CallMeChat Privacy Policy

Effective Date: Nov 22, 2022

1. Introduction

1.1. This Policy is an integral part to the CallMeChat Terms of Services. All the definitions herein have the same meanings as they identified by the Terms. Also, the term “Service” applies in respect of the services are available through the Application. In some cases, the “Service” has the same meaning as the “Application”.

1.2. We undertake a commitment to protect the privacy of the personal data subjects ("you" or the "user"); herein we explain in what way your personal data, i.e., any data connected to you as an identifiable or identified physical person, that we might store about you, can be accumulated, held, used, disclosed, and deleted (any and all termed as "processing").

According to the Policy herein, we can use your personal information to:

(a) Ascertain Users Identity;
(b) Provide our Service to the User;
(c) Inform the User of the updates and promotions;
(d) Protect, maintain, and improve the Service;
(e) Defend both our legal interests and Users’.

1.3. This Policy is only applicable to the data, which we process. It is not applicable to the activities of companies, which we don't control or possess, or staff that is not subordinated to us. Information, which is available by means of our Service, might have links to 3rd-party websites or applications. Thereby, any data you provide to such websites will fall under their privacy policies.

Please, make sure to acquaint yourself with the data protection policies of all 3rd-party applications and/or websites you visit. Those websites are responsible for the protection of any information you provide them with. Thus, we can't be disciplined for their unauthorized usage of your personal information.

1.4. We might update the Policy from time to time, and you will be notified of alterations to the Policy by means of posting at https://callmechat.com/privacy-policy.

2. Your Personal Information and the Way We Use It

2.1. We may process the login details you provide.

While registering your account you provide Us with your full name, nickname, email, birthdate, and gender. You may further provide a piece of additional information to complete your account details: your city of residence, region, country, and Account Photo. You are the data source. These details are necessary for you to have access to the Service and to use it. Your consent to processing personal data, as well as the execution of a contract between us, and/or taking measures, as per your request to conclude such a contract, constitute the legal background for such processing.

2.2. We may process your software or PC data.

All personal information, which is sent by default by User’s installed software, including without limitation: IP-address of the User, files content of cookies, personal information, which is conveyed by the browser or different software allowing you to have access to our Service, and also, time/date and the URL of your requested page, an ID of your digital wallet, CSP name, exact time/date of the sent SMS-message, as well as it's content. When you purchase products or/and services from us, we might collect your name and surname, a partial number of your credit card, and/or other payment details. Your consent and contract performance between us and/or taking measures, as per your request, to conclude such a contract, constitute the legal bases for such data processing.

We put all commercially reasonable efforts to be convinced that the number of your credit card and other payment details is kept highly confidential through the use of only those third-party billing services, which meet GDPR and have branch standard encryption technology for your credit card number protection from unauthorized usage.

2.3. We may process your utilization data.

Utilization data is the information of your use of the Service. Utilization data is commonly identifying information, which is non-personal and is made available by servers, web browsers, and such services, like Google Analytics, for instance, the type of browser, language choice, referring website, as well as the time of every visit. Among the other information we may have access to, there is the way you use the Service (for example, search inquiry), your rough location, and so on.

Utilization data might include the following:

1) Data collected mostly for behavior statistics, email, and business intelligence campaigns ("business analytics "). We collect the traffic data of the Service by means of Google Analytics.
2) Data, which is gathered mostly for the reasons of curb fraud and technical security or monitoring errors ("technical info").

The legal ground for such processing is our lawful interests and/or by third-parties, particularly to keep track of the Service quality, to make improvements to the Service, and to avoid, diagnose and track down fraud, acts of crime or other wrongful use of the Service, as well as to prevent safety concerns.

2.4. We may process the communication data of yours.

Communication data may be defined as any information, which is stored or related to messages you send to us or generate by means of the Service herein.

Communication data consists of:

1) All the requests, messages, and/or other correspondence with our Customer Support that may take place by emails, support tickets, in the course of a dispute review process, or using other means of communication.
2) All your correspondence and enclosure or other data, which is generated mainly by your communications with other Users.

Communication data can consist of a full name, nickname, email, and IP address, avatar, video and audio files, and for manual ID verification: User’s photo, User’s personal ID photo, as well as the photo of the utility bill of the User or associated document. Also, our system can take screenshots of your correspondence with other Users in random order. The reasons for processing your communication data may be for communicating with you or/and keeping records to investigate and settle disputes, keep from wrongdoing and abominable behavior, provide better service to our customers and make improvements to our Service. Our lawful interests constitute the legal background for such processing, particularly, proper administration of the Service herein, as well as our business, prevention of amoral and/or disorderly conduct.

2.5. Your notification data may be processed.

Notification data means the information provided by you in order to subscribe to our SMS or email notifications and/or newsletters. The following may be included in the notification data: your email, full name, and username, phone number. We process the notification data to send you the newsletters and/or due notifications. Your consent constitutes the legal background for this processing. To unsubscribe anytime, you can follow the unsubscribe link in the email, uncheck the checkbox in the Profile Settings or contact us.

2.6. Your personal information may be processed when required for the establishment, defense, or exercise of lawful claims, be it during legal procedures or outside the legal proceedings.

It may refer to the use of information for statutory compliance, safety management, and inspection, litigation, or pre-litigation. You give consent for using your personal information as evidence that you actually used our Service in the event, we have a controversy with the User. The legitimate grounds for such processing are our legal interests, particularly the assertion and defense of our legitimate rights, your legitimate rights, as well as the legitimate rights of others.

Complementary to the particular purposes, which are outlined in the 2nd para hereof, and in respect of which we might process your information, the other reasons for our processing of your information are aimed to protect fundamental interests of yours or of another physical person.

The validity of the personal information, which you provide, is not determined by the company. We expect you to deliver accurate personal information, so we maintain it current. Please make sure not to provide us with any non-mandatory personal information.

3. Information that You Decide to Display Publicly through Our Service

3.1. Several Users often choose to supply openly personal or sensitive information while using our Service. It happens when optional fields in the profile are used, during communications in chats, or when a conversation was changed from private to public. Such information that is posted of your free will in the Service sections visible to the public is treated as public, even though it is in its essence private or sensitive. When publicly posting information of this kind on your accord, it indicates that you have no longer privacy rights for it.

3.2. Please, note that if you select to provide identifiable information when using specific public functions of the Service herein, this information might be used or disclosed by individuals, who read it, to 3rd parties without our control or your awareness of it, as well as search engines might index such information. For this reason, we prompt you to give it a second thought before including any peculiar information you might consider as private, which is either created by you or submitted via our Service.

4. Transfer of Your Personal data to 3rd Parties

4.1. Expect in accordance with the law, the Company takes on the obligation not to sell, lease out, exchange, or otherwise share personal information of Users to 3rd parties unless explicit consent is obtained from the Users.

4.2. The following circumstances empower us to provide 3rd parties with access to the User’s personal information:

4.2.1. Explicit consent has been received from a user to share his/her personal information to 3rd parties;

4.2.2. Personal data transfer is needed for the use of the Service by the User. In such cases, we fulfill the demand with a 3rd party in order to keep your personal information confidential.

4.3. To work on email campaigns, business intelligence, and behavior statistics, we make use of the service called "Google Analytics," which is provided by Google LLC and is situated in the US. Among the information, which we supply to Google Analytics, there is your IP address, as well as data used by Google Analytics for gathering information about the Service usage by you.

4.4. Together with certain disclosures of personal information described in the 4th para., your information might also be disclosed:

(a) to our lawyers, auditors, accountants, counselors and other expert advisors in the extent which is justifiably needed for gaining expert advice or resolving legal controversy or risks;
(b) in cases when a disclosure is required for meeting a contractual obligation. We are subject to, or for protection of your fundamental interests and/or fundamental interests of a 3rd-party.
(с) when required to meet the applicable legislation or in the context of an acquisition, merger, or asset disposition by giving notice to users.

5. Links from 3rd Party Websites

5.1. 3rd-party websites might have links to the Service herein. We apply all commercially reasonable efforts for verifying that they have no connection to any illegal activities and meet GDPR. Still, we can’t control such websites, and they come under this Privacy Policy. It is likely, though, that they have their own terms conditions of use and notices of privacy practices. We are not responsible for such websites. You acknowledge and agree that accessing ad using such websites is only at your risk. You are responsible for checking the notices of privacy practices of such websites to understand in what way they handle your personal data.

6. Children’s Privacy Protection

6.1. Although the Service herein is not for the use by people younger than 18, we understand that children can make an effort to access it. Personal information is collected from the children younger than 18 unintentionally, and we take every measure to prevent such access to the Service herein by people of the age limit mentioned above. In case you are a guardian or a parent and think that your child may be using the Service herein, please, contact us. Prior to deleting any data, we can request a proof of identity to avid the felonious deletion of the account details. In case we find out that children use our Service, their information will be removed with reasonable expediency. You acknowledge and agree that Users’ ID information is accepted “AS IS” for verifying their age – we are not liable in case the information is misleading.

For more information regarding our Retention Policy, please, refer to the 9th para.

7. Illegal Activity

7.1. We have authority to examine complaints or violations reported to us, as well as to take measures we consider as expedient, including, reporting suspected illegal activities to enforcement, regulatory bodies, or other 3rd parties and disclosing the information, which is required to such people or bodies in relation to your profile, email, history of use, materials posted, traffic details, and IP addresses.

8. International Communication of Your Personal Information

8.1. Your information is initially stored within the EEA (European Economic Area). Some service functions and requirements include, though, sending your data to 3rd-party service providers, which are beyond the EEA. All such service providers are described in the 4th para. above. Unless the above-mentioned service providers are introduced in a country guaranteeing a proper protection level as defined by Regulation (EU) 2016/679, the transfers in question will be subject to the standard data security clauses.

9. Storing and Removing Personal Data

9.1. Personal information, which we process for any purpose, will not be stored for a longer time than is required for this purpose.

9.2. Users can request the removal of their account via our Service.

9.3. We will store and remove your personal information in the following sequence:

9.3.1. For the users who have removed their account:

(a) We will delete your confirming identity analytics data following 30 days period after account deletion.
(b) We will hide your public profile after 30 days since you delete your account.
(c) We will remove your communication data 5 years after the deletion of your account. The screenshots taken randomly by our system for tracking and preventing unlawful and abominable User behavior are being overwritten all the time and are held for 90 days.
(d) We will remove your login details, account and ID data, technical, and trade data 5 years after the deletion of your account.

9.4. In certain instances, we are not able to specify beforehand the time periods during which your personal information will be kept. In such instances, the period of retention is determined according to the time period during which having access to the data is essential to us for providing services, getting payment, addressing customer support matters, other issues, or in the event of other legal or auditing reasons.

9.5. In spite of other provisions of the 9th para., we might hold your personal information for a rational time period, and when such storing is needed to meet a legal foundation, we are subject to, for protecting your fundamental interests or the fundamental interests of another physical person.

10. Your Rights

In the 10th para., we summarize the basic rights you have pursuant to data protection law. Several rights happen to be complex and can include limitations based on the warrants of law for information processing, and several details are not included in the summary. Respectively, you are advised to read the corresponding directories and laws from the oversight bodies to find a complete explanation of such rights.

10.1. Below are your basic rights according to data protection law:

(a) access right;

You are entitled to confirm, whether we can process your personal information or not, and, if we do, access to your personal information. If such an act doesn’t prejudice the rights and freedoms of other people, we will be able to deliver you a copy of your data. The first copy is provided for free, whereas extra copies maybe for a fee. To access your personal data, you can get in touch with our Customer Support.

(b) right to rectification;

You can request to correct any misinformation about you and, considering the aim of processing, to complete any partial personal information about you.

You can request to erase your personal information. Our policy for keeping and removing personal data is described in the 9th para. above.

(d) right to answer back the processing;

You are entitled to answer back to your information processing by our Service for reasons of your peculiar situation, but only when there is a lawful excuse for processing like this, that it is required for conducting a task, which is done for the public benefit or under the procedure outlined by any official body assigned to us; or the purposes of the lawful rights which we or any 3rdparty pursue. In case such objection is made, we terminate the processing of your data if no reasonable, lawful excuse for this processing is provided by us to outweigh your interests or rights and freedoms; otherwise, such processing is for the government circles, exercise, or protection of lawful claims.

(e) the right to limitation;

You are entitled to ask for the termination of your data processing in peculiar cases, for example, when your right to object is exercised as specified above, or when you fight for accuracy of your information, that is processed by us.

(f) data portability right;

To the effect that your consent is the legal background for us to process your information, and we conduct such processing with the help of automated means, you may request us to supply you with your information in a structured way, which is in a generally valid and machine recognizable format. This right is not applied, though, in cases, when may prejudice rights and freedoms of others.

(g) right to complain to an oversight body;

If you think that the information about you, which we process, breaches data protection laws, you are entitled to complain to an oversight body liable for data protection. Your complaint may be lodged in the EU member state of your permanent residency, workplace, or the place of the suspected offense.

(h) withdraw consent right.

To the effect that the legal background for your personal information processing the consent, you are entitled to withdraw your consent anytime. Such withdrawal shall not affect the legitimacy of processing prior to the withdrawal.

Without prejudice to the abovementioned, in case of justified doubts regarding the user identity, who exercises his/her rights described in the 10th para., or if we consider it necessary because of security reasons, we might request such a user to provide extra information, and be it further, take all rational measures required to prove the user identity.

You can enforce your rights in connection with your personal information by means of contacting Customer Support. Regarding the "Right to erasure," via our Service, users also can request their account to be deleted.

11. Cookie Policy

11.1. Our Cookies Policy is available at: https://callmechat.com/cookies-policy

12. California Online Privacy Protection Act Notice.

12.1 California Civil Code Section 1798.83 also permits our users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.

Privacy Notice for Users who are California residents, you have the following rights under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

a. You have the right to request that we disclose certain information to you and explain how we have collected, used, and shared your personal information over the past 12 months.
b. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

12.2. On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like us to disclose how we respond to “Do Not Track Signals”; and whether third parties collect personally identifiable information about users when they visit us.

(1) We do not track users, who do not interact with its sharing functionality across the web, and therefore do not use “do not track” signals.

(2) We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies without separate member consent.

12.3. This section supplements the Privacy Policy and applies solely to California residents (excluding our personnel). The table below describes how we process California users’ personal information (excluding our personnel), based on definitions laid out in the California Consumer Privacy Act ("CCPA").

CCPA Category	Legal Basis	Purpose of collection	Source
CCPA Categories A and B	Contractual necessity	To provide you with social networking service	You provide your name, and date of birth to us. We obtain location data from the device that you use to access the service
CCPA Categories C, H, I, J	Consent	To facilitate networking opportunities	You provide this information to us
CCPA Categories B and H	Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard users of the site.	To verify your identity and prevent fraud and to ensure the safety and security of Users	You provide this information to us
CCPA Category B)	Consent	To send you marketing information about our offers and services (if you give us permission)	You provide this information to us (if you give us permission)
CCPA Category G	Legitimate interests – it is in our legitimate interests to provide this functionality as part of the services	To show you other Users near you	We obtain this information from the device that you use to access the service (if you give us permission)
CCPA Categories F and H	Legitimate interests – it is in our interests to analyze the way in which Users are accessing and using our services so that we can further develop the App, implement security measures and improve the service	To carry out research and analysis to help us improve the App	You provide photos and videos to us. We obtain the log and usage information from the device that you use to access the service
CCPA Categories B and F	Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems	To respond to correspondence and queries that you submit to us, including social media queries	You provide your username, email address, and social media name to us when you contact us
CCPA Categories B and F	Legitimate interests – it is in our legitimate interests to prevent unauthorized behavior and to maintain the safety and security of our services	To block accounts as part of our anti-spam procedures	You provide your phone number, and username to us. We obtain the other information from the device that you use to access the service
CCPA Categories A, B, C, E, and H	Legitimate interests - it is in our legitimate interests to prevent unauthorized behavior and to maintain the safety and integrity of our services	To investigate and block Users for reported infringements of our Terms and Conditions of Use	You provide your name, profile content, and activities on the App to us
CCPA Categories A, B, C, and H	Legitimate interests – it is in our legitimate interests to facilitate access to our services	To enable Users to create and enhance their profile and log into the App via third party accounts	We may obtain this information from providers of any other accounts you use to log in or connect with your account
CCPA Categories A, C, and G	Legitimate interests – it is in our legitimate interests to target advertisements so that Users see relevant advertisements and to allow us to generate income from advertising revenue	To serve promo cards and advertisements on the App (if you give us permission)	We obtain age, gender, and profile information from you, and location data from the device that you use to access the service (if you give us permission)
CCPA Categories F and H	Legitimate interests – it is in our legitimate interests to provide these functionalities as part of the services Legitimate interests – it is in our legitimate interests to protect our legal rights, defend legal claims, and protect our users and third parties from harm	To enable video and audio call functions, and the sending of images and video To defend legal claims, protect legal rights, and protect people from harm	We obtain this information from the device that you use to access the service This information may be obtained directly from you, from your device, or from third parties, depending on the information involved

12.4. Disclosure of Information.

Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:

Circumstances where data may be disclosed	Disclosed data
Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below.	This could include all data, including all CCPA Categories listed above
Moderators – To monitor activity on the App and approve content.	Name and user registration details, profile information, the content of messages and photographs (CCPA Categories A, B, C, E, and H)
Law and Harm – As we mentioned in the Terms & Conditions, we think it is very important that all Users behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement inquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behavior or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases, we may raise or waive any legal objection or right available to us.	This could include any personal data that we hold on you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above
Business Transfers – In the event that a we or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.	This could include all personal data that we hold about you, including all CCPA Categories listed above
Marketing Services Providers – To help us serve marketing and advertising on third-party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below	If you give permission (consent)- Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), age, gender, and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App) (CCPA Categories B, C, G, F, and K)
Anti-Spam and Anti-Fraud – Your data may be shared with our other affiliates, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.	Email address, phone number, IP address, and IP session information, social network ID, username, user agent string, and transaction data (CCPA Categories B, F, and D).
Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.

12.5. Exercising Access, Data Portability, and Deletion Rights.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable user request to us by email [email protected].

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable user request related to your personal information. You may also make a verifiable user request on behalf of your minor child.

You may only make a verifiable user request for access or data portability twice within a 12-month period. The verifiable user request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable user request does not require you to create an account with us. We will only use personal information provided in a verifiable user request to verify the requestor’s identity or authority to make the request.

12.6. Response Timing and Format.

We endeavor to respond to a verifiable user request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable user request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable user request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

12.7. Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

13. Ways to Contact Us

13.1. This is our Customer Support’s email address: [email protected].

13.2. In case you have questions referring to the Privacy Policy herein, our data acquisition practices, and/or your rights, please get in touch with our Customer Support.

13.3. Controller of your data is LTD, HE 427842, Pavlou Nirvana, 4 ALPHA TOWER, 1st floor, Flat/Office 13 3021, Limassol, Cyprus.