Last Updated: 15 October 2024

This Privacy Policy explains how your personal information is collected, used, disclosed and otherwise processed by Bending Spoons S.p.A. ("Bending Spoons", "we", "our" or "us").

Bending Spoons is the controller of your personal information. This Privacy Policy applies to our websites and mobile applications and other online services or applications on which this Privacy Policy is posted, and our collection of information from our corresponding social media features and pages (each a "Service" and collectively, the "Services").
If you are a California resident, please review Section 11 below for more information on Your California Privacy Rights.

1. Information We Collect

We may obtain information about you in a variety of ways, including through your use of our Services, when you call, email or otherwise communicate with us (including through social media), or when you participate in events or other promotions.

The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the "GDPR"). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction.

Categories of personal information we collect:

• Identifiers (e.g., a real name, alias, unique personal identifier, online identifier, IP address, email address, account or other similar identifiers).

• Personal Records (e.g., name and surname, email address and username. Some personal information included in this category may overlap with other categories).

• Usage data and network activity (e.g., information on a consumer’s interaction with a website, application, or advertisement. See Information collected by Automated Means below for further details).

• Geolocation data (e.g., physical location or movements).

• Sensory data (e.g., audio: voicemail and call recordings for TapeACall, TrapCall and SwitchUp users).

• Commercial information (e.g., records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies).

• Information about your habits (i.e. the information about your routine that you input on Productive: Habit Tracker).

In addition to the above, we may also collect the following types of information:

• Transcripts of Voicemail and Call Recordings. If you've purchased a second phone number or enabled call forwarding (conditional or unconditional) to use our services, we may create and store transcripts of your voicemail (or call recording if applicable) in order to provide you with our services. Additionally, for some services like TapeACall, we may make transcripts of call recordings available to you. We may use a third party provider to help us provide transcription services to you.

• Call Recordings. If you are a user of an App that allows call recordings (e.g., TapeACall, TrapCall, SwitchUp), we store the recordings, and if applicable, transcripts with our cloud storage or telecom provider. Except where legally required, we do not share these recordings or transcripts with third parties.

• Phone Contacts. If you use one of our Services that provides call blocking, we may access the phone numbers in your contacts to ensure that those numbers are not blocked. We do not share this information except with our telecom and cloud storage providers that are necessary to provide our Services.

• Caller Numbers. If you use RoboKiller, TrapCall, TapeACall or SwitchUp, we may collect the number dialing into your device.

• SMS and MMS Text Messages. We will collect de-identified SMS and MMS text messages from callers that are not in your contacts and filter all those that are spam. These texts are used to help us identify spam and are not connected to your personal information when we collect and store them.

2. Sources of Information and Purposes of Use

Some of this information you provide to us and some we collect when you use our Services. We also may obtain information about you (including personal information) from our business partners, such as vendors, and others, and from previous owners and data controllers. Additionally, if you use SwitchUp, we provide you with a second phone number, which is then associated with your account and other information you provide to us.

Information collected from you

The following are examples of the types of information we may collect directly from you:

• Telephone Number. We require your phone number for the technical provision of our Services to you. If you use SwitchUp, we provide you with a second phone number which is associated with your SwitchUp account information.

• Email Address. We use your email address to (i) respond to your requests, inquiries, comments, and suggestions; (iii) and communicate with you about your account.

• Username and/or PIN. Some of our Services use this information to facilitate your access to our website or mobile application and validate your login for your security.

• Payment Card and Other Payment Information. If you pay for any Services directly through our website, we collect payment card and other payment information.

• Voicemail Recordings and Transcripts. If you use a second phone number or you've enabled call forwarding to use our Services, we collect and store this information as part of the service we provide to you and to improve our ability to identify spam.

• Call Recordings. If you are a user of an App that allows call recordings (e.g., TapeACall, TrapCall, SwitchUp), we store the recordings, and if applicable transcripts of recordings you make using the Services. Except where legally required, we do not otherwise share these recordings or transcripts with third parties.

• Phone Contacts. If you use one of our Services that provides call blocking, we may access the phone numbers in your contacts to ensure that those numbers are not blocked. We do not share this information except with our telecom and cloud storage providers that are necessary to provide our Services.

• SMS and MMS Text Messages. When you enable the SMS Spam Blocking feature and grant us permission, we will collect de-identified SMS text messages from callers that are not in your contacts and attempt to filter all those that are spam. We use those text messages to help us identify spam and new spam tactics. These texts are not connected to your personal information when we collect and store them. If you are a user of SwitchUp, your phone will send us and we will store SMS and MMS Text Messages for the second line we provide to you. These messages may be stored with our third party telecom provider.

• RoboKiller (iOS) and TextKiller (iOS): when you enable the SMS Spam Blocking feature and grant us permission, we will collect de-identified SMS text messages from callers that are not in your contacts and attempt to filter all those that are spam.

• RoboKiller (Android): if you enable RoboKiller (Android) as your default messaging service, then we will obtain technical access to your SMS/MMS text messages; however, we do not collect or store your SMS/MMS messages and these will remain stored on your device only.

• SwitchUp: if you are a user of SwitchUp, your phone will send us and we will store SMS and MMS Text Messages in relation only to the second phone number we provide to you. These messages may be stored with our third-party telecom provider.

• Customer Feedback. We collect information provided directly by our users in relation to our products. Some of our Apps (for example, TextKiller) contain in-app features to report unwanted messages or spam messages that were not filtered by our spam call filters. This allows us to receive direct feedback from our users in order to improve our products and the user experience.

Information collected by automated means ("Automated Information")

We collect Automated Information through the use of cookies and other technologies. Cookies and other online tracking technologies are small bits of data or code that are used to identify your devices when you use and interact with our websites and other Services. When you use our Services, we may send cookies to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. You may modify your cookie setting by consulting your device's web browser.

In addition to cookies, we collect Automated Information through the use of other technologies, which may include:

• "Pixel tags" (also known as a "clear GIFs" or "web beacons") which are tiny images (in most cases, typically just one-pixel) that can be placed on a web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you've opened one of our emails or seen one of our web pages.

• "HTML5" (the language some websites, such as mobile websites, are coded in) may be used to store information on your computer or device about your website usage activities and to help determine how our Services are being used by our visitors, how the Services can be improved and to customize our Services for our users.

Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Your internet browser will contain information on how to disable cookies, or you can visit www.aboutcookies.org/how-to-control-cookies/.

The above tracking technologies may be deployed by us or our service providers on our behalf.

Automated Information includes information such as:

• IP address

• Browser type/version (for example: Firefox 59.0.2 (64 bit))

• Browser language (for example: English)

• Operating system used (for example: Windows 10)

• Internal resolution of the browser window

• Service provider and signal strength

• Hardware and software information

• Device type

• Services online

• Time zone

• Identifiers associated with cookies or other technologies that may uniquely identify your device or browser

• AdvertisingID (such as Google's AdvertisingID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device's settings)

• Adjust ID (this identifier lets us know where our users found our Services online, record user app events and optimize our advertising efforts)

• Screen resolution

• JavaScript activation

• Java on / off

• Cookies on / off

• Color depth

• Referrer

• Dates and times of access

• Call forwarding enabled

• Date and time call is forwarded if call forwarding is enabled

• Subscription data

We or our third-party service providers may assign you a unique identifier through automated means in order to match information collected from you through different means or at different times, (including both personal information and Automated Information) and to use such information as described in this Privacy Policy.

Non-User Data Collection

• RoboKiller. Users of RoboKiller Premium have the option to turn 'on' call screening within the RoboKiller App. Once this feature is activated, when an unknown contact calls that RoboKiller user, that unknown caller will be asked to state their name and the purpose for their call via an automated call screening prompt. The response of the caller is recorded and an automated transcript of the recording is sent to the RoboKiller user. As a result, we may collect ancillary information from non-users of our products, such as those who interact with the call screening feature of RoboKiller. These recordings and transcripts are stored by Bending Spoons and are available to the particular Robokiller user. This information can be deleted directly by the RoboKiller user or will be deleted in line with Bending Spoons's data retention policies.

• TapeACall. We may collect information (such as call recordings) from non-users who interact with TapeACall, when they communicate with those users. Where required in the relevant jurisdiction (e.g, California, China etc.), the non-user will be presented with a beep notification, prompt or otherwise notified that they are being recorded in accordance with applicable laws.

• TapeACall. Where a TapeACall user uses the Automatic Call Recording ("ACR") feature, we may collect the number of the end-call recipient in order to complete the call. The purpose for this processing is to allow a TapeACall user's number to appear for the call recipient (so that the call recipient knows who is calling them).

RoboKiller Spam Call Matching

RoboKiller aims to reduce and prevent robocalls and other spam calls to our users. We do this by prompting a spam caller to play its automated message before the call reaches our users. We quickly analyze the automated message and match it with our database of spam calls. Where we detect a spam call, we will screen the call for our users and send the user a notification that the call was screened. This feature is only available to RoboKiller Premium users.

RoboKiller Personal Data Protection

If you decide to utilize our Personal Data Protection service, we will ask you to provide us with your first and last name, birth year, email address (optional), and your coarse location i.e. city and US State. You can delete this basic information at any time prior to purchasing the service by selecting the clipboard icon in the mobile app. The purpose for collecting this information from you is to search for your publicly available personal information which may be visible online on data broker websites.

We will only use the information you provide us in order to complete online searches of data broker websites and complete any functions offered by our Personal Data Protection service (such as removal of your information from searched data broker websites). We will not use the information you provide us for any other purposes. Please note that we may use your first name for the personalization of our services to you, such as when we communicate with you.

If you use our Personal Data Protection service to scan for your personal information, then a search of selected data broker websites will be undertaken and we may see information about you that is publicly available online, such as your education, employment, gender, occupation, relatives, and presumed property ownership. We will temporarily store this public information on our servers only in order to provide our Personal Data Protection service to you.

• If you carry out an initial scan for your public information but decide not to purchase a subscription for our Personal Data Protection service, then we store this public information for 30 days following your initial search request, and after this 30-day period, your information is permanently deleted from our servers.

• If you do decide to purchase a subscription for our Personal Data Protection service, we will store your public information on our servers until such time as this information is successfully removed from selected data broker websites or if you cancel your subscription or delete your RoboKiller account. After this time, your information is permanently deleted from our servers.

Information collected from service providers and integrated services.

We may obtain information, including personal information from third parties and sources that we integrate into our Services either for the provision of our Services or to facilitate your access to our Services such as described below.

If you purchase a subscription to one of our mobile apps, neither Google nor Apple provides us with any personal information of the subscription purchaser (like name, email, or payment information). Only an anonymized Subscription ID or Order ID gets transferred to Bending Spoons. If you create a Bending Spoons account, this anonymized subscription information gets attached to your record for the purpose of subscription sharing with your Bending Spoons account across multiple devices.

You may be given the option to access or register for our Services through the use of a third-party account, such as Apple, Facebook, or Google. If you select this option, your account provider may make certain of your personal information available to us, such as your email address or other unique identifier or we may be asked to share certain information with such social media providers. We recommend that you review your provider's privacy policies carefully before using their Service to connect to our Services.

3. How We May Use Your Personal Information

In addition to the purposes described above, we may use the information we process for a variety of purposes, such as the following:

Service delivery and Customer support

• Maintaining or servicing accounts, providing customer service, operation our website and mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments;

• Communicating about the products and Services we offer, and responding to requests, inquiries, comments, and suggestions.

• Providing social or community features including publicly displaying comments that you voluntarily post

• For users that have enabled our call or message blocking technology, we may anonymously collect and use recordings/transcripts of calls or contents of SMS/MMS messages which have been identified as spam to help us improve the call and message blocking Services we provide to you and other users by allowing us to better identify and publicly expose spam and new spam tactics. We will only collect SMS/MMS messages received from senders not in your contact list in order to help us identify spam. These SMS/MMS messages are collected anonymously and are not connected to your personal information when we collect and store them.

• For users of Robokiller, we may use anonymized recordings and transcripts of spam messages to provide our online spam lookup tool, lookup.robokiller.com

  • Tracking and responding to quality and safety matters

  • Protecting our rights and property

4. How We May Share Information about You with Others

Your personal data may be transmitted to trusted and reliable third parties. This happens only when there are lawful grounds for the transmission. We don’t sell your data, including your images, to third parties under any circumstances.

The types of third parties to which your data may be transmitted are as follows:

• Third parties that carry out activities related to our business and operations. Such parties can operate either on our behalf as data processors (for example, IT or storage service providers) or as autonomous data controllers (for example, professional advisors providing advice or otherwise protecting and managing our business interests, or Telecom providers).

• Third parties that collect personal data about you to show personalized advertising (if you consent to the installing of tracking technologies).

  • We may share information (usually a unique online identifier) with companies like Facebook, Pinterest or Snapchat that allows us to create Custom or Lookalike Audiences. Learn more about Facebook Lookalike Audiences, Pinterest Audiences, and Snapchat Audiences.

  • Additionally, we may share certain information, including app events, with Facebook or other advertising partners that provide us with optimization services for our advertising. You can learn more about how to opt-out of having such activity sent to Facebook here and about Off-Facebook activity generally here. You can also visit your Pinterest Settings and Snapchat Advertising Preferences to learn more about your privacy options on those platforms.

  • We may also use Google Ads and Google Analytics to advertise our products, and for remarketing and optimization purposes and to understand how you interact with us across different devices. For example, where individuals allow for personalized ads in their Google settings, we use Google Signals on our TypeRight and iTranslate websites and apps to target those interested in our products with advertisements and understand different groups of users based on the different device combinations. You may opt-out of the use of this tracking technology by turning off personalized ads in your Google settings or by visiting Google’s Advertising and Privacy page. Web users mays also opt-out of this technology or by interacting with our website cookie banners or selecting “manage preferences” in our website footer.

• Advisors and new owners, in the event that we carry out a corporate transaction or operation such as a merger, acquisition, reorganization, sale of assets or assignments, and as a part of the associated due diligence.

• Public, judicial, or police authorities, within the limits established by applicable laws.

• Other parties as necessary (for example, competent authorities), if we have reason to believe that your actions are inconsistent with our user agreements or policies or that you’ve violated the law, or if it’s necessary to protect our rights, property, and safety or that of our users, the public, or others.

Additionally, we may share your personal data if it’s required for the fulfillment of a legal obligation, or if you give us your consent to do so.

SwitchUp A2P registration

Starting in 2021, phone carriers (T-Mobile, Verizon, AT&T) will begin charging additional fees for certain types of text message traffic (application to peer A2P). Some second phone number apps such as SwitchUp may be classified as A2P. In those cases, in order to ensure your text messages are delivered and are not blocked at the carrier level for being unregistered, we need to register your SwitchLine and information (such as your name, address, email, and phone number) with The Campaign Registry (TCR). This information will only be shared with TCR for the purposes of registering your SwitchLine with the TCR and to ensure that your messages or calls will not be blocked by phone service providers. For more information on this, please see the Campaign Registry FAQ.

5. Do Not Track Disclosures

Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our Sites do not currently process or respond to "do-not-track" settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

6. Social Media

We may incorporate some third-party social networking features into our Services (including, allowing users to interact with others and share certain content and information on social media platforms) or utilize third-party provided platforms to publish or manage the Services or portions thereof. Through these platforms and features, we receive or may share information about you, and this Privacy Policy applies to that information as well. We do not share call recordings with these providers. In addition, some providers of third-party social media or blogging platforms we utilize have their own privacy policies which explain how the third parties that provide them may collect, use and protect your information (e.g. if you establish an account with such platform providers directly). By using social features, you agree to those third parties' privacy policies and terms of use.

If you choose to communicate with us or another user through social features available on our websites (including lookup.robokiller.com) or mobile applications or through our social media pages, or other similar communication or messaging features or services, such information may be made publicly available. For security purposes, please do not include any password, social security number, payment card, or other sensitive information via these features. We have the right, but not the obligation to monitor messages and communications between and among users for security and training purposes. We may, but are not obligated to, remove any content we deem inappropriate.

7. Data Retention

We retain the personal data for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction.

We retain personal data used for the purpose of compliance with legal obligations for a maximum of five (5) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply.

We retain personal data used for defense purposes for a maximum of ten (10) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply.

Upon the expiry of these retention periods, the data is either deleted or anonymized.

We encourage you to contact us at privacy@bendingspoons.com if you are no longer using the services.

If you delete a recording, it will be deleted from our servers and no longer accessible. If you want to retain recordings or other call data for longer, you should go to call details and share information with your email or cloud storage account. You acknowledge and agree that you bear sole responsibility for the back-up of this information.

8. Your Choices and Rights.

You have the following rights in relation to how we use your personal information:

• Access: you may request access to your personal information and receive copies of it;

• Correction: you may have inaccurate/incomplete personal information corrected and updated;

• Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;

• Deletion: in certain circumstances, you can request a right "to be forgotten" (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;

• Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider); and

• Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.

For your protection, we may require proof of identity and verification before we can answer your requests.

You also have the right to complain before the competent national data protection authority, or any other applicable regulator in the jurisdiction where you reside, in the event that you think we’ve violated the applicable privacy laws and we haven’t addressed your request.

9. Legal basis for processing data

In this section, we identify the legal grounds on which we rely to process personal information.

In some cases, we have a legitimate interest to process the personal information that we process, such as to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities; to facilitate a Corporate Transaction (including a sale of assets or merger or acquisition); or to fulfill our contracts with business partners, such as third parties that distribute our products.

It may also be necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide.

We may also process personal information as specifically permitted by applicable legal requirements.

If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.

10. International data transfers

We may transfer your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we may transfer your personal information to the United States. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.

Specifically, we may transfer personal information from the European Economic Area to:

• Countries that the European Commissions has deemed to adequately safeguard personal information,

• Pursuant to the recipient's compliance with standard contractual clauses (also known as Model Clauses), or Binding Corporate Rules,

• Pursuant to the consent of the individual to whom the personal information pertains, or

• As otherwise permitted by applicable EEA requirements.

11. Information for Residents of California: Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act ("CCPA") may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy regarding our use of your personal information. The CCPA Notice applies to "Consumers" as defined by the law. This section describes your CCPA rights as a California Consumer and explains how to exercise those rights. See Sections 1 - 4 above to learn what information we collected from you and how it is collected, used and shared.

Access Rights

No more than twice in a twelve-month period, you may request the right to know what personal information we have collected about you, including the categories of personal information, specific pieces of personal information, categories of sources from which we collected your personal information, business or commercial purposes for our collection or sale of your personal information, and categories of third parties to whom we’ve disclosed your personal information.

Data Correction Rights

You may request to have inaccurate personal information corrected and updated.

Data Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.

Exercising Your Rights

To make a request for access, correction, or deletion according to your rights under CCPA, send your request to privacy@bendingspoons.com. Consumers may exercise these rights via an authorized agent. 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 that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process ("Verifiable Consumer Request").

The Verifiable Consumer 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; and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer's personal information (e.g., clickstream data tied only to a pseudonymous browser ID). In accordance with the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

Opt-Out

To make a request to opt-out of sale under CCPA, email privacy@bendingspoons.com. See Section 10: Online Privacy Choices and Rights to learn how you can exercise your rights regarding interest-based advertising.

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.

California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As discussed above, if we share Personal Information with third parties for their marketing purposes you will be able to elect for us not to do so by submitting your request to privacy@bendingspoons.com (please include your name, mailing address, and email address).

12. Online Privacy Choices and Rights

Device permissions

Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

Uninstall

You can stop all information collection by the app by disabling call forwarding and deactivating your account by following the instructions on the Service's Settings screen and then uninstalling the app using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

Email

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending a request to privacy@bendingspoons.com. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional or administrative messages from us regarding the Services.

Location information

If you choose to opt-in, some of our apps may collect your device's precise real-time location, and in such cases, you may be able to opt out from further allowing us to have access to such location data by managing your location preferences in the app and/or on your device.

Notice to Nevada users

We do not sell covered information, as defined under Chapter 603A of the Nevada Revised Statutes, and we do not have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please contact us at privacy@bendingspoons.com. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our practices change.

New Privacy Laws

We understand that privacy laws are constantly evolving. New US state laws and new international privacy laws are consistently emerging, developing and being enacted. We will respect all applicable privacy laws.

TapeACall China Users

For TapeACall users, we ensure that we comply with the Personal Information Protection Law ("PIPL") of the People's Republic of China. As a TapeACall user, you agree to the transfer of your personal information (including call recording data) to the United States for storage and processing.

Advertising Opt-Outs

You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance's ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA's opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective.

When you allow Notifications, we may send you offers and promotions related to our products and features. You may opt-out of these through the Settings menu on your device.

13. How We Protect Personal Information

We use various efforts intended to safeguard the security and integrity of personal information collected through our Services. Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you provide information to us at your own risk.

If you correspond with us by email or using Web forms like a "contact us" feature available through our Services, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using our Services, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.

If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you. If we have your email address, we may notify you by email to the most recent email address you have provided us in your account profile. Please keep your email address in your account up to date. You can change that email address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application.

14. Links to Websites and Third-Party Content

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that we do not own or control. We encourage you to review the privacy policies of such third parties before providing them with any personal information.

15. Information Relating to Children

We do not knowingly collect information from children under the age of 13 (or 16 in the EEA, or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 13 years of age (or 16 in the EEA, or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE THE SERVICES. If you are a parent or legal guardian and believe that we may have personal information from or about your child under 13, please contact us at privacy@bendingspoons.com. Note that we'll attempt to delete the account of any child under the age of 13 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.

16. In-app tracking technologies

When we refer to “tracking technology” or “tracking technologies” in this policy, we mean any technology that stores or accesses information on the user’s device, including SDKs, tracking pixels, HTML5 local storage, local shared objects, and fingerprinting techniques.

Tracking technologies are usually classified by purpose (technical, analytics, profiling) and by publisher (first-party, third-party). The legal requirements vary based on these classifications.

The tracking technology classifications and some practical examples now follow.

By purpose

Technical tracking technologies

These are used to transmit messages over an electronic communication network or to provide a service specifically requested by the user. Therefore, they’re necessary for the app to function correctly, and for providing the service requested by and offered to the user.

For example, technical tracking technologies can be used to monitor sessions, store specific server access information related to the user configuration, facilitate the use of online content, keep track of items in a shopping cart, or keep track of information used to fill in a form.

As technical tracking technologies are necessary, they don’t need your consent.

Analytics tracking technologies

These are used to assess the effectiveness of an information society service provided by a publisher, evaluate and improve the design of an app, or help measure traffic. In other words, they serve to track the traffic and performance of an app by collecting aggregate data on the number of users and how they interact with the app, which helps to improve its services.

For example, analytics tracking technologies may collect information about how users access an app, including the number of users and potentially grouped by geographical area, time zone, how long they stay on the app, which parts of the app they interact with, and the number of users who used a particular feature.

Normally, analytics tracking technologies are used only with your explicit consent. However, in the following cases they’re treated like technical trackers, so don’t need your consent:

• When they’re used only to produce aggregated statistics that are performed through the controller’s own resources and that don’t turn into activities that go beyond statistical counting and assisting business-related decision-making

• When the third parties don’t match the analytics trackers' data with any other information, and don’t send any data gathered to other third parties

Profiling tracking technologies

These are used to evaluate some personal aspects of certain users, and to trace specific actions or recurring behavioral patterns in the use of the app in relation to specific, identified or identifiable individuals, so they can be grouped within homogeneous, multi-sized clusters. This enables the company to analyze and predict personal elements, provide users with customized services beyond what’s strictly necessary for the delivery of the service, and sending targeted advertising messages in line with the preferences they express during their in-app activities. These serve to convey behavioral advertising, measure the effectiveness of ads, and customize the services offered in line with the user’s monitored behavior.

For example, profiling tracking technologies can be used for the following activities:

• To create user profiles and offer content in line with the user’s interests

• To send targeted ads or messages

• To conduct statistical analysis or other research activities to improve our products and services and measure the effectiveness of our campaigns

Profiling tracking technologies are used only with your explicit consent.

By publisher

First-party tracking technologies

These are installed and managed directly by the owner of the app (in this case, Bending Spoons S.p.A). As the owner, we process the collected data for our own purposes.

Third-party tracking technologies

These are installed and managed by different apps or developers, either for our purposes or for those of the third party.

The data collected by the third parties for their own purposes is governed by their specific privacy policies and terms and conditions. For further information about these data processing activities, you can directly refer to the privacy policy of the relevant third parties as indicated in the subsection Types of tracking technologies used by the app.

Third-party tracking technologies need your consent, unless they’re anonymized and only used for analytical purposes. You can manage consent at any time from within the app’s privacy settings.

Types of tracking technologies used in the app

This app uses the following types of tracking technologies:

Tracking technologies settings

You can turn on or turn off—in whole or in part—profiling and third-party analytics tracking technologies at any time through the app’s privacy settings. As for Meta Audience Network SDK, if you’re an Android user, you can manage your choices directly on Meta's website.

When you withdraw consent, your data will no longer be collected through those trackers. However, we’ll continue processing the data collected before the withdrawal.

You can’t turn off first-party analytics tracking technologies—they’re treated like technical trackers, so aren’t contingent on consent. However, you can opt out of the further processing of your data that’s been collected via these trackers. To do so, you can contact us at privacy@bendingspoons.com.

After following this process, you may uninstall the app if you’d prefer to.

With regards to your rights under applicable Data Protection Laws, please refer to the section Your choices and rights.

17. Updates to Our Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will update the date of this Privacy Policy. Continued use of the Services after such date constitutes acceptance of such updates. When required by applicable law, we may inform you by additional means, such as through a notification on the website or in our mobile applications if we make material changes to how your personal information is collected, accessed or otherwise used as a result of your use of the Services or if your rights under this Privacy Policy are materially impacted by changes to our privacy practices. We recommend that you check this page from time to time to inform yourself of any changes in this Privacy Policy.

18. How to Contact Us

If you want to submit a request by email or if you have any other questions about privacy or data protection at Bending Spoons, you can contact us at privacy@bendingspoons.com.