I. INTRODUCTION Millcroft Management Inc. ("we," "us" or "our") takes your privacy seriously. This Privacy policy ("Privacy policy") explains our data protection policy and describes the types of information we may process when you install and/or use "
Call Recorder" software application for mobile devices (the "App", "our App") and explains how we and some of the companies we cooperate while processing that information.
When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.
It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.
Our Privacy policy applies to all users, and others who access the App ("Users").
For the purposes of the GDPR, we are the data controller, unless otherwise stated.
PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.
II. INFORMATION WE PROCESS There are several categories of information that can be processed.
Information that you submit We ask for and collect the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.
- Authorization and/or Account Information. When you sign up for an account, we require your mobile phone number.
- Activity Information, e.g. your contacts, call logs and recordings of calls, origination and termination points (i.e. to/from numbers), history of calls made with the help of the App. Upon your consent we also may have technical access to the contact list on your device.
We process this information by ourselves. However, we may also engage third parties for storing this personal data in order to fulfill obligations and deliver the full scope of services. This personal data can be deleted either by these third parties in accordance with our instructions or by our own means.
Information That Is Processed Automatically
When you use the App, some information about your device and your user behaviour may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data we may not be able to provide you with all features of the App.
We use third-party automatic data processing technologies to analyze certain information sent by your device via our App (advertising or analytics tools). Some of them launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first time launch the App.
- Device Details. When you use a mobile device (tablet / phone / smartwatch) to access our App, some of details about your device are reported, including "device identifiers". Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.What data can be processed:
- Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.
- Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser.
- Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. "coffee shop").
- Device identifiers: Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices, user identifiers (if they are set up by the App's developer).
- Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analyzes. Some services also record the list of applications and/or processes which are installed or run on your device.
- Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access a specific areas or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
- Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.
- Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was "clicked" or if it was shown as a "conversion" event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.
- In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).
Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).
Payment Information
Our e-commerce provider (Apple) is responsible for billing, processing and charging for the in-app purchases, handles your personal information and keeps it absolutely safe and secure. We cannot access or use you credit or debit card information. You may access the applicable "in-app" purchase rules and policies directly from the app stores.
III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA
Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:
(a)
To make our service available. We use information that you submit and information that is processed automatically to provide you with all requested services.
(b)
To improve, test and monitor the effectiveness of our App. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.
(c)
To provide you with interest-based (behavioral) advertising or other targeted content. We may use information information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.
(d)
To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
(e)
To prevent fraud and spam, to enforce of law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.
If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.
IV. SHARING OF YOUR INFORMATION
We will share your information with third parties only in the ways that are described in this Privacy policy. Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your personal data, we cannot guarantee the security of any information transmitted from the App directly to such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.
We will not rent or sell your personal data to any third parties, but we may share your information from tools like log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties' tracking technologies or how they may be used.
We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.
We may engage the following third parties in order to provide us with necessary infrastructure for delivery and improvement of our services: