Privacy Policy

Last Modified: December 14th, 2020

I INTRODUCTORY

DEL systems d.o.o. Čačak, Republic of Serbia (in further text: Provider, “we” or “us”), Data Controller for the purpose of this Privacy Policy, is an innovative technology developer and producer of specialized communications system (in further text: Ringzz) that allows registered users to communicate, share information and data in a confidential and secure way, within closed system and between pre-authorized participants, with support for various operating systems.

This Privacy Policy is made available on our website, and provides information on our policies and procedures regarding the collection, use and disclosure of personal information we receive from Users of Ringzz.

By accessing and/or using Ringzz or any part of it or related services and products, User consents to our collection, use, storage, deletion and disclosure of information relating to User as set forth in this Policy.

As used in this policy, the terms “using” and “processing” information include using cookies, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within Republic of Serbia or internationally.

II WHAT INFORMATION DO WE COLLECT&PURPOSE OF COLLECTION

1. General information you provide:
Your Account Information - Name, email and phone number. You provide these information in order to create a Ringzz account and provide our services. We do not user these to track you or create unique profile records on you.
Your Messages - We do not retain your messages in the ordinary course of providing our Services to you. Once your messages (including your chats, photos, videos, voice messages, files, and share location information) are delivered, they are deleted from our servers.
Your Connections - If you give us permission we do have access to your contacts records in order to improve your experience while communicating with your contacts.

2. Phone Number and Contact List:
For the purpose of verification of Ringzz Account you have to provide us your phone number to which SMS with verification code shall be sent. However, we do not store your provided phone number. Each User shall be designated a Ringzz ID number (#RingzzIDnumber) that shall be used for purposes of identification and communication with Ringzz Server and between Ringzz Users. If you chose and allow it, Ringzz Server shall have access and process contacts in your mobile address book in order to enable you and your contacts to connect. Provided information includes your Profile information which will be visible to other Ringzz users.

3. Content:
We never access, collect, monitor, use, permanently store, share, modify or take any other action of disposition towards and/or on User Content (as defined in applicable Terms of Use for Ringzz) and no clause or covenant of this Privacy Policy regarding sharing of personal information shall refer to Content. Once message i.e. Content, is successfully delivered to recipient(s), it is removed from Ringzz server. If messages are not delivered successfully after specific period of time, they are being removed, where removal period depends on particular service contracted and is specified on each particular Ringzz server (7 days for public Ringzz server).

4. Profile Information:
You may add, remove, review and update your profile name, profile picture, and status message in your Account by logging in and editing such information in your user interface.

5. Status Information:
We collect information about your online and status message changes on our Services, such as whether you are online (your “online status”), when you last used our Services (your “last seen status”), and when you last updated your status message.

6. Transactional Information:
If you pay for our Services, we may receive information and confirmations, such as payment receipts, including from app stores or other third parties processing your payment. However, even in these cases, apart from standard app store information (email address, full name etc.) we do not collect or receive any personal and payment information that you might have shared with your payment service provider.

7. Device and Connection Information:
We collect device-specific information when you install, access, or use our Services. This includes information such as hardware model, operating system information, browser information, IP address and device identifiers.

8. Automatically Collected Information:
We do not collect any information automatically and without user’s consent.

9. Data Collection Purpose:
We do not use it for identifying and tracking users nor to advertise. Data collection is not the part of our primary function/purpose. We collect data (e.g. name, email, phone number) in order to deliver our Services and to improve them as well as customer experience, to respond to users in the best manner and to understand how our services are being used.

III SHARING

- 3rd Party information:
We do not share identifying user’s information with any third parties.

We may share and/or disclose only Aggregate Information and Non-Identifying Information that we collect from our Users.

We may share aggregated information that does not include personally identifiable information and we may otherwise disclose non-identifying information and Log Data with third parties for industry analysis, demographic profiling and other purposes.

Service Providers.

We may employ third party companies and individuals to facilitate or provide our services, to perform product-related services (e.g., without limitation, maintenance services, database management, analytics and improvement of Ringzz features) or to assist us in analyzing how Ringzz products and services are used. These third parties have access to information that we collect from our Users only to perform these tasks on our behalf.

Business Transfers.

We may sell, transfer or otherwise share some or all of our assets, including information collected from our Users in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Compliance with Laws and Law Enforcement.

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information collected from our Users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of ours or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

IV SECURITY

We are very concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable laws on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

V INTERNATIONAL TRANSFER

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the Republic of Serbia and choose to provide information to us, we transfer personally identifiable information to Republic of Serbia or other place of service rendering and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

VI MISCELANEOUS

Our Policy Toward Children

Our Products and services are not directed to children under 14. We do not knowingly collect personally identifiable information from children under 14. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us. If we become aware that a child under 14 has provided us with personally identifiable information, we will delete such information from our files.

Contacting Us

If you have any questions about this Privacy Policy, our practices regarding your personal information related to our Ringzz products and services, or if you would like to have us remove your information from our database and terminate your Account, please feel free to contact us at [email protected].

VII MODIFICATIONS

This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on our website. You are advised to consult this policy regularly for any changes.