Privacy & Policy - PhoneDo

Last Updated on May 1, 2020
R. Phonedo Call Centers Ltd., a private limited company based in Jerusalem, owns and manages a web application, mobile application or application on other platforms and devices entitled Phonedo (collectively referred to as the “App”). The App connects users, namely businesses to freelancers, and allows businesses to purchase translation services from freelancers.
The present Privacy Policy (the “Privacy Policy”) sets forth the terms and policy concerning the usage, handling and collection of personal information from and through the App. All personal data provided by way of the App shall be handled, stored and used in accordance with this Privacy Policy.
This Privacy Policy has been prepared in accordance with applicable privacy legislation, including but not limited to the General Data Protection Regulation (the “GDPR”).

1. DEFINITIONS
This Privacy Policy may be read in combination with the latest version of the App’s Terms and Conditions, which is also published on the App for review. The defined terms in this Privacy Policy correspond to the defined terms in the App’s Terms and Conditions, and are as follows:

“Business”
shall refer to any business, organization or entity that uses the App to place Requests and to obtain Services offered by Freelancers.

“Company”
shall refer to R. Phonedo Call Centers Ltd., a limited company having its registered offices located at 3 Bruchim Street Jerusalem 9530803 Israel. The Company may also be referred to as “we”, “us”, “our”, and other similar expressions.

“Freelancer”
shall refer to any freelancer, agent or service provider using the App to offer and provide Services.

“Request”
shall refer to any request for specific Services placed by the Business through the App. The Request shall be placed according to the instructions detailed on the App and the purpose of the Request shall be to obtain Services from a qualified Freelancer.

“Services”
shall refer to the services offered by Freelancers on the App. The Services shall include, without limitation, human phone answering services, sales support, and live translations in a variety of languages.

“Privacy Policy”
shall refer to the latest applicable version of the present Privacy Policy and includes any and all amendments and supplements made hereto from time to time.

“Users”
shall refer to all users of the App, including the Businesses and the Freelancers. Users may also be referred to as “you”, “your” and other similar expressions in this Privacy Policy.

2. APPLICABILITY
Any submission or provision of personal information on or though the App will be handled and governed in accordance with this Privacy Policy. Any information collected by the Company as a result of the App shall also be governed by the terms of this Privacy Policy.
Upon downloading, accessing or otherwise using the App, you shall be deemed to have accepted the terms of this Privacy Policy, in full. As such, any usage of the App signifies your acceptance of this Privacy Policy.

3. MODIFICATIONS TO THE PRIVACY POLICY
The Company may modify this Privacy Policy at any time, at its discretion. The modified Privacy Policy will be published on the App.
The modified Privacy Policy will be applicable to information collected on and through the App as of the date its publication on the App. The date of the latest revision of this Privacy Policy shall be published for reference purposes.

4. APPLICABLE LEGISLATION
This Privacy Policy has been prepared and implemented in accordance with terms of the General Data Protection Regulation 2016/679 (the “GDPR”).
The GDPR was enacted in April 2016, and came into force as of May 2018. The GDPR is applicable to residents based in both European Union (EU) and the European Economic Area (EEA). This legislation governs the collection, usage and transfer of personal data. One of the main purposes of the GDPR is to provide individuals with information regarding the usage, collection and handling of their personal data, in turn, allowing for greater control and data management.

5. PERSONAL DATA
Personal data is information regarding an identifiable individual, also known as a natural person. Personal data includes, without limitation, your name, address, credit card number, and other information regarding a specific individual.
The GDPR defines personal data as follows: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. This definition of Personal data has been reproduced above in italics from the GDPR and is for information purposes.
In accordance with the requirements of the GDPR, we shall only collect personal data that is provided voluntarily by you on the App. We shall handle and manage such information in accordance with the terms of this Privacy Policy.

6. PROVIDING PERSONAL DATA AND INFORMATION
There is no requirement to provide personal data or information to the Company upon downloading the App.
To benefit from Services offered on or by the App, it may be necessary for you to provide us with personal information. To create a user account on the App, you will be required to submit some personal information. More specifically, to make purchase Services, or to offer Services on the App, you may also be required to provide personal data and information.
You are not required to provide personal information to us, however, please keep in mind that you will not be able to provide Services or purchase Services if you have not provided the necessary personal information.
We will only collect personal data and information that you provide voluntarily on the App. You understand that we may be able to collect information that is not personal to you, such as preferences, browsing history or other information that is tracked by way of cookies, or though other means. This type of information will not allow for your personal identification.
Moreover, when you engage in discussions, phone calls, or Services with other Users on the App, you acknowledge that we will be granted unrestricted access to the content of the discussions, phone calls and Services. We will use this content to assess the Services, for internal compliance and to ensure there is no fraud on the App. The reasons for which we collect information are further detailed in this Privacy Policy

7. DATA COLLECTION AND PERMITTED DISCLOSURES
We hereby confirm that the collection and handling of personal data will be fully compliant with applicable laws and regulations applicable to the collection, safeguard, handling and protection of personal data. To ensure that personal information obtained from the App is thoroughly protected and safeguarded, we established appropriate measures and procedures. These measures and procedures are destined to protect the personal data you provide to us on or through the App.
All personal data you provide shall be subject to the procedures and measures we established. As such, we shall not share, transmit or otherwise disclose personal data to our employees, directors and affiliates unless they have a compelling and justified need to know such information.
If such cases, the disclosure of the personal information shall be limited to the information strictly required for purposes of the App. The disclosure of personal data shall further be limited for a specific predetermined purpose, and for no other purpose. Further, we shall ensure that any third party who is granted access to personal data complies with the confidentiality obligations contained in this Privacy Policy.

8. PERSONAL DATA USAGE
We shall use the personal data you provide on the App to fulfill the purpose for which you provided the information and according to this Privacy Policy. The usage of the personal information shall be limited to the extent required by our legitimate business interests, and based on the requirements of the GDPR.
We shall be authorized to use the personal data you provide to fulfill the following general purposes:
– to fulfill the purpose of the App;
– to allow you to offer and provide Services on the App;
– to allow you to purchase Services and submit Requests to secure a Freelancer;
– to respond to a valid court, government directive or applicable legislation;
– if the usage of the personal information relates to the public domain or is of public interest;
– to respond to a Request submitted in the manner and to the extent explicitly authorized by the User providing such personal information;
– in accordance with your explicit consent for a predetermined purpose.
By providing personal information through the App, you acknowledge and agree that we may use your personal information in the accordance with the following specific purposes:
– to provide recommendations, options and corresponding information on the App;
– to offer promotions with respect to the Services or to the App;
– to inform you of Services or products that may be of interest;
– to communicate with you regarding the Services, opportunities, issues, Requests, and other matters relating to the App;
– to respond to questions, information requests, inquiries and all other claims transmitted in connection with the App;
– to assess the App’s features, compatibility, preferences, and suitability;
– to assess and improve the Services, and other features offered on the App;
– to control the effectiveness of the Services, to perform spot checks, and to assess suitability;
– to retain copies of conversations, phone calls and discussions held through the App for quality control and archiving purposes;
– to ensure compliance with court orders and applicable legal provisions.
In accordance with the data minimization obligation set forth in the GDPR, we undertake to limit all usage of your personal information to that which is strictly necessary to satisfy the purpose of the data usage. We will not use the personal data in a way that is unreasonable or excessive to fulfill the purpose of its collection and usage, however, we do reserve the right to share information with selected third parties in furtherance of the App, its development or for any reason deemed appropriate by us, at our discretion.

9. NOTIFICATIONS
You have the right to send us a request to unsubscribe or no longer receive written communications or notices in connection with the App. This request may be sent by email or by adjusting settings on the App.
You may also disable email notifications from us by changing the settings in your user account and on the App, following the instructions applicable to unsubscribing from email notifications.

10. COURT ORDERS AND LAWFUL DISCLOSURES
As mentioned in this Privacy Policy, we shall be authorized to communicate and disclose personal information if required to do so under a valid court order or by a legal obligation.
We shall communicate and disclose all necessary personal data to ensure compliance with applicable laws and regulations. In such cases, we may disclose the personal data without informing you prior to the disclosure. Any disclosure of personal information pursuant to a court order or legal obligation shall be limited to the personal data directly relevant to the legal obligation, and shall not require your prior consent.
We agree communicate and disclose personal information further to a valid court order. Such personal data shall be disclosed in accordance with the instructions set forth in the court order. Insofar as reasonably practicable, we shall notify you upon our receipt of the court order and corresponding obligation to disclose. If you are notified in advance, this shall allow you to seek a protective order or other legal remedy to maintain such information in confidence.

11. STORAGE AND VERIFICATIONS
The personal data collected on the App shall be held and stored in our files and/or servers. We undertake to verify and ensure that the personal data held in our files is correct, accurate and updated.
We will correct or delete any personal information that is false, incomplete, unusable or otherwise inaccurate. You can send us a notification to request for the correction, deletion or destruction of your personal data if it is incorrect, incomplete, unusable or otherwise inaccurate.
Your personal information will remain in our servers for the duration that is necessary based on the purpose, the applicable legislation and the authorization you provided, if applicable. We may hold your personal data for a longer period if it is preferable to do so due to public interest or for reasons exceeding our control, such as government orders or valid third party requests.
We shall not store personal data on file for an excessive or unreasonable duration.

12. CONFIDENTIALITY OF PERSONAL DATA
We shall apply and enforce all necessary measures to protect the confidentiality of your personal data. As such, we shall not disclose your personal information to any third party, except in accordance with this Privacy Policy.
We shall apply all reasonable measures to protect your personal data from unauthorized disclosure, damages or other breaches. These confidentiality obligations shall apply, regardless of whether your personal information is stored or currently used for purposes of the App.

13. USER RIGHTS
We shall grant you the rights provided to personal data providers under the GDPR. If you submit personal data on the App, you will be permitted to exercise rights in connection to the personal data submitted.
You have the right to access the personal data you submitted on the App. To gain access to the personal data submitted, please send us a request. Your request should contain the extent of the personal data requested and the timeframe for which the request applies. We will carefully review your request and we will submit the information requested, if reasonable to do so.
You further have the right to obtain information regarding our usage of your personal data. While our usage of your personal data will comply with the terms of this Privacy Policy, you may request further explanations or details. If you wish to exercise this right, please submit a request to our attention.
As specified in this Privacy Policy, you can request for us to correct and rectify any incorrect, erroneous, unusable or otherwise false personal data. Upon our receipt of your request, we will investigate this matter. If the information is indeed incorrect or false, we will promptly correct or delete the problematic information from your file.
If you would like for your personal data to be deleted from our servers, please send us a request. We will agree to remove your personal data from our servers if reasonable to do so.
We may also delete personal information from our servers if we consider such information to be unnecessary, damageable or otherwise problematic.

14. EXPLICIT CONSENTS
You may provide us with an explicit consent to use your personal data for a purpose that is not specified in this Privacy Policy. Your explicit consent must be provided in writing and must state the reasons for which you would like your personal data used. Your explicit consent must be validly transmitted to us through the App or by email.
We shall then be authorized to use your personal data for the purpose detailed in your explicit consent. If there is no time limit indicated in your consent, we will consider that such consent is for an unlimited duration.

15. APP AS AN INTERMEDIARY
The App operates as an intermediary between Users, allowing for the provision and purchase of Services. You acknowledge that we have certain contractual obligations with respect to the services offered on the App. As such, to process and carry out a transaction between Users, we may require a Business’ payment information. To compensate a Freelancer for the Services performed, we may need to gain access to the Freelancer’s bank account information. It may be necessary for us to collect personal information to fulfill its contractual obligations in connection with the App.

16. TRANSFERS OF DATA
We shall not transfer any personal data collected from, on or through the App outside of the European Union, except if the transfer complies with the conditions specified in the GDPR. The GDPR authorizes for data transfers beyond the European Union only with those countries that abide by strict data protection laws and regulations. The United States is deemed to comply with such data protection legislation. In consideration thereof, we may transfer your personal data to servers located in the United States.

17. COOKIES
Cookies consist of small data files installed onto your device upon the User’s visit to a particular app or website. We reserve the right to use «cookies» in connection with the App or any corresponding website.
Cookies shall allow us to identify your device, prevent hacking and unauthorized usage. Cookies shall further allows us to provide you with a customized experience on our App and corresponding websites. You may disable the usage of cookies by adjusting settings or turning the cookies option off. Some portions of the App or the corresponding website may be unusable if cookies are disabled.

18. THIRD PARTY LINKS
The present Privacy Policy is applicable solely to the App, and does not apply to any third party links, ads, websites or applications. The App may provide links or reference to such third party links, ads, websites or applications. The links provided are for reference and information purposes only, and do not bind or otherwise implicate us.
We shall not be responsible for the usage and collection of personal data by third party websites or applications.

19. QUESTIONS
If you have any questions regarding this Privacy Policy, please submit them to our attention by email or on the App. We will do our best to respond quickly and thoroughly.