Assuract Limited (“Assuract”, “we“, “us” or “our”) is a provider of telecommunications services and solutions. For more information about Assuract, please visit our website: www.pipcall.com (“Website”).
We have developed the PiPcall mobile application which is available for download from the App Store (“App”). The App allows a user to make and receive calls via the App once installed on the user’s mobile device. The App includes a number of features such as managing contacts within the App, providing caller identity details when receiving a call, accessing a personal voicemail service, turning on a ‘do not disturb’ setting and accessing the call history of calls made through the App; more information about the features offered via the App can be found in Clause 4 of the terms and conditions available here: www.pipcall.com/apptermsandconditions (“Services”). The Services available to you in the App may be limited or restricted by your employer or the organisation with which you are associated who has authorised your use of the App (“Associated Business”) or by the settings you have enabled or disabled within the App.
The App is only available to “Business Users”, which means an individual who is authorised to use the App on behalf of its Associated Business, provided that such Associated Business has entered into an agreement with us and has agreed to pay the charges for the individual’s use of the App.
- WHAT PERSONAL DATA DO WE COLLECT AND PROCESS, AND HOW DO WE USE IT?
- Registering an account
- If you are a Business User, you have been authorised by your Associated Business to use the App to carry out the duties required of you by your Associated Business. You will be required to register an account with us, which will include providing us with your name, the name of your Associated Business, your work email address, and if you are authorised by your Associated Business to make personal calls via the App, your personal mobile phone number (“Account Data”) and in return we will provide you with your “PiP Number”. A “PiP Number” is the phone number we allocate to you to enable you to make and receive calls via the App to the mobile device that you provide your personal mobile phone number of when you register your account. You may share your PiP Number with your Contacts to enable your Contacts to make a call to your PiP Number. In some circumstances your Associated Business may choose to override your PiP Number and allow you to use your Associated Business phone number instead. In this situation your Associated Business will provide us with details of your Associated Business phone number so that the system can be configured appropriately to enable you to receive the Services via your Associated Business phone number.
- We process your Account Data in order to set up your account and enable you to receive the Services from us. We process your PiP Number and your Associated Business phone number for the purposes of facilitating your calls using the App, which is further explained below.
- We process your Account Data, your PiP Number and your Associated Business phone number to pursue the legitimate interests of your Associated Business, who has engaged us to provide the Services to it and its Business Users. Your Associated Business intends for you to use the App to carry out the duties required of you by your Associated Business and therefore requires you to have an account with us via which we provide the Services to you.
- Creating contacts in, and transferring contacts to, the App:
- You may create a Contact in the App for the purposes of making calls to, or receiving calls from, such Contact. When you create a Contact, you may provide us with the Contact’s first name, last name, company name, email address(es) and phone number(s) for any of the following: home, work, mobile, company main, work fax, home fax, assistant, pager, car, radio (“Contact Data”). As a minimum you will be required to provide us with a phone number (whether home, work or mobile) of the contact.
- If you transfer a Contact from your mobile device to the App the following data about the Contact is copied to the App: first name, surname, employer or organisation associated with, source (e.g. if the data originates from the mobile device, or webmail or other application), phone number(s), phone number(s) label (e.g. office, home or mobile), email address(es) and email address label(s) (e.g. work or personal) (“Transferred Contact Data”).
- We process the Contact Data and Transferred Contact Data for the purposes of displaying the identity of callers who make calls to you via the App, and we do this via a push notification to you that is displayed on the screen of your mobile device (if you enable push notifications to be sent via the App). We also store the Contact Data and Transferred Contact Data in a database and display this to you as a list of Contacts that you may wish to make a call to via the App. You may designate a Contact as a favourite, which will be listed as one of your favourites within this feature of the App, so that you can make calls to your favourite Contacts without searching through the entire list of your Contacts.
- We process the Contact Data and Transferred Contact Data of your Contacts to pursue your legitimate interests to improve the usability of the App and enable you to use the App most effectively. You can efficiently identify Contacts by name when using the App (including when making and receiving calls, accessing your call history and designating Contacts as favourites) and efficiently interact with your Contacts through various mediums (as a result of storing additional contact information, such as email addresses). As a result of us processing the Contact Data and Transferred Contact Data, you see more than a list of phone numbers within the App.
- Making and receiving calls:
- We process call detail records when you make and receive calls via the App, and such records contain the date and time of when a call begins and ends, the duration of the call, the location of the call (including the origin and destination of the call), whether the call was an incoming or outgoing call, the phone number of the person you make a call to, or received a call from, and the phone number you used to make or receive the call, which may be your personal phone number or work phone number (via your PiP Number) (collectively “Call Data”).
- We process your Call Data to provide our call service to you and enable you to make and receive calls via the App.
- We process your Call Data to pursue the legitimate interests of your Associated Business, who has engaged us to provide the Services to it and its Business Users. Your Associated Business intends for you to use the App to make and receive calls, and we are required to facilitate such calls and comply with our obligations of providing the Services to you pursuant to the contract we have with your Associated Business.
- Accessing your call history:
- We make available some of your Call Data to enable you to see your call history, which includes the date and time of when the call was made or received, the duration of the call, whether the call was an incoming or outgoing call, the phone number of the person you made a call to, or received a call from, the phone number you used to make or receive the call, which may be your personal phone number or work phone number (via your PiP Number), and if you have created or transferred such person as a Contact to the App (which means their Contact Data or Transferred Contact Data is in the App), their name will also be displayed (“Call History Data”).
- We process your Call History Data to provide you with access to an itemised history of the calls made and received via the App.
- We process your Call History Data to pursue your legitimate interests to enable you to use the App most effectively. You can efficiently identify records of Contacts that you have made calls to, or received calls from, when using the App.
- Accessing your voicemail service:
- You may record a voicemail message which may be played to those making a call to you if you are unable to receive the call (“Pre-Recorded Voicemail Data”).
- We process voicemail records which contain the recording of the caller’s message, phone number of the caller, date and time of when the message was recorded (“Recorded Voicemail Data”).
- We process your Pre-Recorded Voicemail Data and Recorded Voicemail Data for the purposes of notifying you when you have missed a call and enabling callers to leave you a message in such event.
- If you record a voicemail, we process your Pre-Recorded Voicemail Data to pursue your legitimate interests by enabling you to provide a personalised message to callers if you are unable to take the caller’s call. If the caller records a voicemail message, we process the Recorded Voicemail Data to pursue your legitimate interests by enabling the caller to leave a message which you may respond to later.
- It is not a mandatory requirement of using the App that you record a voicemail message (unless your Associated Business requires otherwise) or that a caller leaves a voicemail in the event you miss the caller’s call.
- Fraud monitoring:
- We may monitor spending activity (which includes the call duration and destination of the call) on your account using your Call Data for the purposes of checking for unusual activity which may be the result of fraudulent activity.
- In order to be able to investigate fraudulent activity, we process your Call Data to pursue the legitimate interests of your Associated Business to protect against unauthorised use and spending activity on your account.
- We are required to impose spending limits if you have a pay-as-you-go subscription service and we monitor your spending activity for the purposes of complying with our legal and regulatory obligations to impose such spending limits in these circumstances.
- Providing you with support:
- You may require our assistance from time to time. If you contact us for help, we will raise a ticket and need certain information from you, which may include: details of the App you are using (such as the version number you have installed), the nature of the problem you are experiencing and any alternative contact details we can use to reach you in the event your PiP Number or registered email address is not working (“Support Data”).
- We will process your Support Data to pursue the legitimate interests of your Associated Business, who has engaged us to provide the Services to it and its Business Users. We have an obligation to provide you with support as a Business User of our App.
- Complying with legal and regulatory requirements:
- We are required to comply with certain legal and regulatory requirements and may process your personal data for compliance with such legal or regulatory obligation, to which we or regulators or law enforcement agencies are subject.
- WHO DO WE SHARE YOUR PERSONAL DATA WITH?
By using the App, we may need to disclose your personal data to selected third parties in the following limited circumstances:
- Third party user authentication provider: your email address and password are held securely by our third party user authentication provider to enable you to securely login and use the Service. This service provider allows you to manage or change your password for the App at any time.
- Third party contact database provider: Contacts you create and manage in the App are stored securely in a database provided by our third party contact database provider. By maintaining a copy of the database of your Contacts outside of your phone we can retrieved the database of your Contacts should your phone be damaged, lost or stolen and your Contacts can be maintained centrally and synchronized across each device you install the App on.
- Third party infrastructure providers: your personal data is held and processed securely by us on the dedicated systems supplied, monitored and maintained by our third party infrastructure providers.
- Your Associated Business: we share your Call Data and Call History Data with your Associated Business for the purposes of billing your Associated Business for the calls made and received via the App to and from your work phone number (via your PiP Number).
- Third party telecommunications providers of call services: in order for us to connect a call you are making, or a call you are receiving, we transfer your PiP Number, or your Associated Business phone number if your account has been configured to override your PiP Number (which we configure following instructions we receive from your Associated Business), to a third party telecommunications provider that owns or leases the network over which we transmit your call. We also transfer the phone number of the destination or individual which you are calling.
- To comply with legal or regulatory requests: if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency.
We use a third party payment provider to process payments from our customers for their use of our Services. We do not receive any financial personal data in order to process payments from our customers.
- TRANSFERS OF YOUR PERSONAL DATA
We will not transfer your personal data outside of the EU (or the UK to the extent the UK is no longer part of the EU), except to selected third parties that we have instructed to help us provide the Services to you, including in particular that we use Microsoft’s Azure cloud services, Auth0’s cloud authentication services and Realm.io’s cloud database and synchronization services, and such third parties may process and store your personal data in any one of their geographically distributed data centres as part of its cloud platform.
In the case of transfers of your personal data outside of the EU (or the UK to the extent the UK is no longer part of the EU), where the transfers are not to countries that provide an adequate level of protection (for example, we may rely on a Privacy Shield certification where the transfer contains a US entity), we will use reasonable efforts to put in place appropriate safeguards to cover transfers of your personal data which may include, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission. Please click here for a link to the standard contractual/data protection clauses and click here for more information about the Privacy Shield for US companies.
If there are any other circumstances which would require us to transfer your personal data outside of the EU (or the UK to the extent the UK is no longer part of the EU), we will seek your consent to transfer your personal data outside of the EU. In the event of such a transfer, where applicable, we will put appropriate safeguards in place to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission, or where applicable, relying on a Privacy Shield certification where the transfer contains a US entity.
If you would like further information, please contact us via email at firstname.lastname@example.org.
- OUR WEBSITE AND THIRD PARTY WEBSITES
We store your personal data in line with legal, regulatory, financial and good-practice requirements, and on the following basis:
- Account Data is deleted 12 months after an account is terminated.
- Support Data is deleted 1 month after an account is terminated.
- Contact Data and Transferred Contact Data is deleted 24 hours after an account is terminated.
- Call Data and Call History Data is deleted 84 months after an account is terminated to enable us to deal with any account related and billing queries from your Associated Business.
- Pre-Recorded Voicemail Data is deleted 24 hours after and account is terminated
- Recorded Voicemail Data saved by the user is deleted 24 hours after an account is terminated.
- ACCESSING YOUR PERSONAL DATA AND YOUR RIGHTS
As a result of us collecting and processing your personal data, you have the following legal rights:
- to access personal data held about you;
- to request us to make any changes to your personal data if it is inaccurate or incomplete;
- to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
- to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;
- to object to, or restrict, our processing of your personal data in certain circumstances;
- if we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
- if we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;
- to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and
- to lodge a complaint with a data protection supervisory body.
To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at email@example.com.
- CONTACTING US AND CHANGES TO YOUR PERSONAL DATA
Please notify us by email with any changes to your personal data at any time during your use of the App.