Table of Content
Personally Identifiable Information
We define personally identifiable information (or "PII") as "information that can be used to uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single individual." e. g. name, address, social security number, e-mail address etc. This is the common industry definition used by most Internet companies. Information that is collected by various Internet companies, but which does not qualify as PII is called "non-PII."
Certain Non-Personally Identifiable Information would be considered a part of your Personally Identifiable Information if it were combined with other identifiers (for example, combining your zip or PIN code with your street address) in a way that enables you to be identified. However, the same pieces of information are considered Non-Personally Identifiable Information when they are taken alone or combined only with other Non-Personally Identifiable Information (for example, your viewing preferences).
Information Collection and Use
Our primary goals in collecting Personally Identifiable information are to provide and improve your relationship with ABMR, including communication features and capabilities, to administer your account, and to enable users to enjoy and easily navigate the Site, Applications and Services.
What We Collect
The operation and use of Dial involves collection of personal data, where the types of such data depend on the type of Service and interaction with us. For example, when you sign up for Dial, you directly provide us personal data. We also automatically collect certain personal data from our users’ device. We explain which information we collect and how we collect it below.
The types of personal data collected through use of our Services, including the Dial Social Application and website, are listed below. We note that, some types of personal data we collect are required for all Dial Services (for example, your phone number), some types may be required solely for certain Services or features you decide to use (for example, Dial Pay), and some are optional, and subject to your discretion (for example, your photo)
We do not read, listen or store your messages and/ or calls made privately:
Data provided or collected through registration & under your Dial App account or participation in Dial’s activities:
- Identifiers, such as:
- Your mobile number (including mobile country/network code);
- Your personal details, (e.g., name, date of birth), if you provided them;
- Your contact details (e.g., email address), if you provided them;
- Device identifiers, as described below.
- Your photo, if you provided it (including any avatar, etc.).
- Your interests, if you chose to provide them to us.
- Your phone address book, meaning, the names, the phone numbers and the favorites list from your contact lists, if you approved access to them.
- General location, we use IP addresses we collect and additional information (e.g., phone number area codes), to estimate your general location (e.g., city level).
Data we collect automatically from your device, e.g., data collected using cookies and other device identifying technologies (Cookies and Tracking Technologies):
- Device identifiers, meaning identifiers for devices you have used to access our websites and application, including IP address, unique device identifiers, advertising related identifiers, MAC identifiers.
- Electronic network activity data, such as information stored on log files, when you access our Service and website for example, including access time and date stamp, pages viewed, IP address, the pages that directed you to our website, information related to errors and crash reports.
- Activity data, relating to your usage of Services, such as connection status, whether you have received and seen messages sent to you, if you are currently on another call and data related to the calls that you send and receive, such as length of the call, who called who, who messaged who, and at what time, your personal preferences related to such usage (for example how often, for how long, what options are selected, etc.).
- Other device data, e.g., data about your device’s operating system, your browser, browser or operating system language, your wireless network, your mobile carrier.
Data we collect or receive from other sources and inferred data:
- Your contact name, as saved on other users’ devices if they chose to share their contacts with us.
- Dial App may also process inferences about your account and device identifier, such as:
- Inferred gender – for example, inferred from your name;
- Inferred interests – inferred from the links you visited and your activity in communities and channels – as long as you permitted so;
- Inferences from third party data and ads-related interactions – we may receive inferred data, linked to your device identifier (mainly, a unique device identifier generated by cookies or other tracking technologies used on our website and Services) from our trusted third-party advertisers and service providers. Such inferred data we receive may include inferences about your interests and characteristics, generated by such third parties from other websites and services you have visited (for example whether you are interested in fintech, cars etc., which income group you might pertain to, as well as the locations you tend to visit, based on your GPS location). In addition, inferences can be generated from data on how you interact with ads displayed on our App after clicking on them and data about your activity and preferences derived from the clicks on our own ads (and the subsequent installs of our App) associated with your device identifier, delivered on third party’s advertising platforms by our trusted third parties.
Data we collect from your communications with us, including support, customer services and other inquiries:
If you choose to contact us through any means of communications we make available, you may provide us with certain information such as your contact details (e.g., name, email, phone number, mobile carrier, country – mainly where you are not a user of our Services) and other information you voluntarily wish to provide (mainly, related to the issue you wish us to address or resolve). We will further store our contact history and correspondence with you.
Non users’ data:
Mobile phone number and contact name, as saved on a Dial App user’s phone address book: we may process your mobile phone number even if you are not a Dial App user, in the event that your phone number was included in our existing user’s address book that has been provided to us (and subject to such user providing us with approval to access the device address book). We will also save the name it was saved under by our user. We do it to show our user who in their contacts is already using our Services and who is not, to allow users find and communicate with their contacts who are users or who are not users in a more efficient way, and solely for as long as a relevant Dial App user’s account exists on Dial App. In the event you will become an active user, the existing users whose phone book included your number, will be notified that you have joined the Service and you will be automatically added to their App’s contact list.
Business partners data:
When you communicate with us for business purposes as a business partner of ours, we will save your contact data provided by you (names, phone number, email, address etc.), as well as any correspondence we have had. We use trusted third-party providers to manage the maintenance and storage of such data.
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How We Use Your Data
At ABMR, we use your personal data to provide you with the best possible Service. This includes administering your account, customizing and improving the Service we offer, processing payments, serving ads and marketing campaigns, providing you with support and for compliance and safety reasons. We explain below the purposes for which we collect and use your personal data, as well as the types of data we use for each purpose.
Authentication and Account Administration:
Dial uses different types of your personal data to create and administrate your Dial account in order to enable you to register, log in, activate and use the Services. This includes, for example:
- To authenticate and verify your account, as well as to make sure you do not already have a Dial account;
- To synchronize your contact list on the Dial Social Application (meaning, in order to show you your contacts on the Dial interface so you contact them through Dial);
- To create your profile, customize your Dial account according to the information you have provided (i.e., name, photo, etc. including where you sign in through your social media account), and display such information as part of your profile when you use Dial Services.
Provide our Services – Communication & Content Features (messaging, voice and video calls, group chats, communities, channels, bots, chat extensions, explore screen, stickers, Dial App lenses, etc.), and enabling backups:
Dial uses different types of personal data in order to operate, provide and deliver to you our Services, including communication features. This includes, for example:
- To allow mobile carriers to connect calls to you and from you;
- To show your online status;
- To enable you to send messages, participate in Dial App calls, delete messages, etc.;
- To provide you with other App’s features such as operational notifications (e.g., missed calls);
- We will use your IP address to extract your approximate location, in order to enable you to use certain features that are only available in certain countries (for example, sticker packs);
- Enable you to upload and create backups of your messages on external services;
- Enable you to post and share your User Submitted Content (e.g., images and videos, etc.) on our communities, channels, and bots, where allowed by its administrator, and generally utilize our content features;
- Send you operational related and service-related communications, including administrative messages that relate to your use of the Services;
- Subject to the permission you provide, enabling you to share your location with your contacts.
- Please note that your messages will NOT be stored by us once they have been delivered.
Improving and Customizing the Service and Analytics of Dial App Activity:
Dial uses different types of personal data in order to improve, enhance and evaluate the Services, as well as customize the Services. This may include, for example:
- We use activity data, and device identifiers to fix and evaluate the technical functionality and availability of the Services, as well as for statistical analysis of the usage and functionality, product development, continued improvement of existing features and provision of certain features;
- We use your data provided through registration and inferred data (such as inferred gender, and inferences from ads related interactions), interests and general location to customize content we show you, including customized our offers of certain services;
- When we advertise our Services to you on third party platforms, we might receive indications of which advertisement led you to join our Service based on unique device identifiers associated with your device, in order, among others, to assess the performance of our campaigns, to look for similar users, for better ad measurements, as well as to learn more about your activity and preferences on our Services.
Marketing Communications with Dial’s Users & Location based Offers:
Dial uses different types of personal data in order to contact you with marketing and offers relating to products offered by the Dial Services, and our third party trusted partners, in line with applicable laws. This may include, for example:
- We will use your email address, name and inferred gender or age range, for the purpose contacting you with marketing and offers relating to products offered by Dial App, and our third party trusted partners;
- Your IP address will be used to extract your general location, for the purposes of presenting offers applicable to your region;
- Subject to the permissions you have provided, we will use you GPS location data for the purpose of providing you with location-based marketing offers and communications.
Please note that even after you have chosen to unsubscribe. we may send you service-related communications, including administrative messages that relate to your use of the Services.
ABMR uses different types of personal data in order to provide our advertising services (meaning, to enable the display of advertisements, including personalized advertisements provided by third party advertisers, in our App and Services), to measure and optimize the performance of ads and deliver more relevant ads. This may include, for example:
- ABMR may share your device identifier (mainly, a unique device identifier generated by cookies or other tracking technologies used on our website and Services), as well as age range, inferred gender, and reduced IP address (or GPS location data if you allowed us in your settings) with third party advertising partners for the purpose of presenting you with personalized ads;
- ABMR may collect and use data about links you visit through any of your messages and data about the communities and channels you have visited or follow, messages you have liked, messages you have sent and the content you have viewed, for the purpose of personalized advertising.
ABMR uses different types of personal data in order to provide customer service and customer support. This may include, for example:
- We will use your contact details to communicate with you, give you information about your account, and respond to your requests;
- We may use your contact history and correspondence with usfor the purpose of improving our Services, training our support team as well as internal management operation.
Safety, Security & Fraud Prevention:
ABMR uses different types of personal data for security purposes such as fraud and spam prevention. This may include, for example:
- We will collect and examine URLs included in messages or messages, which were reported by other users, or were otherwise suspected to be unsolicited and using your device operating system authentication services;
- We may use automated decisions to close an account based on such data and other logic we have created for this, in order to protect other users and prevent recurring breaches. If your account has been blocked, you can contact our support.
B2B Communications and Engagements: Provide Service to Existing Users:
We will use Business Partners Data (as detailed in the “Data We Collect”
section above) for the purpose of communicating with you, or as otherwise needed to facilitate our engagement, as well as to send you our marketing offers. You have the ability to opt out of our direct marketing emails at any time.
Provide Service to Existing Users:
We will store and use Non-User Data (as detailed in the “Data We Collect”
section above) which includes non-Dial users’ phone number (and names under which they were saved by Dial users) in the event such contact was included in our user’s address book that has been provided to us, and for the purpose of showing our user who in their contacts is already using our Services and who is not, to allow the user find and communicate with their contacts who are users in a more efficient way. If you are not a Dial user and would like to be excluded from such processing, please contact us at firstname.lastname@example.org.
Defend our Rights, Enforce our Policies & Compliance with Legal Obligations and Public Interests:
ABMR may use and share different types of personal data, and depending on the circumstances, for the purpose of defending our rights and enforcing our polices, terms and agreements, where it is necessary to comply with legal obligations to which we are subject to and cooperation with regulators and law enforcement bodies (where there is a valid legal request such as binding order), as well as in very limited and rare circumstances, where we find it necessary and essential for the purpose of protecting your or third party’s life safety and security as well as humanitarian purposes. This may include, for example:
- In the event of a dispute, claims and legal proceedings, and solely to the extent necessary for such purpose;
- We may record and log some of your actions, such as acceptance of our terms and polices, acceptance of certain offers, etc.;
- We will store an indication of your request to exercise your rights related to your personal data in order to be able to demonstrate compliance;
- We may store telecommunication data in accordance with local laws;
- We may be required to provide authorities with information in compliance with criminal investigations laws applicable to electronic communications provider or otherwise applicable to us.
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What Other Users Can See
When you use our Services, other Dial App users can see certain data about you, for example, the fact that you are a Dial App user or a user of certain Dial App Services, the content you voluntarily share, your profile information (subject to your settings), your connection status, etc., as we detail and explain below.
Other users can see on Dial App the following data about you:
- Unless you have changed your settings:
- your user name and photo;
- your phone number (if you are in communication with them);
- your connection status;
- whether you have received and seen messages sent to you;
- If you are currently on another call.
- If they are part of the call with you, data related to the calls and messages you have sent and received such as length of the call, who called who, who messaged who, and at what time, the type of call (audio/video) and whether you answered the call on your primary or another device.
- For disappearing messages, we will notify the other users of any screenshots you’ve taken (so please respect the vibe and do not take them).
- When you join Dial App, the contacts in your address book that are already Dial App members may be informed that you’re now on Dial App too.
- A reminder about your birthday on the date of your birthday.
- When you join Dial App Pay, the contacts in your address book that are already Dial App members may be informed that you’re now using Dial App Pay. In addition, Dial App users will see an indication whether you are a Dial App Pay user.
- If your “Use Peer-to-Peer” option is on, other users can use technical tools to see your IP address. You can turn this option off at any time on your privacy settings.
- Your public posts: if you post information on our public spaces such as communities or channels, it may be searchable and available to anyone on Dial App. You can always delete your posts on those public spaces, but ABMR cannot control and is not responsible for what other users do with this information (e.g., store on their devices, publish on Dial App or outside of it etc.), thus, we recommend you do not disclose your personal data through the content of your posts.
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How We Share Your Personal Data
We share data with third parties, including our corporate family and with trusted companies that help us provide our Services in compliance with strict data security and privacy practices, as well as other third parties such as our advertising partners, and third parties offering services through our App. We may also share personal data in limited circumstances where we are required to do so under applicable law. You can find here information about the categories of such third-party recipients, as well as the purpose for which the personal data is shared with such third parties.
Your data is kept safe with us, but we do share your personal data with third parties we trust, solely as follows:
The ABMR Corporate Family:
We may share the data we collect about you with the ABMR corporate family for the following purposes:
- Certain types of data, such as name, personal email, avatar, phone numbers, Dial App unique ID, may be disclosed in order to provide joint content and our Services (e.g., registration, coordination of membership accounts between the Dial App corporate family, transactions, analytics and customer support);
- Additionally, we may share certain types of data about you as may be necessary to help detect and prevent potentially illegal acts, violations of Dial App policies, fraud and/or data security breaches;
- We share data with ABMR’s subsidiaries due to our global operations, as we have teams and offices located worldwide, and each such subsidiary may operate the services or other functions (such as development, etc.) for a certain region;
Our Service Providers:
We share your personal data with our trusted service providers and business partners that perform business operations for us on our behalf (as data processors) and pursuant to our instructions. This includes the following types of service providers:
- Advertising and marketing service providers, who help us with advertising measurements and app installations;
- Data storage providers, with whom we entrust the hosting and storage of our data;
- Customer support providers, who help us perform such functions as customer support and customer service;
- Data analytics and data management providers, who help us analyze, improve, personalize and enhance our Services;
- Measurement partners, who help us with measurements, tracking and targeting;
- Data security partners, who help us detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches and ensure compliance with legal obligations.
Where we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).
To enable the limited advertisements on our Services, we may share device identifiers (i.e., an advertising identifier associated with your device) with our third-party advertising partners, along with certain of your device data (e.g. language preference), age range, inferred gender, country, city, reduced IP address (or GPS location data if you allowed us in your settings) and certain technical or aggregated data about you and the device you are using. This includes partners managing our advertising placements (ABMR included) and also advertisers themselves and their agencies or third parties managing their advertising demands. Your unique advertising identifier is created by your mobile device’s operating system and you can change it or choose not to share it at any time.
Legal and Law Enforcement:
Subject to our strict data security and privacy practices and without compromising our end-to-end encryption, we may disclose certain types of your data, including, and depending on the circumstances, Activity Data, Identifiers and your phone address book, to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other Dial App user to legal liability, and solely to the extent needed to comply with such purpose.
Limited Payment Services:
If you use our Dial App Pay services, we will share with our third-party payment processor KYC related data such as your name, date of birth, contact details, country, etc.
If you use our Dial App Out Credit and subscriptions, we will share your email address with our payment processor, for the purpose of verification and fraud detection.
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As we have explained above, we process personal data for various purposes. Accordingly, we only keep personal data as long as required to fulfill the purpose for which the data was collected, or, in some instance, where we have other necessities to retain the personal data, for example, where required by law. We explain below the criteria used by us to determine the retention of your personal data (meaning, for how long we store it and when we delete it, aligned with the type of data and purpose of collection).
The criteria used by us to determine Dial’s retention periods are as follows:
- The type of personal data and purpose of collection – unless otherwise specified, we retain data as long as it is necessary and relevant for us to achieve the purposes for which the personal data was collected. For example:
- Personal data required to be retained in order to maintain your Dial App account and to enable you the use of Dial App Services – these types of data, including your mobile number, and phone address book, will be retained for as long as you maintain your Dial App account.
- Personal data you have voluntarily provided during registration or through your account – these types of data, including your photo, date of birth, email address and interests, will be retained for as long as you maintain your Dial App account.
- The details of your communication with our customer support team will be stored for 10 years.
- Call Detail Records (CDRs) of your calls and messaging activity are kept as a raw data for 24 months from creation. CDRs may include, for example, your phone number and device identifiers (i.e., IP address, unique device identifier).
- We delete any message once delivered, or after 14 days if delivery attempts throughout this period was not successful.
If you decide to delete your Dial App account, the CDRs and communications with our customer support will be retained as detailed above, and we will further retain records of purchases you have made (using Dial App Pay, purchasing subscriptions, etc.), for the periods required under applicable laws, or as needed in accordance with our fraud monitoring program.
All other types of data related to your Dial App account will be deleted, unless we are required to further retain the data, subject to the criteria detailed below. We may keep activity data on a non-identifiable basis to improve our Services. Your posts on channels and communities may remain available if you do not delete them. Please note that deletion of the App (i.e., uninstall the App from your device) will not delete your account.
- Compliance with our legal obligations – we are required to retain certain types of data in order to comply with our obligations under applicable laws. For example, we need to retain transactions information to comply with tax legislation. In addition, we may retain certain types of personal data in the event we are required to do so subject to a binding legal request or a court order. Further, subject to EU Directive 2002/58/EC we are required to retain certain personal data (such as phone number) to convey messages and calls.
- Dispute, claims and legal proceedings – if you have a dispute with us, we may retain certain types of personal data as necessary and applicable to your claims, including any legal proceedings between us, until such dispute was resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the applicable correspondence for as long as needed to demonstrate compliance, and usually in accordance with applicable statutory limitation periods.
- Retention for Non users’ data – If you are not a Dial App user, and we process your data to enable Dial App users to communicate with you via Dial App Services we will retain such data as long as it is relevant to Dial App users, or until you have requested us to stop processing your phone number. You can request to exclude your phone number (by contacting us at: email@example.com). Furthermore, if one of our users used our Dial App Out Services in order to communicate with you (i.e., call you through Dial App), we will retain a log of such call (Call Detail Records – CDR – as detailed above), which will include your phone number, for 24 months from creation.
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Data Security and Storage
At ABMR, we take information security seriously and have strict security measures in place to ensure that your account and your personal data are safe. Here you can find information regarding the security measures we have in place.
We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data.
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Third-Party Websites, Apps and Back-Ups
Our App may contain links to other third-party websites or you may access Apps from a third-party website. We are not responsible for the data collection by such third parties, and their privacy practices and polices shall govern your personal data processed by them.
Third parties’ websites and apps:
If you access or Services and App from any third-party website or other digital source, or access any third-party site from our Services and App, note that, your use and the personal data collected will be subject to such third party’s practices and we do not monitor, nor responsible for the privacy practices of these third parties.
If you voluntarily choose to back up your Dial App conversations, such back-ups are made by independent third parties and kept on your device’s service according to operating system’s (Google/ iOS) terms and policies and are no longer protected by Dial’s end-to-end encryption nor Dial App has any control over it. This is also true for using Dial App Desktop – where your conversations are kept on your personal computer under your security definitions.
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Our Services are not intended for children under the age of 13 and we do not knowingly collect personal data from individuals under this age.
Our Services are not intended for children under the age of 13. Therefore, we do not knowingly collect personal data via our websites, applications, services, or tools from anyone under 13.
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As is the case with most sites, we gather certain information automatically which is then stored in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or click-through data. We may combine this automatically collected log information with other information we collect about you for the purposes of improving our products, marketing, analytics and/or Site functionality.
ABMR and our third-party partners such as service providers use technologies such as cookies and web beacons. By using our Site, you accept the use of these tracking technologies.
Cookies are small text files that web servers typically send to users’ computer when they visit a website. Cookies can be used on mobile applications as well. Cookies can be read or edited when the user loads a website or advertisement from the domain that wrote the cookie in the first place. Cookies are used by companies to collect and send information about a user’s visit – for example, number of visits to the application, average time spent, pages viewed, navigation history through the website, and other statistics. This information can be used to improve a user’s online experience by saving passwords or allowing companies to track and improve website loading times, for instance. Cookies can also be used to track a user’s browsing or online purchasing habits and to target advertisements to specific users. Cookies cannot be used to access any other data on a user’s mobile device, to personally identify them, or to act like malware or a virus. Users who prefer not to accept cookies on the web can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive. You can read more about cookies at http://www.allaboutcookies.org/cookies/.
Web beacons are a clear graphic image of 1×1 pixel that is delivered through a web browser usually as part of a webpage request or an email. Web beacons operate as a tag that records an end-users interaction with a web site or email.
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We may modify or update this privacy notice from time to time.
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