INTELIFONE PRIVACY POLICY

Effective Date: April 15th, 2018

Last Modified: January 3rd, 2019

Your privacy is important to us. This privacy policy (hereinafter, “Privacy Policy”) describes how we collect and use personal data that we receive about you as well as your rights in relation to the collection of your personal data when you use the Intelifone mobile application (hereinafter, “Intelifone”). Intelifone provides telecommunication services, such as low cost international calling, recording of calls, and call conferencing (hereinafter, collectively, the “Services”).

Intelifone is operated and your personal data is collected by Snow Labs, Inc.
(hereinafter, the “Company”, “we”, or “us”).

This Privacy Policy does not cover any personal data that we may receive about you through sources other than your use of Intelifone. Through your use of Intelifone, you may find links to other websites or mobile applications, but this Privacy Policy does not and will not apply to any of those linked applications or websites and we are not responsible in any manner for the privacy practices of those websites or mobile applications.

We are committed to the protection of your privacy while you use Intelifone.

By continuing to use Intelifone, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the collection, use, and disclosure of your personal data as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to it, then you agree to immediately cease your use of Intelifone.

This Privacy Policy also specifically incorporates by reference the Intelifone Terms of Use available at the following link:
https://intelifone.com/terms-of-use

TYPES OF COLLECTED PERSONAL DATA & MANNER OF COLLECTION

Through your use of Intelifone, you will be subject to collection of your personal data and different manners of collection. We respect data minimization principles and we collect only the following types of personal data:

1. Registration: In order to access any of the Intelifone Services, you, as a user of Intelifone, will be asked to register with Intelifone by allowing Intelifone to identify you based on the iCloud account configured on your device. We receive a unique key generated by iCloud to identify you as a user. This unique key is integral to your use of Intelifone.
2. Use: Through your use of Intelifone, you may be asked questions about how to improve Intelifone or you may, at some point, communicate with representatives of the Company. In addition, if you sign up for a subscription service with Intelifone, you may be able to send and receive messages (e.g., text messages and multimedia messages).  We will receive the contents of your messages (both text, multimedia, and any special characters) and communications, answers to questions, and all forms of contact between you and the Company. Such communications may contain personal data provided by you voluntarily.
3. Combined or Aggregated Information: We may combine or aggregate some of your personal data with non-personal data collected from you (e.g., your Internet traffic analytics data) in order to better serve you and to better enhance and update Intelifone for your and other consumers’ use. While the information described for analytics purposes in this Privacy Policy may be anonymized, it may be stored in the same location or used in conjunction with your personal data. In case the aggregation of your personal and non-personal data allows us to identify you, we will handle such aggregated information as personal data.

PURPOSES OF YOUR PERSONAL DATA

We primarily use your personal data to provide Intelifone to you as well as any Services requested by you.

We may also use your personal data for pursuing our legitimate interests, such as improving the design and functionality of Intelifone, asking you to provide feedback about Intelifone, and enforcing our Terms of Use.

If you contact us by email, phone, or through any contact forms, we will use your personal data to provide you with the requested customer support, respond to your requests, and answer your questions.

Before we ask for, collect, or use your personal data in any way not indicated by this Privacy Policy, we will seek your explicit prior consent.

YOUR CONSENT

Your use of Intelifone after reading this Privacy Policy substitutes your consent to our collection and processing of your personal data for the specified, explicit, and legitimate purposes described in this Privacy Policy.

In case we would like to (1) use your personal data for any purposes that are not explicitly indicated in this Privacy Policy, (2) provide you with any marketing communication, (3) transfer your personal data to third parties that are not indicated in this Privacy Policy, or (4) significantly amend this Privacy Policy, we will seek your prior express consent.

PROTECTION OF PERSONAL DATA:

We employ organizational and technical security measures to protect your personal data, such as limited access to your personal data, secured networks, encryption, and anonymization.

We use secure physical and digital systems to store your personal data. We ensure that your personal data is protected against unauthorized access, disclosure, or destruction by utilizing practices that are consistent with standards in the industry to protect your privacy and by using the Google Cloud platform for our servers.

After your account is created, we generate a unique authentication token. This authentication token is then stored in the encrypted “keychain” on your phone. Intelifone uses this unique token to ensure the proper identification and security of your personal data for use with our server.

All data transmitted between the Intelifone application and our servers is encrypted.

Please note, however, that no system involving the transmission of information via the Internet or the electronic storage of data, is completely secure. Although we take the protection and storage of your personal data very seriously and we take all reasonable steps to protect your personal data, we cannot be responsible for data breaches that occur outside of our reasonable control.

STORAGE OF PERSONAL DATA

After you provide us with, or we collect, your personal data, we will store it for (1) the specific time periods listed in the Terms of Use, (2) as long as it is necessary for providing you with the requested Services, or (3) until you stop using and uninstall Intelifone. If your personal data is no longer necessary for the purposes for which it has been provided, we will immediately delete such personal data, except for legitimate purposes as described below or in accordance with our Terms of Use.

Please note that we may store your personal data for any applicable legal record-keeping, including after the closure of your account, or for legitimate business purposes (e.g., maintaining our accountancy records, enforcing our Terms of Use, or otherwise maintaining the safety and security of Intelifone) for a time period permitted by applicable law. 

HOW PERSONAL DATA IS SHARED OR DISCLOSED

In certain cases, we may disclose your personal data to third parties that provide us with technical support (e.g., our hosting, data storage, and developing providers), business assistance, or we are requested to do so by public authorities. Please note that some third parties may be located outside the jurisdiction in which you reside.

Our disclosure of your personal data is limited to the following cases:

1. As may be necessary for the operation of Intelifone and provision of the Services requested by you (e.g., your personal data may be accessible to our hosting and cloud storage providers, developing team, and mailing providers);
2. To satisfy any local, state, or Federal laws or regulations;
3. To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
4. To bring legal action against a user who has violated the law or violated the Terms of Use of Intelifone;
5. In the case of any business transfer, sale, or transfer of assets of the Company;
6. To generally cooperate with any lawful investigation about our users; or
7. If we suspect any fraudulent activity on Intelifone, or if we have noticed any activity which may violate our Terms of Use or other applicable rules.

Please note that we do not share, sell, or otherwise provide your personal data to any third-party advertisers. 

THIRD PARTIES

We may utilize third party service providers (hereinafter, the “Third Party Service Providers”), from time to time, or all of the time, to help us to operate Intelifone, and provide you with the Services. Such Third Party Service Providers may include information storage companies (such as cloud storage providers), online application marketplaces, payment processors, or billing storage companies (such as the Apple iTunes Store), and user information logistics providers (such as Google Analytics or other analytics company which helps us track general user information and usage). We use the collected analytics information to understand patterns of, usage of, and to improve Intelifone.

We also utilize the cloud communication platform Twilio to provide our underlying enhanced communication services to you. Twilio will have access to the files containing records of all the calls made and messages sent through Intelifone, and the phone numbers of all Intelifone users, simply to assist in our provision of the Services to you.

Please note that the Third Party Service Providers indicated above will access your personal data only on an “if needed” basis as a part of their partnerships with us. Your personal data will be disclosed only if such third parties agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy.

We will not disclose, transfer, or pass through your personal data to third parties that are not mentioned in this Privacy Policy without obtaining your prior explicit consent.

Notwithstanding the other provisions of this Privacy Policy, we may provide your personal data to a third party in order to protect the rights, property or safety of the Company, our customers or third parties, or as otherwise required by law.

INTERNATIONAL USERS

By providing your personal data to us in any way, you acknowledge and agree that such personal data may be transferred from the location in which you reside to the physical location of the Company, whether that is offices of the Company or other service locations, and the locations of the third parties indicated in this Privacy Policy. Please note that the Company and the third parties acting on behalf of the Company are located in the United States.

ACCEPTANCE OF RISK

By continuing to use Intelifone in any manner, you manifest your continuing assent to this Privacy Policy. You further acknowledge, agree, and accept that transmission of information or data via the Internet is not always completely secure, no matter what reasonable security measures are taken. You acknowledge, agree, and accept that, although we put in place reasonable organizational and technical security measures, a security breach may occur. In case a personal data breach occurs, we will immediately take reasonable measures to mitigate the breach and follow the procedures stipulated by the applicable law. 

MINOR PRIVACY

We do not allow use of Intelifone or any of our Services by users under the age of 18 (eighteen). As such, we do not collect, store, or otherwise use any personal data from any minors.

YOUR RIGHTS

By using Intelifone, you can exercise the following rights:

• REFUSING TO PROVIDE YOUR PERSONAL DATA

The iCloud authorization you provide us is an integral part of Intelifone. If you choose not to provide your iCloud authentication to us, you will not be able to use Intelifone or any of the Services thereon.

• ACCESSING, MODIFYING, AND DELETING YOUR PERSONAL DATA

If you wish to access in a format convenient for you, modify, or delete any personal data we may have about you, you may do so by contacting us at support@intelifone.com.We will reply to your request as soon as possible but no later than 2 weeks.

• SUBMITTING A COMPLAINT

If you would like to submit a complaint to us about the way in which your personal data is handled, please contact us by using the contact details indicated in the section “Customer service contact information”. After you submit such a complaint, we will contact you within 3 business days confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe but no later than 2 weeks.

• LAUNCHING A COMPLAINT WITH A DATA PROTECTION AUTHORITY

If you are a resident of the European Union and you are not satisfied with the outcome of your complaint submitted to us, you have the right to lodge a complaint with your local data protection authority.

MARKETING AND ADVERTISING

We DO NOT send you any direct marketing communications or contact you directly for advertising purposes without obtaining your prior consent, unless we would like to inform you about the Services that are similar to the Services that you already use through Intelifone.

If you would like to receive brochures, updates of our new Services, or our newsletters, you can sign up for a newsletter through Intelifone. By subscribing for a newsletter, you agree to receive marketing communication from us.

At any time, you can opt-out from marketing communication by using the following methods:

• By clicking on the “unsubscribe” link featured in our newsletters and other advertising materials; or

• By contacting us directly (our contact details are specified in the section “Customer service contact information”).

The personal data you submit to us for subscribing for a newsletter will be used for delivering the newsletter only. If necessary, from time to time, we may send you important information about Intelifone, such as announcements about the major updates of Intelifone, data breaches, or other privacy-related matters. Please note that such communication does not fall within the scope of direct marketing communication and it will be sent only in exceptional cases.

CUSTOMER SERVICE CONTACT INFORMATION

If you have any questions about this Privacy Policy or the way we collect and process your personal data, you may contact us by using the following contact details:

Email address: support@intelifone.com

MODIFICATIONS AND REVISIONS

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. The date of the last amendment is indicated at the top of the Privacy Policy. If the Privacy Policy is amended significantly or if it is required by the applicable law and we have your contact details, we will seek your consent to the amended Privacy Policy.

Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the personal data collected on or after the date of the change. It is your responsibility to periodically check this page for any such modification, revision or amendment. Any changes made are assumed to have been accepted by your continued use of Intelifone.