Privacy Policy
Last revision: May 14, 2023 for current users, and upon acceptance for new users.
This is the privacy policy of Phone2 Inc., a company incorporated under the laws of the state of Delaware in the USA and with the registered address 5151 California Avenue, Irvine, CA 92617 USA (“Phone2”, “us”, “our” or “we”) which describes how we receive, collect and use information from you in connection with our website www.phone2.io (or such other sites that are provided by Phone2 from time to time) (the “Site”), the Phone2 mobile application software (the ” App”), and other products and services provided by Phone2 from time to time on the Site or in the App (all of the foregoing, collectively, the “Services”).
This Policy is incorporated into and subject to the Phone2 Terms of Service. Any capitalized term not defined in the Policy shall have the meaning as set forth in the Phone2 Terms of Service. By accessing and/or using our Services you consent to us collecting, processing, storing and sharing information about you in the manners set out in this Policy. If you have any concerns about providing the information to us or having it used in any manner permitted in this Policy you should not use our Services. By downloading the App and/or using the Services you acknowledge you are of legal age.
1. What information about you is collected and how will we use it?
Profile Information
When downloading the App or otherwise start using the Services you are requested to register with us, and creating your Phone2 account. By registering you give your consent for us to collect, use and store the following information:
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Name
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Phone number
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Email address
By making any card payment within the App or on our Site you also consent for us to collect, use and store the following information:
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Address
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Expiry date of card
In addition to using this information to be able to provide you with the Services that you request, we use, store and/or may disclose the above listed information as follows:
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To verify your identity (your phone number will be used as Phone2 user ID).
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To notify other Phone2 users who have your mobile phone number stored in their mobile address book that you are also a Phone2 user.
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To manage your Phone2 account, deliver to you any administrative notices, updates, notifications, alerts and communications relevant to your use of the Service.
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To contact you via email, SMS, telephone call or otherwise for the purpose of informing you about new products, services or promotions offered by Phone2 (you can opt-out of such emails by clicking on the unsubscribe link, withhold your consent to receive an SMS or reply stop to an SMS in order not to receive future SMSs).
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To contact you via telephone call to inform you about different payment methods and, if applicable, assist with registration of your credit card with our Payment Processor.
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For internal operations, including troubleshooting problems, data analysis, testing, research, improvements to the Services, detecting and protecting against error, fraud or other illegal activity.
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When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activitiesAddress Book
When you first install the App on your device, you will be asked to allow us access to your address book. If you consent, we will have access to contact information in your address book on the devices you use for the Services (only names and numbers) and we will store it and use it for the following purposes:
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Correctly formatting the phone numbers for international calling.
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Correctly display the name of each contact as it appears in your address book when a call is received through the App.
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Sync your contacts in the address book on your device with the App.
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Notify you when your contacts become a Phone2 user.
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Indicate which of your contacts is already a Phone2 user.
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For internal operations, including troubleshooting problems, data analysis, testing, research, improvements to the Services, detecting and protecting against error, fraud or other illegal activity.
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To analyze what new products, services or promotions that may be relevant for you.
Usage Information
In accordance with telecommunications market practice, Phone2 collects certain usage statistics, including but not limited to, the phone numbers and/or other identification details of the calling and receiving party, the start time, call duration, call quality, outages (“Call Details”) and maintains a call detail record (“CDR”) for each call that is routed through the system. The Call Details are collected and the CDR maintained for billing purposes and for the purposes of improving the Services and to fulfill our obligations under applicable laws.
We may also collect and store information about your usage of, and interaction with, the Services, including calls, messages, posts, information relating thereto, usage of the Service by geographies, device and connection information IP address, device capability, bandwidth, web browser software, referring website, statistics on page views, network type and traffic to and from our Site or App. Furthermore, we may also collect a list of the installed apps on your device (on an anonymous basis). Such information may be collected by using inter alia cookies (if accepted by you), ad identifiers and other applicable tracking tools.
We collect Personal Data about you for the purpose of:
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Improving our Services, for example by helping us fix bugs or by providing Services updates.
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Preventing cheating, crime or fraud (we may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention).
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To personalize and optimize our Services, promotional content and advertising to you. For example, we may use the information we collect through cookies, ad identifiers and similar technologies to show you ads you may be interested in.
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To create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services.
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As otherwise expressly set out in this Policy or as required by law.
We use Google Analytics or any other such analytics service provider in relation to both the Site and the App in order to collect data, track, create and receive reports of statistics relating to usage thereof.
When you use the Services, such information is collected automatically:
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Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
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If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
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If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
Google Analytics is a web analytics solution which compiles and analyzes certain information about usage of a website or app. It may add cookies to your computer or device or read existing cookies when you visit our Site or interacting with certain parts of our App. By using our Site or the App, you declare your consent to Google’s use of the data collected about you in the manner and for the purposes described above.
Furthermore, when you are using our App, we may also automatically record your Google Advertising ID (if you are using an Android device), for advertising or analytics purposes. The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has a Google Advertising ID, we may collect and use it for advertising and user analytics purposes. If your device does not have Google Advertising ID, we may use other persistent identifiers. If you have a Google Account and/or an Android device, you can opt out of targeted advertising on your device. You can do this by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select “Ads” and check the box “Opt out of interest-based ads”. In addition, or as an alternative, you may reset your device’s Android advertising ID, which will result in your device being disassociated from ad targeting profiles based on the Android advertising ID in effect prior to reset. You can do this by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select “Ads” and selecting “Reset advertising ID”. Note that Android settings menus may vary among device manufacturers and these instructions may not be accurate for your device. You should consult Google’s settings and instructions for the most current settings information.
In addition, we may interact with your phone’s SMS inbox for the purposes of service activation, placing incoming international messages and reading the contents of the activation SMS sent to you by us.
2. Sharing Information
We will only share your data with third parties (for example, our suppliers):
With your consent (including as set out in this Policy).
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As reasonably necessary in order to provide the Services to you (for example, by providing information to suppliers we may use to fulfill the Services or to communicate with you).
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Where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your information to our payment processors).
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Where such third party’s assistance is deemed necessary to enable us to inform you about new products, services, promotions or different payment methods and, if applicable, assist with registration of your credit card.
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Where your data is on an anonymous and aggregated basis, meaning you could not be personally identified from it.
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When you submit information by interacting with our social media channels (for example, by providing a testimonial about one of our Services) we may publish the information you submitted, alongside your name and home country on the Site and social media channels.
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As we reasonably believe is permitted by law or regulation.
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In order to comply with any legal obligation, or in order to enforce or apply the Phone2 Terms of Service and/or any other agreement with you; or to protect the rights, property, or safety of Phone2, our users, or others.
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In the event that there is a sale of the assets of Phone2 or corporate restructuring, or as a result of a change of control of Phone2 or one of its group companies, or in preparation of any of these events. Any third party to which the assets or Phone2 (or any group company) is transferred to will have the right to continue to use the information that you provide to us in the manner set out in this Policy.
In addition, we may use external advertising companies to serve ads when you have visited the Site and/or downloaded the App. These companies may use information (but not information that includes your name, address, email address or telephone number) about your visits to the Site and other websites in order to provide advertisements about goods and services of interest to you.
Your details may be stored and processed in Luxembourg, Sweden or any other country in which Phone2 or its affiliates, subsidiaries or agents maintain facilities. By using the Services, you consent to any such transfer of the information outside your country.
3. Transfer of information outside your country
We may, for the purposes set forth herein, transfer, process and store your information in the USA, Germany or any other country in which Phone2 or its affiliates, subsidiaries, suppliers or agents maintain facilities.
4. Communications, notifications etc.
We may send you messages about updates, faults, alerts and other types of issues relating to technical aspects and/or the usability of the App and other parts of the Services.
We may occasionally ask you to provide information on your experiences of using the App or other parts of the Services which will be used to improve the quality and provision of the Services. You are under no obligations to provide any such information. Any and all information which is voluntarily submitted by you in relation to any survey that you take part in is used for the purposes of reviewing this feedback and improving the Services.
Phone2 may from time to time contact you by phone, SMS or through any other appropriate information channel to keep you up to date with news about Phone2 and the Services, including new products, campaigns, promotions and payment methods.
You can stop the delivery of promotional messages from Phone2 by following the specific instructions in promotional messages or by our customer support at support@Phone2.im). These communication choices do not apply to mandatory service communications that are considered part of the Services, which you may receive periodically unless you delete the App.
5. Third Party Sites
Our Site or App may contain links that will let you leave our Site or App and access a website of a third party. Please note that such linked websites are not under the control of Phone2 and that such websites have their own privacy policy governing such third party’s treatment of personal data. Our Privacy Policy applies solely to personal information that we acquire from you through our Site, our App, your use of our Services and/or your relationship with Phone2.
6. Security
Protecting user privacy and personally identifiable information is a top priority for Phone2. We make substantial efforts to ensure the privacy of all personally identifiable information collected by us in relation to the provision of the Services to our customers. Although we cannot guarantee that the information will not be subject to unauthorized access, loss or misuse we have physical, electronic, and procedural safeguards in place to protect the information.
7. Changes to the Policy
We are constantly innovating and looking for new ways to improve our Services. We therefore reserve the right to update or modify this Policy at any time with or without notice to reflect such improvements or any other changes to our business. We will post the revised Policy on Legal information), 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. You agree that your continued use of the Services after we publish a revised Policy constitutes your acceptance of the revised Policy. If you do not agree with the terms of the Policy, you should not use the Services.
8. Data Deletion
We take your data rights seriously. To delete all your data (messages, call records and voicemail), you can do so by navigating to "My Account" on the iOS or Android app and tapping "Delete Account". Once confirmed, this action cannot be undone.
9. Accessing Your Personal Information
If you would like to view, correct, complete or remove your personal information or if you have any other questions in connection with this Policy, please contact us at hello@phone2.io).