Privacy Policy

Last modified: January 2023

Interest based advertising: to learn more about data disclosure click here
Opt-out options: DO NOT USE MY DATA

I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)

BP Mobile LLC (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you install and/or use “Second Phone Number - 2Number” software application for mobile devices (the “App”, “our App”).

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

Our Privacy policy applies to all users, and others who access the App (“Users”).

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request:

- the categories of personal information that is processed;

- the categories of sources from which personal information is obtained;

- the purpose for processing of user personal data;

- the categories of third parties with whom we may share your personal information;

- the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

Please use the navigation links through this Privacy Policy:

PERSONAL INFORMATION

All about the categories of information, its sources and purposes of processing >>

Please mind that according to CCPA personal information does not include de-identified or aggregated consumer information.

SHARING

How your information can be shared >>

Please note that all third parties that are engaged in processing user data are service providers that  use such information on the basis of agreement and pursuant to business purpose. 

OPT-OUT OPTIONS

If you don’t want us to process your personal information any more please contact us through the contact form. In most cases there is no way to maintain the App’s further operating without functional data therefore you will be advised to remove the App from your device. 

If you don’t want us to share device identifiers and geolocation data with service providers please check your device settings to opt out as described below >>

REQUESTS

To submit a verifiable consumer request for access, portability or deletion of personal data please contact us through the contact form. Please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California”.

When submitting a verifiable request, you should be ready to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.  

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

EQUAL RIGHTS

Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or different level or quality of services for you, if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.

SALE OF DATA

We do not sell any of your personal data to third parties.

II. INFORMATION WE PROCESS

There are several categories of information that can be processed.

Information that you submit 

We ask for and collect the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.

• Authorization and/or Account Information: email and other data (name, address) that is needed for compliance with applicable local laws. Please mind that in some countries due to specific local regulation, addresses are validated to ensure the integrity and accuracy of the data provided.
• Activity Information, e.g. your contacts created through the App, call logs and recordings of calls, logs and records of text messages, origination and termination points (i.e. to/from numbers), history of incoming and outgoing calls performed and the content of messages sent/received with the help of the App, the list of second phone numbers you ever used through the App. Upon your consent we also may have technical access to the microphone and contact list on your device.

Note that if you use a call recording feature within the App it is your sole responsibility to warn your dialog partner that you are going to record a call. Otherwise you cannot use the App. For more information about the rules you must follow when you record any call using the App please check subsection “Specific requirements and legal considerations concerning call recording feature” in Section VII of our Terms of Use.

We process this information by ourselves. However, we may also engage  third party - Twilio Inc. - for storing this personal data in order to fulfill obligations and deliver the full scope of services. This personal data can be deleted either by this third party in accordance with our instructions or by our own means.

• Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, support form. We collect, store and process it by our cloud storage provider (Amazon.com, Inc.). We  use  such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request and perform the requested services.

Information That Is Processed Automatically 

On the basis of your permission we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our App (Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices). Some integrated advertising or analytics tools (check Section IV to see the list of them) launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically once you allow our App to track your activity. You can withdraw your permission at any time - please check opt-out options in Section VIII below.

We may process some information about your device and your user behavior on the ground of our legitimate interest. This information falls within categories of data described above in Subsection “Information That Is Processed Automatically”, it is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We use this information for improving our App and giving our users the best experience

• Device Details. When you use a mobile device (tablet / phone / smartwatch) to access our App, some details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.

What data can be processed:

• Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.
• Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser. 
• Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. “coffee shop”).
• Other device identifiers: e.g. user identifiers (if they are set up by the App’s developer).

• Information about the applications. Name, API key (identifier for application), version,  properties of our App can be reported for automated processing and analysis. Some services also record the list of applications and/or processes which are installed or run on your device.
• Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
• Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.
• Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad. 
• In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).

Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that was already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).

Payment Information

Our e-commerce provider (Apple) is responsible for billing, processing and charging for in-app purchases, handles your personal information and keeps it absolutely safe and secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information. You may access the applicable “in-app” purchase rules and policies directly from the app stores.

The processing of payment information related to eSIM data plans.

If you choose to purchase eSIM data plan(s) available within the App, the payment transaction(s) will be processed via Stripe payment system. Hence, some categories of your personal data (including transaction data) are collected, retained and processed by Stripe payment service provider in accordance with its privacy policy (see https://stripe.com/privacy for more details). Stripe uses this information to operate and improve the payment processing, analytics services it provides to us, including for fraud detection and prevention. We also strongly recommend you to visit Stripe Privacy Center to learn about which Stripe entities are involved in data processing and in what capacity, about the list of third parties with whom Stripe can share your personal data, about legal bases for data processing, international data transfers, rights and choices you may have regarding your personal data as well as about other issues regarding data processing via Stripe.

MESSAGING POLICY AND SMS/MMS PRIVACY STATEMENT

Text (SMS) messages that you can receive from us. We may use phone numbers that you got via the App to contact you with text (SMS) messages. By using the App, you acknowledge and agree that we may send you the following types of text messages:

- Operational messages. You understand and agree that you may receive text messages concerning the status of phone numbers you got via the App, credits you bought to make calls as well as other aspects regarding your phone numbers and operation of the App. We send you such messages for the purposes of providing the services available through the App and communicating with you. Your failure to receive operational messages will significantly impede your further use of the App.

- Messages with invitation to user interview. We are constantly striving to get effective user feedback for the purposes of improving the quality of our App and enhancing user experience. Therefore, you may be asked to provide direct feedback regarding our App by participating in the interview. We may send you relevant text messages with invitation to such user interviews. Specific conditions of participation in user interview (including information on the method of expressing user consent to be interviewed, as well as information about possible bonuses, incentives for participating) will be indicated in the corresponding message that you receive. Note that your decision to participate or not participate in a user interview is completely voluntary, the consent to participate in user interview is not a condition for using the App. If you are uncomfortable with receiving messages with offers to participate in user interview you can opt out at any time by sending us relevant request via support form.

Message content collection and monitoring. As it is indicated above, we engage Twilio Inc. that acts as a data processor on our behalf in order to be able to provide you with messaging services within the App. Sending messages (SMS, MMS, Chat, WhatsApp messages) using our App and Twilio’s platform can be possible only when all applicable policies, regulations and laws are properly observed. Therefore, while sending messages using the phone numbers and other services available within the App you agree to be bound by and comply with the following requirements:

• It is strictly prohibited to use the App for sending messages with the content that is illegal, harmful, unwanted, inappropriate, objectionable, confirmed to be criminal misinformation, or otherwise poses threat to the public, or that violates any law and/or regulation in the country where the message recipient lives (e.g. messages related to cannabis, offers for prescription medication that cannot legally be sold over-the-counter, messages containing hate speech, malicious content, etc.). It is also prohibited to send messages related to high-risk financial services, third-party lead generation services (companies that buy, sell, or share consumer information), “get rich quick” schemes, debt collection or forgiveness, gambling, as well as messages containing "S.H.A.F.T." (sex, hate, alcohol, firearms, tobacco) use cases. The specified list of prohibited content is not exhaustive, messages containing these categories of content cannot be sent via the App, shall be identified and blocked by appropriate unwanted message detection and prevention mechanisms regardless of the fact whether or not you get consent from message recipients for such content. To learn more information about prohibited categories of content and communications please review Twilio Acceptable Use Policy as well as Twilio Messaging Policy. You undertake to comply with all requirements contained in the specified documents while using the App.
• When you use the App to send messages, you also agree to take into account and comply with the requirements regarding the recipient’s consent to receive messages from you (including possible forms, scenarios of obtaining such consent), opt-out mechanisms, as well as with sender identification requirements. Please review Twilio Messaging Policy carefully to learn more details.

Content verification for US/Canadian destination numbers. Please note that all content of messages that you send and/or transmit via the App to United States and Canadian numbers is subject to monitoring and verification process by Twilio Inc. Particularly, Twilio proactively identifies and does not accept the messages in violation of the Twilio Acceptable Use Policy. The messages that are proactively identified as messages in violation of Twilio Acceptable Use Policy will be returned as an error prior to reaching carrier networks. Moreover, in the event that your message(s) violates Twilio Acceptable Use Policy or other applicable regulations your access to the App and/or to messaging services available within the App may be suspended or terminated. Taking into account the foregoing, you hereby provide us and Twilio Inc. with your relevant permission for collecting, processing, storing and monitoring the content of all messages you send using the App for the purpose of detecting spam, fraudulent activity, and violations of Twilio Acceptable Use Policy.

Your failure to provide relevant permissions and comply with the requirements stated above means that you cannot use the messaging services available via the App.

This MESSAGING POLICY AND SMS/MMS PRIVACY STATEMENT are incorporated into the present Privacy policy and constitute its integral part. By accepting the Privacy policy containing this MESSAGING POLICY AND SMS/MMS PRIVACY STATEMENT you hereby express you consent and give all appropriate permissions and authorizations regarding data processing, storage and sharing, the applicable procedures for sending messages and message content monitoring, as well as other issues reflected herein.

Data processing related to eSIM data plans available within the App

The App offers you eSIM data plans that rely on the technology from Flexiroam. When you purchase, activate and/or use eSIM data plan(s) available within the App we may access some categories of information related to such data plan(s). In particular, we may process the information about your email address as it may be necessary for activation of your data plan. In addition, we may access information related to the status of your eSIM data plan. This may include information about activation as well as about traffic data, the amount of data that has been received and/or sent by you. We access such information solely in order to keep you updated on the status of the data plan you’ve purchased. As we partner with Flexiroam and make corresponding call orders via Flexiroam’s API while providing you with eSIM data plans, we also strongly recommend you to review Flexiroam Privacy Policy (https://www.flexiroam.com/privacy-policy/) to learn more details about data processing in relation to your use of eSIM data plans, as well as about the rights and choices you have regarding such data.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a)  To make our service available. We use information that you submit and information that is processed automatically to provide you with all requested services.

(b)  To improve, test and monitor the effectiveness of our App. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

(c)  To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.

(d)  To communicate with you. We use the contact information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

(e)  To prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy. We adhere to the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment.

Please note that while integrating external services we choose third parties that can assure they apply all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our services:

In case you want to learn more about the services and privacy options (including opt-out) please consult the correspondent websites and privacy policies.

Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

- as required by law;

- when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

- if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. Note that some categories of your information (i. e. data about transactions and purchases made in the App, information about email associated with your account, technical data such as blacklisting information) may be retained even after deletion of your account and/or removal of the App from your device. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) and/or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

VII. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct change, update or rectify your data.
• Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

To exercise any of the rights described above, you can contact us through contact form. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.

When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

If you are located in the European Union, you may address our representative when you have questions on privacy issues:

Albina Gulevich Apolskaya, Office: 35, 205 Holland Park Avenue, W11 4XB, London, e-mail: user.data.protection @ gmail.com

VIII. HOW TO OPT OUT

Opt-out of marketing tracking

If you don’t want third-party service providers to use the personalized ads on the basis of your interests please follow the instructions below:

• Choose option "Limit Ad Tracking" on your iOs device in Settings/ Privacy/ Advertising, please find additional information here: https://support.apple.com/en-us/HT202074;

You can also visit https://youradchoices.com for the same purpose.

Please mind when you opt out of certain interest based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

Opt-out of Location Data Processing

If you don’t want third-party service providers to use your precise location data, or street-level location information about you please follow the instructions below:

• iOS 11 or later: turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services”. Then select the applicable App and set the “Share My Location” status to “Never”. Please see additional information here: https://support.apple.com/en-us/HT203033.

IХ. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through the contact form displayed below.

X. CHILDREN’S PRIVACY

Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under age 18 may provide any personal information to the App. If you are under 18, do not use or provide any information on this App or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

XI. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.

Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

XII. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us via support form.