Privacy Policy of

Effective from 27th of June 2018

CallUpper collects Personal Data from its Users, it is necessary for performing services of CallUpper listed on the website. You may contact CallUpper through email at any time if you want to delete, change, transfer or perform any other actions with data, that belongs to You; requested by You actions regarding your personal data shall be performed in 48 hours’ time frame.

COMPANY CODE: 12974765

Data Controller
COMPANY CODE: 12974765

Types of Data collected

Among the types of Personal Data that CallUpper collects, by itself or through third parties, there are Cookies, Usage Data, phone number, email address, and the name of User.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using CallUpper.

All Data requested by CallUpper is mandatory and failure to provide this Data may make it impossible for CallUpper to provide its services. In cases where CallUpper specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact Data Controller.
Any use of Cookies – or of other tracking tools – by CallUpper or by Data Controllers of third-party services used by CallUpper serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through CallUpper and confirm that they have the third party’s consent to provide the Data to Data Controller.

Mode and place of processing the Data

Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Data Controller. The updated list of these parties may be requested from the Data Controller at any time.

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data
The Data concerning the User is collected to allow Data Controller to provide its services, as well as for the following purposes: Analytics, Contacting the User, Handling payments, Hosting and backend infrastructure, Interaction with support and feedback platforms, Location-based interactions, managing contacts and sending messages and Managing support and contact requests.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

The services contained in this section enable Data Controller to monitor and analyze web traffic and can be used to keep track of User behavior.

  • Google Analytics (Google Inc.)
    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of CallUpper, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America – Privacy Policy – Opt Out

Contacting the User

  • Phone contact (CallUpper)

    Users that provided their phone number might be contacted for commercial or promotional purposes related to CallUpper, as well as for fulfilling support requests.

    Personal Data collected: phone number.

  • Contact form (CallUpper)
    By filling in the contact form with their Data, the User authorizes CallUpper to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data collected: email address.

  • Handling payments (Fondy Ltd)

    Payment processing services enable CallUpper to process payments by credit card, bank transfer or other means. To ensure greater security, CallUpper shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

    Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

    Place of processing: FONDY LTD, 22 Long Acre, Covent Garden, UK, London, WC2E9LY – Privacy Policy

  • Hosting and backend infrastructure (DigitalOcean, LLC.)

    This type of service has the purpose of hosting data and files that enable CallUpper to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of CallUpper. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Place of processing: Germany and United States of America – Privacy Policy

  • Managing support and contact requests

    This type of service allows CallUpper to manage support and contact requests received via email or by other means, such as the contact form.

    The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address, name, details specified in a message, created by User).

Further information about Personal Data

Additional information about Data collection and processing

Legal action
The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of CallUpper or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, CallUpper may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, CallUpper and any third-party services may collect files that record interaction with CallUpper (System logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using CallUpper and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Definitions and legal references

Personal Data (or Data)
Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data
Information collected automatically from CallUpper (or third-party services employed in CallUpper), which can include: the IP addresses or domain names of the computers utilized by the Users who use CallUpper, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, et.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

The individual using CallUpper, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject
The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller
The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of CallUpper. The Data Controller, unless otherwise specified, is Data Controller of CallUpper.

The hardware or software tool by which the Personal Data of the User is collected.

A small piece of data stored in the User’s device.
Legal information
Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to CallUpper.

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