SNAPCALL PRIVACY POLICY
Updated November 15th, 2022
PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY BEFORE USING OR ACCESSING ANY PART OF THE SNAPCALL WEBSITE, MOBILE APPLICATION, OR THE RELATED SERVICES
SECT. 1 – LEGAL BASIS AND DATA CONTROLLER
SIEGMA LTD, a company incorporated under the laws of Seychelles, with registered office at Global Gateway 1720, Providence, rue de la perle, Mahe, and care offices in Cite Moussa, Bloc C, 8th Floor, Zalka main road, Metn, Lebanon, business registration no. IBC 065857 (hereinafter “SNAPCALL”, “us”, “we” or “our”), knows how important privacy is to its customers (hereinafter “you” or “your”), and strives to be clear about how personal data are collected, used and disclosed.
This policy (hereinafter the “Privacy Policy”) provides an overview of our privacy practices and tells you about the information that we collect when you access or use our website https://snapcall.app, our mobile application “SNAPCALL” and any other related service that refers to or links to the Privacy Policy (hereinafter, collectively, our “Services”), as well as how we may use or disclose such collected information.
We act as “Data Controller” of your personal data.
SECT. 2 – PRINCIPLES OF THE PROCESSING
We have configured our Services so that the use of personal data is kept to the minimum necessary, and we also adopted reasonable safeguards and technical and organizational measures in order to protect the rights of data subjects and to ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed.
In particular, and without limiting the foregoing, we are also committed to fully complying with the European Regulation no. 2016/679 (General Data Protection Regulation) in case our processing activities are related to the offering of our Services to data subjects in the European Union.
SNAPCALL does not intend to use the Services to collect any information from data users under age of 13.
SECT. 3 – CATEGORIES OF PERSONAL DATA CONCERNED
We may receive from you the following categories of personal data (hereinafter collectively referred to as “Personal Data”):
3.1. information that you submit or upload through the Services, whether through your account registration, dialing or inputting a telephone number, purchasing additional calls or other functionality through in-app purchases, uploading of user content, posting of comments, or otherwise (such information may include, without limitation, to the name, email address, telephone number, contact information, or personal preferences for you or any call recipient for whom you input information into the Services, and may also include payment information or any other information submitted by you or any user through the Services);
3.2. telephone calls generated through the Services, that will necessarily contain any information spoken by any party to the call;
3.3. information about you from third-parties (including from any account through which you log into SNAPCALL, such as Facebook or Google), to which we may have access and aggregate (including but not limited to your public profile information, your email address, or other information possessed by those third-parties); for more information on the type of information those third-parties may collect about you, please review the privacy policies for those third-parties;
3.4. passive information about your device, visit, or use of the Services (including, but not limited to, the date and time of your visit or use of the SNAPCALL application, the length of your visit or use, the specific web pages you visited, your IP address, the type of web browser and operating system used, the address of any website that directed you to the Services), information about your mobile device used to access the Services (including but not limited to phone number, operating system details), and any applicable unique identifiers for you or your device (including but not limited to your devices’ Unique Device Identifier – UDID, any Apple or iOS identifiers – e.g., IDFA or an Advertising Identifier, any Google or Android identifiers – e.g., Android or Google Advertising ID, any Windows identifiers – e.g., Windows Advertising ID, or any other similar identifiers which identify you or your device).
SECT. 4 – DENYING CONFERRAL OF PERSONAL DATA AND RELATING CONSEQUENCES
Conferring your Personal Data to us and, if applicable, also your credit/debit card and bank details, is required in order to fulfil the Purposes (as defined below). Some of the aforementioned data may be indispensable so as to fulfil the obligations imposed by the law or other regulations, or to provide the Services you may have requested. Refusal to disclose certain Personal Data, identified on the applicable form with an asterisk (*), may make it impossible to provide you the Services and/or complete all purchase contract phases and/or fulfil all obligations required by the laws and regulations in force. Therefore, failure to disclose certain Personal Data can, according to individual circumstances, constitute a legitimate and justified reason preventing the supply of our Services.
SECT. 5 – PURPOSES, PROCESSING AND RETENTION
5.1 Purposes. Your Personal Data will be processed by us, individually or in the aggregate, for the following purposes (hereinafter collectively referred to as the “Purposes”):
5.1.a. provide you with the Services;
5.1.b. manage, conclude and process commercial transactions concerning the supply of our Services to you;
5.1.c. conduct internal operations (including troubleshooting, data analysis, testing, research and service improvement)
5.1.d. subject to your separated and specific consent, conduct direct marketing activities, sending you (via regular mail, email, text message, telephone, or otherwise) promotional information or offers regarding your account, the Services, or any other relevant information or offer as determined by SNAPCALL;
5.2 Process. Your Personal Data are mainly processed in electronic format and in certain cases also in paper format.
5.3 Time of retention. Personal Data are stored as long as it is necessary to provide our Services to you, so that information associated with your account will be kept until such account is deleted, subject in any case to your right to withdraw your consent (see below). In case of a legal request or duty, a governmental investigation, or in case of investigations concerning possible violations of our Terms of Services, as well as in case we need to establish, exercise or defend a legal claim, your Personal Data may be accessed, processed and retained for an extended period of time.
SECT. 6 – RECIPIENTS OF PERSONAL DATA
6.1 Disclosure to third-parties. Personal Data will be disclosed and made available to the following third-party companies that provide specific services to SNAPCALL and that will process your data according with the Purposes:
6.1.a. the telecommunications carrier(s) for any party to the telephone calls initiated through the Services, that may have access to information concerning the parties to the telephone call, including telephone number and geographic location;
6.1.b. any SNAPCALL employee, subsidiary, holding company, associated company, affiliate of, or companies controlled by or under common control with SNAPCALL;
6.1.c. companies, agents, or contractors to perform services on our behalf, such as companies that personalize our web pages, analyze our website or usage information, process payments or credit card transactions, fulfill or ship orders, collect debts, analyze or enhance the data collected by the Services (including user’s interaction with the Services), or otherwise assist SNAPCALL in better serving the Services’ users;
6.1.d. SNAPCALL may disclose your information to third-parties for marketing purposes. These third-parties may contact you via any method of contact you provide to SNAPCALL.
6.2 Legal requests. Personal Data may be accessed, preserved and shared in response to a request from judicial or governmental authorities or agencies, if we have a good faith belief that the law requires us to do so, as well as when we have a good faith belief it is necessary to detect, prevent and address fraud and other illegal activity, to protect us, you and others persons, or to prevent death or imminent bodily harm.
6.3 Transfer abroad. Your Personal Data will be processed in Gravelines (France) and, if a transfer of your Personal Data is necessary to achieve the Purposes, we will acquire your previous consent, after having informed you about any appropriate or suitable safeguard implemented by us or, if you are an EU citizen, about the existence of an adequacy decision by the European Commission. In any case your Personal Data will not be transferred to recipients in a countries or international organizations other than those which ensure that the level of privacy protection is compliant with the applicable laws and regulations.
6.4 General. Exception for the above, no Personal Data shall be disclosed, assigned or otherwise transferred to third-parties for purposes not permitted by law or without informing you and obtaining your consent in advance or, if applicable, unless having removed your name and any other personally identifying information or combined it with other people’s data in a way that it no longer personally identifies you.
SECT. 7 – YOUR RIGHTS
7.1 Right of access. You are always entitled to receive confirmation as to whether or not your Personal Data are being processed and, where that is the case, access and receive copy of such Personal Data in an intelligible form. Furthermore, you are also entitled to receive information concerning: the purposes of the processing; the categories of Personal Data concerned; the recipients (or categories thereof) to whom the Personal Data have been or will be disclosed; where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from us rectification or erasure of personal data or restriction of processing of your Personal Data or to object to such processing; the right to lodge a complaint with a supervisory authority; the source of the Personal Data; the existence of automated decision-making; where Personal Data are transferred to a third country or to an international organization, the appropriate safeguards relating to the transfer
7.2 Right to withdraw consent. You are always entitled to withdraw, at any time, your consent to the processing of your Personal Data, both on legitimate grounds (even though they are relevant to the purpose of the collection) and if the processing is carried out for direct marketing purpose. The preceding will not affect the lawfulness of processing based on consent before the withdrawal.
7.3 Right to rectification, erasure and restriction. You are always entitled to obtain from us, without undue delay: the rectification or integration of your Personal Data that are inaccurate or incomplete; the erasure of your Personal Data that have been processed unlawfully or whose retention is unnecessary for the Purposes; the restriction of processing, in case you challenge either the accuracy of your Personal data or the lawfulness of the processing, or in case we no longer need the Personal Data for the Purposes, but they are required by you for the establishment, exercise or defense of a legal claim.
7.4 Right to data portability. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format, as well as the right to transmit those data to another controller without hindrance from us, where technically feasible.
7.5 Right to lodge a complaint before a European supervisory authority. If you are an EU citizen, you have the right to lodge a complaint with a Data Protection Supervisory Authority located in the Member State of your habitual residence.
7.6 Contacts. You are entitled to exercise your rights at any moment in time, within the terms and conditions provided by the law, sending such requests by e-mail to: info@snapcall.app.
SECT. 8 – CHANGES AND UPDATES TO THE PRIVACY POLICY
We may amend or simply update all or part of this Privacy Policy, also when amendments are made to laws or regulations that govern protection of personal data and your rights. Changes and updates to this Privacy Policy will be notified to you as soon as the same are adopted and shall be binding once posted on the website https://snapcall.app in this section. We therefore recommend you access this section regularly in order to check the most recent and updated version of this Privacy Policy. You can check the “effective date” posted at the top to see when the Privacy Policy was last updated.
If you have questions or concerns regarding this statement, please Contact Us.
SIEGMA LTD
Address: Zalka main str., Cite Moussa Center, Bloc C, 8th Floor, Metn, Lebanon.
Phone: +961 1 886 386
Email: info@snapcall.app
Registration no: IBC 065857