Apollo Telecom Limited - Privacy Policy in Relation to the White Calling App

General Data Protection Regulation Privacy Notice

Apollo Telecom Limited (registered in Ireland with registration number 277835 and whose address is Office 7, Strand Campus, Sligo Airport Business Park, Strandhill, Co. Sligo) (“Apollo”, “us”, “we” or “our”) is the data controller of any personal information you provide to us or personal information that has been provided to us by a third party. In partnership with our third party service providers, we collect and process information about you in order to ensure the on-going provision of the White Calling app and to enable you to access a range of services provided by third parties (“Services”). This may involve sharing your information with payment service providers, third parties to whom you send credit and international service providers on a worldwide basis.

We value your privacy and want you to understand the choices and control you have over your information we collect and process via the White Calling App (the ‘App’).

What information about you is collected and how will we use it?
Profile Information
When downloading the App or otherwise start using services accessible via the App you are required to register with us, and create your White Calling account. By registering you give your consent for us to collect, use and store the following information:

• • Contact details such as phone numbers and email address
• • Payment details such as cardholder name; credit or debit card details (however, we only retain certain parts); chargeback information; billing address
• • Transaction Details: transaction amount and currency
• • Electronic Identifying Details: IP address; SMS content; cookies; pixels; activity logs (e.g. user session recordings); online identifiers; device identifiers (e.g. the mobile device and/or the internet browser that you use) and geolocation data;
• • Correspondence and Complaints: any correspondence that you choose to send to us (including complaints); any information you provide to our customer care team; any information you publish about us (including on the app stores);
• • Transaction History: details of the transactions (including date and time and relevant service provider) you carry out on, and your visits to, the Applications.

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:

• • To verify your identity (your phone number will be used as your White Calling account ID), both to create your account and identify your account
• • To display your phone number to the person you are communicating with via the App. Note: we also send the phone number of the person you are communicating with to our servers, to allow us to setup that call
• • To manage your White Calling account, deliver to you any administrative notices, updates, notifications, alerts and communications relevant to your use of the Service
• • To facilitate the future purchase of credit or services via the White Calling App
• • To contact you via email, SMS, telephone call or otherwise for the purpose of informing you about new products, services or promotions offered via the White Calling app (you can decide not to receive such communications of such communications by clicking an unsubscribe link, withhold your consent to receive an SMS or reply stop to an SMS in order not to receive future SMS)
• • To contact you via telephone to discuss matters specific to your White Calling account, as applicable for internal operations, including troubleshooting problems, data analysis, testing, research, improvements to the Services, detecting and protecting against error, fraud or other illegal activity
• • When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities

Sharing Information
We will only share your data, and that of users accessing services via the App, with third parties (for example, third party suppliers of Services):

• • With your consent (including as set out in this Policy)
• • As reasonably necessary in order to provide the Services to you (for example, by providing information to suppliers we may use to fulfil the Services or to communicate with you)
• • 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)
• • Where you have asked us to share your information with third parties, for example your friends and families
• • 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
• • Where your data is on an anonymous and aggregated basis, meaning you could not be personally identified from it
• • 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
• • As we reasonably believe is permitted by law or regulation
• • In order to comply with any legal obligation, or in order to enforce or apply the White Calling Terms of Service and/or any other agreement with you; or to protect the rights, property, or safety of White Calling, our colleagues, and other users
• • With auditors, legal and financial advisors and potential purchasers or bidders.

Your details may be stored and processed in the EU or the UK or any other country in which White Calling or its affiliates, subsidiaries or suppliers maintain facilities or provides access to Services. By using the Services, you consent to any such transfer of the information outside your country. To ensure that your personal data receives an adequate level of protection and is treated securely, and where a specific derogation does not apply, we put the appropriate safeguards in place to protect the privacy and integrity of such personal data when being transferred outside the EEA (e.g. EU-approved standard contractual clauses / binding corporate rules).

Transfer of Data to an Acquiror
We reserve the right to transfer information (including your personal data) to a third party in the event of a merger, liquidation, receivership or transfer of all or substantially all of the assets of our company. The third party must only use your personal data for the purposes that you provided it to us in the first place and as set out in this privacy notice. You will be notified in the event of any such transfer.

Third Party Sites
Our App may contain links that will let you access a website of a third party. Please note that such linked websites are not under the control of White Calling 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 App, your use of our Services and/or your relationship with White Calling.

Security
Protecting user privacy and personally identifiable information is a top priority for White Calling. We make substantial efforts to ensure the privacy of all personally identifiable information collected by us in relation to the downloading and use of the App. 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. Any sensitive personal identifiable information specific to payments is solely processed and stored (if applicable) by our Tier 1 PCI DSS accredited payment provider, and adheres to the most stringent levels of payment data security.

Changes to this Privacy 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. 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.

Your Rights to Access and Control Your Personal Information
You have a right to obtain a copy of, and the right to rectify any inaccuracies in, the personal data we hold about you by making a request to us in writing. You also have the right to request erasure, restriction, portability, or object to the processing, of your personal data or not to be subject to a decision based on automated processing, including profiling. You should inform us of any changes to your personal data. Any requests made under this section can be made using the contact details set out below. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than one (1) month after receipt of your request. In each case, these rights are subject to restrictions as laid down by law. If you are unhappy with any aspect of processing or your data protection rights please contact use in the first instance and we will be happy to listen to your concerns. We can be contacted as follows: ask@whitecalling.com At all times, you have the right to lodge a complaint with the Office of the Data Protection Commission if you are unhappy with how your personal data is being handled by us. Their contact details are as follows:

Data Protection Commission Canal House Station Road Portarlington County Laois
Telephone: +353 (0)761 104 8000
Telephone: +353 (0)57 868 4800
LoCall Number: 1890 252 231
Email: info@dataprotection.ie

If we are relying on your consent to allow us to process your information, you can withdraw your consent at any time. From that point on we would no longer be able to carry out the processing we were carrying out with your consent. Any processing we carried out before you withdrew your consent would remain valid. We do not generally rely on consent for processing personal data.

This Policy and our Terms of Service
This Privacy Policy forms part of and is subject to our 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.