Privacy Policy

Effective Date: August 14, 2024

These Privacy Policy is a binding legal contract between us - FrontGuard Bilisim Hizmetleri ve Ticaret Limited Sirketi, ("we," "us" or "our") and users ("User", "you", "your") of Call Recorder application distributed via application store(s) (the "App"). Please read this Privacy Policy (this "Privacy Policy") carefully. To use the App that We provide, you as a user of the App must accept this Privacy Policy. If you do not consent to the terms of the Privacy Policy, please do not access or use the App. This Privacy policy applies to all users, and others who access the App ("Users"). For the purposes of the GDPR, we are the data controller, unless otherwise stated.

INFORMATION THAT WE PROCESS

Information Provided by You: We ask for and collect the following personal information about you when you use the App. This information is necessary to provide complete functionality of the App and perform the requested services.

• Authorization and/or Account Information. When you sign up for an account or log into your account, we require your mobile phone number. We collect, store and process it by our cloud storage provider. However, we may also engage third party - Google (Firebase) - for storing this personal data in order to improve protection against spam and abuse in Google services

• Activity Information, e.g., your contacts, call logs and recordings of calls, origination and termination points (i.e., to/from numbers), history of calls made with the help of the App. Upon your consent we also may have technical access to the contact list on your device. Please mind that it is your sole responsibility to warn your dialog partner that you are going to record a call. Otherwise, you cannot use the App. For more information about the rules, you must follow when you record any call using the App, please check our Terms of Use.

• 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 and that we will use for communication purposes.

• Automatically Processed Information. Based on your consent and permission we use third-party automatic data processing technologies to analyze certain information sent by your device via our App 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 (see the list of data described below). Such Processing starts automatically once you allow our App to track your activity. You can withdraw your permission at any time.

We may process some information about your device and your user behavior on the ground of our legitimate interest in aggregated non-identifiable form to improve user experience of our App.

• Device Details. When you use a mobile device to access our App, some details about your device are reported, including “device identifiers” which uniquely identify your mobile device but not your personality. Device identifier enables generalized reporting or personalized content and ads by the third parties. This data includes:

- 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;

- Other device identifiers: e.g. user identifiers (if they are set up by the App’s developer).

Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analysis, list of applications and/or processes which are installed or run on your device.

• Cookies and similar technologies. When you use the App, cookies and similar technologies may be used. This enables us to operate the App more effectively and 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.

• 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, your interaction with the App.

• 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 (text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.

• Transactions. We may have access to technical information about in-app purchases.

Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. We do not control or supervise how the third parties process your personal data, that might be collected by their own means (not through our App).

Note : Please note that we have no access to your payment information (your credit or debit card information), billing, processing and charging for in-app purchases, handling of your relevant personal data is on App Store exclusively and are subject to “in-app” purchase rules and policies directly from the App Store.

THE PURPOSES OF YOUR PERSONAL DATA PROCESSING

We use your information for the following purposes:

• Availability of the service. We use the information that you submit and information that is processed automatically to provide you with all requested services.

• Testing, monitoring and improvement of our App. We use the information that is processed automatically to analyze behavior and patterns, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

• Interest-based / targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences).

• Communication. We use the information we have to respond to your requests, to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms.

• Compliance and law enforcement. We are doing our best to protect you of spam and fraudulent content. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities.

Any other purposes for processing your personal data are subject to prior modification of this Privacy Policy.

DATA SHARING AND DATA TRANSFER

We will share your information with third parties only in the ways that are described in this Privacy policy and with application of necessary technical and organizational measures to protect your personal data. But please be aware that we are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like 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. We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements.

Third-party service providers we engage in order to provide our services:

Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest: a) as required by law; b) 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; c) if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a 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.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

THE TERM OF YOUR PERSONAL DATA USE

Your personal information retains for as long as is necessary for performing the service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and your account. Please be informed that some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other illegal activity.

YOUR PRIVACY RIGHTS

You have the following options in relation to your personal data we collected:

• Data Access and Portability. You can request copies of your personal information held by us.

• Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct, change, update or rectify your data.

• Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.

• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

To exercise any of the rights described above, you can contact us through info@frontguard.co . When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third-party services listed in the relevant section of this Privacy Policy.

OUR SECURITY MEASURES

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible. While we do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through the email info@frontguard.co .

CHILDREN’S PRIVACY

We do not knowingly collect or solicit any personal information from children under 18. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us via info@frontguard.co .

CALIFORNIA RESIDENT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request: a) the categories of personal information that is processed; b) the categories of sources from which personal information is obtained; c) the purpose for processing of user personal data; d) the categories of third parties with whom we may share your personal information; e) the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

• PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above. Be informed that according to CCPA personal information does not include de-identified or aggregated consumer information.

• DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

• OPT-OUT OPTIONS. If you don’t want us to process your personal information any more, please contact us through info@frontguard.co. Please be informed that such opt out may impact App’s further operation without functional data and you will be advised to remove the App from your device. If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described above.

• REQUESTS. To submit a verifiable consumer request please contact us through the email info@frontguard.co. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

• SALE OF DATA. We do not sell any of your personal data to third parties.

UPDATES AND EDITIONS TO THE PRIVACY POLICY

As we grow and change we may amend this Privacy Policy. The Policy in effect at the time you use the Site governs how we may use your information. If we make material changes we will post the revised Policy and the revised effective date on this Site and inform you of the change upon your next use of the Services. Please check back here from time to time to review any changes.

CONTACT INFORMATION

If you have any questions about our privacy practices, this Privacy Policy, our Products, or Services, please contact us at info@frontguard.co or call +902124001168 or write to us at FRONTGUARD BİLİŞİM HİZMETLERİ VE TİCARET LİMİTED ŞİRKETİ, Asmalı Mescit Mah. Asmalı Mescit Cad. Şahin Han No: 21 İç Kapı No: 55 Beyoğlu/İstanbul - Türkiye.