aware that you have provided their data and that they consent (and continue to consent as long as you use the Advanced Search Functionality and Matching Functionality) to our processing of such data stored on your device, according to our Privacy Policy.

·       In addition, for the provision of the Advanced Search Functionality and the Functionality, the App may gather public information available online regarding the Users and their contacts.

·       The App may also require for its proper functioning that the User chooses to grant us with certain access permissions to his/her existing Facebook account (FB Account), and thereby provide us with certain information about the User, such as the User’s photo, date of birth and list of friends, as made available by the User through his/her FB Account.

·       For the purpose of securing the app and user authentication access, the app may also collect IMU (inertial measurement unit) from the device’s sensors (e.g. accelerometer, gyroscope).

·       Finally, the User may voluntarily provide us with any other Non-personal and Personal Information, such as certain Contact Information provided by the User when contacting us (and any additional information related to such contacts), and/or other information related to actions performed by the User in connection with the App.

Please Note: We will require to upload your Contact Information to our servers for the purpose of providing you with the App services and experience. 

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the EULA and the Privacy Policy.

 

3.        How Do We Collect and Store Information of Our Users?

We use the following methods of collection:

(i)    We collect Non-personal Information through your use of the App. In other words, we may be aware of your use of the App, and may gather, collect and record the information relating to such usage, either independently or through the help of third-party app as detailed below. We may also collect Non-personal Information through the processing, analysis, aggregation and anonymization of Personal Information provided by you.

(ii)  We collect Personal Information which you provide us voluntarily. For example, we collect Personal Information when you contact us directly for questions or help.

(iii)                    We collect Personal Information which is publicly available from third party online sources. For example, we collect Personal Information from public profiles in social media networks.

(iv)  Third Parties. We may store the Non-personal and Personal Information either independently or with the help of our authorized third-party service providers as detailed below.

 

4.        What are the Purposes of the Collection of Information?

We collect Non-personal and Personal Information in order to provide you with the App services and experience; to enable us to further develop, customize and improve the App based on Users’ common preferences, uses, attributes and anonymized data; to create and provide our research and business partners and affiliates with anonymized aggregated data and/or statistical or inferred Non-personal Information; to enable us to provide our Users with a better user experience, with more relevant and accurate information, services, features and functionalities, and with technical assistance and support; to further improve and develop security and authentication methods and features for the purpose of securing your use of the App; and in order to abide by any applicable law.

We collect Contact Information in order to provide with the Advanced Search Functionality, and Matching Functionality, which allows a User to identify unknown and unfamiliar phone numbers and have its address book contacts automatically associated with corresponding publicly available pictures and social network IDs of such contacts. A number will be associated with a name, picture and/or social network IDs through these functionalities if a sufficient number of independent Users, based on our algorithm, have indicated the same name, picture and/or social network IDs for the relevant number.

 

5.        Where Do We Store Personal Information?

Information regarding the Users will be maintained, processed and stored by the Company and our authorized affiliates and service providers in Europe, USA, India, and as necessary, in secured cloud storage provided by our Third Party Services.

While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that the Company, its affiliates and service providers that store or process your Personal Information on the Company's behalf are each committed to keep it protected and secured, in accordance with this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

You hereby agree to the storage location and transfer of information as described hereunder.

 

6.        Sharing Information with Third Parties

The Company will not share any Personal Information it collects with any third party, except in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the EULA, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User's support requests or other correspondences; (e) to respond to claims that any use of the App violates the rights of third-parties; (f) to protect the rights, property, or personal safety of Company, any of its Users, or the general public; (g) when Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets but solely under appropriate confidentiality obligations; (h) to collect, hold, process and/or manage your Personal Information through Company’s authorized third party service providers (for example, Google analytics platform, and as fully detailed in section 10 of this Privacy Policy), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (i) pursuant to your explicit approval prior to the disclosure; or (j) to cooperate with third parties for the purpose of enhancing the User's experience. All such potential sharing of information shall be made under appropriate and reasonable protective and confidential standards. 

For avoidance of doubt, the Company may transfer and disclose to third parties or otherwise use Non-personal Information at its own discretion.

 

7.        Modification or Deletion of Personal Information

If for any reason you wish us to delete your Personal Information or your Contact Information stored with us, please send us an e-mail to: support@truedirectory.info, and we will make reasonable efforts to delete any such Personal Information pursuant to any applicable privacy laws.

Note that unless you instruct us otherwise, we may retain your Personal Information for the minimal period of time required to provide you with our App, or pursuant to any applicable law.

 

8.        Minors

To use the App, you must be over the age of thirteen (13). The Company does not knowingly collect Personal Information from children under the age of thirteen (13) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the App. In the event that it comes to our knowledge that a person under the age of thirteen (13) is using the App, we may prohibit and block such User from using the App and will make all efforts to promptly delete any Personal Information with respect to such User.

 

9.        Security

We take a great care in implementing and maintaining the security of the App, and our Users’ Personal Information and Contact Information. The Company employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information and Contact Information, and prevent unauthorized use of any such information. However, we do not and cannot guarantee that unauthorized access will never occur.

 

10.     Third Party Software/ Services

The App may utilize certain third party software and/or service, in order to collect and/or process the information detailed herein. Such third party software providers include:

·       Google Analytics, which privacy policy is available at http://www.google.com/intl/en/analytics/privacyoverview.html

·       Google Ads, which privacy policy is available athttps://policies.google.com/technologies/ads

·       Google, which privacy policy is available athttps://policies.google.com/privacy

·       Facebook Analytics, which privacy policy is available at https://developers.facebook.com/products/analytics

·       Facebook , which privacy policy is available at https://www.facebook.com/policies

·       Facebook Ads, which privacy policy is available at https://www.facebook.com/policies/ads

·       Firebase, which privacy policy is available at https://www.firebase.c