Last updated: December 10, 2018
Your privacy is very important to us and we want you to know everything we do and don’t do with the data you provide. Our guiding principle is that any data we collect from you will be treated with the utmost care and respect, and every effort will be made to ensure the data is kept private.
If you have any questions about the Policy, please contact:
Digipom Legal Services
Under applicable law, Digipom Inc. is the “data controller” of Personal Data collected through the Services. Personal Data is any data relating to an identified or identifiable natural person.
What personal data does Digipom collect?
The Personal Data we may collect about you through the Services falls into the following general categories:
Information that you provide voluntarily
Certain parts of our Services may ask you to provide Personal Data voluntarily. For example, we may ask for certain information in order to use features in our Apps, register an account with us, subscribe to marketing communications from us, and/or to submit enquiries to us, such as:
- your name, email address or other contact details.
- any information you submit to our customer service team in the App or via email.
The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be explained to you when we ask you to provide your Personal Data.
Information we collect automatically
When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered Personal Data under applicable data protection laws, such as:
- Data and analytics about your use of our Services (e.g. in-app usage, session length, preferred settings, which in-app advertisements you may have viewed, crash reports, and the means by which you were referred to our Services).
- Your IP address, device identifiers such as your Advertising ID, other device information, and your general geographic location (e.g. country or city location) based on your IP address.
“Advertising ID” includes the Apple Identifier for Advertisers (“IDFA”) on Apple, and the Google Advertising Identity (“GAID”) on Android. These are unique identifiers for mobile devices that advertisers use for interest-based advertising. They are consistent across all apps and thus allow tracking across apps. These identifiers can be reset from the device’s settings. On Apple, you can opt out by choosing the “limit ad tracking” option in the privacy settings. On Android, you can opt out by choosing “Opt out of interest based ads.”
Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
“Device information” means device type, model, manufacturer, operating system and language, or other technical data like supported application programming interfaces (“APIs”), screen size, processor, or a combination of this data, available from a device for a developer to check the device’s compatibility with a particular application.
Information we obtain from third party sources
(a) Third party service providers.
We may receive Personal Data about you from third-party sources. We may obtain your Personal Data, for example, when you installed our App or when, prior to installation, you click on an advertisement for the App (see the “Third-Party Advertisements” section below for more information).
In order to better understand our users of the Services, we may conduct research on our customer demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Digipom may use Google Analytics (see http://www.google.com/analytics/), Google Firebase Analytics (see https://firebase.google.com/features/analytics/), Crashlytics (see https://try.crashlytics.com/terms/privacy-policy.pdf) or other similar services to collect such information.
The Application makes use of Google Analytics Demographics and Interest Reporting (see https://support.google.com/analytics/answer/2799357) which gives Digipom certain demographic and interest information about our Application users. None of this information, however, can identify you personally to Digipom. The information may be used to serve you advertisements that will be of interest to you. You can disable this feature through your Android settings of your Device or the Google Settings App. You can also opt out of such Google advertising at any time by visiting your Google Ads Settings page (see https://www.google.com/settings/ads).
(b) Advertising partners.
From time to time, we may also receive Personal Data about you from other third-party sources. For example, if you clicked on an advertisement directing you to one of our Services (such as an ad for one of our Apps in another publishers’ app), we will be provided with Data about which ad network and advertising campaign the install originated from. Please see the Advertising section below for more information.
What we don’t collect
Under no circumstances does Digipom collect, download or otherwise make copies of any recordings you make using any of our apps (hereinafter “Recordings”) and any reference to Personal Data in the present Policy does not include Recordings, or any Personal Data about you or any third party included in the Recordings. Notwithstanding the foregoing, you may make copies of Recordings via application or operating system features (such as the share menu or via file system access), and/or by uploading them to various cloud services such as Dropbox, Google Drive and iCloud. However, Digipom has no access whatsoever to these copies and therefore any Personal Data about you or any third party contained in the copies of Recordings is also not covered by this Policy.
How we use your personal data
We use your Personal Data for the following purposes:
To provide and operate our Services
- To provide you with the correct versions of our apps (e.g. knowing which language to make our apps available to you in).
To improve our Services and keep them secure
- To respond to your customer support requests (e.g. if you write to us with a complaint),
- To receive error messages about any issues you or your device encounter with our Services to enable us to fix bugs and interoperability issues,
- To detect and prevent illegal activities,
- To track App installs (e.g. for purposes of measuring the effectiveness of marketing campaigns),
- To conduct optional user feedback surveys,
- To understand you, your preferences and user traffic to enhance your experience and enjoyment of our Services,
- To conduct research.
To personalize our Services
- To remember you the next time you visit one of our Services,
- To communicate with you about promotions, rewards, upcoming events, and other news about products and services we offer.
For promotional activities, including marketing and advertising
- To provide you with in-app offers and rewards based on your in-app behaviors,
- To serve you with relevant targeted advertisements (necessary to fund our Services),
- To make you offers to purchase in-app items on discount based on your in-app activity and purchase history,
- To send you marketing communications and/or newsletters about rewards and promotions if you have subscribed to them.
- To comply with our legal obligations,
- To exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person,
- To prevent and/or detect fraud or fraudulent behavior.
We use advertising to fund our Services and to make some of our apps or versions of our apps available for free. We show third-party advertising in our Apps and also advertise our Services via third parties. We want to provide you with more detail about how we use information for advertising, both in our properties and in third-party properties.
When you view ads in Digipom properties (e.g. in our Apps)
To enable us to show in-app ads, we may send your advertising ID, IP address and device information to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our Apps and on third-party properties. You can control and limit our use of your advertising ID in your device settings. Digipom does not control which specific ads are shown in our apps (this is controlled by the ad networks), but we do prohibit certain types of ads.
Advertising IDs are used by ad networks for a number of purposes, including, for example, to:
- Limit the number of times you see the same ad.
- Ensure they are dealing with humans with real devices and not automated “bots”.
- Serve you with advertisements likely to be relevant to you based on your advertising ID, your engagement with other brands and ads which is recorded using your advertising ID, and to use your general geographic area.
- Other brands may buy ad placements via an ad network or ad exchange to advertise their products in our Apps. The ad network or ad exchange acts as an intermediary between the other app companies and Digipom. In order for the ad network to charge the company purchasing the ad, clicks from the ad and potential installs of other developers’ apps are tracked. These views, clicks and installs from ads are measured using the Advertising ID.
- Track which apps you have used to market you similar kind of apps. Your IP address is typically used by advertisers to identify your general geographic location, for example, your country, state and, sometimes, your city.
When you view Digipom ads on third-party services
Digipom also advertises its Apps on other apps by asking ad networks to place ads for audiences that will be interested in them, determined using Advertising IDs. Ad networks use Advertising IDs for this and other purposes, including, for example, to:
- Measure ad effectiveness (including total views, clicks and installs generated by its advertising in other publishers’ apps),
- Not display ads for an app a user is already using. Digipom may send a list of active users in the form of Advertising IDs to an ad network. The ad network then excludes these users from seeing the ad.
Where you have downloaded one of our apps, we may use Google, a third-party vendor, to serve advertisements in the App, using the AdMob system (see http://www.admob.com/home/privacy).
In addition to Google advertisements, from time to time we may allow other third-party companies to serve ads and/or collect certain anonymous data when you use the Application. This list currently includes:
- InMobi (see https://www.inmobi.com/privacy-policy/)
- Mobfox (see https://www.mobfox.com/privacy-policy/)
You can opt out of interest-based advertising on mobile applications by changing the privacy settings of your device and selecting “limit ad tracking” (Apple iOS) or “opt out of interest-based ads” (Android).
Legal basis for processing personal data
Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where (i) we need the Personal Data to perform a contract with you, (ii) the processing is in our legitimate interests and not superseded by your rights, or (iii) we have your consent to do so.
(a) Under our terms of service, “performance of contract” as a legal basis for processing your Personal Data refers to when we make the App and Services available to you, provide customer support, integrate Apps with technology and distribution platforms such as Apple iOS and Google Android, and inform you of service-related changes and App progress.
(b) We process your Personal Data on the basis of our legitimate interests for example when we provide you the App and App events, serve interest-based advertisements to you (both in-app and on third-party properties), carry out marketing, keep our apps secure, for engineering purposes, analyzing the users’ behavior across our Apps, moderating chat discussion.
(c) We have a “legal obligation” to process your Personal Data when complying with a legal obligation, such as the preventing a crime or fraud or maintaining tax records.
(d) If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
Who does Digipom share my personal data with?
We may share your Personal Data with the following types of recipients:
(a) With third-party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help enhance the security of our Services), or parties that otherwise process Personal Data for the purposes described in this Policy or communicated to you when we collect your Personal Data.
(b) With any competent law enforcement body, regulatory authority, government agency, court of law or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
(d) With any other person, with your consent for such disclosure.
How does Digipom keep my personal data secure?
Digipom uses standard industry practice (physical, electronic and procedural) to protect all data collected (including Personal Data) secure. We take reasonable steps to protect the Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what Personal Data you send to us via email. Please keep this in mind when disclosing any Personal Data via the Internet.
We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so, for example, to provide you with a Service you have requested, or to comply with applicable legal, tax or accounting requirements. We generally retain Personal Data so long as it may be relevant to the purposes identified herein. To dispose of Personal Data, we may anonymize it, delete it or take other appropriate steps. Personal Data may persist in copies made for backup and business continuity purposes for additional time, but it will be deleted as soon as practicable.
Your data protection rights
If you wish to inquire about and access what Personal Data Digipom holds about you to verify and/or correct it, or if you wish to delete any Personal Data held about you from our databases, please contact us using the information further up in this Policy. Please note that deletion of your Personal Data may make it impossible for you to use the Services. Please note that if you request deletion of your Personal Data, Digipom reserves the right to retain some of your Personal Data for a reasonable time in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.
You have the following data protection rights:
(a) To access, correct, update or request deletion of your Personal Data.
(b) To object to the processing of your Personal Data (which is processed on the grounds of legitimate interests), ask us to restrict processing of your Personal Data or request portability of your Personal Data.
(c) To opt out of marketing communications we send you, at any time.
(d) If we are processing your Personal Data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Data conducted pursuant to lawful processing grounds other than consent.
If you wish to exercise any of these rights, please contact us at email@example.com.
(e) You have the right to file a complaint with a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
Transfer of your Personal Data outside of the European Economic Area (EEA)
For European users, we endeavour to keep your personal data inside the EEA. However, certain of our data processors (and Digipom) are in other countries where your Personal Data may be transferred. However, these countries are limited to countries with particular circumstances that protect your data, specifically:
Canada. Canada has been determined to have an “adequate level of protection” for your Personal Data under European data protection law.
The United States. Your personal data is only transferred to companies in the United States that: (1) participate in the Privacy Shield; and (2) have signed agreements with us or have informed us that they are GDPR-compliant.
Notwithstanding the foregoing certain of our advertising network partners may transfer unique identifiers including your IP address (considered personal data under the GDPR) to their advertisers who may be located outside Canada or the USA. You can avoid this transfer by opting out of our advertising, as described in the Advertising section of this Policy.
Use of device permissions
The following is a listing and description of certain functions on the Device that are accessed and/or modified by our Apps, and which may require explicit user permission to access. You acknowledge that denying explicit user permission may affect or reduce your user experience with the App, or prevent the App from working at all.
Allows the App to make Recordings using the microphone.
CHANGE YOUR AUDIO SETTINGS
Allows the App to modify global audio settings such as volume and which speaker is used for input/output.
FULL NETWORK ACCESS
Allows the App to create network sockets and use custom network protocols.
PAIR WITH BLUETOOTH DEVICES / ADMINISTRATE BLUETOOTH
Allows the App to view the configuration of Bluetooth on the Device, and to make and accept connections with paired devices.
MODIFY OR DELETE THE CONTENTS OF YOUR USB STORAGE / MODIFY OR DELETE THE CONTENTS OF YOUR SD CARD
Allows the App to read and write to the USB storage and / or SD card.
PREVENT DEVICE FROM SLEEPING / PREVENT PHONE FROM SLEEPING
Allows the App to prevent the Device from going to sleep to ensure continuous recording.
MODIFY SYSTEM SETTINGS
Allows the App to modify the system’s settings data (i.e. to set a Recording as a ringtone).
VIEW NETWORK CONNECTIONS
Allows the App to view information about network connections such as which networks exist and are connected.
READ PHONE STATE
When enabled, allows the App to pause a Recording when a phone call is received.
Verifies the market license.
Allows the App to make Recordings using the microphone.
Allows the Application to generate transcriptions of the Recordings.
When we collect Personal Data we do not know the age of our users. If we discover we has inadvertently gathered Personal Data from a minor under 13 years of age, we will take reasonable measures to promptly delete such Personal Data from our records.
© Digipom 2018