Terms of Service | Privacy Policy | Cookie Policy | California Privacy Rights

Privacy Policy

Last Updated: 31st of December 2019

 

Privacy Policy 

We at 24apps, GmbH (“24apps”, “we”, “us”, or “our”) have created this Privacy Policy to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business. This Privacy Policy describes the practices concerning the information collected by 24apps, through the use of our website and mobile applications on which this Privacy Policy is posted. 

This Privacy Policy applies to our website and mobile application and other online services we may provide on which this Privacy Policy is posted, and our collection of information from our corresponding social media features and pages (each a “Service” and collectively, the “Services”). In addition to describing how we collect, use, disclose and otherwise process personal information, this Privacy Policy explains the rights and choices available to individuals with respect to their personal information.

We may provide additional privacy notices to you at the time we collect your data. This type of an “in-time” notice will govern how we may process the information you provide at that time.  

Click on the links below to jump directly to sections of the Privacy Policy:

  1. Information We Collect

  2. Sources of Information and their Purposes of Use

  3. How We May Use Your Personal Information  

  4. How We May Share Information about You with Others

  5. Do Not Track Disclosures

  6. Social Media 

  7. Information for Individuals in the European Economic Area 

  8. Information for Residents of California: Your California Privacy Rights

  9. Online Privacy Choices

  10. Data Retention

  11. How We Protect Personal Information

  12. Links to Websites and Third-Party Content

  13. Information Relating to Children

  14. Updates to Our Privacy Policy

  15. How to Contact Us

  16. Call Recorder 24 App

 

 

It goes without saying, we can't help you have an awesome user experience without some information about you, such as your IP Address which is technically required to offer you our VPN24 app. The IP-Address is only used for initiating the connection and protecting our servers from malicious behavior against our infrastructure, we don’t use it for any other purpose. We also collect information generated as you use our services, like when you downloaded our apps from a certain advertising campaign of ours. If you want additional info, we go into more detail below.

The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the “GDPR”).  Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction. 

 

Category

Specific Examples

A. Identifiers

unique personal identifier (UUID, Advertising ID, IDFA), IP address,  or other similar identifiers.

B. Personal Records 

Some personal information included in this category may overlap with other categories.

C. Internet or other similar network activity

Information on a consumer’s interaction with our website or application, but for clarity, shall not include browser history. See Information collected by Automated Means below for further details. 

 

 

Some of this information you provide to us and some we collect when you use our Services. We also may obtain information about you (including personal information) from our business partners, such as vendors, and others. 

The following are examples of the types of information you choose to give us when using our services: 

 

 

 

We collect Automated Information through the use of cookies, SDKs and other technologies. Please see our Cookies Policy for more information on cookies. On our websites we offer users the option to disable receiving certain types of cookies via our privacy preference centre; however, if cookies are disabled, some features or functionality of our websites may not function correctly. 

Automated Information includes information such as: 

 

We or our third-party service provider may assign you a unique identifier through automated means in order to match information collected from you through different means or at different times, (including both personal information and Automated Information) and to use such information as described in this Privacy Policy.

This Automated Information is generally used for the following purposes: 

We may obtain information, including personal information from third parties and sources that we integrate into our Services either for the provision of our Services or to facilitate your access to our Services such as described below: 

When you use our Services, we collect information about which features you've used, how you've used them and the devices you use to access our Services. See below for more details. 

In our VPN 24 app, we collect information from and about the device(s) you use to access our Services, including:

In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following:

We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

For clarity, VPN IP or usage data (i.e. network activity) is never shared.

We may share information about you for the purposes described in this Privacy Policy or pursuant to a specific “in-time” privacy notice we may provide at the time we collect the information. 

24apps is part of the IAC Group family of businesses. We share your information with other parts of IAC for legitimate business purposes, including:

to assist us in technical processing operations, such as data hosting and maintenance, finance, legal and accounting assistance, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings; and

for corporate audit, analysis and consolidated reporting as well as compliance with applicable laws.

 

We may share information about you with the following categories of third-party providers for a variety of business purposes:

 

We may share information about you in connection with (including during the evaluation or negotiation of) a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind-down of a business (each a “Corporate Transaction”). Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we engage in any Corporate Transaction (including, selling or transferring all or a portion of our business or assets). If we engage in such a sale or transfer, we will where feasible - direct the recipient to use the information in a manner that is consistent with this Privacy Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.

In addition, we may disclose and/or share your information to comply with legal or regulatory requirements (including to comply with a court order, judicial subpoena or other subpoena or warrant), industry standards, judicial process, and our company policies, as well as to protect against, identify, investigate, prevent and respond to fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), adverse event reporting, and claims and other liabilities.  

We also reserve the right to disclose your information (i) when we believe in good faith that disclosure is appropriate or necessary to take precautions against liability, (ii) to protect our rights or property or the legal and property rights of others and (iii) investigate and defend third party claims or allegations against us. 

In addition, we may collect, use and disclose your personal information as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.

Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our sites do not currently process or respond to "do-not-track" (DNT) settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

Certain third parties, such as ad networks, web analytics companies and social media and networking platforms, collect information about your online activities over time and across websites. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. Information about how to opt out from your data being used by third parties can be found above under " Information collected by automated means."

We maintain a presence on several social networking and blogging platforms, such as Facebook, Instagram, Google, Wordpress, LinkedIn, TikTok and Twitter. We may incorporate some third-party social networking features into our Services (including, allowing users to interact with others and share certain content and information on social media platforms) or utilize third-party provided platforms to publish or manage the Services or portions thereof. Through these platforms and features, we receive or may share information about you, and this Privacy Policy applies to that information as well. In addition, some providers of third-party social media or blogging platforms we utilize  have their own privacy policies which explain how the third parties that provide them may collect, use and protect your information (e.g., if you establish an account with such platform providers directly). By using social features, you agree to those third parties’ privacy policies and terms of use. 

If you choose to communicate with us or another user through social features available on our websites or mobile applications or through our social media pages, or other similar communication or messaging features or services, such information may be made publicly available. For security purposes, please do not include any password, social security number, payment card or other sensitive information via these features. We have the right, but not the obligation to monitor messages and communications between and among users for security and training purposes.  We may, but are not obligated to, remove any content we deem inappropriate.

As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:

If you are a resident of the EEA and you wish to access, change or delete personal information we hold about you, you may contact us here. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with our Services or some of the features and functionality of our Services. In addition, you may contact us here to request that we not disclose your personal information to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors).  Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our Service to you anymore.

For your protection, we may require proof of identity and verification before we can answer the above requests. 

In this section, we identify the legal grounds on which we rely to process personal information.

In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and Services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities; or to facilitate a Corporate Transaction (including a sale of assets or merger or acquisition).

In other cases, we process personal information to fulfill our contracts with business partners, such as third parties that distribute our products. 

It may be also necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the Services we provide.

Our processing of certain information may be necessary to comply with our legal obligations, and for reasons of public interest, such as with respect to adverse event and product safety reporting. 

We may also process personal information as specifically permitted by applicable legal requirements.  

If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information. 

We may transfer your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Policy. For example, if you are located outside of the United States, we may transfer your personal information to the United States, where IAC Group is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.  

Specifically, we may transfer personal information from the European Economic Area to:

 

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy rights regarding our use of your personal information. The CCPA Notice applies to “Consumers” as defined by the law. This section describes your CCPA rights as a California Consumer and explains how to exercise those rights.

 

Access to Information and Data Portability Rights

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

 

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.  

Data Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining.  Note also that we are not required to delete your personal information that we did not collect directly from you.  

Exercising Your Rights

To make a request for access, portability or deletion according to your rights under CCPA, click here or mail your request for the attention of the Privacy / Legal Department to 24apps, GmbH, 330 West 34th St., 5th Floor, New York, NY 10001. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). The Verifiable Consumer Request must:

 

Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID).  As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.  

 

We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests.  We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.   

 

We do not “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request.  There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your personal information as defined by the CCPA. 

 

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.  However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data.   In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels.  The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.

 

California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As discussed above, if we share Personal Information with third parties for their marketing purposes you will be able to elect for us not to do so by submitting your request here (please include your name, mailing address, and email address). 

 

To find out more about our “do not track” practices under Cal. Bus. & Prof. Code § 22575, see theDo Not Track Disclosures” section of this Privacy Policy. 

 

If you are a resident of the EEA, your rights to access, edit and delete your information can be found in the “Information for Individuals in the European Economic Area (EEA)] section of this Privacy Policy. If you are a California resident, you rights to access, edit and delete can be found in the “Information for Residents of California: Your California Privacy Rights” section of this Privacy Policy. 

If you are not a resident of the EEA or California, depending on your location, you may be able make requests to access, correct and/or delete certain personal information that you provide to 24apps.  For your protection, we may require proof and verification of identity and jurisdiction of residency before we can answer the above requests. If you wish to make such a request, you may contact us at the applicable mobile application support email. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide to you our Services or some of the features and functionality of our services. Once we have verified that you own the account, we will honor such requests at our discretion and in accordance with applicable law.    

Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

You can stop all information collection by the app by disabling call forwarding and deactivating your account by following the instructions on the Service’s Settings screen and then uninstalling the app using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by the applicable mobile application support email. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional or administrative messages from us regarding the Services.

If you choose to opt-in, some of our apps may collect your device’s precise real-time location, and in such cases, you may be able to opt out from further allowing us to have access to such location data by managing your location preferences in the app and/or on your device. 

 

Under Nevada law, Nevada residents may opt out of the “sale” of certain “covered information” (as defined under Nevada law) collected by operators of websites or online services.   We currently do not sell covered information, as “sale” is defined by Nevada law, and we do not have plans to sell this information.  However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please contact us.  You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our practices change. 

 

Our Services are hosted in the United States. If you choose to use our Services from outside the United States, with laws governing data collection and use that may differ from United States law, note that you are transferring your personal information outside of those regions to the United States for storage and processing. We may transfer your data from the United States to other countries in connection with the storage and processing of data to operate our business.  By using our Services and providing personal information, you consent to such transfer, storage and processing. If you are a resident of the EEA, you can learn more about transfers outside the EEA in the Information for Residents of the European Economic Area section of this Privacy Policy.

Except as provided below, we may retain your personal information for the longer of three (3) years after we become aware that you have ceased using our Services or for so long as necessary to fulfill any contractual obligation governing the information or our legal and regulatory obligations. However, we may not know if you have stopped using our Services so we encourage you to contact us if you are no longer using the Services. We may retain other information that is not personally identifiable for backups, archiving, prevention of fraud and abuse, analytics, or where we otherwise reasonably believe that we have a legitimate reason to do so.

We use various efforts intended to safeguard the security and integrity of personal information collected through our Services.  Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you provide information to us at your own risk.

If you correspond with us by e-mail or using Web forms available through our Services, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using our Services, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.

If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can change that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application.  You consent to our use of email, text message and/or notification through the app as a means of such notification. If you prefer for us to use the postal service to notify you in this situation, please let us know by submitting your request here. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information.

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies.  We are not responsible for the privacy practices of any entity that it does not own or control. We encourage you to review the privacy policies of such third parties before providing them with any personal information. 

We do not knowingly collect information from children under the age of 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE THE SERVICES. If you believe that we may have personal information from or about a child under the age of 16 years old, please contact us here. Note that we'll attempt to delete the account of any child under the age of 16 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.

 

We reserve the right to change this Privacy Policy at any time. When we update this Privacy Policy, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Policy. In some cases (for example, if we make certain material changes) and when required by applicable law, we may inform you by additional means, such as by sending you an email. In some cases, when required by applicable law, we may obtain your consent to the changes.

You may contact us with questions, comments, or concerns about our services and this Privacy Policy or our privacy practices, or to request access to or correction of your information by submitting your requests or inquiries as detailed below:   

For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached here.

 

If you are a resident of California, please contact us here

 

Our support team can be contacted help@24apps.co.  

 

Or 

 

24apps GmbH

Gadollaplatz 1

8010 Graz

Austria

 

Without prejudice to any other rights you may have, if you are located in the EEA, you also have the right to file a complaint against 24 Apps with the Austrian Data Protection Commissioner ("DPC"), which is 24 Apps’s Lead Supervisory Authority. The DPC’s contact details are:

 

Österreichische Datenschutzbehörde

Hohenstaufengasse 3

1010 Wien

AUSTRIA / EUROPE 

Telephone: +43 1 531 15 / 202525

Fax: +43 1 531 15 / 202690

E-Mail: dsb@dsb.gv.at

 

If you live in the EEA, you may also file a complaint with your local data protection regulator.

 

The Call Recorder 24 App is no longer for sale, however, if you own and continue to use the app, it is subject to this Privacy Policy and the following terms: 

Your Rights

If you wish to receive information from our Call Recorder 24 app (which includes information relating to another individual, such as a call recording), the other individual may have to contact our Data Protection Officer to provide their written consent and/or proof of identity before the information is released.

 

END OF DOCUMENT.

 

©2019 24apps GmbH. ® All rights reserved.