Last update 1 September 2022
Overview
1. Information We Process
1.1 Information that you submit
1.2 Information That Is Processed Automatically
1.3 Payment Information
1.4 Messaging Policy and SMS/MMS Privacy Statement
2. The Purposes of Processing your personal data
3. Information We Share: Partners and Integrations
4. Retention of information
5. Security of Personal Information
6. Accuracy of Personal Information
7. Privacy of children
8. Changes and amendments
9. Acceptance of this policy
10. Contact Us
DoCall is a brand of DynApps Bilisim Hizmetleri ve Ticaret Limited Sirketi. DoCall is founded on the principle of helping people keep their private communications private without compromise as they should be. The purpose of this Privacy Policy is to outline (DynApps Bilisim Hizmetleri ve Ticaret Limited Sirketi) commitment towards respecting your privacy and to comply with the applicable privacy laws and associated rules governing how or when any of your personal information is collected, used and disclosed while accessing our services. This Policy is a legally binding agreement between you ("User", "you" or "your") and DynApps Bilisim Hizmetleri ve Ticaret Limited Sirketi ("DynApps Bilisim Hizmetleri ve Ticaret Limited Sirketi", "DoCall", "DynApps LTD", "we", "us" or "our"). By accessing and using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Agreement. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
This Privacy Policy describes the privacy practices of DynApps Bilisim Hizmetleri ve Ticaret Limited Sirketi. (“DynApps LTD”, “DoCall”,“we”, “us” and/or “our”) with respect to our use and disclosure of the information that we collect about users of the DoCall mobile application, the website, docall.me, the other mobile applications, related services, and any other services where the Privacy Policy is shown (collectively, our “Services”).
Before you use or submit any information through or in connection with our Services, please carefully review this Privacy Policy. By using any part of our Services, you understand that your information will be collected, used, and disclosed as outlined in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services.
In order to provide and improve upon our services and better market our services to customers, we receive and collect information about you in various ways. When you interact with us through our Services, we collect information in multiple ways, including when you provide information directly to us; when we passively collect information from or about you, such as from your browser or device; and when we collect information about you from third parties. We may combine all of the information we collect from or about you from these various sources.
1.1 Information that you submit
We ask for and collect the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.
1.1.a. Authorization and/or Account Information: email and other data (name, address) that is needed for compliance with applicable local laws. Please mind that in some countries due to specific local regulation, addresses are validated to ensure the integrity and accuracy of the data provided.
1.1.b. Activity Information: e.g. your contacts created through the App, call logs and recordings of calls, logs and records of text messages, origination and termination points (i.e. to/from numbers), history of incoming and outgoing calls performed and the content of messages sent/received with the help of the App, the list of second phone numbers you ever used through the App. Upon your consent we also may have technical access to the microphone and contact list on your device.
We process this information by ourselves. However, we may also engage third party - Twilio Inc. - for storing this personal data in order to fulfill obligations and deliver the full scope of services. This personal data can be deleted either by this third party in accordance with our instructions or by our own means.
1.1.c. Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, support form. We collect, store and process it by our cloud storage provider. We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request and perform the requested services.
1.2 Information That Is Processed Automatically
On the basis of your permission we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our App (Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices). Some integrated advertising or analytics tools launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements. Processing information through automatic data processing technologies starts automatically once you allow our App to track your activity.
We may process some information about your device and your user behavior on the ground of our legitimate interest. This information falls within categories of data described above in Subsection “Information That Is Processed Automatically”, it is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We use this information for improving our App and giving our users the best experience.
1.2.a. Device Details: When you use a mobile device (tablet / phone / smartwatch) to access our App, some details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by third parties.
What data can be processed:
- Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.
- Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser.
- Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. “coffee shop”).
- Other device identifiers: e.g. user identifiers (if they are set up by the App’s developer).
1.2.b. Information about the applications: Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analysis. Some services also record the list of applications and/or processes which are installed or run on your device.
1.2.c. Cookies and similar technologies: When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
1.2.d. Log file information Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.
1.2.e. Ad-related information: The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.
1.2.f. In-app events: When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).
Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that was already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties.
1.3 Payment Information
Our e-commerce provider (Apple and Google) is responsible for billing, processing and charging for in-app purchases, handles your personal information and keeps it absolutely safe and secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information. You may access the applicable “in-app” purchase rules and policies directly from the app stores.
1.4 Messaging Policy and SMS/MMS Privacy Statement
1.4.a Text (SMS) messages that you can receive from us: We may use phone numbers that you got via the App to contact you with text (SMS) messages. By using the App, you acknowledge and agree that we may send you the following types of text messages:
- Operational messages. You understand and agree that you may receive text messages concerning the status of phone numbers you got via the App, credits you bought to make calls as well as other aspects regarding your phone numbers and operation of the App. We send you such messages for the purposes of providing the services available through the App and communicating with you. Your failure to receive operational messages will significantly impede your further use of the App.
- Messages with invitation to user interview. We are constantly striving to get effective user feedback for the purposes of improving the quality of our App and enhancing user experience. Therefore, you may be asked to provide direct feedback regarding our App by participating in the interview. We may send you relevant text messages with invitation to such user interviews. Specific conditions of participation in user interview (including information on the method of expressing user consent to be interviewed, as well as information about possible bonuses, incentives for participating) will be indicated in the corresponding message that you receive. Note that your decision to participate or not participate in a user interview is completely voluntary, the consent to participate in user interview is not a condition for using the App. If you
are uncomfortable with receiving messages with offers to participate in user interview you can opt out at any time by sending us relevant request via support form.
1.4.b Message content collection and monitoring: As it is indicated above, we engage Twilio Inc. that acts as a data processor on our behalf in order to be able to provide you with messaging services within the App. Sending messages (SMS, MMS, Chat, WhatsApp messages) using our App and Twilio’s platform can be possible only when all applicable policies, regulations and laws are properly observed. Therefore, while sending messages using the phone numbers and other services available within the App you agree to be bound by and comply with the following requirements:
- It is strictly prohibited to use the App for sending messages with the content that is illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or otherwise poses threat to the public, or that violates any law and/or regulation in the country where the message recipient lives (e.g. messages related to cannabis, offers for prescription medication that cannot legally be sold over-the-counter, messages containing hate speech, malicious content, etc.). The specified list of prohibited content is not exhaustive, messages containing these categories of content cannot be sent via the App, shall be identified and blocked by appropriate unwanted message detection and prevention mechanisms regardless of the fact whether or not you get consent from message recipients for such content. To learn more information about prohibited categories of content and communications please review Twilio Acceptable Use Policy as well as Twilio Messaging Policy. You undertake to comply with all requirements contained in the specified documents while using the App.
- When you use the App to send messages, you also agree to take into account and comply with the requirements regarding the recipient’s consent to receive messages from you (including possible forms, scenarios of obtaining such consent), opt-out mechanisms, as well as with sender identification requirements. Please review Twilio Messaging Policy carefully to learn more details.
Content verification for US/Canadian destination numbers. Please note that all content of messages that you send and/or transmit via the App to United States and Canadian numbers is subject to monitoring and verification process by Twilio Inc. Particularly, Twilio proactively identifies and does not accept the messages in violation of the Twilio Acceptable Use Policy. The messages that are proactively identified as messages in violation of Twilio Acceptable Use Policy will be returned as an error prior to reaching carrier networks. Moreover, in the event that your message(s) violates Twilio Acceptable Use Policy or other applicable regulations your access to the App and/or to messaging services available within the App may be suspended or terminated. Taking into account the foregoing, you hereby provide us and Twilio Inc. with your relevant permission for collecting, processing, storing and monitoring the content of all messages you send using the App for the purpose of detecting spam, fraudulent activity, and violations of Twilio Acceptable Use Policy.
Your failure to provide relevant permissions and comply with the requirements stated above means that you cannot use the messaging services available via the App.
This message content collection and monitoring are incorporated into the present Privacy policy and constitute its integral part. By accepting the Privacy policy containing this message content collection and monitoring you hereby express you consent and give all appropriate permissions and authorizations regarding data processing, storage and sharing, the applicable procedures for sending messages and message content monitoring, as well as other issues reflected herein.
In order to make the Services available to you, or to meet a legal obligation, we need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
- Verifying identity and authenticating information;
- Registration;
- Payment processing;
- Monitor information you transmit through our Services to operate our Services properly and to protect ourselves, our users, and the public;
- To send email notifications and reminders related to the Services;
- Providing the Services and operating our business;
- Responding to customer requests and complaints;
- Sending newsletters or other marketing information;
- Establishing and maintaining relationships with our users;
- Optimizing experiences by performing analytics and conducting research;
- Conducting investigations, detecting fraud, abuse, security breaches and other harmful activity;
- Resolving disputes and enforcing agreements and policies; and
- Meeting and complying with legal and regulatory requirements.
Processing your Personal Information depends on how you interact with the Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California(?) Consumer Privacy Act or European data protection law; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject (e.g. when you buy phone numbers from countries where providing personal identity information is compulsory. More information at Phone Number Regulatory Compliance); (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your personal data may be processed in accordance with the Republic of Turkey Law No. 6698 on the Protection of Personal Data.
Privacy laws applicable in your country may give you the following rights:
Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.
The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.
If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed below.
Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may contract with other companies and share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. These third parties are given Personal Information they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes.
We may disclose personal information to fulfill the purposes identified in this Privacy Policy, and for purposes related thereto, and to provide the Services, including as follows:
3.1 Within our organization
3.2 To help us provide certain aspects of our Services, we use third party affiliates and trusted key partners with whom we enter into confidentiality and data processing terms to ensure that they comply with high levels of confidentiality and best practice in privacy and security standards. In particular we engage third parties to:
facilitate payment processing;
facilitate sending customer email surveys or marketing notifications;
manage our sales and customer support services to you;
deliver and help us track our marketing and advertising content;
help us provide core features of telecommunications services;
help us track website conversions and success metrics;
3.3 Please note that while integrating external services we choose third parties that can assure they apply all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.
3.4. We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.
3.5 At your request or with your consent
3.6 As required by applicable laws and related rules and regulations
3.7 We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:
- as required by law;
- when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
3.8 If you are a registered user of our Services and have supplied your email address, we may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with our Services and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
3.9 We may collect statistics about the behavior of visitors to our websites. We may display th
is information, in aggregated form, publicly or provide it to others. However, we will not disclose personally-identifying information other than as described in this Privacy Policy.
911 Calls or 112 Calls or your local countries emergency number Calls and Requests for Emergency Assistance. NOTE THAT THE SERVICE CAN NOT AND SHOULD NOT BE USED FOR 911 OR EMERGENCY CALLING or 112 or your local countries any of EMERGENCY NUMBER CALLING. However, if you attempt to contact emergency services via the Service, we may provide information about you to a public safety answering point; emergency medical service provider or dispatch provider; public safety, fire service, or law enforcement official; or hospital emergency or other medical care facility. As permitted by law, we may also disclose information without a user’s consent in an emergency situation involving risk of death or serious physical harm, such as to a user’s legal guardian or members of a user’s immediate family or to database management services or information providers solely to assist in delivering emergency services.
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
We are committed to the security of your personal information and we take steps to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal and other risks. We store personal information in a secure location, accessible by designated staff and we only use it for the purposes for which you provide it (as set out in this Privacy Policy).
We use appropriate security measures when we destroy personal information.
However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
We make reasonable efforts to ensure your personal information is accurate and complete. You may make a request to update, correct, or delete your personal information at any time by submitting a request in writing to [email protected]. It is your responsibility to provide updates to your personal information and to maintain its accuracy.
We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Services, please contact us. You must also be at least 16 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).
We reserve the right to modify this Policy or its terms relating to the Services from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Services.
In case of dispute, Istanbul Anadolu Mahkemeleri (Courts) are authorized and Turkish Law is applied in disputes.
If you have any questions or concerns regarding this Privacy Policy, please send us an email at [email protected] or write to us at DynApps Bilisim Hizmetleri ve Ticaret Limited Sirketi, Visnezade Mah. Suleyman Seba Cad. No:79 Ic Kapi No:1 Akaretler, Besiktas-Istanbul / Turkiye. +90 212 400 0655
If we receive formal privacy-related complaints, it is our policy to use reasonable efforts to communicate with the complaining party about its concerns to resolve privacy complaints.