RINGL PRIVACY POLICY

Effective date: May 26, 2020.

1. About Us

RINGL messenger («RINGL») is operated by RINGL TECHNOLOGIES LLC («Us», «We» or «Our»), a limited liability company registered in the Republic of Belarus (Payer's Identification Number 193175076) and having its registered office at office 324, level 3, 2 Tolbukhina str., the city of Minsk, 220012, the Republic of Belarus.

2. Introduction

In order to provide You with the best experience with RINGL, We need You to share certain types of Your personal and non-personal data with Us. «Personal data» means any information capable of identifying You (such as Your mobile number or e-mail). «Non-personal data» means any information that does not, on its own, permit direct association with You (such as Usage data or User agent data as defined below). However, 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 committed to protecting the privacy and security of all personal data We receive from RINGL users.

This Privacy Policy explains Our policies regarding the collection, use, retention and disclosure of personal data when You use RINGL and the choices You have associated with those data.

This Privacy Policy forms part of User Agreement, which describes the terms under which You use RINGL and which is available at https://ringl.im/terms/ («User Agreement»). This Privacy Policy should therefore be read in conjunction with that User Agreement.

3. 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 only on the lawful basis;

- We make it transparent for You what operations We perform on your personal data, how we perform them and why;

- We will not process Your personal data in a way that is detrimental, unexpected or misleading to You;

- We process Your personal data only for the specific reasons We collected it and We assure You that such reasons are clearly defined and legitimate;

- We will not collect and ask You to provide Us with Your personal data more 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;

- We will always facilitate the exercising of Your legitimate rights concerning the processing of Your personal data by Us.

4. What information do We process about You?

We may process certain types of information that may contain personal data about You as follows:

a) Contact data: includes Your mobile number or e-mail;

b) Contact list data: includes hashed mobile numbers of all contacts stored on Your communication device;

c) Artificially created data: Your Registration ID (as described in clause 6.3 below) generated by Us;

d) Usage data:

IP-addresses of Your communication device and of Your contact’s communication device;

- date/time/volume of each request for communication session sent to Our servers from Your communication device;

e) User agent data:

- the name of Your RINGL Application;

- the current version of Your RINGL Application;

- Your iOS / Android current version;

- the model of Your communication device;

f) Transferable data: includes Your personal data that may be contained in heavily encrypted and inaccessible to Us calls, messages and files sent (made) between You and Your contact(s) via Our servers;

g) Push notifications data:

- a unique identifier generated by Apple, Inc / Google LLC indicating the device and application to which a push notification will be sent;

- the sender's encrypted mobile number or e-mail (for calls to iOS devices only);

h) Error-related information: the following information is collected by:

Firebase Crashlytics (for Android devices):

- User agent data;

- Your communication device display orientation at the moment an error occurred;

- Your communication device IP-address;

- the date and time an error occurred;

- the date/time/volume of each request to transfer data to Firebase Crashlytics;

- Your RINGL Application ID in Google Play;

- information about how Your RINGL Application was used;

- information relating to the physical location of Your communication device;

- OS version of Your communication device.

iOS Crash Reports (for iOS devices): the data specified in the relevant agreement(s) concluded between Apple, Inc and You.

We receive only the following information of the above from Firebase Crashlytics / iOS Crash Reports:

information about how Your RINGL Application was used;

- how many times an error happened to Your RINGL Application;

- the number of users who encountered such error;

- Your RINGL Application current version;

- OS version of Your communication device.

The following third-party services («Third Party Services») are currently accessible via RINGL built-in functions:

- Speech Recognition (voice-to-text conversion), operated by Apple, Inc;

- ML Kit for Firebase (translation of messages into different languages), operated by Google LLC;

- Giphy services (searching and sharing of GIF files), operated by Giphy, Inc.

If You opt to use Third Party Services, the information that may contain Your personal data will be transmitted from Your communication device to Third Party Services operators as follows:

Third Party Service used by You

Apple, Inc

receives

Google LLC

receives

Giphy, Inc

receives

Speech Recognition

(1), (2), (4), (5), (6)

-

-

ML Kit for Firebase

-

(1), (3), (4)

-

Giphy Services

-

-

(1), (2), (4)

Note:

(1) IP-address of Your communication device;

(2) date/time/volume of each request to use services sent from Your communication device;

(3) date/time/volume of each request to use services sent from Your communication device (only when a request for download of translation language is made);

(4) Your iOS / Android current version;

(5) a voice file provided by You for conversion into text (if required in accordance with Your iOS device settings);

(6) the language of the communication device operating system of Your contact who has sent the voice file to You.

5. How do We collect information about You?

We may receive information about You:

- directly from You when You sign up for RINGL or use certain RINGL built-in function 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.

6. How, why and how long will We use information about You?

6.1. Mobile number or e-mail

You provide Us with Your mobile number or e-mail to create a RINGL account. Your mobile number (e-mail) is stored on Our servers and is used as a unique identifier (login) of Your RINGL account to distinguish it from RINGL accounts of other users.

Your mobile number (e-mail) is available to all persons in Your RINGL contact list to make it possible for them to identify You.

We store Your mobile number (e-mail) for all the lifetime of Your RINGL account.

6.2. Contact list data

Once You have signed up for RINGL, You may give a separate consent to sync Your communication device contact list with Your RINGL account contact list. If You do so, You will share hashed mobile numbers of all persons in Your communication device contact list with Us.

Once the synchronization is completed, We will immediately delete the contact list data from Our servers.

6.3. Registration ID

When You register as a RINGL user, We will generate a unique Registration ID, which will be stored on:

- RINGL servers;

- Your main communication device (when You link an additional communication device to Your RINGL account, Your Registration ID will be shared with such another device);

- the communication devices of Your RINGL contacts.

A recipient device will use Your Registration ID to check if a new communication session with You was encrypted with the same set of encryption keys as the previous one. If an unauthorized person manages to communicate with Your RINGL contacts via Your RINGL account using another device, these contacts will receive a warning that any communication with You might not be safe. This function is purposed to keep Your RINGL contacts safe from fraudulent actions that may be carried out by unauthorized persons with the use of Your RINGL account.

However, Your Registration ID will be automatically replaced by a new one when You change Your communication device or reinstall Your RINGL Application. So upon the next communication session with You Your RINGL contacts will receive the same warning in these cases as well.

Your Registration ID (which might be replaced from time to time) will be stored:

- on RINGL servers for all the lifetime of Your RINGL account;

- on Your communication device until You uninstall Your RINGL Application from it;

- on the communication device of Your RINGL contact until he / she uninstalls RINGL Application from it or until You uninstall Your RINGL Application from Your communication device, whichever comes earlier.

6.4. Communication sessions logs

Each time You send a text message or a file to Your contact or You are calling him/her via RINGL Your device shares the following information («Recorded Information») with Our third party service provider’s (Amazon Web Services EMEA SARL) servers («AWS servers»):

- Usage data;

- User agent data.

We use AWS servers to determine the optimal route to deliver Your message, file or call to Your contact. The Recorded Information may be processed by AWS servers in accordance with Amazon Web Services EMEA SARL privacy notice (https://aws.amazon.com/ru/privacy/).

Once the optimal route is determined, AWS servers share the Recorded Information with RINGL servers. Besides the Recorded Information We also obtain Your and Your contact’s logins (mobile numbers and/or e-mails). All this data is stored on RINGL servers for 30 calendar days before it is deleted to make it possible for Us to conduct Our anti DDoS and anti flood policy.

What concerns one-to-one and group calls, once Your contact takes a call, normally all further communication between You and Your contact are carried out without the facilitation of RINGL or third parties’ servers. However, in case there is no technical possibility to create a stable direct connection, the corresponding call will be facilitated by Our and/or AWS servers.

You may turn off the processing of Your calls by AWS servers in the privacy settings of Your RINGL Application. Please, be aware that if You opt to do so, the quality of Your calls may get worse.

6.5. One-to-one and group calls

Generally, all calls are made directly between RINGL users and We do not process any calls that You may initiate or participate in.

However, in case there is no technical possibility to create a stable direct connection, the corresponding call will be facilitated by Our and/or AWS servers with the application of all appropriate safeguards as mentioned in section 11 herein. Neither We, nor Amazon Web Services EMEA SARL can decrypt or otherwise access the content of Your call facilitated by Our and/or AWS servers and it is not processed in any way once the call is over.

You may turn off the processing of Your calls by AWS servers in the privacy settings of Your RINGL Application. Please, be aware that if You opt to do so, the quality of Your calls may get worse.

6.6. One-to-one and group messages

6.6.1. Generally, all messages are encrypted and sent to recipients through RINGL servers. We cease to retain a message once it is successfully delivered to its recipient.

RINGL queues messages (up to 1000 messages per one person in Your contact list for a period not exceeding 30 calendar days) on its servers for delivery to devices that are temporary offline. We cease to retain Your message queued on RINGL server:

- after the message has been delivered to the recipient, OR

- once all attempts to deliver the message within 30 calendar days failed, OR

- once You have sent another 1000 messages to the recipient’s devices that are temporary offline.

We cannot decrypt Your messages and their content is absolutely inaccessible to Us.

6.6.2. ML Kit for Firebase

If You opt to use ML Kit for Firebase to translate a message into the language of its recipient, the following information («Translation Related Information») will be sent to Google LLC servers from Your communication device:

- IP-address of Your communication device;

- date/time/volume of each request to use services sent from Your communication device (only when a request for download of translation language is made);

- Your iOS/Android current version.

The transmission of the Translation Related Information is carried out with the use of secured HTTPS connection.

Google LLC may process the Translation Related Information in accordance with their privacy policy available at: https://policies.google.com/privacy.

6.7. Files

6.7.1. Even if You and Your contact are simultaneously online, a stable transfer of a file that You may send to or receive from Your contact can not be guaranteed when it is carried out without the facilitation of a third party’s server because normally file size is too big to be transferred directly between two users’ devices without interruption.

Thus each photo, video, document and any other type of files that You may send to Your contact will be encrypted and uploaded to AWS servers and then transferred to Your contact in a smooth and prompt way. Since all files are encrypted, Amazon Web Services EMEA SARL has no possibility to decrypt or otherwise access the content of such files stored on its servers.

Your files will be stored on AWS servers for 30 calendar days before they are deleted. Therefore You cannot synchronize files sent or received via RINGL between Your devices once the mentioned period has expired.

6.7.2. Speech Recognition

If You opt to use Speech Recognition to convert a voice file into a text, the following information («Conversion Related Information») will be sent directly to Apple, Inc from Your communication device:

- IP-address of Your communication device;

- date/time/volume of each request to use services sent from your communication device;

- Your iOS current version;

- a voice file provided by You for conversion into text (if required in accordance with Your iOS device settings);

- the language of the communication device operating system of Your contact who has sent the voice file to You.

The transmission of the Conversion Related Information is carried out with the use of secured HTTPS connection.

The Conversion Related Information may be further processed by Apple, Inc in accordance with their privacy policy available at: https://www.apple.com/legal/privacy/en-ww/.

6.7.3. Giphy services

If You opt to use Giphy services to get a GIF file, the following information («GIF Related Information») will be sent directly to Giphy, Inc from Your communication device:

- IP-address of Your communication device;

- date/time/volume of each request to use services sent from your communication device;

- Your iOS / Android current version.

The transmission of the GIF Related Information is carried out with the use of secured HTTPS connection.

The GIF Related Information may be further processed by Giphy, Inc in accordance with their privacy policy available at: https://support.giphy.com/hc/en-us/articles/360032872931-GIPHY-Privacy-Policy.

Once the GIF Related Information is transmitted to Giphy, Inc, the further use of Giphy services by You shall be regulated by GIPHY User Terms of Service available at: https://support.giphy.com/hc/en-us/articles/360020027752-GIPHY-User-Terms-of-Service.

6.8. Error-related information

You may activate the option to send to Us reports on errors (crashes, malfunctions) that may happen to Your RINLG Application during its operation to provide Us with the possibility to examine and rectify them in order to prevent their occurrence in the future. All error-related information will be collected from Your communication device and transmitted to Us through Firebase Crashlytics (for Android devices) or iOS Crash Reports (for iOS devices) as described below. Please note that the use of Firebase Crashlytics / iOS Crash Reports contemplates the use of technology to track Your activity and otherwise collect information from You.

Android devices

If You have activated the option “Allow RINGL to collect advanced analytics and crash reports?” in Your RINGL Application settings, when an error occurs the following data will be send to Firebase Crashlytics operated by Google Ireland Limited from Your communication device:

- User agent data;

- Your communication device display orientation at the moment an error occurred;

- Your communication device IP-address;

- the date and time an error occurred;

- the date/time/volume of each request to transfer data to Firebase Crashlytics;

- Your RINGL Application ID in Google Play;

-  information about how Your RINGL Application was used;

- information relating to the physical location of Your communication device;

- OS version of Your communication device.

Google Ireland Limited may process these data in accordance with:

- Firebase Crashlytics privacy settings available at: https://docs.fabric.io/apple/fabric/data-privacy.html#data-collection-policies, AND/OR

- their privacy policy available at: https://policies.google.com/privacy.

iOS devices

If You have activated the option “Share with developers” in Your iOS device analytics settings, when an error occurs a crash report containing the data specified in the agreement concluded between Apple, Inc and You will be send to iOS Crash Reports operated by Apple, Inc. from Your communication device.

These data may be further processed in accordance with Apple, Inc. privacy policy available at: https://www.apple.com/legal/privacy/en-ww/.

We receive only the following information of the above from Firebase Crashlytics / iOS Crash Reports:

information about how Your RINGL Application was used;

- how many times an error happened to Your RINGL Application;

- the number of users who encountered such error;

- Your RINGL Application current version;

- OS version of Your communication device.

We will store this information for a period required to examine and rectify errors evidenced by such information, but anyways not longer than 1 (one) year from the moment We have received the information.

6.9. Push notifications

If the recipient of Your call/message/file has allowed the receipt of push notifications from his/her RINGL Application, he/she will be notified of the receipt of Your call/message/file from You via a push notification if his/her RINGL Application is inactive at the moment the call/message/file is sent/made. In this case the following information will be send from RINGL servers to Apple, Inc (in case of communication to a user who uses iOS device) / Google LLC (in case of communication to a user who uses Android device):

- a unique identifier generated by Apple, Inc / Google LLC indicating the device and application to which a push notification will be sent;

- the sender's encrypted mobile number or e-mail (for calls to iOS devices only).

These data may be further processed in accordance with:

- Apple, Inc. privacy policy available at: https://www.apple.com/legal/privacy/en-ww/;

- Google LLC privacy policy available at: https://policies.google.com/privacy.

7. What information will We not process?

7.1. Profile name and profile picture

We do not require You to add Your profile name and/or profile picture to Your RINGL account, but You may decide to do so to make it easier for other RINGL users to recognize who You are. Such information is always accessible to Your RINGL contacts.

RINGL users’ profile names and profile pictures are transferred on peer-to-peer basis without the facilitation of RINGL servers. We have no access to and do not process Your profile name and profile picture in any way.

7.2. PIN code, fingerprint, face ID

Should you opt to enhance the security of Your RINGL account by using a PIN code, Touch ID and/or Face ID protection, all Your personal data related to these means of protection, i.e digital code, fingerprint, facial image will be stored on your communication device only. All this information is absolutely inaccessible to Us and there is no way for Us to process it.

7.3. The history of successfully delivered messages

The history of successfully delivered messages is stored on Your devices only. The messages stored on one device will be being automatically synchronized from that device to others providing all devices are online and are bound to the same RINGL account. Such synchronization will be carried out directly between user’s devices without the facilitation of RINGL servers.

8. How do We process Your personal data when You use RINGL through VPN?

If You use RINGL thought VPN then VPN servers automatically process IP-address of Your communication device. This information is the minimum required and enough for VPN servers in order to provide you access to RINGL.

Please note that VPN servers do not share or otherwise disclose IP-address of Your communication device to any Third Party Services for any purposes. Neither do we match IP-address of Your communication device and your any other personal data for any purposes. We would like to stress that IP-address of Your communication device is process by VPN servers only to provide you access to RINGL.

After you gain access to RINGL, Your use of RINGL will be governed by this Privacy Policy, particularly, you can find how RINGL process Your personal data in sections 4-7 herein.

9. Non-use of automated decision-making (profiling)

We do not analyze Your personal data in an automated way to identify or predict Your behaviour, personal preferences, movements, interests or other personal aspects.

10. Legal basis for processing your personal data

We will only use Your personal data when legally permitted. The most common uses of Your personal data are:

- where You have given a consent to the processing of Your personal data for one or more specific purposes;

- where We need to take steps at Your request prior to entering into User Agreement with You and to perform it;

- where it is necessary for Our legitimate interests (or those of a third party) and Your interests and fundamental rights and freedoms do not override those interests.

Please be aware that, in certain circumstances, where You do not provide personal data which is required by Us, We may not be able to enter into User Agreement with You or provide the services under the User Agreement concluded with You. You will be made aware if this situation arises and what the consequences of not providing the personal data will be.

Set out below is a description of the legal grounds on which We will process Your personal data:

Purpose / Activity

Type of data

Lawful basis for processing

To register You as a RINGL user

 

(a) Your mobile number, OR

(b) Your e-mail

Taking steps at Your request prior to entering into User Agreement with You

 

To maintain your RINGL account

(a) Your mobile number, OR

(b) Your e-mail

Performance of the User Agreement concluded with You

To sync Your communication device contact list with Your RINGL account contact list

Hashed mobile numbers of all contacts in Your communication device contact list

Your consent

 

To sync Your mobile number stored on the communication device of another RINGL user from that user’s device to that user’s RINGL account

Your hashed mobile number

The legitimate interest of a RINGL user to have Your contact details transferred from his/her communication device to his/her RINGL account in a simple and accurate way

To keep Your RINGL contacts safe from fraudulent actions that may be carried out by unauthorized persons with the use of Your RINGL account in case You have lost Your communication device

Your Registration ID generated by Us

The legitimate interest of your RINGL contacts to be safe from fraudulent actions that may be carried out by unauthorized persons with the use of Your RINGL account

To identify and stop malicious actions against Our servers, including “denial of service” attacks, flooding

(a) Usage data;

(b) User agent data

 

Our legitimate interest to protect Our servers from malicious attacks in order to provide RINGL users with Our best services on an ongoing basis

 

To facilitate the communication between You and Your RINGL contact(s) when it can not be carried out on peer-to-peer basis

 

(a) Usage data;

(b) User agent data;

(c) Your and Your contact’s logins (mobile numbers and/or e-mails);

(d) Encrypted content of one-to-one and group calls, AND/ OR encrypted text messages, AND/OR encrypted files, taken, sent or received by You via RINGL

Performance of the User Agreement concluded with You

 

To assist You in communication with Your RINGL contact(s), who doesn’t (don’t) speak Your language

(a) IP-address of Your communication device;

(b) Date/time/volume of each request to use ML Kit for Firebase sent from Your communication device (only when a request for download of translation language is made);

(c) Your iOS/Android current version.

All the data mentioned in paragraphs (a) - (c) herein are transmitted from Your communication device directly to Google LLC.

 

Performance of the User Agreement concluded with You

To provide You with the opportunity to convert voice files received from Your contacts into text messages

(a) A voice file, which is to be converted into text with the use of Speech Recognition (if required in accordance with Your iOS device settings);

(b) IP-address of Your communication device;

(c) Date/time/volume of each request to use Speech Recognition sent from Your communication device;

(d) Your iOS/Android current version;

(e) The language of the communication device operating system of Your contact who has sent the voice file to You.

 

All the data mentioned in paragraphs (a) - (e) herein are transmitted from Your communication device directly to Apple, Inc.

 

Performance of the User Agreement concluded with You

To provide You with the possibility to intersperse Your text communications with GIF files to Your taste

(a) IP-address of Your communication device;

(b) Date/time/volume of each request to use Giphy, Inc services sent from Your communication device;

(c) Your iOS/Android current version.

 All the data mentioned in paragraphs (a) - (с) herein are transmitted from Your communication device directly to Giphy, Inc.

 

Performance of the User Agreement concluded with You

To procure that Your recipient is well-informed about Your attempts to call him / her and about the delivery of Your messages / files to him / her

 

(a) A unique identifier generated by Apple, Inc. / Google LLC indicating the device and application to which a push notification will be sent;

(b) Your encrypted mobile number or e-mail (for calls to iOS devices only).

Performance of the User Agreement concluded with You

To rectify failures in functioning of Your RINGL Application

To provide You access to RINGL through VPN

(a) User agent data;

(b) Your communication device display orientation at the moment an error occurred;

(c) Your communication device IP-address;

(d) The date and time an error occurred;

(e) The date/time/volume of each request to transfer data to Firebase Crashlytics;

(f) Your RINGL Application ID Google Play;

(g) information about how Your RINGL Application was used;

(h) information relating to the physical location of Your communication device;

i) OS version of Your communication device;

j) the data specified in the relevant agreement(s) concluded between Apple, Inc and You.

All the data mentioned in paragraphs (a) – (i) above are transmitted from Your communication device directly to Firebase Crashlytics (for Android devices) operated by Google Ireland Limited.

All the data mentioned in paragraph (j) above are transmitted from Your communication device directly to iOS Crash Reports (for iOS devices) operated by Apple, Inc.

We receive only the following information of the above from Firebase Crashlytics / iOS Crash Reports:

(a) information about how Your RINGL Application was used;

(b) how many times an error happened to Your RINGL Application;

(c) the number of users who encountered such error;

(d) Your RINGL Application current version.

(e) OS version of Your communication device.

IP-address of Your communication device

Your consent

Taking steps at Your request prior to entering into User Agreement with You

11. How do We keep Your personal data safe?

11.1. Technical measures

Your personal data is stored on:

- servers leased by Us located in data centers in the Netherlands;

- Amazon Web Services EMEA SARL servers;

- Apple, Inc. servers;

- Google Ireland Limited / Google LLC servers;

- Giphy, Inc servers.

We took all appropriate technical safeguards to protect the privacy and security of Your personal data processed by Us by implementation of such systems as firewalls, access control, health monitoring, anti virus, anti DDoS, anti flood and others.

Personal data stored on other parties’ servers is protected in accordance with their privacy policies available at:

 

Name of the party

A link to the party’s privacy policy text

Amazon Web Services  EMEA SARL

https://aws.amazon.com/ru/privacy/

Apple, Inc.

https://www.apple.com/legal/privacy/en-ww/

Google Ireland Limited / Google LLC

https://policies.google.com/privacy?hl=en-US

Giphy, Inc.

https://support.giphy.com/hc/en-us/articles/360032872931-GIPHY-Privacy-Policy

11.2 End-to-end encryption

End-to-end encryption is a system of communication where only the communicating users have access to the content of their communication.

Your messages and files, profile name, profile picture and the content of Your calls, before they are sent (made) from Your communication device, are encrypted with a key known only to You and the recipient.

Any third party that may store Your encrypted communication as set out herein has no means to decrypt it.

The recipient receives the encrypted communication and decrypts it himself / herself only.

11.3. Encryption of Your data stored on Our servers

We encrypt the following personal data related to Your communication sessions stored on Our servers:

Usage data;

- User agent data.

The encryption of that personal data is carried out on the day next to the day when We obtained such data.

11.4. Hashing

All contact list data synced from Your communication device to Your RINGL account is hashed to prevent unauthorized access to this type of information.

11.5. Secured connection

All the Translation Related Information, the Conversion Related Information, the GIF Related Information are transmitted with the use of secured HTTPS connection.

12. Who do We share Your personal data with?

12.1. Other RINGL users

You may choose to communicate and share certain information via RINGL with other RINGL users who may be located outside the country where You live. To perform this instruction given to Us by You on the basis of the User Agreement with You We will transfer Your personal data, on Your behalf, to those users in accordance with this Privacy Policy.

12.2. Amazon Web Services

For the purpose of performance of the User Agreement concluded with You We have to share Your personal data as specified in clauses 6.4, 6.5, 6.7.1 herein with Amazon Web Services operated by Amazon Web Services EMEA SARL based in Europe.

The privacy notice of Amazon Web Services that explains how Amazon Web Services collects and uses your personal data, is available at this link – https://aws.amazon.com/ru/privacy/.

At all times You may turn off the processing of Your calls by AWS servers in the privacy settings of Your RINGL Application. Please, be aware that if You opt to do so, the quality of Your calls may get worse.

12.3. Apple, Inc

For the purpose of performance of the User Agreement concluded with You, when You use Speech Recognition or communicate to a user who uses iOS device with push-notifications permitted, Your personal data as specified in clauses 6.7.2, 6.9 herein will be sent to Apple, Inc.

Your information as specified in clause 6.8 herein will also be transferred to Apple, Inc if You give a consent to do so.

12.4. Google Companies

When You use ML Kit for Firebase or communicate to a user who uses Android device and has permitted the receipt of push-notifications through his/her RINGL Application, Your personal data as specified in clauses 6.6.2, 6.9 herein will be transferred to Google LLC.

Your information as specified in clause 6.8 herein will also be transferred to Google Ireland Limited based in Europe, as well as be transferred, stored and used in the USA and any other country where Google or any third party service providers acting on its behalf, operates, if You give a consent to do so.

Google LLC based in the USA is recognized as a company that ensures an adequate level of protection of personal data of persons located in the EEA since it is a participant of EU-U.S. Privacy Shield Framework (the confirmation of the certification is available at this link – https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI).

12.5. Giphy, Inc.

For the purpose of performance of the User Agreement concluded with You, when You use Giphy services Your personal data as specified in clause 6.7.3 herein will be sent to Giphy, Inc.

Giphy, Inc. complies with the EU.-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data transferred from the EU to the U.S. Giphy, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU.

12.6. Law enforcement authorities

We also will share Your personal data stored by Us with judicial and law enforcement authorities subject to their lawful orders/requests, if We are required by law to do so.

13. Risks in relation to the processing of Your personal data by Us

13.1. Possible risks of international transfers of Your personal data

As described in section 12 herein, We may transfer Your personal data outside the country where You live to persons located in countries where the privacy and data protection laws may vary from those in Your country. Please be aware that in such cases Your personal data undergoing processing may not have the same level of protection as required in Your country.

13.2. Misuse of Your personal data by Your RINGL contacts

Other RINGL users to whom We may transfer Your personal data on Your behalf as described in clause 12.1 herein may use it in a way that infringes Your right to the protection of Your personal data. For this reason We urge caution when You share Your personal data with anyone of Your RINGL contacts.

13.3. Accidental or unlawful privacy breach

Despite We take all appropriate technical and organizational measures to keep Your personal data processed by Us safe and secure, it may be accidentally or unlawfully destroyed, lost, altered, disclosed or accessed due to non-preventable malicious actions against Our servers or servers of Our third party service providers, their subsidiaries or contractors, as well as due to misconduct or malicious intent from Our employees or those of Our third party service providers, their subsidiaries or contractors. Our highest priority is to exert every possible effort to ensure that no such cases occur.

14. Your legal rights in connection with Your personal data

14.1. You have the right to withdraw Your consent to the processing of Your personal data by Us at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Please, note that the withdrawal of Your consent to the processing of some personal data concerning You may make it impossible for Us to provide you with Our services in whole or in part.

14.2. Under certain circumstances, by law You have the right to:

(a) Request access to Your personal data processed by Us, meaning that You are entitled to request the confirmation from Us whether We process Your personal data or not, and where that is the case, to receive a copy of Your personal data that is being processed by Us together with the following information:

·      categories of personal data processed;

·      the purposes of processing;

      the persons or categories of persons who receive Your personal data from Us;

      how long We will process Your personal data;

      the existence of Your right to request correction or erasure of Your personal data or restriction of or objection to its processing;

      the existence of Your right to lodge a complaint with a supervisory authority;

      information about the personal data’s source if We do not collect personal data directly from You;

      whether We use automated decision-making, including profiling, the auto-decision logic used and the consequences of such processing;

      information about the appropriate safeguards if Your personal data are transferred to a third country or international organization.

Where You have decided to send the request via Your RINGL Application, You may specify the information or processing activities to which Your request relates to make it easier for Us to perform it.

(b) Receive Your personal data that You have provided to Us on the basis of Your consent or  the User Agreement with You in a usable electronic format and have this data transmitted directly to another controller (where technically feasible).

(c) Request correction of Your data. This enables You to ask Us to correct any incomplete or inaccurate information We hold about You.

We will communicate the correction of the personal data to each recipient to whom We disclosed the personal data (for example, Our third party service providers who process the data on Our behalf), unless this is impossible or involves disproportionate effort. We will also inform You about those recipients if You request it.

(d) Request the restriction of processing of Your data. This enables You to ask Us to suspend the processing of Your data when:

- You contest the accuracy of the personal data held by Us (the restriction shall be in force until the accuracy of Your personal data is verified by Us);

- You feel Your personal data has been unlawfully processed;

- We no longer need to process Your personal data but You need the personal data for the establishment, exercise, or defence of legal claims;

- You have objected to Our processing of Your personal data carried out to meet legitimate interests pursued by Us or by a third party (the restriction shall be in force while We are deciding whether We have an overriding legitimate ground to the processing);

- You have objected to Our processing of Your personal data carried out to meet Our public interest tasks (the restriction shall be in force while We are deciding whether We have an overriding legitimate ground to the processing).

To help Us process Your request quickly and efficiently, You may specify the personal data the processing of which You are requesting Us to restrict.

We will communicate the restriction of the personal data to each recipient to whom We disclosed the personal data (for example, Our third party service providers who process the data on Our behalf), unless this is impossible or involves disproportionate effort. We will also inform You about those recipients if You request it.

Please, note that the restriction of processing of some personal data concerning You may make it impossible for Us to further provide You with Our services in whole or in part.

(e) Object to processing of Your datawhere We are processing it:

- for direct marketing purposes;

- for scientific or historical research purposes or statistical purposes;

- to meet Our public interest tasks and there is something about Your particular situation which makes You want to object to processing on this ground;

- to meet Our legitimate interests (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground.

Please, note that the objection to processing of personal data concerning You for some purposes may make it impossible for Us to further provide You with Our services in whole or in part.

(f) Request erasure of Your data. This enables You to ask Us to erase Your data, particularly when:

- You feel Your personal data is no longer necessary for the purposes for which We originally collected or otherwise processed it;

- You withdraw Your consent to Our processing activities (this only applies to the personal data being processed by Us on the basis of Your consent);

- You object to Our processing of Your personal data carried out to meet Our legitimate interests (or those of a third party);

- You object to Our processing of Your personal data carried out to meet Our public interest tasks;

- You object to Our processing of Your personal data for direct marketing purposes;

- You feel Your personal data has been unlawfully processed;

- You feel We are subject to a legal obligation of the EU or its Member State that requires the erasure of Your personal data;

- You are a child or You were a child at the time of the data processing and You feel Your data was used to offer You information society services.

If We made the personal data that is the subject of Your erasure request public, We will take reasonable steps, including technical measures, to inform other organizations processing Your personal data that You have requested erasure, including any links to, and copies of, the personal data.

We will communicate the erasure of the personal data to each recipient to whom We disclosed the personal data (for example, Our third-party service providers who process the data on our behalf), unless this is impossible or involves disproportionate effort. We will also inform You about those recipients if You request it.

Please, note that the erasure of some personal data concerning You may make it impossible for Us to further provide You with Our services in whole or in part.

14.3. If You live in the European Economic Area, You have the right to lodge a complaint with a data protection authority if You feel that Your rights concerning Your personal data are infringed by Us.

However, We are committed to working with You to obtain a fair resolution of any complaint or concerns about Your personal data processed by Us. So We would appreciate if You contact Us before you lodge a complaint with a data protection authority to attempt to resolve any outstanding issues in the most efficient and expeditious manner.

14.4. Your California Privacy Rights

Under California’s «Shine the Light» law, California residents who provide personal information in obtaining RINGL services for personal, family, or household use are entitled to request and obtain from Us once a calendar year information about the customer information We shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which We shared customer information for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 sharing activities).

15. How can You exercise Your legal rights in connection with Your personal data?

15.1. If You would like to exercise any of the rights mentioned in clauses 14.1, 14.2, 14.4 herein please follow these steps:

- open your RINGL Application;

- select “Settings”;

- choose “Privacy and Security”;

- click on the option, which is referred to the right that You want to exercise, and then follow the steps to confirm Your decision, OR click on the option “Contact Us” and send the corresponding request to Us.

We will contact You for additional information if the scope of Your request is unclear or does not provide sufficient information for Us to act on it.

We will begin processing Your request as soon as We have all of the information We need to locate Your relevant personal data.

But please note that applicable law may allow or require Us to refuse to act on Your request, or We may have destroyed, erased, or made Your personal data anonymous in accordance with Our record retention obligations and practices. If We cannot honor Your request, We will inform You of the reasons why, subject to any legal or regulatory restrictions.

15.2. Please, note that with the use of RINGL Application You also may:

- manually change Your profile name, profile picture and status message;

- manually change the content of a message You have sent to Your contact providing that no more than 30 days elapsed since the message has been sent;

- manually delete a message (file) You have sent to Your contact providing that no more than 30 days elapsed since the message (file) has been sent;

- delete Your RINGL account at any time, which will result in erasure of all personal data processed by Us in connection with You.

15.3. To exercise Your right mentioned in clause 14.3 herein, please refer to https://edpb.europa.eu/about-edpb/board/members_en.

16. 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 Your RINGL Application. 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, You must delete Your Account and no longer access or use RINGL Application. Your continued use of RINGL Application after the changes become effective means that You are consenting to the updated terms.

17. Contact Us

If You have any questions, comments or concerns about this Privacy Policy, please contact Us by e-mail at business@ringl.im.

18. Notice for users who live in the European Economic Area (EEA)

If You live in the EEA, the processing of Your personal data by Us will be governed by the European General Data Protection Regulation («GDPR»).

19. Representative in the EEA

Whereas We are located outside the EEA, pursuant to Article 27 of GDPR, We have appointed ELMANOR ENTERPRISES LIMITED, located at Poseidonos, 1, LEDRA BUSINESS CENTRE, Egkomi, P.C. 2406, Nicosia, Cyprus, as Our GDPR representative in the EEA. You can contact ELMANOR ENTERPRISES LIMITED regarding matters pertaining to the GDPR by sending an email to business@elmanor.com.