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Privacy Policy

The updated Privacy Policy (“Policy”) will automatically come into effect for all existing users of Refog web site and products (“Services”) on May 25, 2018 and, once in effect, your continued use of our services will be subject to this new Privacy Policy.

1. Introduction

Your privacy is always our priority. In this Policy, we describe how and why we gather, share, store and use your personal data. Here you can also find information about your opportunities and how to manage your personal data.

Please read this Privacy Policy carefully.

2. The aim of this Policy

This Policy contains detailed information about Refog’s interaction with your personal data. This Policy applies to all Refog services, including associated ones. The Policy also presents the terms of your use of the service.

We may improve our product and services in the future – adding new features, extending old ones, etc. If one of these changes will have an impact on our conditions for collecting personal data, we will certainly inform you. In this case, we may update this Policy or add terms. All new features are subject to this Policy; if they are not a subject of this Policy, we indicate that fact.

This Policy has several purposes:

  • Inform you about how we use the personal data you share with us.
  • Ensure you understand why we collect data, who uses it and how.
  • Clarify your rights and opportunities in relation to personal information.
  • Share more about the ways we protect your privacy.

Our goal is to help you understand our Privacy Policy. Please note that if you do not agree with this Policy, it is your choice as to whether you will use the Refog Service.

3. Your rights and preferences

We have changed our Policy according to the new European General Data Protection Regulation (GDPR) law to provide even better service for you. This law regulates interactions with personal data and gives rights to individuals.

At the same time, we have improved users’ accounts to give the opportunity to take advantages of those rights.

You have the right to:

  • Be informed - this Policy is part of this right, as we inform you about collected personal data;
  • Access information held about you;
  • Fix (rectify) personal data if it is outdated, incomplete or inaccurate;
  • Erase (delete or remove) personal data;
  • Restrict processing - in this case, personal data about you will be stored but not processed;
  • Have data portability - you can copy, move or transfer your data from one service to another without inconvenience and interference with your work;
  • Complain - you can complain to a supervisory authority.

Also, you have the right to not be subject to automated decision-making.

To exercise your rights, contact us: support@refog.com.

4. Who are we? (identity of the Data Controller)

To begin, let's clarify the term Data Controller. This is a person who, alone or with other persons, is responsible for defining the purposes for – and the manner of – processing any personal data.

Refog Inc. is the Data Controller for the purposes of the personal data processed under this Policy. Refog, a United States Incorporation, having its registered office at 901 N. Pitt Street, Suite 325; Alexandria, Virginia, 22314, USA.

5. How do we collect your personal data?

Methods of data collection are described below.

  1. When you register (sign up) for the Refog Service - personal data such as email address, age, country and IP address is collected when you sign up. This allows us to provide you with services.
  2. During your use of the service - we collect information related to how you use the Refog Service, such as account information, device information, website access information and other usage data.
  3. Additional requests - sometimes we collect personal data to provide you with additional functionality or features. In this case, you may be asked for additional permission access.
  4. From third parties - information that we receive about you from advertisers, advertising networks, and other persons and companies is known as data from third parties. We use the information that you allowed other services to share.
  5. Cookies and other technologies - we use Cookies and other technologies, such as pixel tags, to provide you with our Services. These technologies allow us to improve, protect and promote our product. If you do not want to share Cookies, please set your browser – Google Chrome, Opera, Firefox, Edge, Explorer and so on – so that it does not accept Cookies. This setting can affect the serviceability of the Refog Service.

To test our IT systems, create marketing plans and promotion models, conduct research or data analysis, improve the Refog Service or develop new features/functionality, we may use anonymised and aggregated information based on users' personal data.

6. What personal data do we collect from you?

Below you will learn about the personal information we collect about you.

When you sign up for Refog Services

- Account Registration Data - this includes data you provide during registration. We collect data to let you use the Refog Services. Account Registration Data includes your email address, age, country and IP address.

Some information is optional. You may provide more information about yourself to make your account more personalized.

Your Refog product settings affect the personal data we collect.

If you used a third-party service to create a Refog account, we will receive the data through that third-party service. In this case, you must agree that the third-party service will process your personal data.

When you use the Refog Services

- Refog Service Usage Data - this includes personal information about your use of the service, such as:

  • Technical data, such as your IP address, Cookie, URL, your device (IDs, attributes, etc.), your network connection as a provider, your network or device performance or connection type (LTE, 3G, Wi-Fi, etc.), your device’s operating system, your browser and language, and other information enabling digital rights management;
  • Information about your interaction with the Refog Services;
  • Information about your tariff;
  • Information about your interaction with the Support service and other messages and content you create while using the Refog Service.

The data we collect with your consent

For additional features/functionality or for a better user experience, you may give us permission to collect additional personal data.

- Voluntary Data - without your prior consent, we do not collect the information indicated below. You can give us access to the following data:

  • Contacts - you may give us access to your contacts on a mobile phone, in your email and other sources. In this case, we will obtain access to the contacts stored on your device and/or in your personal accounts in other Internet services.
  • Call History/Records - you may give us access to the history of the calls you have made, and also allow us to record calls. In this case, we have the right to follow the call history and record your conversations on your mobile phone and other devices that carry out voice communications.
  • SMS/Chat Messages - you may give us access to your SMS and other text messages that you wrote, sent, received or interacted with on your phone or other electronic device.
  • Visited Websites - you may give us access to information about the websites you visited on your mobile phone, computer or other electronic device. In this case, we will get access to your browser history and other software used to access websites.
  • Calendar Events - you may give us access to data from your electronic calendar and other programs, which are used for task scheduling purposes (to-do lists, etc.). In this case, we will get access to your schedule and other personal information about events listed in the calendar.
  • Device And Connection Information - you may give us access to your device and connection information. This will allow us to receive and process information about your device and your connections to the network.
  • Photo and Media Data - you may give us access to photo and media data. In this case, we can take screenshots of your screen; use the camera; and process, forward and perform other operations using the media data of your phone, computer or other electronic device.

- Payment Data - when you pay for our services, conduct transactions or make purchases through the Refog Services, we can collect your personal information. The exact data depends on the method of payment, but includes the following:

  • Name;
  • Date of birth;
  • Mobile phone number;
  • Debit or credit card information: type (Debit or Credit), expiration date, and certain digits of your card number;
  • Postal code;
  • Details of your transaction history.

- Marketing Data - with this information, Refog and our partners and service providers can carry out marketing communications with you via Refog, via electronic communication channels or directly from a third party.

- Surveys, Sweepstakes and Contests Data - the collected data varies depending on the promotion and is used to give you the opportunity to subscribe to and participate in these types of promotions.

7. How do we use your personal data?

When you use the Refog Service, we use various technologies to collect data about you. There are various reasons for this.

Below you will find information about the reasons why we process your data and about the categories of personal data we use for this purpose. Also, you will learn about the legal basis upon which we rely in the processing of data.

Account Registration and Service Usage Data

We use this data to:

  • Provide, personalize, and improve your experience with the Refog Service and other services and products that Refog provides; for example, providing customized, personalized, or localized content, recommendations, features, and advertising on or outside the Refog Service (including for third-party products and services).
  • Understand exactly how you use the Refog Service. This helps us analyze and understand your interaction with our products and services. It also helps us develop new products and make our services even better.
  • Communicate with you for Refog Service-related purposes

The legal basis for the processing purpose is: - Performance of Terms; - Legitimate Interest.

Payment Data

We use this data to:

  • Process a payment;
  • Prevent or detect fraudulent payments;
  • Prevent or detect fraud using the Refog Service.

The legal basis for the processing purpose is:

  • Performance of Terms;
  • Compliance with Legal Obligations;
  • Legitimate Interest.

Contests, Surveys, Sweepstakes and Marketing Data

We use this data to:

  • Communicate with you.
  • Communication is carried out directly or through one of our partners for research; participation in contests, surveys and sweepstakes; advertising purposes or other marketing.

The legal basis for the processing purpose is:

  • Legitimate Interest;
  • Consent.

Voluntary Data

We use this data to:

  • Provide you with the features/functions of our service based on your consent, such as: record calls; track calls and call history; track phone locations; track SMS and chats; track Facebook, WhatsApp, Viber and other messengers and social networks; take screenshots and photos; save all contacts, track the calendar and to-do list; and track the browser and Internet history;
  • Offer parental controls;
  • Monitor employees.

The legal basis for the processing purpose is:

  • Consent

8. Sharing your personal data

Below you will find information about with whom we share your personal information. We will also clarify the reasons for this action.

Third-Party Applications you Connect to Your Refog Account

Refog may share your Service Usage Data with Third-Party Applications you connect to your Refog Account. For example, if you connect your Refog account to a social network, another device, audio, television, automotive or other platforms.

Third-Party Applications You Use to Log Into Refog

Third-Party Applications may have access to certain Service Usage Data if you log into your Refog account using a Third-Party Application. This Third-Party Application may have access to your activity and other Service Usage Data.

Service Providers and Others

To provide you with the Refog Service, we use a technical infrastructure operated by the technical service providers. In particular, we use the services of providers that store, host, maintain and manage the Refog Service. Providers allow us to communicate with you and to provide you with our services.

** Refog Partners**

If you are accessing the Refog Service through an application you received from a third party, we may share some personal data about your usage of the Refog Service.

For example, we may share your Refog username or other Account Registration Data if doing so is necessary to provide you with our services.

Other Refog Inc. Group Companies

To carry out our daily business operations and maintain our service, we share your personal data with other companies in the Refog Inc. Group.

Purchasers of the Refog Business

If we are selling, or discussing the sale of, our business, we may share your personal data with a prospective buyer or buyers. Refog will ensure your personal data remains safe. You will receive a notice if your personal data becomes subject to a different Privacy Policy.

Law Enforcement and Data Protection Authorities

We may share your personal data to comply with a legal obligation under an applicable law if we, in good faith, believe it necessary to do so. Also, we may share your personal data when responding to a valid legal process, such as a court order, subpoena, search warrant, etc.

If you have more questions about your publicly available information and what you share with others, please contact us by email (support@refog.com) or use our company's address in this Policy.

9. Data retention and deletion

We keep your personal data (including voluntary data) as long as we need it to provide you with the Refog Service and as long as you have a valid account with a paid license. After the paid license expires, the data is stored for 30 calendar days. Then we delete it.

You have the right to deletion. This means you can delete information about yourself and we will delete the personal data that we’ve collected. To do this, you must delete your account; after that, we will delete the information about you. Please note, there may be a delay in removing the information from our servers and backup storage. If we need your personal data to enforce our agreements or legal obligations, we may retain this information. A delay in the removal of information can also occur due to unresolved disputes or a continuation of the process of resolving disputes.

10. Transfer to other countries

To ensure the service’s operation and perform the actions specified in this Policy, Refog shares your personal data worldwide. The company can subcontract with performers from other countries that are granted limited access to your personal data.

Refog may also share your personal data with third parties located in countries other than your home country. If your personal data is shared beyond the European Union and Switzerland, we ensure that its sharing, storage and usage comply with the Standard Contractual Clauses approved by the EU Commission.

11. Links

In our work, we may use content and services from third-party suppliers. We cannot be held responsible for the confidentiality and rights of third parties, as we cannot control them.

Please, always be aware when you use third-party services. Learn about their Privacy Policies, as they may be different from ours.

12. Keeping your personal data safe

Our goal is to protect our users’ personal data. To do this, we use the appropriate organizational and technical solutions. We always do our best to protect data; however, no system can be absolutely safe.

You are also responsible for your safety. Please choose a unique and strong password for your account, log out of your account after you are done using it, install and use anti-virus software, and monitor the security of your personal data.

13. Children

In some countries, age restrictions may be governed by the laws of a particular jurisdiction. In standard cases, the Refog Service is not directed towards children under the age of 16.

Please note that we do not knowingly collect personal data from children under 16 or under the applicable age limit (the "Age Limit"). If you are younger than the Age Limit, please do not provide us with your personal data

Parents of a child under the Age Limit who have learned that their child provided his or her personal data to Refog should contact us by email (support@refog.com) or via our company's address, provided in this Policy. You have the right to be informed and access information held about you or your child.

We will take all steps necessary to erase the personal data of a child under the Age Limit if we learn that such data was collected. Please note that this may also require you to delete your child's account.

14. Changes to this Privacy Policy

We reserve the right to change this Policy.

If we make a material change, we will notify you by displaying a prominent notice within Refog website.

This notification may be done in advance. This is why it is very important to read our notifications.

To learn more, please contact us.

15. How to contact us

Thank you for reading this Privacy Policy. Contact us with any questions about the Policy or visit our Support Center: https://support.refog.com. You may also write to us at the following address:

Refog Inc. 901 N. Pitt Street, Suite 325 Alexandria, 22314 Virginia, USA

We work for you and hope you enjoy Refog!