Privacy Policy


Last updated: August 30th, 2021


CallIn Corp. (“CallIn,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what personal information we collect, how we use and share that information, and your choices concerning our information practices. Through our mobile application (the “App”), we allow users to engage in audio-based conversations with people everywhere, and we allow users who start an audio-based conversation room to create content and record, edit, and share audio of conversations that occur on our platform (such services, including https://www.callin.com  (the “Site”) and the App, are referred to collectively in this Privacy Policy as the “Service”).

This Privacy Policy explains what personal information (defined below) we collect, how we use and share that information, and your choices concerning our information practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.

Before using the Service or submitting any personal information to CallIn, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy, including with respect to recording rooms. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.



Personal Information We Collect

Personal Information You Provide: We collect the following categories of personal information from you when you interact with the Services:

Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation patterns. In particular, the following information is created and automatically logged in our systems:

Derived Information: We may infer your preferences for our products and services based on the personal information we collect about you.

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit  All About Cookies.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect personal information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.



How We Use Personal Information

We may use personal information for the following purposes:

Aggregated Information. We may aggregate personal information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your personal information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email, we may use that information to send you updates and special offers. If we do, where required by law, for example if you are in the EU, we will only send you such emails if you consent to us doing so at the time you provide us with your personal information. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Services, management of your account, other administrative matters, and to respond to your requests.



Sharing and Disclosure of Personal Information

CallIn does not sell your personal information. In certain circumstances we may share the categories of personal information described above without further notice to you, unless required by the law, with the following categories of third parties:



Personal Information You Make Available to Others

Certain actions you take may be visible to other users of the Service. For example, your profile image will appear in other rooms that you join and your profile information will be accessible to other users. Further, after a room closes, the room host may access and freely use and disclose the room audio and associated attendee profile information and room activity for their own purposes. You acknowledge that by adding information to your profile or attending rooms you make your profile information and room activity available to other users and that CallIn cannot control, and shall not be responsible for any use other users make of such information.



Data Retention

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.



California Privacy Rights Disclosures

Where provided for by law and subject to any applicable exceptions, California residents may have the right:

If you would like to exercise any or all of these rights, you may do so by contacting us. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

Please contact us with questions or to request access to an alternative format of this Privacy Policy.



Children

Our Service is not directed to children who are under the age of 13. CallIn does not knowingly collect personal information from children under the age of 13. If you have reason to believe that a child under the age of 18 has provided personal information to CallIn through the Service please contact us and we will endeavor to delete that information from our databases.



EU Users

Scope. This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway, the United Kingdom, and, to the extent applicable, Switzerland).

Data Controller. Data protection laws in the EU differentiate between the “data controller” and “data processor” of personal information. CallIn is the data controller for the processing of your personal information that we collect that alone or in combination with other information could be used to identify you. You can find our contact information, and the contact information of our EU-based representative, in the “Contact Us” section below.

Legal Bases for Processing. We process your personal information as necessary to perform our contract with your or other users (“Contractual Necessity”), where necessary for our legitimate business purposes (“Legitimate Interests”), or with your consent (“Consent”).

The specific purposes for which we process your personal information and the legal bases we rely on for the processing are listed below.


Type of Personal InformationPurposeLegal Basis For Processing
Identification Information and Social Media InformationTo create, authenticate, maintain, and support your accountContractual Necessity
Room InformationTo facilitate conversations and the sharing of those conversationsContractual Necessity
Identification and Communication Information

To respond to your inquiries

To communicate with you about the Services, including by sending you announcements, updates, security alerts, support and administrative messages

Legitimate Interests in (i) providing you the information that you request, (ii) keeping our Services, network and information systems secure, and (iii) sending you information on our own products and services that may be of interest to you and informing our marketing strategy

Consent, for sending marketing communications regarding other products and services that may be of interest to you

Financial InformationTo process your transactions with usContractual Necessity
Internet Activity Information and Social Media InformationTo administer and protect our Service, to measure the audience and analyze the general behavior of App users to understand what users are mostly focused on and help us improve the App, personalize your experience, and improve the ServiceLegitimate Interests in (i) enhancing user experience; (ii) improving the Service and developing new features and services; (iii) keeping our Service, network and information systems secure

Your Rights. Pursuant to the European Union General Data Protection Regulation (or GDPR), you have the following rights in relation to your personal information, under certain circumstances and subject to any applicable exceptions:

Please see the “Contact Us” section below for information on how to exercise your rights.

Information Processing in the U.S. CallIn is based in the U.S. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the EU and UK. Transfers of your personal information to CallIn in the U.S. are necessary to perform the agreement we have entered into, or are about to enter into, with you.



Links to Other Websites

The Service may contain links to other websites not operated or controlled by CallIn, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.



Security

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any personal information to CallIn via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.



Your Choices

In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of our Service, you may be unable to use those features. You can also log in to your account or contact us to request updates or corrections to some of your personal information.



Changes to the Privacy Policy

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.



Contact Us

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: legal@callin.com.

If you are an individual in the EU, you can also contact VeraSafe, who has been appointed as CallIn’s representative in the EU pursuant to Article 27 of the GDPR on matters related to the processing of personal information that take place in the EU. To make such an inquiry, please contact VeraSafe via this contact form, via telephone at +420 (228) 881-031, or at:

VeraSafe Ireland Ltd.

Unit 3D North Point House

North Point Business Park

New Mallow Road

Cork T23AT2P

Ireland

If you are an individual in the UK, you can also contact VeraSafe, who has been appointed as CallIn’s representative in the UK pursuant to Article 27 of the UK GDPR on matters related to the processing of personal information that take place in the UK. To make such an inquiry, please contact VeraSafe via this contact form, via telephone at + 44 (20) 4532 2003, or at:

VeraSafe United Kingdom Ltd.

37 Albert Embankment

London

SE1 7TL

United Kingdom