PRIVACY POLICY – VIEWCALLER

Last Updated: October 23, 2024

Welcome to ViewCaller (“the App”). This Privacy Policy (“Policy”) is provided by Smart Media Internet Marketing LTD (“Smart Media,” “we,” “us,” or “our”) and explains how we collect, use, share, and protect information in connection with our websites, the ViewCaller mobile application, and any related services (collectively, the “Services”).

By downloading, accessing, or using the Services, you agree to the terms of this Policy and (if applicable) the ViewCaller Terms of Service. If you do not agree, please do not use the Services.

1. SCOPE & REGIONAL NOTICES

This Policy applies globally. However, depending on your region, specific rights and provisions may apply:

• • EU, EEA, UK, & Switzerland Residents: See Section 11.
  • California Residents: See Section 12 (CCPA/CPRA).
  • Virginia Residents: See Section 13 (VCDPA).

• • Brazilian Residents: See Section 14 (LGPD).

• • Nigeria Residents: See Section 15 (NDPR).

For any questions about how this Policy applies to you or about your region’s coverage, please contact us at [email protected].

2. INFORMATION WE COLLECT

We collect various types of information to provide and improve our Services:

2.1 Profile & Account Information

• Registration Data: When you create an account, we collect your phone number. You may optionally provide your name, email address, username, or profile photo.
• Verification: We verify your phone number via SMS code (sent using a third-party provider like Twilio) or an automated “missed call.”

2.2 Phone Number Storage

We collect and store your phone number when you register. This is essential to identify you, provide core Services like caller ID and spam blocking, enable account features, and communicate with you.

2.3 Device & Technical Information

• Device Identifiers & Technical Data: We collect IP address, device IDs (e.g., IMEI, Android ID, Google Advertising ID [GAID]), device model, operating system version, hardware details, browser type, language settings, time zone, network connection type (Wi-Fi/cellular – via `ACCESS_NETWORK_STATE`, `ACCESS_WIFI_STATE`), and mobile carrier. The Advertising ID (`com.google.android.gms.permission.AD_ID`) is used for advertising personalization (in the free version) and analytics. We may also access identifiers related to Android’s Privacy Sandbox features (`ACCESS_ADSERVICES_AD_ID`, `ACCESS_ADSERVICES_ATTRIBUTION`, `ACCESS_ADSERVICES_TOPICS`) if utilized for advertising measurement or relevance.
• Usage Data & Crash Logs: This includes app interaction data (screens visited, taps, clicks, features used), install/update dates, last usage dates, performance data, diagnostic information, and **Crash Logs**. Crash logs (collected via services like Firebase Crashlytics) help us diagnose and fix bugs and improve app stability. This data is typically anonymized or pseudonymized.

2.4 Call Log Data

• Purpose: With your explicit permission (`READ_CALL_LOG`), we access call log information (incoming, outgoing, missed calls, phone numbers, timestamps, duration) *on your device* to provide core features like caller identification, spam detection/blocking, and call history display within the App. Permissions like `READ_PHONE_STATE`, `ANSWER_PHONE_CALLS`, `CALL_PHONE`, and `MANAGE_OWN_CALLS` may be required to detect call events, manage calls via the app interface, or enable specific call-related features.
• Primarily Local Processing: Call log data required for real-time caller ID and spam checks during a call is typically processed locally on your device. We generally do not store your detailed call logs on our servers. However, anonymized or aggregated call patterns might be used to improve our spam detection algorithms globally. Specific features might require limited server interaction, which will be made clear.
• Default Handler Permissions: We only request to be set as the default call or SMS handler if essential for core functionality (e.g., advanced call screening or SMS blocking).

2.5 Contacts (Address Book)

• Read Access (`READ_CONTACTS`): With your explicit consent, the App accesses your device’s address book *locally* to display names for known numbers during calls (Caller ID) and potentially to improve spam detection accuracy by identifying numbers in your contacts.
• Limited Upload/Server Use: We do **not** upload your entire address book to our servers for building a public database. Matching contact names for caller ID happens on your device. In specific, clearly disclosed cases (e.g., optional contact backup features you enable), contact data might be transmitted to our servers with your explicit consent.
• Write Access (`WRITE_CONTACTS`): With your explicit permission, the App may request permission to write to your contacts. This is **only** used for features allowing you, the user, to explicitly save an identified phone number (e.g., from a call log) as a new contact in your device’s address book. We do not automatically add or modify contacts without your direct action.

2.6 SMS and MMS Data

• Purpose: With your explicit consent (`READ_SMS`, `RECEIVE_SMS`), the App may access SMS/MMS metadata (e.g., sender number/ID, timestamps) *on your device* to identify spam messages, categorize messages, or provide related organizational features. The `SEND_SMS` permission might be requested if you use a feature to initiate sending a message through the app (e.g., replying to a call notification, sharing content).
• Local Content Processing: All processing of SMS/MMS *content* for spam detection or display occurs solely on your device. We do **not** store, transmit, or share the content of your personal messages from your device.
• SMS Delivery (Verification/Notifications): As mentioned (Sec 2.1), we use third-party providers (e.g., Twilio) to send SMS for verification or essential service notifications. This involves transmitting your phone number and necessary metadata for message delivery only.

2.7 Voice or Sound Recordings (`RECORD_AUDIO`)

• Purpose & Consent: We request the `RECORD_AUDIO` permission **only** if it is necessary for specific, optional features within the App, such as [**Example 1:** voice commands for hands-free operation] or [**Example 2:** an opt-in call recording feature]. **Audio is NEVER recorded without your explicit knowledge and affirmative action (e.g., tapping a record button, enabling a specific voice feature).**
• Usage: If you use such features, the audio data is processed solely for the purpose of that feature.
• Storage & Retention: [**Specify Storage:** e.g., Audio recordings initiated by you may be stored locally on your device, or if explicitly stated for a feature like cloud backup, securely on our servers.] We retain audio data only as long as necessary for the feature or as requested by you (e.g., until you delete a recording). Access is strictly controlled.
• If you do not use these specific features, no audio will be recorded.** We do not passively listen or record background audio.

2.8 Other File Access (Music/Audio Files)

Google’s automated checks may sometimes detect potential access to categories like “Music Files” or “Other Audio Files,” often due to the inclusion of broad SDKs or standard Android functionalities. ViewCaller does **not** intentionally access or collect your personal music or unrelated audio files stored on your device unless required for a specific, user-enabled feature (e.g., selecting a custom notification sound), which would be clearly indicated at the point of interaction. Permissions like `MODIFY_AUDIO_SETTINGS` might be used to control audio output during calls (e.g., speakerphone).

2.9 Purchase Information (`com.android.vending.BILLING`)

• Subscription Data: If you purchase a subscription (e.g., premium features, ad-free), we receive transaction confirmation, subscription status, and related identifiers from the app store provider (Google Play). Payment processing is handled entirely by the third-party platform; we do **not** collect or store your full credit card numbers or financial account details.

2.10 Online Activity & Tracking Technologies

Tracking Technologies: We and our third-party partners (including advertising and analytics providers listed in Section 5) use cookies (on our websites), mobile SDKs, pixels, beacons, and similar technologies within the App and on our website. These collect information about your device (as described in Sec 2.3) and your interaction with our Services (Usage Data, Sec 2.3) and potentially other apps/sites over time.

Purpose: This is used to operate the service, remember preferences, analyze usage patterns, measure engagement, diagnose problems, deliver personalized advertising (in the free version), measure ad effectiveness, and prevent fraud.

Further Details: See Section 10 for more on Cookies & Tracking Technologies and Section 8 for Advertising Opt-Out information.

2.11 Other Information You Provide

Additional Data: This includes information you voluntarily submit, such as through feedback forms, surveys, contests, promotions, or when contacting customer support.

2.12 Device Permissions Summary

ViewCaller requests various permissions to enable its features. We only request permissions necessary for specific functionalities. You can manage these permissions via your device Settings menu at any time, though disabling a required permission may limit or break related App features. Key permissions include:

• Phone (READ_PHONE_STATE, CALL_PHONE, ANSWER_PHONE_CALLS, MANAGE_OWN_CALLS, READ_PHONE_NUMBERS): Essential for detecting incoming/outgoing calls, identifying numbers, displaying caller ID overlays, managing calls through the app interface, and potentially accessing your own number for account setup.
• Call Logs (READ_CALL_LOG): Required to access call history for caller ID lookup, spam checking, and displaying call history within the app. Processed primarily locally.
• Contacts (READ_CONTACTS, WRITE_CONTACTS): Read access (with consent) to match numbers with names locally. Write access (with consent) *only* to allow you to save new contacts via the app. Contacts are not uploaded to our servers except for specific, opt-in features clearly disclosed.
• SMS (READ_SMS, RECEIVE_SMS, SEND_SMS): Read/Receive access (with consent) for SMS Caller ID, spam filtering, and message organization features (content processed locally). Send access (with consent) for user-initiated actions like replying via the app.
• Microphone (RECORD_AUDIO): Requested *only* for specific optional features requiring voice input (e.g., voice commands, opt-in call recording), requiring explicit user action/consent. Not used for background listening.
• Storage (READ/WRITE_EXTERNAL_STORAGE – varies by Android version): May be needed for storing app data, settings, or user-initiated actions like saving recordings (if applicable) or logs.
• Location (ACCESS_COARSE_LOCATION / ACCESS_FINE_LOCATION): *[If requested, add explanation – e.g., “May be requested to provide location-based spam reporting or features. We only collect location with your explicit consent.” Otherwise, remove this bullet.]*
• System Alert Window (SYSTEM_ALERT_WINDOW): Needed to display caller ID information as an overlay while a call is active.
• Notifications (POST_NOTIFICATIONS): Allows the app to show notifications (e.g., missed call alerts, caller ID info).
• Network State (ACCESS_NETWORK_STATE, ACCESS_WIFI_STATE): To determine network connectivity for online features (e.g., number lookup, ad loading).
• Internet (INTERNET): Required for communicating with our servers (number lookup, account sync) and third-party services (ads, analytics).
• Billing (com.android.vending.BILLING): Needed to process in-app subscriptions via Google Play.
• Advertising ID (com.google.android.gms.permission.AD_ID): Used for personalized advertising and analytics.
• AdServices (android.permission.ACCESS_ADSERVICES_*): Used for privacy-preserving advertising features on supported Android versions.
• Run at Startup (RECEIVE_BOOT_COMPLETED): Allows the app service to restart after the device reboots to ensure continuous caller ID/spam protection.
• Ignore Battery Optimizations (REQUEST_IGNORE_BATTERY_OPTIMIZATIONS): May be requested to ensure the app runs reliably in the background for real-time call screening without being terminated by the OS.
• Foreground Service (FOREGROUND_SERVICE, FOREGROUND_SERVICE_MICROPHONE, etc.): Required for tasks that need to run persistently, like displaying caller ID during a call or potentially active call recording (with consent).
• Other Permissions: Permissions like `WAKE_LOCK` (keep device awake briefly for tasks), `MODIFY_AUDIO_SETTINGS` (control audio during calls), `BLUETOOTH`/`BLUETOOTH_ADMIN` (if Bluetooth features exist), `KILL_BACKGROUND_PROCESSES` (rarely used, potentially for optimization or stopping conflicting processes) may be used to support app functionality.

3. HOW WE USE YOUR INFORMATION

We use the collected information for legitimate purposes:

1. Service Provision & Enhancement: Operating, maintaining, improving, and personalizing our Services (e.g., accurate caller ID, effective spam detection/blocking, call/SMS management features, optional voice features, contact saving).
2. Communication: Responding to inquiries, support requests, feedback; sending technical notices, updates, security alerts, and administrative messages related to your account or the Services.
3. Marketing & Advertising (Free Version): With your consent where required, using identifiers (like Advertising ID) and usage data to display relevant ads via third-party ad networks, measure ad performance, and control ad frequency.
4. Security & Fraud Prevention: Protecting our Services and users; detecting, investigating, and preventing spam, fraud, malicious activity, or policy violations; verifying identity; securing your account.
5. Legal & Compliance: Complying with applicable laws, regulations, legal processes (subpoenas, court orders), and lawful government requests; enforcing our terms and policies.
6. Analytics & Improvement: Analyzing usage trends, measuring feature effectiveness, understanding user behavior (using tools like Google Analytics, Firebase, Mixpanel, AppsFlyer, UXCam), gathering diagnostic data (Crashlytics) to improve the App and develop new features. Data is often aggregated or pseudonymized for this purpose.
7. Reliability & Performance: Using permissions like `RECEIVE_BOOT_COMPLETED`, `REQUEST_IGNORE_BATTERY_OPTIMIZATIONS`, and `FOREGROUND_SERVICE` to ensure the app functions reliably for real-time features.

4. HOW WE SHARE YOUR INFORMATION

We do not sell or rent your personal information in the traditional sense. We share data only in these limited circumstances:

1. With Your Consent: When you explicitly direct us or consent to share your information with a third party (e.g., saving a contact, using a feature that inherently involves sharing).
2. Service Providers & Partners: We share necessary information with trusted third-party vendors, consultants, and service providers who perform services on our behalf. This includes:
   • Cloud hosting providers (e.g., Google Cloud, AWS, Microsoft Azure)
   • Analytics providers (e.g., Google Analytics, Firebase, Mixpanel, AppsFlyer, GrowthBook, UXCam – see Sec 5)
   • Crash reporting services (e.g., Firebase Crashlytics)
   • Payment processors (via Google Play Billing)
   • SMS delivery providers (e.g., Twilio for verification/notifications)
   • Customer support platforms
   • Consent Management Platforms (e.g., Google UMP/FundingChoices)

   These providers are contractually obligated to protect your data and use it only for the services they provide to us.

3. Advertising Partners (Free Version): In the free version, we partner with third-party ad networks (e.g., Google AdMob/AdX, Meta Audience Network, AppLovin, Pangle, InMobi – see Sec 5). We may share/allow them to collect technical data, device identifiers (like Advertising ID), IP address, coarse location (if permission granted), and usage data through their SDKs to serve personalized ads and measure performance. **We do NOT share your name, phone number, call logs, contacts, or SMS content with advertisers.** You can opt-out of personalized advertising (see Section 8).
4. Legal & Safety Requirements: If required by law, legal process, or government request (e.g., subpoena, court order), or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Smart Media, our users, or the public.
5. Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, or dissolution, your information may be transferred to the relevant third party as part of that transaction, subject to confidentiality agreements.
6. Aggregated/Anonymized Data: We may share aggregated or anonymized data (which cannot reasonably identify you) for research, statistical analysis, industry reporting, or other purposes.

5. THIRD‑PARTY SERVICES & SDKs

We utilize various third‑party SDKs and services to provide functionality, analyze usage, show ads (in the free version), and improve the App. These partners may collect and process your information according to their own privacy policies. We encourage you to review them. Key partners include:

6. DATA SECURITY & RETENTION

6.1 Security Measures

• We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, or destruction. This includes encryption (for data in transit and at rest where feasible), access controls, secure development practices, and network security measures.
• However, no internet transmission or electronic storage method is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

6.2 Data Retention

• Call Log & SMS/MMS Content: Primarily processed locally on your device for real-time features and generally not stored on our servers. Local data is subject to your device’s storage management.
• Voice/Sound Recordings (if applicable): Retained only as long as necessary for the specific feature or until you delete them, as described in Section 2.7.
• Phone Numbers & Account Data: Retained as long as your account is active and for a reasonable period thereafter as necessary to provide the Services, maintain records, comply with legal obligations, resolve disputes, and enforce our agreements. If you delete your account, we will take steps to delete or anonymize your primary account information (like phone number) from active databases within a reasonable timeframe, subject to legal or operational requirements (e.g., backups, logs).
• Usage, Technical & Analytics Data: Retained for as long as necessary for the purposes outlined in this Policy, including service improvement, analytics, and fraud prevention. This data is often aggregated or pseudonymized over time.
• Other Data: Retained only for the period necessary to fulfill the specific purpose for which it was collected (e.g., resolving a support ticket, duration of a promotion), or as required by law.

7. YOUR RIGHTS & CHOICES

Depending on your location and applicable law, you may have rights regarding your personal data:

• Right to Know/Access: Request information about the categories and specific pieces of personal data we have collected about you, the sources, the purposes, and the categories of third parties data is shared with.
• Right to Correction/Rectification: Request correction of inaccurate personal data we hold about you.
• Right to Deletion/Erasure: Request deletion of your personal data, subject to certain exceptions (e.g., legal obligations, ongoing service provision).
• Right to Object/Restrict Processing: Object to or request restrictions on certain processing activities (e.g., direct marketing).
• Right to Data Portability: Request a copy of certain personal data you provided to us in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on consent (e.g., for accessing Contacts, Call Logs, SMS, Microphone, non-essential cookies/tracking), you can withdraw your consent at any time via device settings or app settings without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Opt‑Out: Opt out of the “sale” or “sharing” of your Personal Data and of targeted advertising or certain profiling (See Section 6 / Opt-Out Section above).
• Right to Lodge a Complaint: File a complaint with your local data protection authority if you believe our processing violates applicable laws.

Managing Permissions & Choices:

• Device Permissions: You can typically enable/disable permissions (Call Logs, Contacts, SMS, Microphone, etc.) via your phone’s Settings menu (e.g., Settings → Apps → ViewCaller → Permissions).
• Advertising Choices: Use the device-level controls and opt-out methods described in Section 6 (Opt-Out section) and Section 8.
• Account Deletion: You may be able to delete your account via the App’s settings or by contacting us.

To exercise your rights (other than those managed via device/app settings), please contact us at [email protected]. We will respond to verifiable requests in accordance with applicable laws.

8. INTEREST-BASED ADVERTISING & OPT-OUT (FREE VERSION ONLY)

If you use the free version of ViewCaller, we partner with third-party advertising networks (listed in Sec 5) to display advertisements. These partners use SDKs and tracking technologies (Sec 2.10, Sec 10) to collect data (e.g., Advertising ID, IP address, usage data, technical info) to show ads they believe are more relevant to your interests (interest-based advertising or personalized advertising) and to measure ad performance.

Opt-Out Options:

You can limit or opt out of interest-based advertising using these methods:

• Device Settings (Primary Method):
  • iOS: Settings → Privacy & Security → Tracking → Disable “Allow Apps to Request to Track” for ViewCaller, OR Settings → Privacy & Security → Apple Advertising → Disable “Personalized Ads”.
  • Android: Settings → Privacy → Ads → Select “Delete advertising ID”.
• In-App Settings (if available): Check within ViewCaller’s settings for specific advertising privacy controls.
• Ad Network Opt-Outs: Some ad networks offer their own opt-out mechanisms (check their privacy policies linked in Section 5), though device-level settings are generally more effective for mobile apps.
• Industry Tools: Tools like the DAA’s AppChoices app (https://youradchoices.com/appchoices) may offer controls for some participating networks.

Note: Opting out does not mean you will stop seeing ads, only that they may be less relevant to your interests.

9. CHILDREN’S PRIVACY

Our Services are not directed to or intended for children under the age of 13 (or a higher age threshold applicable in certain jurisdictions, such as 16 in the EEA/UK/California). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under the relevant age threshold without verifiable parental consent, we will take steps to delete such information promptly. If you believe we might have collected information from a child, please contact us at [email protected].

10. COOKIES & TRACKING TECHNOLOGIES

As mentioned in Section 2.10, we and our third-party partners (e.g., analytics providers, ad networks) use various tracking technologies:

• Mobile SDKs (Software Development Kits): Pieces of code embedded in the App provided by third parties (like those listed in Sec 5) to enable functionality such as analytics, advertising, crash reporting, etc. These SDKs may collect device identifiers, usage data, IP addresses, and other information as described in their respective privacy policies.
• Cookies (Websites): Small text files stored on your browser when you visit our websites, used to remember preferences, analyze site traffic, and support login sessions.
• Pixels/Beacons (Websites & potentially Emails): Tiny images embedded in web pages or emails to track engagement (e.g., page views, email opens).
• Local Storage: Storing data directly on your device (e.g., preferences, cached data).

These technologies help us operate our Services, understand usage, improve performance, personalize experience, prevent fraud, and deliver/measure advertising (in the free version). You can often control cookies via your browser settings and limit ad tracking via your mobile device settings (see Section 8). Disabling some of these technologies may impact Service functionality.

11. ADDITIONAL PROVISIONS FOR EU/EEA, UK, & SWITZERLAND

If you are located in the European Union (EU), European Economic Area (EEA), United Kingdom (UK), or Switzerland, the following provisions apply under the General Data Protection Regulation (GDPR) and relevant local laws:

• Legal Bases for Processing: We process your personal data based on the following legal grounds:
  • Consent: Where you have given explicit consent (e.g., for accessing contacts, call logs, SMS, microphone; for non-essential cookies/tracking; for certain marketing). You can withdraw consent at any time.
  • Contract Performance: To provide the Services you requested and fulfill our obligations under the Terms of Service (e.g., creating your account, providing caller ID).
  • Legitimate Interests: For purposes like security, fraud prevention, service improvement, analytics, and displaying contextual ads (in free version), provided these interests are not overridden by your fundamental rights and freedoms.
  • Legal Obligation: To comply with applicable laws and legal processes.
• Data Subject Rights: You have the rights outlined in Section 7 (Access, Rectification, Erasure, Restriction, Portability, Objection, Withdraw Consent, Lodge Complaint).
• Data Transfers: Your personal information may be transferred to, stored, and processed in countries outside the EU/EEA/UK/Switzerland (such as the U.S.A. and Israel, where our company and many service providers are located), which may have different data protection laws. We ensure such transfers rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (SCCs), adequacy decisions, or other mechanisms permitted under applicable law.
• Data Protection Officer: Our DPO can be contacted at [email protected].

12. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Categories of Personal Information Collected: We collect categories of personal information as described in Section 2, which may include: Identifiers (name, phone number, email, IP address, device IDs, Advertising ID); Customer Records Information (purchase history); Internet or Network Activity (usage data, interactions); Geolocation Data (coarse location, if permission granted); Audio information (if voice features used with consent); Inferences drawn from other data.
• Business Purposes for Collection/Use: See Section 3.
• Categories of Sources: Directly from you, your device, analytics providers, advertising partners, service providers.
• Categories of Third Parties Shared With: See Section 4 (Service Providers, Ad Partners, Legal entities, potential acquirers).
• Your Rights:
  • Right to Know/Access: Request disclosure of data collected, sources, purposes, and third parties shared with (as described above).
  • Right to Delete: Request deletion of your personal information, subject to exceptions.
  • Right to Correct: Request correction of inaccurate personal information.
  • Right to Opt-Out of Sale/Sharing: Request that we do not “sell” or “share” (for cross-context behavioral advertising) your personal information. See Section 6 (Opt-Out section) for how to exercise this right. We do not sell personal information for monetary value. Sharing with ad partners may constitute “sharing” under CPRA.
  • Right to Limit Use of Sensitive Personal Information (SPI): We generally only use SPI (like precise geolocation or contents of communications, if collected) for permitted business purposes. If we use it for other purposes requiring this right, we will provide a mechanism to limit such use. We do not use audio recordings (if collected) for purposes requiring this limitation right beyond providing the requested feature.
  • Right to Non-Discrimination: You will not be discriminated against for exercising your CCPA/CPRA rights.
• How to Exercise Rights: Submit requests via email to [email protected] with “California Privacy Rights” in the subject line, or use the opt-out mechanisms described in Section 6. We will verify your request using information associated with your account or device. Authorized agents can submit requests on your behalf with appropriate documentation.
• Data Retention: See Section 6.2.
• “Shine the Light”: California residents may request information about disclosures of certain categories of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes.

13. NOTICE TO VIRGINIA RESIDENTS (VCDPA)

If you are a Virginia resident, the Virginia Consumer Data Protection Act (VCDPA) provides you with the following rights:

• Confirm whether we process your personal data and access it.
• Correct inaccuracies in your personal data.
• Delete personal data provided by or obtained about you.
• Obtain a copy of your personal data in a portable format (data portability).
• Opt out of the processing of personal data for: (i) targeted advertising; (ii) the “sale” of personal data (we don’t sell data for money); (iii) profiling in furtherance of decisions that produce legal or similarly significant effects (we don’t do this).

To exercise these rights (except opt-out, see Sec 6), email [email protected] with “Virginia Privacy Rights” in the subject line. To opt out of targeted advertising or “sale” (as defined by VCDPA, potentially covering ad-related sharing), use the methods in Section 6 (Opt-Out section). We will respond within 45 days. If we deny a request, you may appeal by replying to the denial email within a reasonable period.

Note: ViewCaller does not sell data for monetary consideration. Data processing aligns with the purposes disclosed herein. Retention periods are described in Section 6.2.

14. NOTICE TO BRAZILIAN USERS (LGPD)

If you are located in Brazil, the Lei Geral de Proteção de Dados (LGPD) grants you specific rights:

• Confirmation of the existence of processing.
• Access to your data.
• Correction of incomplete, inaccurate, or outdated data.
• Anonymization, blocking, or deletion of unnecessary or excessive data or data processed in non-compliance with the LGPD.
• Portability of data to another service or product provider, subject to regulations.
• Deletion of personal data processed with your consent, subject to exceptions.
• Information about public and private entities with which the controller has shared data.
• Information about the possibility of denying consent and the consequences.
• Revocation of consent at any time.

To exercise your LGPD rights, please contact us at [email protected] or [email protected] (if specifically monitored for LGPD). We will respond in accordance with LGPD timelines.

15. NIGERIA DATA PROTECTION REGULATION (NDPR)

If you are a resident of Nigeria, we process your personal data in compliance with the Nigeria Data Protection Regulation (NDPR) and any amendments.

• We rely on lawful bases for processing, primarily consent and contract performance, as detailed in Section 11 (Legal Bases).
• You have rights under the NDPR, including the right to access, rectify, erase your data, restrict processing, data portability, object to processing, and withdraw consent.
• Data may be transferred outside Nigeria based on adequacy decisions or appropriate safeguards as required by NDPR.
• To exercise your rights or for inquiries regarding NDPR, please contact our Data Protection Officer (DPO) at [email protected] or our general privacy contact at [email protected].
• You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

16. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of significant changes by posting the updated Policy within the App or on our website, and updating the “Last Updated” date. Your continued use of the Services after the effective date of the revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.

17. CONTACT US

If you have any questions, concerns about this Privacy Policy, or wish to exercise your rights, please contact us:

Smart Media Internet Marketing LTD
Attn: Legal – Privacy
Sderot Hayahasut 11
Beer Sheva, Israel

Email: [email protected]

Data Protection Officer Email: [email protected]

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By using ViewCaller, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the Services immediately.