Privacy Policy

ROBO TERMINATOR

PRIVACY POLICY

Last updated October 12, 2022.

Your privacy is important to you – otherwise, you would not be using Robo Terminator. Accordingly, we take your privacy rights seriously. This Privacy Policy is meant to explain our practices when it comes to your use of our applications, products, services, and websites. We encourage you to take the time to review it carefully, to understand what information we collect, why we collect it, and what we do with it. 

1. Who We Are.

1.1. ROBO TERMINATOR, including its corporate affiliates, is the owner and developer of the Robo Terminator application that screens unwanted spam and robo calls from your smart phone. 

1.2. This Privacy Policy applies to our customers, prospective customers, our customers’ customers (both direct and indirect), and visitors to our company websites, including but not limited to theroboterminator.com.

1.3. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, DO NOT ACCESS OR USE OUR SERVICES OR INTERACT WITH ANY OTHER ASPECT OF OUR BUSINESS.

2. What Information We Collect.

2.1. We collect the following kinds of information as described below:

2.1.1. Information you provide directly to us. When you sign up for our services, request us to contact you, or through other interactions with us, we may ask you for certain personal information, such as your name, postal address, e-mail address, telephone number, cellular service provider, or payment information. When you request support from us, we may also collect information from you such as contact information, documentation, screenshots, or other information you or we may believe is helpful to resolving the issue. When you speak with our customer service or sales representative on the phone, your calls may be recorded and/or monitored for quality assurance, training and research purposes. In certain circumstances, we may collect your Social Security number from you for a limited purpose, such as for tax reporting relating to a payment for a customer referral or to facilitate an international money transfer. 

2.1.2. Information we collect automatically when you visit our websites. We and our third-party partners, such as our server providers and analytics partners, collect information about your visits to our websites and your interactions with our ads or content, together with information such as your internet service provider and IP address, cookies, and other tracking technologies (e.g., web beacons, device identifiers, and pixels). 

2.1.3. Information about our customers’ users. Our customers and other third parties may also provide us with personal information about our customers’ users and others. For example, we may receive personal information and other information from our customers, message senders, mobile network operators, databases with information relevant to mobile telephone numbers submitted to or identified by our services, and other third parties. This information may include, without limitation, telephone numbers, telephone numbers’ validity, type (e.g., mobile, landline, etc.), corresponding device status (e.g., whether or not it is currently available for messaging), roaming status, carrier, country of location, and whether or not the number has been ported and is used to help us provide our services.

2.1.4. Information collected in connection with your use of services delivered via our platform. We and our service providers may collect information in connection with your use of communications services delivered via our platform. 

2.1.5. Communications usage information. This includes information about your communications delivered via our platform such as the time and duration of usage, source and destination identifiers, completion status, location, IP address, and amount of usage.

2.1.6. Device information.  Our platform may collect information regarding your device(s) in order to provide you with access to and the ability to use our services in. This may include, for example, your hardware model, operating system version, firmware, browser information, device and network configuration, device identifier, IP address, device performance, signal strength, call quality, telemetry, and mobile or wireless network information. We use the device information we collect in order to deliver and improve our services.

2.1.7. Your contact lists and address book. Our platform requests your permission to access and store the contact list or address book maintained on your mobile phone, tablet, or other broadband-connected device.  Your contact list is considered your personal data. We may use your contact list information to facilitate our services in identifying and preventing spam or robo calls. We will not use your contact list information for other purposes without first notifying you of the proposed use. You do not have to allow us to access your contact list information, but if you do not, certain features of our mobile apps will not be available to you. You may at any time opt out from allowing this access via the privacy settings on your device.

3. Why We Collect Your Information And How We Use It.

3.1. We developed our services with the intent to assist you in eliminating unwanted spam and robo calls. Accordingly, we use the information you provide or our application collects as follows:

3.1.1. To deliver our services. We use your information because it is necessary to perform our obligations in delivering our services to our customers. This includes identifying possible spam or robo calls to your device, processing transactions with you (such as billing), authenticating you when you log into our platform, providing customer support, and operating and maintaining our services. We also need your information to communicate with you about the services, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, administrative messages, and other communications necessary to usage of the services.

3.1.2. To carry out core activities relating to our services. To effectively deliver our services to you, we use your information to engage in important supporting activities such as:

a. billing and collections, including maintenance of records in the event of a subsequent billing dispute;

b. troubleshooting, quality control, and analytics; and

c. monitoring the performance of our systems and platform.

3.1.3. For research and development. We are constantly looking for ways to improve our services, to make them more reliable, secure, and useful to you and our users.  We use data regarding our users’ communications on our platform to understand how our services are performing and how they are being used in order to identify areas where we can do better. For instance, we may use message delivery and call connection information to evaluate whether our platform is performing as intended. We and our service providers may use your information to assess the level of interest in, and use of, our services, our communications to our customers, and our other messaging campaigns, both on an individual basis and in the aggregate. We also use information about your use of our websites to understand how our website visitors are using our websites.  Among other things, this usage information, along with tracking technologies, enables third-party analytics companies, such as Google Analytics, to generate analytics reports on the usage of our services. To opt out of your usage information being included in our Google Analytics reports, you may follow these instructions.

3.1.4. To comply with legal requirements.Applicable laws or regulations may require our processing of your data, such as laws mandating retention of communications data. 

3.1.5. To protect our legitimate business interests and legal rights. Where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business. 

3.1.6. According to your explicit consent.If we wish to use your information for certain purposes which require consent under applicable law, we will first seek out and obtain your consent. This may include, for example, testimonials or case studies that identify you in your individual capacity.

4. Special terms regarding European Economic Area users and our “lawful bases” for using their data.

4.1. EEA Data Laws. European data protection law requires organizations like us to provide a lawful basis to collect and use your information. Our lawful basis to collect and use information from our EEA users include when:

4.1.1. We need it in order to provide you with the services and to carry out the core activities related to our provision of the services.

4.1.2. We need to comply with a legal obligation. 

4.1.3. We have a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests.

4.1.4. You give us your consent to do so for a specific purpose.

5. Who We Share Your Information With And Why.

5.1. We may share your information as detailed below:

5.1.1. Third-party service providers that help us to deliver the services and allow us to operate our businesses. We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you.  We only work with carefully selected vendors, and we require any vendors with whom we share personal data to protect the confidentiality of such information and use it solely for the purposes for which it was shared.

a. Azure: We use Microsoft’s AZURE cloud platform to store and process data collected from or submitted by you.  

b. Twilio: We use third party software from a company called Twillio to send some of our text notifications and call processing functions.  

c. Firebase: We use third party software from a company called Firebase for cloud-based messaging and providing notifications to you. 

5.1.2. Third party websites. Our services and websites may include links that direct you to other websites or services whose privacy practices may differ from ours.  If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one.  We encourage you to carefully read the privacy policy of any website you visit.

5.1.3. Compliance with law enforcement requests and applicable laws; enforcement of our rights.  We may disclose personal data as required by applicable law, regulation, legal process or government request; to protect our company, our services, our customers or the public from harm or illegal activities; and to enforce our agreements, policies and service terms.

5.1.4. With your explicit consent. We share information about you with third parties when you give us consent to do so.  For example, we may display use cases or testimonials of satisfied customers on our public websites and require your consent to identify you in your individual capacity.  If you are a business customer, and have requested this, your business name and phone number may be included in public directories. 

5.1.5. Our affiliates; business transactions.We share your information with and among our corporate affiliates in order to operate and improve the services we provide to you; and we may share your information in connection with a sale, merger, liquidation, or reorganization of our business or assets.

6. How We Protect Your Information.

6.1. We have implemented administrative, physical, and technical safeguards to help protect the personal data that we transmit and maintain.  However, no system or service can provide a 100% guarantee of security, especially a service that relies upon the public internet. Therefore, you acknowledge the risk that third parties may gain unauthorized access to your information. Keep your account password secret and please let us know immediately if you think your password was compromised. Remember, you are responsible for any activity under your account using your account password or other credentials.

7. Where we store your information and international transfers.

7.1. Personal information that we collect is stored on and processed on computers situated in the United States. Specifically, we use Microsoft’s AZURE cloud platform to store and process data.  

7.2. If you are an EEA resident, be aware that your personal data is transferred to and stored in the United States, which is a outside the EEA and is not be subject to equivalent data protection laws.  When you sign up for our service or inquire about our services, we transfer your information to the United States as necessary to perform our agreement with you or to respond to an inquiry you make.  It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers. 

7.3. Accordingly, by using our services, you authorize the transfer of your information to the United States, where we are based, and to the locations where our service providers operate, and to their storage and use of your information as specified in this Privacy Policy and any applicable terms of service or other agreement between you and Robo Terminator.  In some cases, we may seek specific consent for the use or transfer of your information overseas at the time of collection.  If you do not consent, we may be unable to provide you with the services you requested. The United States and other countries where we operate may not have protections for personal information equivalent to those in your home country.

7.4. Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this Privacy Policy. 

8. How Long We Store Your Information.

8.1. In General. We store your information for the lifetime of our data servers or until it is no longer necessary to provide the services or otherwise relevant for the purposes for which it was collected.  This time period may vary depending on the type of information and the services used, as detailed below. After such time, we will, in our discretion, either delete or anonymize your information or securely store your information and isolate it from any further use until deletion is possible.  We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. 

8.2. Customer account information. We store your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services. 

8.3. Communications usage information. While you’re an active customer, we retain the communications usage information generated by your use of the services until the information is no longer necessary to provide our services, and for a reasonable time thereafter as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services.

8.4. Marketing information, cookies and web beacons. If you have elected to receive marketing e-mails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an e-mail from us or visited our websites. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.   

8.5. Device information. We collect device-specific information from you when access our services. This may include, for example, your hardware model, operating system version, firmware, browser information, device and network configuration, device identifier, IP address, device performance, signal strength, call quality, telemetry, and mobile or wireless network information. 

9. How To Access And Control Your Information.

9.1. Access to your account information. Consistent with applicable laws and data security requirements, we will reasonably honor written requests from you to access or amend your account information, such as name, address, and billing information.  You are responsible for ensuring that your information on file with us is current and accurate.  You may access and update your account information by logging into your account or contacting us as described in this Privacy Policy. Where permitted by law, we may charge a reasonable fee to process requests for access to data and may limit the number of requests per year.  Your right to amend your information is subject to our records retention policies.

9.2. Withdrawing your consent. Where the processing of your personal data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.

9.3. Concerns or questions. If you have any concerns or complaints regarding the treatment of your personal data by us, or you believe we have breached any privacy law in relation to your personal data, please contact us. We will treat any concerns or complaints confidentially. We will promptly investigate any concern or complaint that you raise with us.

9.4. Contact us. You can exercise the rights listed above at any time by contacting us and if you feel that your request or concern has not been satisfactorily resolved, or our response is not provided within a reasonable time, you may approach your local data protection authority.

9.5. Your Rights as a California Resident. This section applies only to California consumers. It describes how we collect, use, and share California consumers’ personal information in our role as a business, and the rights applicable to such residents. For purposes of this section "personal information" has the meaning given in the California Consumer Privacy Act (“CCPA”).  We does not sell your personal information or your end users’ personal information.

9.5.1. Purposes for collection. We process your personal information only in order to provide the services and we do not retain, use, or disclose your personal information outside of the scope of the agreement we have with you. The business and commercial purposes for which we collect personal information are described in the section of this Privacy Policy entitled “Why we collect your information and how we use it”. The categories of third parties to whom we “disclose” this information for a business purpose are described in the section of this Privacy Policy entitled “Who we share your data with and why”. 

9.5.2. Your Specific Rights. You have certain rights regarding the personal information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

a. The right of access means that you have the right to request that we disclose what personal information we have collected, used and disclosed about you in the past 12 months. 

b. The right of deletion means that you have the right to request that we delete personal information collected or maintained by us, subject to certain exceptions. 

c. The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights. 

d. We do not sell personal information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199).

9.5.3. How we collect, use, and share your personal information. We have collected the following statutory categories of personal information in the past twelve (12) months:

a. Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources. 

b. Information collected in connection with your use of our services, including communications usage information and the communications content processed through the services.

c. Internet or network information, such as browsing and search history. We collect this information directly from your device.

d. Geolocation data, such as IP address. We collect this information from your device.

e. Financial information, such as payment details or financial account numbers in the process of providing you with our services. We collect this information from you. 

f. Inferences based on your use of the services and browsing history.

g. Other personal information, in instances when you interact with us online, by phone or e-mail in the context of receiving support from our sales and customer service teams

9.5.4. How to Exercise your California Rights. You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your personal information. 

10. Other Important Information.

10.1. Information from children. We do not sell products or services intended for purchase by children and we do not knowingly solicit or collect personal data from children or teenagers under the age of eighteen. If you believe that a minor has disclosed personal data to us, please contact us.

10.2. Changes to this policy. In the event we make changes to this Privacy Policy, we’ll let you know by posting a notice on our website and in relation to substantive changes that broaden the types of personal data collected or their usage, we will notify you via SMS, e-mail to the e-mail address associated with your account, via our platform or websites, or by some other means. 

11. How To Contact Us.

11.1. If you have questions or complaints about our privacy practices, this privacy policy, or any other aspect of our services contact us at info@theroboterminator.com.

12. Cookies and Tracking Notice.

12.1. What are cookies? A cookie is a small text file that a website saves on your computer or mobile device in order to facilitate and enhance your interaction with that service. 

12.2. Why we use them. We or our service providers may use cookies and equivalent technologies such as clear gifs, web beacons, pixel tags, Javascript, device fingerprinting, and third-party cookies on our website and, where relevant, in our promotional e-mails. They also help us track users, conduct research, allow you to back click to earlier registration pages viewed by you and improve our content and services. For instance, we may use web beacons on our websites to access and set cookies and otherwise help us to better understand how users are moving through our websites. Information provided by the web beacon includes the computer’s IP address, the type of browser being used and the time that the web beacon was viewed. We may also use web beacons in e-mails and newsletters so that we know when such communications have been opened and to otherwise help us tailor our communications to individual users.

12.2.1. When it’s strictly necessary. These cookies and other technologies enable us to recognize you when you return to our service and to maintain your web session so you can more easily navigate the subscription process or your viewing of your call details. They are also essential for you to access secure areas of our sites, for example, to use shopping baskets or make payments.

12.2.2. For performance and analytics. These cookies and similar technologies collect statistical information about how you use our websites so that we can improve your user experience. We use cookies to identify the number of unique visitors we receive to different parts of the website and identify where leads originate. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.

12.2.3. To enable functionality. These cookies and similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our sites more easily. They also enable customization of the layout and/or content of the pages on our sites.

12.2.4. Twilio: We use third party software from a company called Twillio to send some of our text notifications and call processing functions.  

12.2.5. Firebase: We use third party software from a company called Firebase for cloud-based messaging and providing notifications to you. 

12.3. How to control cookies. You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the services. Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the site.