Privacy Policy

We’re Bending Spoons S.p.A., the parent company of Bending Spoons Operations S.p.A. (collectively, "Bending Spoons", "we", "our" or "us"). This Privacy Policy explains how your personal information is collected, used, disclosed and otherwise processed by Bending Spoons.

Bending Spoons S.p.A. is the controller of your personal information. This Privacy Policy applies to information we collect and process when you access, use, or otherwise interact with us in connection with our RoboKiller, TapeACall, or TrapCall mobile applications and websites that link to this policy (each a "Service" and collectively, the "Services"). Note that Bending Spoons and our subsidiaries and affiliates own and operate many different products and services, and this Privacy Policy does not apply where those products and services link to separate privacy policies.

CONTENTS

  1. Information We Collect

  2. Use of Your Personal Information

  3. Disclosure of Information

  4. Do Not Track Disclosures

  5. Data Retention

  6. Your Privacy Choices

  7. Legal Basis for Data Processing

  8. International Data Transfers

  9. Additional U.S. State Disclosures

  10. Your rights

  11. Links to Websites and Third-Party Content

  12. Information Relating to Children

  13. Updates to Our Privacy Policy

  14. How to Contact Us

1. Information We Collect

We may obtain information about you in a variety of ways, including through your use of our Services, or when you otherwise interact with us in connection with our Services (such as by phone, email, or social media).

The information that we collect may be considered “personal information” or “personal data” as defined by applicable data protection laws in the relevant jurisdiction.

Information You Provide to Us

  • We collect information you provide directly to us. For example, we collect information directly from you when you create an account, make a purchase, fill out a form, communicate with us via third-party platforms, sign up for marketing communications from us, request customer support, or otherwise communicate with us. The types of information that we collect directly from you might include your telephone number, username, email address, and feedback or any other information you choose to provide.

Information We Collect Automatically

We automatically collect information about your interactions with us or our Services, including:

  • Usage data and network activity (e.g., information about your interaction with our Services, access dates and times, browsing behavior, whether call forwarding is enabled, and the date and time of any calls forwarded).

  • Location information (e.g., the city and state where you reside, such as when you use the RoboKiller Personal Data Protection service).

  • Audio data (e.g., recordings of voicemail and calls).

  • SMS and MMS text messages from callers that are not in your contacts.

  • Device information (e.g., data about the device and network you use, such as your hardware model, operating system version, mobile network, service provider and signal strength, screen resolution, IP address, unique device identifiers, browser type, browser language, browser window resolution, and app version).

  • Caller numbers (e.g., the number dialing into your device).

  • Your phone contacts (e.g., 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 only collect this information with your consent).

  • Information collected by cookies, pixels and similar tracking technologies, such as SDKs and HTML5. We use these tracking technologies to collect information about your interactions with the Services and our marketing communications. For more information about the tracking technologies we use, and the choices available to you, see the In-App Tracking Technologies section below.

Information We Collect from Other Sources

We obtain information from other sources. For example:

  • If you access or register for our Services through a third-party platform (such as Google), we will have access to certain information from that platform, such as your email address or other unique identifier, in accordance with the authorization procedures determined by such platform.

  • If you purchase a subscription to one of our mobile apps through a third-party app store, the third-party app store will provide Bending Spoons with an anonymized subscription ID or order ID. If you have or later create a Bending Spoons account, this anonymized subscription ID or order ID is associated with your account so that you can log into your account on multiple devices.

  • For some Services, such as the RoboKiller Personal Data Protection service, we may collect information about you that is publicly available online, such as information about your education, employment, gender, occupation, relatives, and presumed property ownership.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address.

Information We Collect About Non-Users

We also collect information about non-users in connection with providing our Services. For example, to provide our call recording and spam blocking services, we collect non-users’ names, phone numbers, and call and voicemail recordings, and the content of SMS and MMS text messages exchanged between users and message senders (who may be non-users) for purposes of detecting spam. To contact us about phone numbers that may have been erroneously marked and blocked as spam, please fill out this webform. We also collect certain information about non-users from third-party telecommunications providers, such as phone numbers. We process information collected about non-users solely to provide the Services to our users. Where required by law, you are responsible for notifying non-users of Bending Spoons’ data processing activities and obtaining their explicit consent for Bending Spoons to process their information in accordance with this Privacy Policy.

2. Use of Your Personal Information

We use the information we process for a variety of purposes, such as:

  • Providing, maintaining, and improving the Services, including by processing or fulfilling orders and transactions and processing payments.

  • Personalizing your experience with us.

  • Sending you technical notices, security alerts, support messages, and other transactional or relationship messages.

  • Sending you marketing communications (See the Your Privacy Choices section below for information about how to opt out of these communications at any time).

  • Monitoring and analyzing trends, usage, and activities in connection with our Services.

  • Providing community features, including publicly displaying comments that you voluntarily post.

  • Complying with our legal and financial obligations.

  • Detecting, investigating, responding to, prosecuting, and helping protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and protecting the rights, property, and safety of Bending Spoons and others.

3. Disclosure of Information

We disclose your personal information in the following scenarios:

  • Vendors and Service Providers. We make personal information available to our vendors, service providers, contractors, and consultants who perform services on our behalf, such as companies that assist us with IT or cloud storage, web hosting, payment processing, fraud prevention, customer service, analytics, and marketing.

  • Data Brokers. If you use the RoboKiller Personal Data Protection service, we provide certain information to data broker websites to complete online searches of those websites and complete any functions offered by the Personal Data Protection service (such as removal of your information from searched data broker websites).

  • Other Users or the Public. If you provide a review of the Services or otherwise post content on our Services, other users and members of the public will be able to see this information.

  • Professional Advisors. We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

  • Corporate Transactions. We disclose personal information in connection with, or during negotiations of, certain corporate transactions, including a merger, financing, acquisition of all or a portion of our business by another company, reorganization, sale of company assets, or as part of the associated due diligence.

  • Corporate Affiliates. Personal information is disclosed between and among Bending Spoons and our affiliates, subsidiaries, and other companies under common control and ownership.

  • Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public, judicial, or police authorities to meet national security or law enforcement requirements.

  • To Protect the Rights of Bending Spoons and Others. We disclose information to 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.

  • With Your Consent and at Your Direction. We might also make personal information available to third parties when we have your consent or you intentionally direct us to do so.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

4. 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 Services 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.

5. Data Retention

We store personal information associated with your account for as long as your account remains active. If you close your account, we will delete this data within one day. Otherwise, we retain the personal information 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.

If you use our Services to capture call recordings, you can delete these recordings at any time. If you delete a recording, it will no longer be accessible in your app, and we cannot guarantee that we will be able to restore it for you. We encourage you to share your recordings through the mobile applications, such as to an email address or cloud storage account.

In some cases, we retain personal information for longer than the retention period described above. For example, we retain personal information 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 also retain personal information used for legal 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 expiration of these retention periods, the data is either deleted or anonymized.

6. Your Privacy Choices

You can request the following in relation to how we process your personal information:

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

  • Correction: you may request that we update or correct inaccurate/incomplete personal information.

  • 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: you can request that we delete your personal information. 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: you can request a transferable version of your personal information, such that it can be shared with another provider).

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

You can make these requests by following these steps:

  • Log in to the app from your device

  • Long press four fingers on any screen within the app until a menu appears

  • Tap Send a Privacy Request and follow the instructions

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

You may 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.

You may have additional privacy rights if you reside in certain U.S. states. Please see Additional U.S. State Disclosures for more information.

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. With your permission, we may send push notifications to your mobile device. 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 app’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 following these steps:

  • Log in to the app from your device

  • Long press four fingers on any screen within the app until a menu appears

  • Tap Send a Privacy Request and follow the instructions

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.

7. Legal Basis for Data Processing

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

We may process personal information to perform our responsibilities under our contract with you, such as to provide the Services you requested.

In some cases, we have a legitimate interest to process the personal information that we process, such as to develop, administer and support the Services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; 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 or to comply with our obligations under 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.

8. 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 Policy. For example, 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

  • As otherwise permitted by applicable EEA requirements.

9. Additional U.S. State Disclosures

Certain U.S. states have state-level privacy laws that grant their residents certain rights and require specific disclosures (“State Privacy Laws”). This section provides information about your personal information and additional information about your rights under applicable State Privacy Laws and serves as our California notice at collection.

Category of Personal Information Use of Personal Information Categories of Recipients
Identifiers (such as your name, email address, or IP address)
  • Maintain, improve, or servicing accounts

  • Provide customer service

  • Provide the Services

  • Verify your information

  • Communicate about the Services we offer

  • Respond to requests, inquiries, comments, and suggestions

  • Send marketing communications

  • Advertising and marketing partners

  • Data analytics providers

  • Payment processors

  • IT, web hosting, and cloud storage providers

  • Data broker websites

  • Fraud prevention partners

  • Customer support partners

  • Other users of our Services and the public

Internet or other electronic network activity information (such as information from cookies and browsing behavior)
  • Provide, maintain, and improve the Services

  • Analyze trends and statistics

  • Learn about your preferences and interaction with the Services

  • Improve your experience

Geolocation data (such as the city and state where you reside)
  • Provide, maintain, and improve the Services

Audio information (such as call recordings and voicemails)
  • Provide, maintain, and improve the Services

Inferences (such as your location based on your IP address)
  • Provide, maintain, and improve the Services

Other personal information that relates to or is reasonably capable of being associated with you (such as customer feedback, call and voicemail transcripts, messages and communications between and among users)
  • Provide, maintain, and improve the Services

  • Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity.

Sensitive personal information (the content of SMS and MMS text messages exchanged between senders and users, if spam blocking is enabled)
  • Provide, maintain, and improve the Services

  • Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity.

We do not sell or share personal information or use or disclose it for the purposes of targeted advertising.

As described in the Information We Collect and Use of Your Personal Information sections above, we collect personal information from various sources, including directly from you, automatically when you access or use our Services, and from third-party sources.

10. Your Rights

Access, Correction, and Deletion: you have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. To request access, correction, or deletion of your personal information, you can email us or our Data Protection Officer by following these steps:

  • Log in to the app on your device

  • Long press four fingers on any screen within the app until a menu appears

  • Tap Send a Privacy Request and follow the instructions

Nondiscrimination: you have the right not to be discriminated against for exercising any of your privacy rights.

Appeals: if we deny your request, you may appeal our decision by following these steps:

  • Log in to the app on your device

  • Long press four fingers on any screen within the app until a menu appears

  • Tap Send a Privacy Request and follow the instructions

  • When you reach the My Request screen, select I have another request

  • Explain the reasons for your appeal in the email form that will appear

If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

To authenticate your request, we will send you a one-time passcode to your phone number or ask you to answer a security question.

Your authorized agent may submit a rights request on your behalf. We may ask your authorized agent to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may contact you to confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make a request, please send your request by following these steps:

  • Log in to the app from your device

  • Long press four fingers on any screen within the app until a menu appears

  • Tap Send a Privacy Request

  • When you reach the Contact Information screen, click on the privacy request form highlighted in blue

11. 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.

12. 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:

Name & Purpose Retention period Type of publisher & Description Description

Robokiller SDK

Technical

3 years First-party Our internal software development kit (SDK). It’s necessary for the app to function correctly.

Robokiller SDK

Technical

3 years First-party Our internal software development kit (SDK). It allows us to produce aggregated statistics.

Firebase Crashlytics

Technical

3 years

Third-party

https://policies.google.com/privacy

A tool provided by Google that’s necessary for the app to correctly interact with the backend and provide you with key features. 

Firebase Dynamic Links

Technical

3 years

Third-party

https://policies.google.com/privacy

A tool provided by Google that’s necessary for the app to correctly interact with the backend and provide you with key features. 

FirebaseAuth

Technical

3 years

Third-party

https://policies.google.com/privacy

A tool provided by Google that’s necessary for the app to correctly interact with the backend and provide you with key features. 

Google Sign In

Technical

Defined by the third party

Third-party

https://policies.google.com/privacy

Thanks to this SDK developed by Google we can provide you with a secure, fast, and easy way to log in into our app using Google.

Facebook SDK

Technical

Defined by the third party Third-party https://www.facebook.com/privacy/policy/?entry_point=facebook_page_footer Thanks to this SDK developed by Meta we can provide you with a secure, fast, and easy way to log in into our app using Facebook. If you like, you’ll also be able to share your workouts on Facebook in an easy way.

Zendesk Chat SDK

Technical

Defined by the third party https://www.zendesk.com/company/agreements-and-terms/privacy-notice/ Thanks to this SDK we can easily integrate customer support features within our app.

Firebase

Analytics

3 years

Third-party

https://policies.google.com/privacy

A tool provided by Google that’s necessary for the app to work properly. When analytics features are enabled, it can help us to improve app traffic and performance.
Apple Analytics Defined by the third party Third-party https://www.apple.com/legal/privacy/data/en/app-store/ Enables us to provide Apple with data to assist with processing your refund request, such as whether you used the purchase.

Robokiller SDK

Profiling

3 years First-party Our internal profiling software development kit (SDK). It allows us to provide customized services.

Firebase

Profiling

3 years Third-party https://policies.google.com/privacy Firebase is a tool provided by Google which is essential for the app to work properly. When profiling features are enabled, it can help us to measure the effectiveness of our ads.

The advertising network services (ad networks) used by the app are not operational in China.

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.

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, contact us at at one of the following steps:

  1. Access the app from your device (you can download and access it without purchasing a subscription)

  2. Long press four fingers on any screen within the app until a menu appears

  3. Tap Send a Privacy Request and follow the instructions

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 rights.

13. 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. When required by applicable law, we may inform you by additional means, such as through a notification on the Services 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.

14. How to Contact Us

For any requests about how we use your personal data, you can email us or our Data Protection Officer by following these steps:

  • Log in to the app from your device

  • Long press four fingers on any screen within the app until a menu appears

  • Tap Send a Privacy Request and follow the instructions

Last Updated: 7 February 2025

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