Last Revised : December 22 th , 2019
This notice ("Privacy Notice") addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulation by the Attorney General (collectively, "CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.
Sync.Me Technologies Ltd (“we”, "us" or the "Company") provides disclosures for the 12 months preceding January 1, 2020 as required by the CCPA vis-à-vis California residents.
This Privacy Notice outlines our practices with respect to the information we may collect from you when you use the Service, the manners in which we may use such information and the choices that are available for you.
By accessing, downloading or using our Service, you acknowledge that you have read and understood the terms of this Privacy Notice. If you disagree with any term provided herein, please do not install or use the Service.
- About the Service
- What Information We Collect
- Why We Process Personal Information
- Sharing Personal Information
- Selling Personal Information
- User Rights Under the CCPA
- Non Discrimination
- Do Not Track Signals
- Children's Information
- Updates or Amendments to the Privacy Notice
- How to Contact Us
If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy Notice.
About the Service
The Company is firmly committed to ensure that the Personal Information that users (“user” or “you”) share with us and with other users in our community in connection with the use of our mobile application and/or by accessing our website (collectively the "Service") is safeguarded and protected.
Our Service is primarily designed to empower consumers to make informed decisions and deter illegal and fraudulent calling activities. We are dedicated to ensure that our activity is firmly grounded upon a legitimate interest, and that the privacy expectations of consumers are carefully weighed and reasonably balanced against such legitimate purposes.
Our Service plays a key role in enhancing connectivity and thwarting intrusive and fraudulent calls, by introducing a variety of smart features that empower consumers to make informed decisions and reducing the risks of the user community from being targeted by malicious or misleading activities, including:
- Reporting and blocking spam: our users can choose to report and block numbers to be added to their personal spam call list, and potentially a regional spam call list. In the event a certain number was reported as spam by a certain number of users, other users will be notified if they receive a call from that same number.
- Live Caller ID and Spam detection: our Live Caller ID displays the name of the caller before the consumer answers the call, and flags if the number was reported as spam.
- Number search (reverse lookup): individuals, including those who are not registered users with Sync.ME, may manually search a number on Sync.ME's web-based platform in order to ascertain the identity of the caller and whether a number is spam.
The contact information collected by Sync.ME is used solely to empower individuals to identify incoming calls from unknown sources, identify unknown numbers through the use of reverse numeric lookup, as well as to report and block fraudulent, intrusive or inappropriate calls. We designed our features to better respond to deceptive and abusive practices aided by anonymity, both in telemarketing as well as in other abusive or deceptive practices (such as abusive calls).
Our goal is to promote consumers' privacy by allowing them to know who is calling them, as well as promoting accountability throughout the industry.
HOW TO OPT OUT? If you would like to remove your Personal Information from our Service, you may do so by visiting this link: https://sync.me/optout/ .
WHAT INFORMATION WE COLLECT?
We collect certain information which identifies an individual or may with reasonable effort identify an individual (“Personal Information”). In addition, we treat information which is specifically connected or linked to any Personal Information – as long as such connection or linkage exists – as Personal Information.
We have collected the following categories of Personal Information:
|Category of Personal Data Collected||Personal Information Collected||Sources of Personal Data||Business/Commercial Purpose for Collection|
|To provide you with our Service. To improve our Service. To detect and prevent fraud or illegal activities. To respond to your requests and inquiries, and communicate with you. Direct marketing purposes – we may use the contact details you provided us to send you promotional offers. To perform research, technical diagnostics, analytics or statistical purposes. Information is also sold to business partners for commercial purposes (e.g. for calling centers for caller identification and spam blocking)|
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
Information exempted from the California Consumer Privacy Act (CCPA), such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA);
- Personal Information covered by certain privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Why We Process Personal Information
- To allow you to automatically identify incoming calls or to perform a manual numeric search (Caller ID), to enable you to use our Sync.ME Search feature, to enable you to block phone numbers or report phone numbers as SPAM, to integrate and update information relating to you and your contacts with the information stored on your social platform, and to fulfill your request for providing, maintaining and improving the Service (including other features);
- We also use your Personal Information when using our Name Tag feature – when sufficient number of users indicated that the phone number is associated with the same name, the name and phone number will be included in our directory.
- To respond to your inquiries, support request, feedbacks or questions, and update you with information pertaining to your request, and respond to claims that any content available through the Service violates the rights of third-parties;
- To enhance and personalize your experience and customize the advertising content we display;
- To communicate with you (via email, mobile device, etc.) and to authenticate your identity;
- To resolve disputes and enforce our policies, including investigation of potential violations thereof, or in accordance with any applicable law or regulation, or for the purpose of law enforcement;
- To perform research, technical diagnostics, analytics or statistical purposes;
- To provide you with the most relevant additional services and offers;
- To detect, prevent, or otherwise address fraud, security or technical issues;
- Direct marketing purposes – we may use the contact details you provided us to send you promotional offers; you may withdraw your consent via sending a written notice to us by email to the following address: firstname.lastname@example.org or on the same manner as the advertising was transmitted to you (e.g. via phone text message).
Sharing Personal Information
We disclose your Personal Information to third parties for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires both parties to keep that Personal Information confidential and not use it for any purpose except in the performance of the contract.
In the preceding twelve (12) months, we have disclosed the above-mentioned categories of Personal Information with the following categories of recipients for a business purpose:
- Our business partners;
- Our affiliates;
- Service providers.
We may share or transfer Personal Information to third parties as assets that are part of a merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of the Company. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Information (as it is defined in the CCPA).
We may sell (according to the CCPA definition of a "sale") your Personal Information to third parties and businesses for commercial purposes. You have the right to opt-out of a sale of Personal Information, see below for more information on how to exercise your rights.
- User Rights under the CCPA
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
- Access to Personal Information
You may request that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
You have the right to request that we delete any Personal Information collected from you and retained, unless retaining the information is necessary for us or for our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.
- Right to Opt-Out of the Sale of Personal Information
In the event that we sell your Personal Information, you have the right to submit a request to opt-out of the sale of your Personal Information. You may change your decision at any time and permit us to sell your Personal Information.
If you do not want us to sell your Personal Information to third parties, please click here: https://sync.me/optout/
After you opt-out, we may continue to share some Personal Information with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Service, ensuring that the Service is working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site (or app) from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the Personal Information collected when you use those devices or browsers.
Additionally, although clicking the “Do Not Sell My Personal Information” link will opt you out of the sale of your Personal Information for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Information (except for Personal Information sold within 90 days prior to your exercising your right to opt-out) or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may also download the AppChoices app at http://www.aboutads.info/appchoices to opt-out in connection with mobile apps, or use the platform controls on your mobile device to opt-out.
- Exercising Your Rights
- Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
- 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 the Personal Information relates to you. 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 the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
You can request access to your Personal Information or request deletion of your Personal Information, you can submit a verifiable consumer request to our email address: email@example.com.
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.
The request must:
You may only request a copy of your data twice within a 12-month period.
If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at firstname.lastname@example.org.
- Response Timing and Format
Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.
Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
In order to use our mobile-app you will be required to provide us with your Personal Information from the following categories:
- Category A – Identifiers
- Category B – California Customer Records Personal Information categories
If you provide us with the above-mentioned categories of Personal Information, our Service will enable you to report and block spam calls and get a live caller-id and spam detector. If you do not provide your Personal Information or ask us to delete or to not sell or share your Personal Information, we will not be able to provide you with our mobile-app service, since your Personal Data is essential to provide our Service to you.
Our Service is not intended for minors below the age of 16 years or otherwise below the legal age for providing consent that is not subject to authorization by the holder of parental responsibility, in accordance with the laws in the jurisdiction your reside (“Age of Consent”), and we will not knowingly collect personal information from children. If we become aware that a user is under the age of Age of Consent, we will remove their information from our files. We reserve the right to request proof of age at any stage so that we can verify that children are not using the Service.
Updates or Amendments to the Privacy Notice
We reserve the right to change this Privacy Notice at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Notice on the Service and/or we will send you an e-mail regarding such changes to the e-mail address that you volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above-mentioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.
How to Contact Us
If you have any questions (or comments) concerning this Privacy Notice, you are welcome to contact our Data Protection Officer here: email@example.com or through the following contact details:
Attn: Data Protection Officer
Sync.Me Technologies Ltd.
3076 Sir Francis Drake’s Highway, P.O. Box 3463, Road Town, Tortola, British Virgin Islands
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time.