(Last updated on Apr 16, 2019)
1. Collection and Use of Information
When you install the LalaPhone App, you might be asked to set your phone number (collectively, "Personal Information"). A copy of the phone numbers will be stored on our servers and will only be used to,
(a) support caller ID display when you enable it,
(b) we may also create a feature in the future that will use this data to facilitate your use.
LalaPhone also maintains a Call Detail Record (CDR - more info available at http://en.wikipedia.org/wiki/Call_detail_record) for each call conducted on the system. These are industry standard records used by all phone companies. We maintain this information in order to better understand network behavior and trends (numbers of calls made by users, typical destinations, call lengths, network type, etc.), detect potential outages and technical issues (this helps us notice things like a drop in call volume in a certain geography, a shift in call length, a change in typical networks, etc.) and for public safety reasons. All log analysis is done in an anonymous, aggregate, non-personally identifiable manner. We may look into a specific Call Detail Record in response to a customer support request.
Audio calls by users are transmitted either directly from user to user or, if direct transmission is not possible (due to, for example, firewalls), LalaPhone servers are employed to transmit the call. In the latter scenario, the information transmitted is stored briefly in volatile memory solely to enable the transmission of the call to the other user. WE NEVER RECORD ANY PART OF YOUR CALL ON OUR SERVER.
In the event we make message boards and forums available to you (collectively, "Forums"), you will be solely responsible for the information and any other content you post on and through these Forums and should be aware that when you voluntarily disclose personal information (e.g., name, e-mail address, telephone number) on or through these Forums, such information is generally accessible to, and may be collected and used by, other users. This may result in unsolicited messages from third parties, and such messages are beyond our control. We do not exercise control over any users or Site visitors, and in no way are we responsible, and have any liability whatsoever, for any collection or use of information you may disclose through the Forums. This Policy does not cover such disclosure of information. You are encouraged to exercise discretion when providing personal information about yourself in and through Forums. Please do not disclose any personal information on this Site that you expect to keep private.
Cookies, Clear GIFs and Other Automatically Collected Data
We may use "clear GIFs" (aka "Web beacons" or "pixel tags") or similar technologies, in the Site and/or in our communications with you to enable us to evaluate Site usage information about visitors to the Site, target campaigns, upgrade visitor information, and know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual's viewing or receipt of a Web page or message. A clear gif may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your Personal Information.
Our servers may automatically collect data about your Internet address when you visit us. This information, known as an Internet Protocol address, or IP Address, is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet. When you request pages from our Site, our servers may log your IP Address and, if applicable, your domain name. Your IP Address is used to help identify you and to gather demographic information about our members and users as a whole, but does not include personally identifiable information. Our server may also record the referring page that linked you to us (e.g., another web site or a search engine); the pages you visit on this Site; the web site you visit after this Site; the ads you see and/or click on; other information about the type of Web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Site or a referral site; and other Web usage activity and data logged by our servers. We use this information for internal system administration, to help diagnose problems with our servers, and to administer our Services. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider.
We will not link any Personal Information, including e-mail addresses, with aggregate data of our users.
Any or all of these activities with regard to Site usage information may be performed on our behalf by our services providers, including, for example, our analytics vendor(s) and our e-mail management partner(s).
Third-Party Sites and Privacy Practices
2. Sharing and Disclosure of Information
We do not rent, sell, or share any information about the user with any third-parties. We may disclose your Personal Information if we believe such action is necessary to,
(a) comply with the law, or legal process served on us;
(b) protect and defend our rights or property (including the enforcement of our agreements); or
(c) act in urgent circumstances to protect the personal safety of users of our services or members of the public.
We may use Apple's Push Notification Service to notify you about our apps. If we do, the personal information may be part of the message. This message is sent to Apple Inc., for delivery to your iPhone.
3. Children's Privacy
Protecting the privacy of the very young is especially important. We operate our Site in compliance with the Children's Online Privacy Protection Act (COPPA). We never knowingly, directly or indirectly, collect or maintain Personal Information at or on our Site from those we actually know are under 13, and no part of our Site is directed at or structured to attract anyone under 13. Visitors younger than 13 years of age may NOT use the Services (including the LalaPhone App) and must LEAVE immediately.
We take reasonable precaution to protect Personal Information from misuse, loss and unauthorized access. Although we cannot guarantee that Personal Information will not be subject to unauthorized access, we have physical, electronic, and procedural safeguards in place to protect Personal Information. Personal Information is stored on our servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.
5. Business Transitions
We will post a notice on this Site of any such change in ownership or control of the Personal Information we may have prior to such transfer.
6. Changes to Policy
From time to time, we may revise this Policy. We reserve the right to update or modify this Policy, or any other of our policies or practices, at any time with or without notice. We will post the revised Policy on the Site, so that users can always be aware of what information we collect, how the information is used and under what circumstances such information may be disclosed. You agree to review the Policy periodically so that you are aware of any modifications. Your continued use of the Site indicates your assent to any changes and signifies your agreement to the terms of our Policy. If you do not agree with these terms, you should not use the Site, the LalaPhone App, or any of the other Services.
7. Change or Removal of Information
Due to technological reasons, we do not know when and if you delete the application. Therefore, if we detect no activity from your device for 60 days, we will assume that you deleted the application and we will remove your data from our servers. However, since we are not certain that you deleted the application (you may just be on vacation, etc.) we will not deactivate your LalaPhone account (which is your phone number and device ID). We do not want to force you to register again in the event of non-use.
8. Contact Information
Please direct all questions in connection with this Policy via e-mail to firstname.lastname@example.org.