Whocalls Privacy Policy

Effective date: September 20, 2021
We may change this policy at any time and we invite you to review it on a regular basis to be informed of any updates.

The website https://whocalls.info is published by: IT digital POMELO, a limited liability company registered in Romania (European VAT N° RO38093953) with main offices in Romania, Timisoara, Calea Aradului, DN69, KM7+800M.

Whocalls system

IT digital POMELO SRL offers Whocalls a system addressing Business Application Providers who want to offer out of the box, the integration of their Business Application (like CRM, reservation management, customer support…), with the telephony system of their customers.
By simply connecting their Business Application to Whocalls via APIs (ApplicationProgramming Interface) Whocalls allows Business Applications to:
- Get in real time the CallerID of who is calling the Partner’s customer
- Get the CallerID of unanswered calls
- Send SMS to Partner’s customer who got unanswered calls
The Service is provided through our web site: https://whocalls.info
In this policy “users”, “you” and “your” refer to Business Application providers (“Partners”) and their authorized users (“Users”), who are using Whocalls.
In this policy “we”, “us”, and “our” refer to IT digital POMELO SRL.
In this policy “Service” refers to the set of services provided by Whocalls to Partners
In this policy “Platform” refers to the applications and devices of the Whocalls system
This policy applies only when we are the data controller with respect to the personal data of our users and Partners visiting our websites or using our applications. This policy doesn’t apply when we have no control over and therefore assume no responsibility for the content, privacy policies or practices of any external third-party sites or services that our sites visitors or applications users/businesses may reach when using our Service.
By using Whocalls, you agree to the collection and use of information in accordance with this policy.
Data collected, and data use is summarized in the table 23.

Data we collect and how we use it

We collect the information listed below to provide and improve our Service. We describe below the type of data we are collecting, the reason of doing it (purpose), and the legal ground of data processing. Table in 23 summarizes the data collected, data use, purpose and legal ground.
Types of Data Collected:

Account data: while using our Service, we may ask you to provide us with certain Personally Identifiable Information (PII) that can be used to contact or identify you, like email address, mobile phone, name, address, etc. When sharing your email address with us you make possible receiving information about Service changes, Policies updates.

Usage data: We may also collect information that your browser sends whenever you visit our Site or when you access the Service. Usage Data may include automatic collection of information when visiting our Site such as your computer’s Internet Protocol address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, the way you use our Service, unique device identifiers and other diagnostic data. We collect this type of information for diagnosis purpose and to improve the reliability of our Service .
When you access the Service by or through a mobile device, this Usage Data may include automatic collection of information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system and version, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. We collect this type of information for diagnosis purpose and to improve the reliability of our Service

Publication data: We may process the data, users post in our websites or applications (for example: a customer review, a courier rating, etc.) and/or data businesses post in our websites or applications (for example: venue details, like open hours, menu, food description, etc.).

Customer relationship data & Transaction Data: We may process information related to our commercial and contractual relationship with Partners like contract, business legal name registration number, VAT number, contact details and history of transactions. This information is required to perform the Service and requires business consent.Cookies Data: We use cookies and similar tracking technologies to enable the Site functions and to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

We use cookies strictly necessary for the normal Site functions (“Essential Cookies”) and cookies to measure Service features effectiveness and Service features relevance to our users and businesses (“Analytics Cookies”). Analytics cookies are not mandatory for the Site functionalities, and you can have disabled them at any time, you can also instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, by doing so, we may not be able to monitor our Site performance properly, making challenging to deliver you the best user experience. We also use authentication cookies to identify and login users.

We may use the following essential cookies:

- Authentication cookies to login an authorized user
- Cookies to analyze how Site is used and how Site performs

For more information about Cookies and how to set a browser to refuse Cookies, please refer to https://www.allaboutcookies.org

Use of Data

The table below summarizes the data collected, the purpose of the processing and the legal ground.

Purpose	Data	Legal Ground
Account creation enabling to use the Service	*Email address	Your explicit consent
To be able to contact the Partner	Name Email *Phone	Your explicit consent
To establish a contract between IT DIGITAL POMELO SRL and the Partner To invoice and collect the payment for the use of the Service	Company name Company registration address Company registration number VAT number IBAN Website URL	Our legitimate interests to collect and process customer experience feedback. Necessity for the performance of a contract with you.
To detect, prevent and address technical issues and monitor the usage of the Service.	device type, brand, manufacturer browser type	Our legitimate interest to improve reliability and quality of our Service.

Transfer of Data

Your information, including Personal Data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you choose to provide information to us, please note that we transfer and process the data, including Personal Data within servers located in the European Union.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In case we transfer your personal data outside the European Economic Area this will be done only to a country or a company recognized by the European Commission as providing an adequate level of protection with your explicit consent.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Providing data to others

We may disclose the data collected including your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend our rights or property
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
We may disclose statistical data and/or anonymous data with other parties: like other Service providers, business partners, technical partners.
The Services execution requires to share phone and/or email between couriers, customers, and businesses to facilitate direct contact between parties in case of issues.

Data security and data protection

The security of your data matters to us, therefore we use reasonable commercial, organizational, technical and physical measures to protect your Personal Data.
However, and despite all reasonable efforts it is not possible to guarantee 100% data security and data protection when processing data online (like data transmission over the Internet, data electronic storage, etc.).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties may have temporary access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service like Google Analytics, Hotjar.
Google Analytics is a web analytics Service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Hotjar is a tool tracking and reporting website traffic and site visitor’s actions with the purpose to improve Site’s user experience, performance and conversion’s rate. For more information about Hojar cookies, please visit Hotjat Cookies web page: https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies

Children’s privacy

Our Service does not address anyone under the age of 18.We do not knowingly collect personally identifiable information from anyone under the age of 18.
If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children, we take immediate steps to remove that information from our servers.

Right to information and withdrawal

You are entitled to receive information on your data stored by us; you may use in this respect the contact details below
You are entitled to ask us to delete your data stored by us; you may use in this respect the contact details below

Changes to this privacy policy

We may update our Privacy Policy from time to time. We will notify you of any changes by updating the new Privacy Policy on our website and will notify you by sending you an email and/or sending you an InApp message and/or posting a notice in our website.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at:
contact@whocalls.info
Our full details are:
IT digital POMELO SRL.
Calea Aradului, DN69, KM7+800M, Timisoara, 300645, Timis county
Romania.