In general, we only collect information that allows us to provide you with our best Services. This includes, for example, simple tasks like allowing other users to see the name and picture you choose to show. It also helps us to keep our Services clear of fraud and spam, and it allows us to get a unique understanding of what additional services may be useful to you, and all other purposes set out in this policy below.
Starting with Zvonilka 1.0.1, all of Zvonilka’s core features are secured with end-to-end encryption: Zvonilka calls, one-on-one messages, group messages, private media sharing and secondary devices. This means that the encryption keys are stored only on the clients’ devices and no one, not even Zvonilka itself, has access to them.
Scope and consent
Before you start sharing good voice and text experience, it’s important you understand that by using our Services, you allow us to collect, use, disclose, and retain your personal information and other information but we will never read or listen to the content you are sharing privately. You can be sure that we will only use your information as described in this Policy.
Information we collect
First of all, we want you to be assured that we do not read or listen to the content of your messages and/or calls made privately via Zvonilka and we do not store those messages once they have been delivered to their destination (which on average takes less than one second). If for some reason, the message, wasn’t delivered to its destination within up to 2 weeks, it will be deleted from our servers.
Note that chats with bots and Public Accounts, and communities are not end-to-end encrypted, but we do encrypt such messages when sent to the Zvonilka servers and when sent from the Zvonilka servers to the third party (the Public Account owner and/or additional third party tool (e.g. CRM solution) integrated by such owner).
We collect the minimum information required to achieve the purposes set out in this Policy (see below), and you have the ability to limit such collection, as specified below under “Your Choices”:
(a) Registration and Account Information: When you use our various Services you voluntarily give us personal information (e.g., name, email, phone number and, when necessary, billing information) and you are not anonymous to us. That means your name and photo (if you choose to provide them) will be visible to other Zvonilka users. When you install the Zvonilka App, you’ll also be asked to allow us access to your mobile device’s address book. A copy of the phone numbers and names of all your contacts won’t be collected and stored on our servers.
(b) Social Media Information: If you sign in to your Zvonilka account through third-party social media sites like Facebook, Twitter or VK, you agree to give us on-going access to your personal information on such sites (e.g., your public profile, friend list, accounts you follow or who follow you, your email address, birthday, work history, education history, interests, current city, and video viewing). We may receive certain information about you which is stored on social media sites if users of those sites give us access to their profiles and you are one of their friends or connections, depending upon your settings on those sites.
(c) Activity Information: While using the Zvonilka Services, we won’t display your connection status, whether you have received and seen messages sent to you. We’ll present if you are currently on another call, and information related to the calls and messages you have sent and received such as length of the call, who called who, who messaged who, and at what time. As for call information (length of the call, missed calls etc.), we believe they are important for other Zvonilka users and therefore cannot be canceled.
We will receive interaction information from your use of our Services. When you interact with Public Accounts, bots and Communities on our Service, we may obtain information about the messages you have liked, comments you have left and also websites you’ve viewed through links in them. When you use our Chat Extensions and shopping solution we may know which items you searched and shared. In addition, we collect information about the accounts you have visited and the content you have viewed in order to improve the relevance of our Services.
We collect information about the value added services you are using over Zvonilka and/or apps (such as games) you have downloaded through Zvonilka. This includes whether you are presently online, your personal preferences (such as connecting the service to Zvonilka) and the way you use that service (for example how often, for how long). We may also tell other Zvonilka users that you are using a certain service or app (to recommend them to try that service as well).
(d) Information from Other Sources: The information we collect may be combined with information from outside records (e.g. demographic information and additional contact information) that we have received in accordance with the law.
(e) Additional Information: We collect additional information when you access our App through a certain device (e.g. your mobile device’s unique identifier; information about your device’s operating system, your browser, browser or operating system language; your wireless network, and your mobile carrier; the Zvonilka call log). We may also collect your WPS location data – you can choose whether to allow this by changing your geolocation tracking settings.
Zvonilka service allows you to call a number outside of the Zvonilka registered community at low cost local rates. If you want to use Zvonilka, you’ll need to create a “Zvonilka Account” by selecting a password, and providing certain personal information (e.g., name, email and billing information). We will also keep your Zvonilka call detail records for billing and legal records, and to make you relevant offers. When calling through Zvonilka, just like regular phone calls you make, details of the call are available to the phone operator of the person you called (and possibly other facilitating phone operators – but this is the same as any regular phone call you make).
When you select to connect your email to your Zvonilka account, we will use information you provided in the registration process (e.g., name, email, password, phone number), as well as your IP address to do so. When we link your email account to the Zvonilka account, we will also automatically create an account for you with our parent company, T-ONE Inc., and other entities in the Zvonilka corporate family (Group) if you do not already have an account with one of the services. Certain registration and activity data will be shared with the T-ONE corporate family as part of this process, as described below. You can choose to delink your Zvonilka account from the T-ONE account at any time by editing your profile on the app.
Uses and Retention:
Our mission is to constantly improve our Services and provide you with new experiences. As part of this mission, we use your information for the following purposes:
(a) Make our service available: We use your Registration and Account information to (i) register you for the App and create your User Account for Zvonilka; (ii) create your profile and make it visible; (iii) process your payments; (iv) create your Zvonilka ID; (v) provide customer service, give you information about your account, and respond to your requests; (vi) personalize your experience by providing content (such as games) on the Service, including targeted advertising of Zvonilka services and other 3rd party services that we believe may be of most interest to you; personalization may include automated decisions about what you will view and when, but be assured that it will not have legal effects on you; (vii) indicate which of your contacts is already a Zvonilka member and notify you when your contacts become active on the Service; (viii) display the name of the contact as it appears in your address book when a call is received on the Service.
(b) Improve our Services: We use call log information and usage information (as described above) to better understand network behavior and trends (numbers of messages and calls made by users, typical destinations, call lengths, network type, etc.), detect potential outages and technical issues (this helps us notice things like a drop in call volume in a certain geography, a shift in call length, a change in typical networks, etc.) to improve our Services.
(c) Provide Interesting Offerings to You and others: As part of value added services provided by us or by a third party within Zvonilka, we may use your information to continuously optimize and personalize those services and send you personal updates about new offerings which we believe you will find relevant. We may share with our service providers unique identifiers to determine the best way to tell potential new users about our services. When you join Zvonilka, the contacts in your address book that are already Zvonilka members may be informed that you’re now on Zvonilka too.
Sending a message to a bot or Public Account, subscribing to a bot or Public Account will allow admins of that bot or Public Account to send you notifications and personal messages. If you do not wish to receive such notifications, you may adjust your account settings to decline them or opt-out at any time from receiving further notifications. You will be asked to allow the use of your location data before Zvonilka provides you specific location services offerings, and you may also adjust your phone preferences to disable the use of your location data at any time.
(d) Process Your Payments: We may use your Information like your name and phone number to process your payments for our Services through a secured third-party service provider and, on an aggregate basis to determine charges for our phone carriers and other service providers.
(f) Communicate With You: As part of the Zvonilka family, we want to keep in touch with you. We use your information to contact you (via message or other means) to maintain the App, including your Zvonilka User Account, to comply with your stated communication preferences or to provide updates about other Zvonilka services.
Data Retention: Unless otherwise specified, we retain information as long as it is necessary and relevant for us to achieve the purposes referred to above or to enable us to comply with our legal data protection retention obligations. Upon deactivation of your account, we will minimize the personal data we keep about you only to such data which we are required to keep to comply with laws, or other legal reasons. We may keep activity data on a non-identifiable basis to improve our services. Your posts on public accounts and communities may remain available if you do not delete them.
Your data is kept safe with us, but we do share your personal information with third parties we trust in order to provide you with our services, as follows:
(b) App Providers and Other Third-Parties: We may disclose your information to service providers and other third-parties under contract who help with providing you and others our Services on our behalf or other services provided by third-parties via our Services (such as, but not limited to, fraud and spam investigations, payment processing, site analytics and operations, providing special partnership features in our service– either on an aggregate non identifiable basis, or using a unique identifier which is not attributable to you). They are required to secure the data they receive.
(c) Advertising partners: to enable the limited advertisements on our service, we may share a unique advertising identifier that is not attributable to you, with our third party advertising partners, and advertising service providers, along with certain technical data about you (your language preference, country, city, and device data), based on our legitimate interest. This includes partners managing our advertising placements and also advertisers themselves and their agencies or third parties managing their advertising demands. Your unique advertising identifier is created by your mobile device’s operating system and you can change it or choose not to share it at any time. If you want to know more, read our Cookies and Tracking Technologies Policy.
(d) Legal and Law Enforcement: We may disclose your information to law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other Zvonilka user to legal liability.
(e) Change of Control – New Owners: We may share your information with another business entity, if we plan to merge with or be acquired by that business, or are involved in a transaction with similar financial effect. In such a situation we would make reasonable efforts to request that the new combined entity or other structure follow this Policy with respect to your personal information. If your personal information was intended to be used differently, we would ask the new entity to provide you with prior notice.
Because Zvonilka is global, the recipients above may be located outside the country in which you are located. See the section on “International Data Transfers” below for more information.
Information You Share Publicly
Some of our Services allow you to share information with others on a public basis. If you post information on a public feature of our Services or through social media sites, plug-ins or other applications, do not forget this information is public on our Services and, depending upon your privacy settings, may also become public on the Internet. When you post on Communities, the admin of the Community has the ability to allow everybody to access it, but you can always actively delete messages you posted. We cannot prevent or control further use of this information so please make sure you only post information that you’re happy to be seen publicly. We may also further use such public information you share, for various reasons, such as improving our service and providing you with relevant content, and analyzing trends.
At this stage, whatever you share publicly is available to the entire Zvonilka community. If you wish to remove a certain piece of content you have shared in the past, you can do that by deleting that content. It will be removed from our services but may remain on local devices of some users (assuming they have chosen to save it).
We want you to have control over how you communicate. That is why, for example, we allow you to delete messages even after they have been sent (it will be deleted for you, your friend and our service). How cool is that? You can also control your privacy settings within the App to change the visibility of your online status or prevent other users from knowing which Zvonilka apps and games you are using. You can disable the “seen” notification so that other users do not know whether you’ve read a message yet. You can choose not to share your photo, opt not to receive location-based messages along with many other additional options, which are available within the app. You can also make additional choices on your phone’s settings by changing our app’s permissions such as location sharing, access to contact list and more.
Every now and then, Zvonilka may send you updates about administration and operation of the Service (for example, about your transactions, policy changes, technical issues, etc.). We may also send notifications about offerings by Zvonilka or third-parties, that we think may be of interest to you. If you do not wish to receive such notifications, you may adjust your system settings to decline them.
Cookies and Tracking Technologies
Accessing, Reviewing, and Changing Your Personal Information
EEA Privacy Rights
If you use our services from the EEA, you have certain rights regarding your personal information, subject to local law. These include the following rights to: access your personal information, rectify the information we hold about you, erase your personal information, restrict our use of your personal information, object to our use of your personal information, receive your personal information in a usable electronic format and transmit it to a third party (right to data portability), lodge a complaint with your local data protection authority. To learn more about exercising your EEA rights, visit our EEA rights page. If you would like to understand or exercise such rights, please contact us at the details below. We will contact you if we need additional information from you in order to honor your requests.
We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:
to fulfill our contractual obligations to you, for example to provide the services, to ensure that invoices are paid correctly.
Where you have given your consent to the processing.
to comply with our legal obligations, as explained above.
to meet our legitimate interests, for example to understand how you use our products services and to enable us to derive knowledge from that, which allows us to develop new products and services, and to personalize the service for you and the ads you see. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
to protect the vital interests of the data subject or of another natural person.
necessary for the performance of a task carried out in the public interest.
Zvonilka Land Privacy Rights
If you made Zvonilka your daily choice for connecting and sharing, make sure to be sending good voice and text experience and make your friends smile. Eventually, this is what Zvonilka is for.
Third-Party websites and Apps:
Our app may contain links to other third-party websites or you may access Apps from a third- party site. We are not responsible for the privacy practices or the content of these third-party sites.
Back-Up: When you back-up your Zvonilka conversations, they are kept on your device’s service according to operating system’s (iOS / Android and desktop operating system) terms and policies and are no longer protected by Zvonilka’s end to end encryption.
We know that security is important to our users and we care about the security of your information. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use include firewalls, data encryption, physical access controls to our data centers and information access authorization controls. We need your help too: it is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third-parties. Starting with Zvonilka 6.0, all of Zvonilka’s core features are secured with end-to-end encryption: Zvonilka calls, one-on-one messages, group messages, private media sharing and secondary devices. This means that the encryption keys are stored only on the clients’ devices and no one, not even Zvonilka itself, has access to them.
Our Services are not intended for children under the age of 10. Therefore we do not knowingly collect personal information via our websites, applications, services, or tools from anyone under 10. In the EEA, certain default privacy settings will be applied to users under the age of 16 and can only be changed if the legal guardian instructs so in writing.
We operate internationally and provide our Services to Zvonilka users worldwide allowing them to communicate with each other across the globe. That means that your personal information may need to be processed in countries where data protection and privacy regulations may not offer the same level of protection as in your home country. We store and process your personal information on our computers in the United States, Asia, Europe (including Russia), Australia and Brazil, and use service providers that may be located in various locations outside of the European Economic Area (EEA).We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected.
B2B Partners Data
Updates to this Policy
From time to time, as our services evolve, we may update this Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the App. Please check the App frequently for updates.