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Effective date: 25 May 2018
NOTICE OF COLLECTION
This notice addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (“CCPA”), by Truecaller International LLP to provide certain information about our data processing practices to California residents in addition to the disclosures in our Privacy Notice at or before the point of collecting personal information.
Truecaller provides disclosures for the 12 months preceding January 1, 2020 as required by the CCPA vis-à-vis California residents. For purposes of clarification, without limitation, the CCPA provides that for purposes of the disclosure requirements pertaining to the preceding 12 months, and until January 1, 2021, these disclosure requirements do not extend to:
(i) personal information collected by Truecaller about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of Truecaller to the extent that the natural person’s personal information is collected and used by Truecaller solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of Truecaller; personal information that is collected by Truecaller that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of Truecaller to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; or personal information that is necessary for Truecaller to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of Truecaller to the extent that the personal information is collected and used solely within the context of administering those benefits (“HR Exemption”), or
(ii) California residents who are not acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency (a “Business Representative”) where Truecaller holds personal information reflecting a written or verbal communication or a transaction between Truecaller and the Business Representative and the communications or transaction with Truecaller occur solely within the context of Truecaller conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency (“Business-to-Business Exemption”).
2. YOUR RIGHT TO KNOW ABOUT INFORMATION COLLECTED, DISCLOSED, OR SOLD
WE DO NOT SELL CALIFORNIA RESIDENTS’ PERSONAL INFORMATION.
3. PERSONAL INFORMATION COLLECTED
3.1 USER PROFILE
When You create a user profile in the Services and confirm being the holder of a certain number, Truecaller will collect the information provided by You. In order to create a user profile, You must register Your first name, last name and phone number. Additional information that may be provided at Your option include, but is not limited to, photo, gender, street address and zip code, country of residence, email address, professional website, Facebook page, Twitter address and a short status message. Truecaller may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. additional contact information that is publicly available.
3.2 INSTALLATION AND USE
3.3 THIRD PARTY SERVICES
3.4 CONTACT INFORMATION
Where the Truecaller mobile applications (“Truecaller Apps”) are obtained from other sources than Apple App Store or Google Play, You may share the names, numbers, Google ID’s and email addresses contained in Your address book (“Contact Information”) with Truecaller by enabling the Truecaller Enhanced Search Functionality. Where the Truecaller Apps are obtained from Apple App Store or Google Play, we do not share any user Contact Information. In addition to Contact Information, if You choose to activate use of a third-party service, such as social networks services, within the Services, Truecaller may collect, store and use the list of identifiers associated with said services linked to the Contact Information in order to enhance the results shared with other Users.
Please note that no other contact information other than the phone numbers and thereto attached names, Google ID’s and email addresses will be collected and used from Your address book. Other numbers or information that may be contained in Your address book will be filtered away by our safety algorithms and will therefore not be collected by Truecaller. Please also note that You can always choose not to share Contact Information with Truecaller and if You have shared such information and changed Your mind, You can delist Your number or opt-out to render Your entire Contact Information unavailable for search in the Truecaller database.
3.5 OTHER INFORMATION YOU MAY PROVIDE
You may provide us with various information in connection with Your interaction with our Services. For example, You may through tagging functionality associate a phone number, that is not registered in the Truecaller database or belongs to a User, with a business or name and You may report a phone number as spam or some other attribute to be included in spam blocking directories. Truecaller may also from time to time offer You the opportunity to provide information on Your experience from using the Services or to participate in, surveys or other promotions. Truecaller will collect the information You provide in connection therewith, as well as any other information You provide through the Services or when You communicate or interact with us.
4. USE OF PERSONAL INFORMATION
4.1 PROVIDE, AND IMPROVE OUR SERVICES
Truecaller may use the personal information collected to provide, maintain, improve, and analyze the Services to its Users, partners and third-party providers. More specifically, Truecaller may use such information to:
- provide smart caller ID, dialer and messaging functionality that, among other features, allow for population of unidentified numbers and other data in call or message logs, display the name associated with a certain number for incoming or outgoing calls and messages or following a manual number search against the Truecaller database;
- display the number associated with a certain name following a manual name search against the Truecaller database, subject to that name searches will only produce a number linked to the name if the number is available for search in a public database or relates to a User who has made his or her name available for search, provide Your information to the person You reach out to when requesting a contact via the Truecaller name search service, in which case Your request will be forwarded to that person via an SMS and he/she may choose whether or not to share the phone number with You at his/her own discretion;
- display information based on connections a User may have in common, directly or indirectly, with other Users via a “social graph” algorithm, display the “who viewed my profile” and “availability” functionalities of the Services;
- send in application push notifications and reminders and deliver messages via the Services, in which case Your messages will be kept for a limited period of time in order to deliver the messages but Truecaller will not, unless specifically stated, monitor the content of Your messages;
- maintain User spam lists and build a community based spam blocking directory;
- enable You to use and share Your information in connection with Your registration, login or other use of third-party services e.g. payment service providers, online services, social networking sites and other third-party API’s; and
- otherwise improve our Services, business and operations.
4.2 STATISTICAL DATA FROM THE SERVICES
We use aggregated or anonymized personal information for statistical and analytical purposes. We may come to share such data with third parties for providing and improving our services.
We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
4.3 ADVERTISING AND COMMUNICATIONS
We may use your information to provide you with non-personalized advertising, by enabling restricted data processing using Google as a service provider. We do not use your precise location or personal information to serve you personalized ads.
Subject to your settings, we may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, SMS and similar notifications about Truecaller’s and our business partners’ products and services. We may use your information to contact you about our Services and features or to inform you of updates including to our terms and policies.
4.4 COMPLIANCE WITH LAWS AND PREVENTION OF FRAUDULENT OR ILLEGAL ACTIVITIES
We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of Truecaller, its Users or any other person and verify provided User profile information with third-party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.
5. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
In addition to the sharing and disclosure of personal information that is included as part of the functionality of the Services as described in section 4 above, Truecaller may disclose personal information if we believe such action is necessary to:
- comply with the law, or legal process served on us;
- protect and defend our rights and the enforcement of our agreements; or
- protect the security and safety of Users or members of the public or other aspects of public importance, provided, of course, that such disclosure is lawful.
We may disclose and transfer Your Information to our associated or affiliated organisations or related entities and to any third party who acquires, our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.
6. DELISTING OF CONTACT INFORMATION, RIGHT TO OPT-OUT
If a User chooses to disable the Enhanced Search Functionality, the Contact Information made available by that User is disabled and will thereafter not be available for search in the Truecaller database. If any persons do not wish to have their names and phone numbers made available through the Enhanced Search or Name Search functionalities, they can exclude themselves from further queries by notifying Truecaller via its website at www.truecaller.com or as set forth in the contact details below. You acknowledge and agree that Truecaller may keep and process personal information related to such request in order to be able to honor the request. You have the right to opt-out of the sale of Your personal information. However, for avoidance of doubt, we do not sell Your personal information.
7. INFORMATION SECURITY AND TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES
8. ACCESSING, UPDATING AND RIGHT TO DELETE PERSONAL INFORMATION
Truecaller may on its own initiative, or at Your request, replenish, rectify or erase any incomplete, inaccurate or outdated personal information retained by Truecaller in connection with the operation of the Services. When required by applicable law, You have the right to know what personal information is stored about You.
You have a right to request the deletion of personal information that we collect or maintain about You. You can access and control Your information via our in-app Privacy Center (available under Settings>Privacy Center) where you can use tools to deactivate and retain or delete your data. Alternatively, if you prefer You may submit a request to delete Your personal information, please contact us using the contact information below, and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA. You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code §1798.125.
Services are not intended for or designed to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. Truecaller does not intentionally or knowingly collect personal information through the Services from anyone under that age. We encourage parents and guardians to be involved in the online activities of their children to ensure that no personal information is collected from a child without their consent.
WE DO NOT SELL THE PERSONAL INFORMATION OF MINORS UNDER 16 YEARS OF AGE.
12. AUTHORIZED AGENT
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, addition to the steps described under Section 2 and Section 8 above, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
We will ask that you provide certain information to verify your identity, such as a code sent to your device we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
You can also send Your enquiries (including in relation to any grievances to our Grievances Officer) via email to email@example.com or by post to ‘The Greivances Officer’ at the address below:
Truecaller International LLP
1st Floor, Platina Tower
M.G Road, Near Sikandarpur Metro Station,
Sector 28, Gurugram,