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PRIVACY  POLICY
Effective Date: [20/03/2023]

Scope of this Privacy Policy

Information Collection

Purpose of Information Collection

Legal Basis

Information Sharing and Disclosure

Third Party Sites and Privacy Policies

Cookies, Web Beacons, and Other Similar Technologies

Information Security

Retention of Information

Data Subject Rights

Privacy Rights in Other Jurisdictions

Updates to this Privacy Policy

Contact Us support.all-recovery@top-apps.com

Scope of this Privacy Policy

CallApp Software LTD and its affiliates (“we”, “us”, or “our”, as applicable) respect your privacy and are committed to protecting your personal information. This Privacy Policy describes how we collect and use your information, and it applies to information collected by us in connection with your visit to our website and your use of the application and/or services provided by us (collectively, the “Service”). Some of the information collected by us may be “Personal Information” – information that identifies you personally.

This Privacy Policy forms an integral part of our Terms of Service. By using the Service, you acknowledge that you have reviewed both our Terms of Service and this Privacy Policy and agree to be bound by them. Please be aware that this Privacy Policy does not apply to the practices of any third parties to whom we may disclose Personal Information pursuant to the terms of this Privacy Policy.

 

This Privacy Policy may be updated from time to time. If we make any substantial changes in the manner we use your Personal Information, we will provide a proper notice.

 

This Privacy Policy shall apply to any personal information collected by us, regardless of the manner in which it was obtained.

 

1.  Information Collection

Information Provided to Us. We collect the information that you provide when you subscribe to the Service or otherwise interact with us on our application or website, and information that is provided to us in any other manner, such as your name, gender, address, email address, phone number, date of birth, credit card or other financial account information, sign-in information, feedback.

Information Collected Automatically. We automatically collect certain types of information when you interact with us on our application or website. This information may include geo-location, IP address, device ID or unique identifier, device details (including: device manufacturer and type, device model and name, device hardware and settings), keywords and meta data of incoming and outgoing calls and messages, supported apps information, ID for advertising, ad data, operating system and operator. The information we receive may depend on your browser or device settings. The information we receive from your device and/or web browser may or may not be Personal Information, however we may combine it with other information in an attempt to identify you or we may combine it with information that does identify you.

 

Cookies, Web Beacons, and Similar Technologies. We may use industry-wide technologies such as cookies, web beacons, and similar technologies, which store certain local information on your device, for various reasons, such as to help us learn more about how you use the Service and enhance your experience. The information collected by such cookie, web beacon, or similar technology may include IP address, device ID, information about browser or operating system, and depending on device settings (e.g. latitude and/or longitude). Please see Section 6 below for further detail on our use of cookies and similar technologies.

 

Opting Out. You can prevent collection of your information by not providing such information, and by ceasing your use of the Service, visit of our website and interaction with us. You may also contact us using the contact details provided below in Section 12.

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2.  Purpose of Information Collection.

We collect and process your information, including Personal Information, in order to:

  • Offer the Service to you and other potential users of the Service;

  • Sign you up and provide you the Service;

  • Address Service users' queries, questions, requests, comments, responses, etc;

  • Discuss and consider business interactions and proposals of any kind;

  • Study Service users' interaction with the Service and/or to study the behavior of users in the context of such use, and assess the Service performance and/or effectiveness;

  • Understand traffic to our website and/or improve our website’s functionality, content and usability; and

  • To comply with any legal obligation we are subject to under applicable law, for example credit or fraud prevention.

3.  Legal Basis

In addition to your consent to the collection and processing of information, including Personal Information, for the various purposes mentioned above (consent which you have given us and can revoke at any time), our collection and processing is also based on the following:

  • If you subscribe to our services, our legal basis for processing your Personal Information is that it is necessary for the performance of the contract between you and us for the provision of the Service.

  • If we obtain your personal information through your visit to our website, interaction with us or any other manner, our legal basis for processing your personal information is our legitimate interest in providing and developing the Service and conducting an effective interaction with our current and prospective users.

  • If we use the Personal Information for advertising or promotional activities, we will request your specific, freely given and separate consent to such use. You may choose at any time to unsubscribe from our promotional materials by contacting us or by clicking the unsubscribe link at the bottom of each promotional material.

4. Information Sharing and Disclosure

We are committed to protecting your privacy and will not share or disclose information about you, including Personal Information, other than in connection with or under the following circumstances and/or terms:

  • When we have your consent to share such information;

  • When we need to share your information in order to provide the Service;

  • When we need to deliver the information to service providers, including infrastructure providers, who work on our behalf. Such service providers are prohibited from using that information for any other purpose;

  • For the purpose of analysis and statistics, provided that such disclosure is done in a non-personally identifiable manner;

  • In the event of sale or transfer, in whole or in part, of our or any of our affiliates’ shares or assets, in the event of merger, or in case of negotiations with respect to the foregoing;

  • If required to do so by applicable law, or in the good-faith belief that (i) disclosure is necessary to comply with any applicable law or respond to any court order or equivalent, or where in reasonable belief an action is needed in order to protect the personal safety of any individual; and (ii) such disclosure is appropriate or necessary in order to enforce the Terms and Conditions, this Privacy Policy, or take precautions against liabilities, investigate and defend against any third party claims or allegations, protect the security or integrity of our website and the Service and servers and protect our rights and property.

  • With third-party partners for the purpose of serving interest-based content and targeted and non-targeted advertising. We may be compensated for information, including Personal Information, shared with third-party partners. You will not receive any compensation in connection with the sharing of your information. Our third-party partners may also collect information directly from your device, such as IP address, device ID, browser, operating system and geographic location data (depending on your device settings). Our partners may combine such information with information from other sources and may place or recognize unique cookies on your browser.

 

All Personal Information may be transferred as described above to recipients in countries around the world, which may be located outside the EU / EEA and in some cases may have a lower level of protection than that within the EU / EEA. When transferring Personal Information to countries outside the EU / EEA that did not receive an adequacy decision by the European Commission, we use Standard Contractual Clauses issued by the European Commission to ensure a sufficient level of protection for your Personal Information. Without derogating from the foregoing, upon your information being shared with service providers or third-party partners as described above, we will treat this information according to the terms of this Privacy Policy and the relevant service provider or third-party partner will treat it according to the terms of its own privacy policy.

If you would like to request further details about the third parties to which your information may have been disclosed,

please contact us at support.all-recovery@top-apps.com.

 

5. Third Party Sites and Privacy Policies

The Service may contain links to third-party websites. We are not responsible or liable for the privacy policies, practices, and information collected, received, stored, used, or shared by third-party websites. We encourage you to carefully read the privacy policies and the terms of use or service of third-party websites prior to submitting any information, including Personal Information.

6. Cookies, Web Beacons, and Other Similar Technologies

​We may use industry-wide technologies such as cookies (a string of information that can be stored on your device) or other similar tracking technologies, which store certain local information on your device to help us learn more about how you use the Service, enhance your experience, save your preferences for future use of the Service or visits to our website, and compile aggregate data about traffic to our website and interaction with the Service. You may adjust your device, operating system or web browser settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features of the Service. It is possible to prohibit and/or delete the cookies, inter alia, via the “Settings” option on your device.

 

The information collected by cookies or similar technology depends on your browser settings and may include IP address, device ID, information about browser or operating system, and depending on device settings, geographic location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the device.

 

We also use web beacons to further assist our understanding of the behavior and preferences of our users. Web beacons are transparent graphic images placed on our website or in our emails to establish an appreciation of the behavior of the website visitor or of the recipient of an email, including by allowing us to know when an email has been opened. While you are unable to opt out of our use of web beacons, your policies with respect to cookies may limit our use of web beacons.

 

We also allow third-party companies, including Google Analytics and others, to use cookies and spotlight tags to collect certain information when you visit our website or use the Service (“Usage Information”). Usage Information helps us measure the performance of our online advertising campaigns, analyze users’ activity with the Service and with other business purposes. Usage Information may include IP address, device ID, information about browser or operating system, and depending on device settings, geographic location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the device. Similarly to altering your cookies settings, you can also install the Google Analytics Opt-out Add-on Ads Settings, which prevents Google Analytics from collecting information.

 

7. Information Security

​We use reasonable and appropriate efforts, applying administrative, physical, electronic and procedural safeguards, to maintain and protect the confidentiality and security of all information collected by us, including your Personal Information. We allow only authorized personnel to access your Personal Information, on a need-to-know basis.

 

We may use cloud service providers for our servers and\or storage. In such cases, we rely on the safeguards applied by the cloud service provider for the physical security, the integrity, redundancy and the data protection of the data which relates to your information.

Although we make good faith efforts to store your information in a secure operating environment, we cannot guarantee the security and confidentiality of your information and you do so at your own risk. We encourage you to exercise discretion regarding the Personal Information you choose to disclose.

In the event that we become aware of any accidental or unauthorized access to your information, we will notify you of such data breach in accordance with applicable laws.

​​8. Retention of Information

​If you subscribe to the Services, provide your information on your visit to our website, or interact with us in any other manner, or if we obtain your information in any other manner, we will store the information we collect about you for as long as is necessary for the purpose(s) for which we collected it and in accordance with applicable law and legitimate business interests. This includes accommodating your choices regarding marketing and promotional materials.

 

When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements. If we are required to retain your information under applicable law, then we will implement appropriate measures to safeguard its confidentiality.

 

If you will request the deletion of your information that is stored on our systems, your information will be deleted from our active database, but a copy of such information, generated by our automated computer archival back-up systems, may remain in our archives for a period of up to 3 additional months. Such copy will not be displayed on our active database and be used for back-up purposes only. Aggregated and/or anonymized information derived from your use of the Service may remain on our systems indefinitely.

 

If you would like more information on our retention practices, including how to access, update, or request the deletion of your information that is stored on our systems, please contact us at the contact details provided below in Section 12, detailing your request. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law.

 

9. Data Subject Rights

​Subject to any local or national law exceptions, if you are in the EEA and your Personal Information is processed by us, you have the right to: (i) withdraw your consent to the processing of your Personal Information if such processing is based on consent; (ii) request the rectification or deletion of your Personal Information. However, please note that deletion could mean that we cannot provide you the Service; (iii) request a copy of your Personal Information from our record; and (iv) request the limitation or termination of use of your Personal Information for certain purposes.

 

You may contact us using the contact details provided below in Section 12 to exercise any of the rights which apply to you. We may need to request specific information from you to help us confirm your identity.

10. Privacy Rights in Other Jurisdictions

​You may have rights in relation to your Personal Information under applicable data protection laws in other jurisdictions. If you wish to exercise any such rights, please contact us using the contact information below in Section 12.

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11. Updates to this Privacy Policy

​We may update this Privacy Policy. We will post prominently any Privacy Policy changes on our website and our application. To the extent permissible under applicable law, your continued use of our website and/or the Service will signify your express agreement to such updated Privacy Policy.

We encourage you to periodically check for Privacy Policy updates. For your convenience, whenever this Privacy Policy is changed, we will update the “Effective Date” at the top of this page.

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12. Contact Us

​If you have a question or complaint about this Privacy Policy or our information collection practices,

please contact us at email: support.all-recovery@top-apps.com.

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