ANNEXURE I

Our Personal Information Handling Practices in 2019

We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.

  1. Identifiers

    Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

    We collected such personal information to use for the following business or commercial purposes:

    To provide the services, a more customized experience and to understand application usage and improve the content and offerings of the Truecaller application and website;

    To register for our Services, Users are needed to provide only name and phone number. Providing additional information such as profile photo or email address was optional.

    We have collected such personal information from the following categories of sources:

    Directly from the California resident and Users, from telephony directory service providers.

    We shared such personal information with the following categories of third parties:

    With other Users of the Services. Online identifiers, IP address, device ID, model, and manufacture type with advertising networks. With data analytics providers, government entities (only upon a valid formal request), operating systems and platforms, social networks.

  2. Personal information

    Any categories of personal information described in subdivision (e) of Section 1798.80.

    We collected such personal information to use for the following business or commercial purposes:

    By the very nature of our Services name and phone number is required to provide the Services;

    For the purposes of recruitment and evaluations of qualifications for possible employment or internship possibilities;

    For employee onboarding;

    To make contacts with you by telephone, email, or ground mail, to provide you with information and advertisements about Truecaller and our Services, establish and maintain a well-managed customer or prospective customer relationship, and to evaluate, develop, and improve our services.

    We have collected such personal information from the following categories of sources:

    Directly from the California resident and Users, from telephony directory service providers.

    We shared such personal information with the following categories of third parties:

    Other Users subject to the settings of the User. Online identifiers, IP address, device ID, model, and manufacture type with advertising networks. With data analytics providers, government entities (only upon a valid formal request), operating systems and platforms, social networks.

  3. Protected classifications

    Characteristics of protected classifications under California or federal law.

    We collected such personal information to use for the following business or commercial purposes:

    Not applicable for the preceding year 2019.

    We have collected such personal information from the following categories of sources:

    Not applicable for the preceding year 2019.

    We shared such personal information with the following categories of third parties:

    Not applicable for the preceding year 2019.

  4. Commercial information

    Commercial information regarding paid Truecaller subscriptions and/or any related information from the relevant app store (such as Google Play Store or Apple App Store) to activate user subscriptions, including, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies of the User.

    We collected such personal information to use for the following business or commercial purposes:

    To offer and maintain paid Truecaller subscriptions, make contacts with you by email, to provide you with information and advertisements about Truecaller and our Services, establish and maintain a well-managed customer or prospective customer relationship, and to evaluate, develop, and improve our services.

    We have collected such personal information from the following categories of sources:

    Directly from the California resident and Users, app stores from which the Users may have purchased the subscription, from public records, from telephone directory service.

    We shared such personal information with the following categories of third parties:

    Within Truecaller Users and entities, app stores, other Users if they raise any query regarding a particular subscription.

  5. Biometric information

    Biometric information: Truecaller does not mandatorily collect biometric data. The User has the option to upload their photo as part of their Truecaller profile.

    We collected such personal information to use for the following business or commercial purposes:

    User photo is only to be used as part of the user profile.

    We have collected such personal information from the following categories of sources:

    Available for other Users to see as part of the User’s profile.

    We shared such personal information with the following categories of third parties:

    The photo is hosted on our systems and we use cloud based services from Google.

  6. Activity information

    To provide the Services we may collect Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a user’s interaction with an internet web site, application, or advertisement.

    We collected such personal information to use for the following business or commercial purposes:

    To make contacts with you by telephone, email, to provide you with information and advertisements about Truecaller and our services, establish and maintain a well-managed customer or prospective customer relationship, and to evaluate, develop, and improve our services;

    To provide a more customized web experience and to understand site usage and improve the content and offerings of the site.

    We have collected such personal information from the following categories of sources:

    Directly from the California resident and User’s device.

    We shared such personal information with the following categories of third parties:

    Advertising networks certain categories, data analytics providers, government entities (only upon a valid formal request), operating systems and platforms, social networks.

  7. Location

    Geolocation data.

    We collected such personal information to use for the following business or commercial purposes:

    To allow you to share your location via flash messages.

    We have collected such personal information from the following categories of sources:

    Directly from the device of the California resident.

    We shared such personal information with the following categories of third parties:

    The information is shared with other Truecaller Users only to the extent to provide Services.

  8. Other information

    Audio, electronic, visual, thermal, olfactory, or similar information.

    We collected such personal information to use for the following business or commercial purposes:

    We do not collect such information, but Users can choose to provide their profile photo.

    We have collected such personal information from the following categories of sources:

    Directly from the device of the California resident.

    We shared such personal information with the following categories of third parties:

    The profile photo is used for the User’s profile and may be visible to other Truecaller Users.

  9. Educational information

    Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

    We collected such personal information to use for the following business or commercial purposes:

    Users can choose to provide their education information as part of their Truecaller profile;

    For the purposes of recruitment and evaluations of qualifications for possible employment or internship possibilities;

    For employee onboarding.

    We have collected such personal information from the following categories of sources:

    Directly from the California resident, from government entities from which public records are obtained.

    We shared such personal information with the following categories of third parties:

    The educational information uploaded by a User on its profile (which is optional) may be visible to other Truecaller users.

    Used for Truecaller internal business and recruitment process.

  10. Inferences

    Inferences drawn from any of the information identified in this subdivision to create a profile about a user reflecting the User’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

    We collected such personal information to use for the following business or commercial purposes:

    Name may be used to infer gender.

    We have collected such personal information from the following categories of sources:

    Directly from the California resident, from other Truecaller Users, public records.

    We shared such personal information with the following categories of third parties:

    Not shared with any third parties.