Last updated September 26, 2024

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This privacy policy for Digifoon Group BV (doing business as Qaller) ( 'we', 'us', or 'our' ), describes how and why we might collect, store, use, and/or share ( 'process' ) your information when you use our services ( 'Services' ), such as when you:

• Download and use our mobile application (Qaller), or any other application of ours that links to this privacy policy

• Install or use our Phonebook API Integration (Qaller Phonebook), or any other integration that links to this privacy policy 

• Download and use our click 2 dial browser extension or any other extension of ours that links to this privacy policy

• Engage with us in other related ways, including any sales, marketing, or events

 

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@digifoon.nl.

 

 

SUMMARY

 

This summary provides key points from our privacy policy, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

 

Do we process any sensitive personal information? We do not process sensitive personal information.

 

Do we receive any information from third parties? We may receive information from your Telephony / Cloud PBX provider, in which case we act as a 'data processor' on behalf of your Telephony / Cloud PBX provider. This information is protected by to the privacy policy you agreed with your Telephony / Cloud PBX provider.

We may also receive information from other third parties through API's, for instance phonebook contacts from your CRM, but do so upon your explicit action and consent. Learn more about information collected from other sources.

 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

 

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties, including your Telephony / Cloud PBX provider. Learn more about when and with whom we share your personal information.

 

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

 

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

 

Want to learn more about what we do with any information we collect? Review the privacy policy in full.

 

 

TABLE OF CONTENTS

 

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO WE MAKE UPDATES TO THIS POLICY?

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

 

1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us

 

In Short: We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• phone numbers

• email addresses

• usernames

• passwords

• contact or authentication data

• contact preferences

• job titles

• mailing addresses

• call logs

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Sensitive Information. We do not process sensitive information.

 

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, contacts, microphone, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

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Information collected from other sources

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In Short: We may collect data from public databases, API's or other outside sources.

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In order to enhance our ability to provide services to you, we may obtain information about you from other sources, such as your Telephony / Cloud PBX Provider, public databases, API's and from other third parties. This information may include mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, call logs, social media profiles and custom profiles. The information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

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Google APIs: The use and transfer of information collected from Google APIs to this and any other application will adhere to Google API Services User Data Policy, including the Limited Use requirements.

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2. HOW DO WE PROCESS YOUR INFORMATION?

 

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

 

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent .

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Diagnose problems and/or prevent fraudulent activities

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

 

In legal terms, we are generally the 'data controller' under European data protection laws for the personal information described in this privacy policy which we gather or process independently. This privacy policy does not apply to the personal information we process as a 'data processor' on behalf of our customers (including Telephony / Cloud PBX providers). In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the 'data controller' responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ( 'third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Your Telephony / Cloud PBX service provider

 

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

• Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

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This privacy policy does not apply to the personal information we share as a 'data processor' on behalf of our customers (including Telephony / Cloud PBX providers). In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the 'data controller' responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

 

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

In Short: We may use cookies and other tracking technologies to collect and store your information.

 

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

 

6. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than six (6) months past the termination of the user's account .

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

 

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

8. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short: We do not knowingly collect data from or market to children under 18 years of age.

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us.

 

9. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland , you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

 

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ' HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

 

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority .

 

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner .

 

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ' HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Account Information

 

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact your telephony provider

• Log in to the panel of your telephony provider and update your user account

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

 

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

 

If you have questions or comments about your privacy rights, you may email us at privacy@digifoon.nl.

 

10. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT' ) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

 

11. DO WE MAKE UPDATES TO THIS POLICY?

 

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

 

We may update this privacy policy from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a policy of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

 

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

 

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Ralf Gerrits, by email at privacy@digifoon.nl, or contact us by post at:

 

Digifoon Group BV

Ralf Gerrits

Modemstraat 1

Amsterdam 1033RW

Netherlands

 

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request by contacting us.