Privacy Policy

Last modified: 10 August 021

Effective Date: 15 April 2021

Ringl Technologies Pte. Ltd., a private company registered in the Republic of Singapore with its registered office at 84 Genting Lane #07-01 Axxel Innovation Centre Singapore 349854 (together with Ringl Technologies Pte. Ltd.’s current and future subsidiaries and affiliates, “RINGL,” “we,” “us,” or “our”) provides inter alia voice, video and chat messaging, Internet calling services on and through our RINGL Communications Platform, which is designed to operate on mobile devices and personal computers with the use of Internet.

This Privacy Policy is part of, and incorporated into, our [Terms]. Please review this Privacy Policy in conjunction with our other posted policies carefully, before you create an Account with us or before you use or access our Services. By installing, creating an Account, accessing or using any of our Services, you hereby confirm that you accept the terms of this Privacy Policy (which shall constitute a binding agreement between you and us) and agree to comply with them. Capitalised or other terms used herein but not defined or given interpretation in this Privacy Policy shall have the meanings set forth in our [Terms].

1. INTRODUCTION

In order to provide you with the best experience with RINGL, we need you to share certain types of your personal data and non-personal data with us. Personal data means any information capable of identifying you and/or any individual from the company, organization, business or entity that you are authorised to represent. Non-personal data means any information that does not, on its own, permit direct association with you. If your non-personal data is combined with your personal data, the combined data will be treated as personal data for as long as it remains combined. We are responsible for processing your personal data and are committed to protecting the privacy and security of all personal data we receive from RINGL users. It is important that you are comfortable and trust us with your data. This Privacy Policy explains our policies regarding the collection, use, retention, processing and disclosure of personal data when you use RINGL and the choices you have associated with those personal data. 

2. OUR PRINCIPLES FOR PROCESSING PERSONAL DATA

We are strictly guided by the following key principles while processing your personal data:

– We process your personal data on a lawful basis and only for the specific reasons we collect the same, and we assure you that such reasons are clearly defined and legitimate;
– We ensure transparency on the operations we perform on your personal data, how we perform them and why;
– We do not process your personal data in a way that is detrimental, unexpected or misleading to you;
– We do not collect or request you to provide us with more personal data than required to provide you with our best Services;
– We will not store your personal data for longer than required to make it possible for you to enjoy RINGL;
– We will keep your personal data accurate and will rectify or delete any inaccurate personal data that relate to you without delay;
– We apply all appropriate safeguards to ensure the adequate level of protection of privacy and security of your personal data; and
– We will always facilitate the exercising of your legitimate rights concerning the processing of your personal data by us.

3. OUR PRINCIPLES FOR PROCESSING PERSONAL DATA

We receive or collect your personal data when we operate and provide our Services, including when you install, create an Account, access or use our Services. The information that we receive and collect depends on the context of your interactions with us and our Services, the choices you make and the products and features you use and have access to. Please read paragraph 6 below for the legal bases for which we process your personal data.

Generally, we receive or collect information about you:

– directly from you when you install, create an Account and register with RINGL or use certain RINGL built-in functions or communicate with us in any way; and/or
– from other RINGL users when they use certain RINGL built-in functions or communicate with us in any way.

We may collect the following types of information that may contain personal data about you:

3.1 Information Provided by You

a. Registration and Account information. 

We collect your contact information that you provide to us when you register and create an Account, which includes your mobile number and email address. Your mobile number and email address are stored on our servers and are used as a unique identifier (login) of your Account with us. Please note that your mobile number and/or email address is available to all persons in your Account’s contact list to make it possible for them to identify you. We store your mobile number and/or email address for all the duration of your Account being in operation. 

b. Address Book. Where you have opted to sync our Services with your device’s address book, we may collect hashed phone numbers of all persons in your address book (whether they are RINGL users or not) stored in your device. Once the synchronisation is completed, we will immediately delete your address book data from our servers.

For RINGL business administrator accounts, where you have opted to use the “import contact”  or “add contact” feature of the administration panel and having in so doing, agreed to provide us and other RINGL business users in the same company, organization, business or entity, subject to applicable laws, with names, phone numbers and email addresses (“Business Contacts”), including those of users of our Services and your other contacts, we may access these Business Contacts in accordance with paragraph 6 below.  

c. Other Data. We may from time to time process information that you disclose, share or disseminate in Groups or Channels, which have TLS encryption. Your mobile number will not be used to relay messages or data within Groups or Channels and will also not be visible to other users on Groups or Channels. You will instead be identified by your user ID on such Groups or Channels.

3.2 Information collected through the use of our Services

If you access or use our Services, we (and in some cases our Third-Party Service Providers, as defined below) are authorised to collect the following information:

Registration ID. When you register as a RINGL user, we will generate a unique Registration ID (which may be replaced from time to time) that will be stored on (i) the RINGL servers for all the lifetime of your Account; (ii) your device(s) until you uninstall RINGL; and (iii) the device(s) of other RINGL users from your address book (“RINGL Contacts“), until they uninstall the RINGL from it or until you uninstall your RINGL from your device(s), whichever comes earlier.
Generally, a recipient device will be able to use your Registration ID to check if a new communication session with you has been encrypted with the same set of encryption keys as the previous communication session. If an unauthorised person manages to communicate with RINGL Contacts via your Account using another device, your RINGL Contacts will receive a notification alert that any communication with you may not be safe. This function ensures that your RINGL Contacts are safe from fraudulent actions that may be carried out by unauthorised persons using your Account.
Your Registration ID will be automatically replaced by a new one when you change your device or reinstall RINGL. Upon the next communication session with you, your RINGL Contacts will receive the same notification alert in these cases as well.

Location Information. If you wish you to share your location in a Group or Channel, you may opt to give us access or permission in your device’s settings to process your location-based information. Such location-based information will be stored in an encrypted format on our RINGL servers.

Transferable Data. We collect meta data that may be contained in heavily encrypted calls, messages and files sent (made) between you and your contact(s) via our RINGL servers, for example, information about whether a recipient has viewed the content you create or provide.

Photos and Camera Data. If you wish to send photos or take photos through RINGL, you may opt-in to give us access to your camera or photos on your device. To this extent, we may process images and other information from your device’s camera and photos.

User Agent Data. We collect information from and about your device, which includes (i) information about your device’s hardware and software (e.g. the current version of your device’s operating system and platform, device’s model, current version of RINGL).

Usage Information. We collect information about your activity through the use and access of our Services. This includes collecting information about how you interact with our Services, your wireless and mobile network connections, such as, your service provider, your Internet Protocol addresses, network signal strength, the type of search queries or API requests you submit, the type of features and products you use from our Services, how you communicate with other RINGL users (including information about which RINGL user you interact with the most, your interactions with messages or calls, the volume of messages or calls you exchange with other RINGL users, the time, date and volume of your requests sent to our servers for communication sessions, traffic routing information, origination and termination points (i.e. sender and recipient numbers), your online status and status message.

Automated technologies or interactions. As you use and access our Services, we will automatically collect technical data about your device, browsing actions and patterns, information on your search history, access times, including pages viewed while using our Services and pages visited before or after navigating through our Services. We collect this information using cookies, server logs, and other similar technologies. Please read and review our cookie policy set out in our [Terms] for further details.

Recorded Conference calls. You may use our Services to record and/or stream conference calls to other RINGL users, and such data may be collected and stored on our servers for your use.

3.3 Information from third parties or publicly available sources

Error-related information. You may opt to send to us reports on errors (crashes or malfunctions) that may occur when you are using RINGL in order for us to examine and rectify such errors. All error-related information is collected from your device and transmitted to us through Firebase Crashlytics (for Android devices) or iOS Crash Reports (for iOS devices). Please note that our Firebase Crashlytics and/or iOS Crash Reports may track your activity and otherwise collect information from you. Please refer to paragraph 9 below for details on the information collected through crash reports from our Third-Party Service Providers.

We receive the following information collected by Firebase Crashlytics and/or iOS Crash Reports:
– information about how the RINGL was used;
– how many times an error occurred in RINGL;
– the number of users who encountered such error;
– the current version of RINGL installed on your device; and
– the version of the operating system installed in your device.

Other sources. We may receive information about you from RINGL users and others. For example, when others use our Services, they may provide us with your contact details from the address book in their device.

4. INFORMATION WE DO NOT COLLECT AND PROCESS

Profile Information. It is not a requirement to add your profile name and/or profile picture to your Account, but you may wish to do so. We do not have access to and do not process your profile name and profile picture in any way. Nonetheless, such information is accessible to your RINGL contacts, and profile names and profile pictures may be transferred on peer-to-peer basis without the facilitation of our RINGL servers.

Touch ID, Face ID and Passcode. If you opt to use a Passcode, Touch ID and/or Face ID for Account security, all your personal data in connection with such security (e.g. digital code, fingerprint, facial image) will be stored on your device and no such information is accessible to us and we do not process such information.

History of Delivered Messages. The history of successfully delivered messages is stored on your device. These messages that are stored on one device is automatically synchronised with all such other devices that are online and are bound to the same Account. Such synchronisation is carried out directly between a user’s devices without the facilitation of our RINGL servers.

5. PROCESSING YOUR INFORMATION WHEN YOU USE RINGL THROUGH VPN

If you operate RINGL through the VPN function within RINGL, our VPN servers automatically process the Internet Protocol address of your device for the purpose of providing you access to RINGL. Please note that (i) our VPN servers do not share or otherwise disclose the Internet Protocol address of your device to any Third-Party Service Providers for any purposes; and (ii) we do not match the Internet Protocol address of your device and any other personal data of yours for any purposes.

6. LEGAL BASIS FOR PROCESSING PERSONAL DATA

We will only collect, use and disclose or otherwise process your personal data on the following lawful bases:

1. where you have given consent for to the processing of your personal data for one or more specific legitimate purposes;
2. where it is necessary for our legitimate interests (or those of a third party), except where such interests (i) outweigh any adverse effect on your interests and/or (ii) override your fundamental rights and freedoms;
3. where it is necessary for the purposes of improving or enhancing our Services to you;
4. where it is necessary for us to enter into or perform contractual obligations with you; and
5. where it is necessary for us to comply with legal obligations, which we are subject to;

Kindly note that in certain circumstances if you do not provide us with requisite personal data, we may not be able to (i) enter into the [Terms] with you and/or (ii) provide our Services to you in accordance with the [Terms] concluded with you. We will notify you if such circumstances arise.

7. USE OF THE INFORMATION COLLECTED BY US

7.1 To operate and provide our Services. We may use your information to operate, maintain, manage and provide our Services, which includes:

a. registering you as a new RINGL user;

b. enabling user-to-user communications and, user to third-party communications (including procuring that RINGL users are informed of your attempted calls and delivery of messages and/or files to them);

c. maintaining and managing user Accounts and keeping it in working order;

d. syncing our Services with your device’s address book; 

e. syncing your mobile number and/or email stored on another RINGL user’s device with their Account in order to help RINGL users connect with you;

f. interspersing your text communications with GIF files (where necessary);

g. converting the voice files that you receive from other RINGL users into text messages (where necessary);

h. assisting with language translation in respect of communications between with your and other RINGL users who speak a different language;

i. communicating with you about administrative information, such as information about changes to our Terms and posted policies and other important updates, new products, services and features;

j. evaluating and improving our Services to ensure operational efficiency;

k. researching and developing and testing new services and features, and conducting troubleshooting activities (including rectifying operational failures in RINGL); 

l. understanding you and customising our Services to you through the use of cookies and other tracking technologies (please refer to our cookie policy).

7.2 To ensure safety and security of our Services. We may use your information as part of our efforts to keep our Services safe and secure, including:

a. providing you access to RINGL through VPN;

b. verifying your identity and your RINGL Account;

c. conducting fraud monitoring and prevention (particularly to notify you in case of any unauthorised use of your Account);

d. investigating suspicious activities or violations of our [Terms] or other posted policies; and

e. identifying and preventing malicious actions against our servers, including “denial of service” attacks.

7.3 To provide customer support. We may use your information to:

a. request feedback and to contact you about your access and use of our Services;

b. respond to your inquiries and communications and solve any potential issues you might have with accessing or using our Services; and

c. resolve any disputes between RINGL users, Third-Party Service Providers, and/or between you and us.

7.4 To comply with legal and regulatory requirements. We may use your information for legal and business purposes, to comply with legal and regulatory requirements or in connection with our [Terms] and other posted policies;

7.5 To provide you with third party services. We may use your information to allow us to work with various Third-Party Service Providers (defined below) to help us operate, provide, improve, understand, customise and support our Services. Please refer to paragraph 9 below for further information;

We will only use your information for the purposes and legal bases in paragraph 6 above, unless we reasonably consider that we need to use it for another reason (and that reason is compatible with the original purpose). If you wish to get an explanation of how processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your information for an unrelated purpose, we will notify you and explain the legal bases and specific purposes, which allows us to do so.

8. SHARING THE INFORMATION WE COLLECT

We may share your information with the following parties for the legal bases set out in paragraph 6 above:

8.1 Our related corporations and affiliates. We may share your information with our related corporations, and our subsidiaries and affiliates (which includes joint venture partners, other corporations that we control or that are under common control with us) (“Group”), in which case we will require our Group to honor this Privacy Policy.

8.2 Other RINGL users. When you communicate and share certain information (such as your online status and status message, profile name and photo) via RINGL with other RINGL users or interact with public sections of our Services, such information may be viewed by other RINGL users who may be located outside the country where you live and may also be publicly made available outside of our Services in perpetuity. To perform this instruction given to us by you on the basis of the Terms with you we will transfer your personal data, on your behalf, to those users in accordance with this Privacy Policy.

Further, RINGL users with whom you communicate may store or re-share your information with others on or through our Services or even outside our Services.

8.3 Law Enforcement and Government Agencies. We may disclose your personal data stored by us where we are legally required to do so in order to comply with applicable law, governmental requests, criminal investigations, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements), any alleged illegal activity or any other activity that may expose us, you or any other RINGL user to liability.

We may also disclose your information where we believe it is necessary to (a) prevent, or take action regarding potential violations of our [Terms] and other posted polices; (b) investigate, prevent and address fraud, and other illegal activity, security or technical issues; (c) protect the rights, property, safety of RINGL users, us and our Group; (d) or as evidence in litigation in which we are involved.

8.4 New Owners – Change of Control. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

8.5 Third-Party Service Providers. We may share your information with Third-Party Service Providers (defined below) who (i) facilitate our Services; (ii) provide and perform with their services on and through our Services; and (iii) help to analyse how our Services are used. Please refer to paragraph 9 below for further information.

9. SHARING THE INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS

We work with certain Third-Party Service Providers and/or business partners (“Third-Party Service Providers”) that help us to operate, provide, improve, understand, customize, support, and market our Services. Our Third-Party Service Providers include those that distribute RINGL, provide our infrastructure, databases and other systems, process payments, provide gaming services, assist with fraud monitoring and prevention, data analytics and operations, supply geo-location and maps, and help us to market our Services.
Generally, our Third-Party Service Providers may have access to your information you provide to us to perform the tasks assigned to them on our behalf. In some instances our Third-Party Service Providers offer their services exclusively on our behalf. In other instances, they may process, retain, share and use your information they collect pursuant to their own terms and privacy policies, which will govern your use of those services.

We do not control how these Third-Party Service Providers manage the information they gather or handle and store the information that you provide to them. Please read and review their relevant terms and policies carefully before making your data available to them. We have set out below, in a table format, a detailed description of the ways we share your personal data with Third-Party Service Providers as well as a link to their relevant privacy terms and policies:

 

Third-Party Service Provider	Description	Third-Party Terms and Policies
Amazon Web Services EMEA SARL (Luxembourg-based entity)	Peer-to-Peer or Group calls   Generally, all peer-to-peer calls or group calls are made directly between RINGL users and we do not process any calls that you initiate or participate in. However, if it becomes technically impossible to create a stable and direct connection between the RINGL users, the corresponding call will be facilitated by our RINGL servers and/or AWS servers, applying all relevant safeguards. Neither AWS nor we are able to decrypt, process or otherwise access the content of your call facilitated by our RINGL servers and/or AWS servers.   If you wish, you may opt out of the processing of your calls by AWS servers in the privacy settings of RINGL; however, calls may be of lower quality.   Communication Session Logs   Each time you send a message, or initiate or participate in a call with another RINGL user, your device shares your Usage Information (see paragraph 3.2(f) above) and User Agent data (see paragraph 3.2(e) above) (collectively, “Communication-Related Information”) with AWS Servers.   We use AWS servers to determine the optimal route to deliver your message or call to such RINGL user. Once an optimal route is determined, the AWS servers will share the Communication-Related Information with our RINGL servers. The Communication-Related Information is stored on our RINGL servers for thirty (30) calendar days before it is deleted   Files Each photo, video, document and any other type of files that you may send to another RINGL user is encrypted and uploaded to AWS servers and then transferred to such RINGL user. All files are encrypted and Amazon Web Services EMEA SARL is unable to decrypt or otherwise access the content of such files stored on its servers. Depending on the type of Services you sign up for, your files may be stored on AWS servers for up to 2 weeks or indefinitely, before they are deleted. You will not be able synchronise files sent or received via RINGL between your devices after the expiry of such period.	Privacy Notice
Twillio, Inc	Global Network Traversal Service   Generally, all peer-to-peer calls or group calls are made directly between RINGL users and we do not process any calls that you initiate or participate in.   Nonetheless, in the event it is difficult to secure a stable connection, your device will share your Communication-Related Information with Twilio, Inc to relay calls with the lowest latency possible using Twilio’s STUN/TURN relay.	Developer Products and Account Portal Privacy
Google LLC, Google Ireland Limited or Google Asia Pacific Pte. Ltd. (“Google”)	Language translation services   If you opt to use the Firebase ML Kit to translate a message, your Communication-Related Information will be sent to Google from your device.   Push Notifications: Android Devices   If you have opted for push notifications, a unique push notifications identifier generated by Google’s push notification service will enable the notification alerts to be delivered to your device through RINGL and your mobile number and email remain encrypted.   Error-related Information: Android devices   If you opt to allow us to collect your crash reports, when an error occurs the following data will be sent to Firebase Crashlytics operated by Google from your device:   User Agent data (see paragraph 3.2(e) above); the date and time an error occurred; the date, time and volume of each request to transfer data to Firebase Crashlytics; your RINGL ID on Google Play; and Usage Information (see paragraph 3.2(f) above)   Google’s API Services   We use Google Maps features and content to provide the location sharing service. By using our location sharing service, you agree to Google’s Privacy Policy and Google Maps/Google Earth Additional Terms of Service.	Privacy and Security in Firebase   FIREBASE CRASHLYTICS AND FIREBASE APP DISTRIBUTION TERMS OF SERVICE   Google’s Privacy Policy   Google Maps/Google Earth Additional Terms of Service
Apple, Inc	Error-related Information: iOS Crash Reports   If you opt to allow us to collect your crash reports, when an error occurs a crash report containing relevant error data will be sent to iOS Crash Reports operated by Apple, Inc. from your device.   Push Notifications: iOS devices   If you If you have opted for push notifications, a unique push notifications identifier generated by Apple, Inc’s push notifications service will enable the notification alerts to be delivered to your device through RINGL and your mobile number and email remain encrypted   Speech Recognition   If you opt to use Speech Recognition to convert a voice file into a text message, the following information will be sent directly to Apple, Inc from your device:   User Agent data (see paragraph 3.2(e) above); Usage Information (see paragraph 3.2(f) above); your voice file for conversion into text (if required in accordance with your iOS device settings); and the language of the device operating system (of the RINGL user who sent the voice file to you).	Apple Privacy Policy
Giphy, Inc	GIF files   If you opt to use Giphy’s services to obtain a GIF file, your Communication-Related Information will be sent directly to Giphy, Inc from your device.	GIPHY Privacy Policy   GIPHY User Terms of Service

 

 

14. CHANGES TO THIS PRIVACY POLICY

We will update this Privacy Policy when necessary to reflect customer feedback, changes in our Services or legal changes. When we post the updated Privacy Policy, we will revise the “Effective Date” at the top of the Privacy Policy.

If there are material changes to the Privacy Policy or in how we will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification through RINGL. We encourage you to periodically review this Privacy Policy to learn how we are processing your personal data.

If you do not agree with any changes to our Privacy Policy and do not wish your personal data to be subject to our revised Privacy Policy, you shall cease to use our Services, and deactivate your Account. Your continued use of our Services after the effective date shall constitute your acceptance and agreement that all information collected from or about you on or through our Services after our revised Privacy Policy becomes effective and you will be subject to the terms of our revised Privacy Policy.

 

15. CONTACT US

We have appointed a data protection officer who is responsible for overseeing your queries in relation to this Privacy Policy. If you have any questions or suggestions about our Privacy Policy, including any requests to exercise your legal rights, please do not hesitate to contact our data protection officer using the details set out below:

Contact Details:

Address
84 Genting Lane #07-01 Axxel Innovation Centre Singapore 349854

E-mail address
privacy@ringl.im

Subject to our Data Request Policy, we try to respond to all legitimate requests within ten (10) business days. Occasionally it could take us longer than ten (10) business days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

16. GOVERNING LAW AND JURISDICTION

Nothing in this Privacy Policy shall limit your rights under any data protection or privacy related law that is applicable to you. This Privacy Policy shall be governed by the laws of the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the Singapore courts.