1. Interpretation and Definitions

1.1 Interpretation

Words whose initial letter is capitalized have meanings defined under this policy. The following definitions apply whether in singular or plural.

1.2 Definitions

• You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
• We (referred to as either "Us" or "Our" in this Agreement) refers to the developer of the Application.
• Application means the software program downloaded by You on any electronic device.
• Account means a unique account created for You to access our Service or parts of our Service.
• Service refers to the Application.
• Third-party Social Media Service refers to any website or social network through which a User can log in or create an account to use the Service.
• Personal Data is any information relating to an identified or identifiable individual.
• Device means any device that can access the Service, such as a computer, cellphone, or tablet.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Do Not Track (DNT) is a concept that allows internet users to control tracking of their online activities across websites.

2. Data collection and usage practices

2.1 Types of Data Collected

Personal Data

While using our Service, we may ask you to provide certain information that can identify you ("Personal Data"), such as Cookies and Usage Data (which can include age range, general location, and preferences, where provided).

Usage Data

When you access the Service by or through a mobile device, we may collect information automatically, including device type, device unique ID, IP address, operating system, browser type, device identifiers, interactions with the app, session logs, and preferences and other diagnostic data ("Usage Data").

Device Information

We may collect device model, OS version, language, carrier, IP address, device identifiers, and diagnostic data for analytics and to maintain/improve the Service.

Tracking & Cookies Data

We use cookies and similar technologies to operate, analyze, and improve our Service. You can refuse cookies in your browser settings, though some features may not work.

Examples of Cookies we use:

• Session Cookies. Operate our Service.
• Preference Cookies. Remember preferences and settings.
• Security Cookies. Improve security.

2.2 Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

2.3 App Permissions

Depending on your use, the app may request permissions such as:

• FOREGROUND_SERVICE_PHONE_CALL
• INTERNET
• READ_EXTERNAL_STORAGE
• ACCESS_NETWORK_STATE
• ACCESS_WIFI_STATE
• WRITE_EXTERNAL_STORAGE
• INSTALL_SHORTCUT
• USE_FINGERPRINT
• FOREGROUND_SERVICE
• MANAGE_EXTERNAL_STORAGE

You can review, manage, or revoke these permissions at any time in your device settings.

2.4 Location Information

2.5 Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

2.6 Communication services providers

2.7 Your Consent and Our Use of Your Personal Data

By creating a profile or registering to use our apps, you expressly agree to:

• We may process the account data you provide for login/registration and third-party sign-in.
• Except as provided in this policy, we will not transfer your personal data to third parties.

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including monitoring usage.
• To manage Your Account and registered user features.
• For the performance of a contract, including purchases or other agreements.
• To contact You (e.g., service updates and security notices).
• To provide You with news/offers about similar services unless you opt out.
• To manage Your requests.

2.8 Retention of Your Personal Data (if any)

We retain Personal Data only as long as necessary for the purposes set out in this policy and to comply with legal obligations, resolve disputes, and enforce agreements. Usage Data may be kept for a shorter period unless needed for security/functionality or required by law.

2.9 Transfer of Your Personal Data (if any)

Your information may be processed in locations with different data-protection laws. We take reasonable steps to ensure appropriate safeguards are in place before any transfer.

2.10 Disclosure of Your Personal Data (if any)

• Business Transactions: In a merger, acquisition, or asset sale, your data may be transferred with notice.
• Law enforcement: We may disclose data as required by law or valid government requests.
• Other legal requirements: To comply with law, protect rights, investigate misuse, protect safety, and prevent liability.

2.11 Security of Your Personal Data (if any)

We use administrative, technical, and physical safeguards (encryption in transit/at rest where applicable, vulnerability scanning, integrity protections, organizational measures). No method is 100% secure.

3. Why we collects data

We collect information to:

• Deliver core features such as account management, sync, backups, and notifications.
• Maintain safety & reliability by detecting abuse, preventing fraud, and ensuring app stability and performance.
• Measure performance and understand how features are used so we can fix bugs and improve the app.
• Personalize (where available) certain in-app experiences such as recommended content or settings, if you choose to enable them.
• Comply with legal obligations and enforce our terms, including security and auditing requirements.

Where required by law, we rely on your consent. Otherwise, we rely on legitimate interests (e.g., security, analytics), performance of a contract (providing the Service), and legal obligations.

4. Your privacy controls

You have choices about how your information is used. Depending on your device and app version, you can:

• Manage app permissions (e.g., Location, Microphone, Storage etc.) in your device settings.
• Adjust in-app settings for data collection toggles where available (e.g., analytics, crash reports, personalized tips).
• Control notifications (enable/disable categories such as reminders or promotions).
• Limit ad relevance using your device’s advertising preferences.
• Choose cookie/storage preferences where presented (web components only).

Some controls are provided by your device manufacturer or operating system and may vary by version or model.

5. Sharing your information

We do not sell your personal information. We share information only as described below:

• Service providers (processors): Vendors who host our services, provide analytics, security, customer support, or other operational assistance. They are bound by confidentiality and data-protection obligations and may process data only on our instructions.
• Legal, safety, and security: When required by law, subpoena, or to protect our rights, users, the public, or our services (e.g., investigating fraud, abuse, or security incidents).
• With your direction or consent: We will share information with third parties when you request or consent to it.

We take steps to ensure any international data transfers are subject to appropriate safeguards consistent with applicable law.

6. Compliance with GDPR

6.1 Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

6.2 Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

6.3 Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

7. Compliance with CCPA

7.1 Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

• The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
• The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or web page.

• The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:

  • The categories of Personal Data collected
  • The sources from which the Personal Data was collected
  • The business or commercial purpose for collecting or selling the Personal Data
  • Categories of third parties with whom We share Personal Data
  • The specific pieces of Personal Data we collected about You
• The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:

  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

7.2 Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email us or visit our "Do Not Sell My Personal Information" section or web page.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

7.3 Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.

7.4 Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• From Our "Cookie Consent" notice banner
• Or from Our "CCPA Opt-out" notice banner
• Or from Our "Do Not Sell My Personal Information" notice banner
• Or from Our "Do Not Sell My Personal Information" link

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

7.5 Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

8. Purchases for Products/Services

Our app may offer in-app purchases and subscription-based features. All payments are processed securely through trusted third-party platforms such as Google Play (for Android) and Apple Pay / App Store (for iOS).

We do not directly collect or store any payment information such as credit card details. All financial transactions are managed by the respective app store in accordance with their privacy and security policies.

For more information, please refer to:

• Google Play Terms of Service
• Apple Media Services Terms and Conditions

9. Remarketing & Advertising services

We use re-marketing and targeted advertising services, including Google Ads and other similar platforms, to promote our app and reach users who have previously interacted with our service. These services allow us and our advertising partners to show relevant ads to you on third-party websites, apps, and platforms based on your past visits or activity.

Our advertising partners may use cookies, identifiers, and similar tracking technologies to deliver ads that are more relevant to your interests, measure the effectiveness of our campaigns, and improve user engagement — always in accordance with applicable privacy laws and your consent preferences.

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.

10. For Users Within the European Economic Area (EEA)

Our company undertakes to respect the confidentiality of Your Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law, if You are within the European Union (EU), to:

• Access Your Personal Data and update or delete the information We have on You. Please contact Us to assist You.
• Correct the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to the processing of Your Personal Data. This right exists where We are relying on legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object to where We are processing Your Personal Data for direct marketing purposes.
• Erasure. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Users can exercise their rights to prevent processing by contacting us at truecallapps.anro@gmail.com.

You have the right to complain to the Danish Data Protection Authority about Our collection and use of Your Personal Data.

11. For users within state-specific areas in the United States

If You are a resident in specific states in the United States, additional rights may apply to You in addition to this Privacy Policy. Supplemental information applicable solely to all visitors, users, and others who reside in the specified states.

12. PIPA – For users in South Korea

You have the right under this Privacy Policy, and by law, if You are within South Korea, to:

• Access Your Personal Data and update or delete the information We have on You. Please contact Us to assist You.
• Correct the Personal Data We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to the processing of Your Personal Data. This right exists where We are relying on legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object to where We are processing Your Personal Data for direct marketing purposes.
• Erasure. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

Our company and Our Data Partners will not collect, process, share, or access any location data from South Korea.

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Users can exercise their rights to prevent processing by contacting us at truecallapps.anro@gmail.com.

13. Children's Privacy

Our Service is intended for a general audience and is not directed toward children under the age of 13 (or the minimum age required by law in your region). We do not knowingly collect, use, or share personal information from anyone under this age.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately. We will promptly take steps to delete any such information from our records.

We are committed to maintaining a safe and privacy-respecting environment for all users.

14. Links to Other Websites

Our Service may include links to third-party websites that are not operated or controlled by us. When you click on a third-party link, you will be directed to that external site.

We encourage you to review the Privacy Policy of every website you visit, as we have no control over and are not responsible for the content, privacy practices, or policies of any third-party websites or services.

15. Changes to this Privacy Policy

We may update this Policy from time to time and will post the new Policy here. Please refer to the Last Updated date above to review the most recent version of our Policy.

16. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at truecallapps.anro@gmail.com