Last updated: May 5, 2022
1. What Is Personal Information?
Personal Information is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
In other words, personal information is any information about you that enables you to be identified. Personal information covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
2. Collecting, Using, and Sharing Your Personal Information
Yolla may collect Personal Information as you interact with the Product, the Services, and the Site as described below. We endeavor to collect only the information which is relevant for the purposes of processing, provide our users with all means to rectify the information, and delete the information that is no longer necessary for the purposes for which the data is processed.
(I) Types of Personal Information Yolla Collects
Yolla collects Personal Information regarding its current, prospective, and former users, visitors, guests.
- Information you provide directly to Yolla through interacting with the Product, the Services, and the Site, participating in surveys, and contacting the support. Yolla collects information when you register, sign in and use our Product and Service. When you install the Yolla App or register on the Site, you will be required to provide us with your phone number, which is used for identification purposes as your Yolla user ID. Yolla also collects your email in order to send you important updates about your account changes and payment confirmations.
You may allow Yolla App to access your mobile device’s address book in order to: call your contacts from the applications; receive the notifications when your contacts sign up to Yolla; see which of your contacts already uses Yolla; see the name of contact as it appears in your address book when you receive or make a call; sync your contacts with the web application. To provide these services, the copy of your address book (only names and phones) is stored on the Yolla servers.
Since other Yolla users may add your Yolla number to their address book and see that you registered to Yolla, we do not consider the fact that your number exists on Yolla as a private information.
- Yolla may collect certain information automatically. Yolla may read the contents of the activation SMS sent to you by Yolla for the sole purpose of service activation. Yolla will not read the contents of any other messages on your device.
Yolla keeps the phone numbers and/or other identification details of the calling and receiving party, start time, call duration, call quality, and Call Detail Record (CDR) for the calls that are made with the Yolla Product and Service. These are industry standard records used by all phone companies for billing and statistics analysis that only contain technical information about calls. We do not record any part of your call.
Yolla may collect certain information through the Product, the Services, and the Site, or methods of web analysis and technologies, such as your IP address (an IP address is a number that can identify a specific computer or other network device on the internet), cookie identifiers (“cookies”), mobile advertising identifiers, and other identifiers that are automatically assigned to your device, location data, browser type, operating system, Internet service provider, mobile carrier, pages that you visit before and after using the Site, the date and time of your visit, the amount of time you spend on each page of the Site, information about the links you click and pages you view on the Site, and other actions taken on the Site. We analyze this data for trend, statistics and security reasons, e.g. to identify the location of users from different countries and to block disruptive and fraudulent use.
Yolla does not store banking card data – the card information is safely treated by the payment processing system. For your convenience, you may still opt in to use the same card for your next payment. In this case, you will not be required to enter the card details again, and the payment processing system will use the payment details you have already provided.
We may also use mobile advertising identifiers to recognize your device and perform the services. Depending on your device, you can choose to change or limit the transmission of your mobile advertising identifier by going into your device settings. If you would like to opt out of other technologies we employ to collect certain types of information, you may do so by blocking, deleting, or disabling them as your browser or device permits.
- Yolla may also obtain information about you through third-party services as described below to supplement information provided by you. This supplemental information allows us to verify information that you have provided to Yolla and to enhance our ability to communicate with you, and to detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues.
We may use your personal data in order to provide our Services, including improving your satisfaction and loyalty. The purpose of data processing is to improve co-operation, promote loyalty and maintain satisfaction (loyalty call, service call for a person with the goal of improving their experience, identifying desires and needs, identifying a person’s satisfaction). We may occasionally ask you to provide information on your experiences of using the Product and the Services. Such information is used to improve the quality of the Services.
(III) Analytics Information
Yolla may use Google Analytics and Yandex Metrics to collect, process, and analyze trends regarding Site visitor behavior and demographics. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. You can also out opt of Yandex Metrics following this link https://yandex.com/support/metrica/general/opt-out.xml
We use these tools in our client software for analytics & communications with users:
(IV) The Purposes of the Processing
Yolla collects your personal information for the purpose of:
- Providing our Services: we use your registration and account data to (i) sign you up for the Product and create your user account for Yolla; (ii) create your profile and make it visible; (iii) process your payments; (iv) provide customer service, give you information about your account, and respond to your requests; (v) indicate which of your contacts is already a Yolla user and notify you when your contacts become active on the Service (vi) display the name of the contact as it appears in your address book when a call is received on the Service, and (vii) sync your contacts with Yolla running on different devices.
- Improving our Services: we use call log information and usage information (as described above) to better understand network behavior and trends (numbers of calls made by users, typical destinations, call durations, network type, etc.), detect potential technical issues.
- Processing your payments: we may use your information like your name and phone number to process your payments for our Services and mobile top-ups through a secured third-party service provider and, on an aggregate basis to determine charges for our phone carriers and other service providers.
- Personalizing and optimizing our Services, promotional content and advertising to you. For example, we may use the information we collect through cookies, ad identifiers and similar technologies to show you ads you may be interested in.
- Communicating with you: we use your information to contact you (via message or other means) to maintain the Product, to comply with your stated communication preferences or to provide updates about other Yolla’s services.
- As otherwise expressly set out in this Policy or as required by law.
(V) Sharing of Personal Information
In order to provide you with the Service you have requested, enhance your user experience, and improve the Product and Service, Yolla may sometimes, if necessary, share your personal information with trusted partner service providers, including, but not limited to: payment and analytical services, customer support, hosting services, quality control of services, safety and protection, providing organizational management. Yolla will always require these third parties to take all necessary measures to protect your personal data and to observe the relevant legislation. The following is a description of how we may share your personal information with trusted third-party partners:
- We use third-party companies in order to send you an authentication SMS when you register with Yolla. In order to send you the SMS, we send one of these third-party companies your phone number and the authentication message. These third parties are obligated to use your phone number for the transmission of the authentication SMS only.
- If you do not receive an SMS you may ask us to call you and read you the authentication code. This is done using a third-party automated phone system. In order to call you, we provide this third-party partner with your phone number and send the “audio content” of the call to them. The third-party partner in turn will typically use another phone provider who may use another phone provider and so on until the call reaches you. This is an industry standard mechanism. The third-party partner is obligated to use your phone number for the completion of the authentication phone call only.
- We use third-party companies in order to deliver SMS texts that are sent by users. These third parties are obligated to use your phone number, the phone number of the receiving party, and the text message for the transmission of the text only.
- We use payment solution providers to process the payment and/or billing information. We require that these third parties take the appropriate organizational and technical measures to protect your personal information and to comply with relevant laws, but we are not liable or responsible for these third-party transactions. Therefore, you should review such third-party terms and conditions before providing your payment or billing information.
- Yolla uses third-party services to provide the functionality of the money transfer service. We provide a limited amount of your personal information (such as email address, full name, and date of birth) to Remitly, Inc. As a data processor acting on our behalf, Remitly uses your personal information to provide the money transfer service envisioned by our partnership. For more information on Remitly’s use of personal information, please visit https://www.remitly.com/us/en/home/policy. Remitly, Inc. can act as a medium for communications through email. Remitly’s services are governed by Remitly’s user agreement, which can be found at https://www.remitly.com/us/en/home/agreement.
- We use third-party services to provide the VPN functionality – one of the top VPN market players.
The following information may be kept and stored in regards to using the VPN service:
- Bandwidth use and consumption
- Software analytics and statistics (device-specific information, such as device model, operating system version, browser type, mobile network information)
- Data from emails, live chats, and feedback forms you send or submit to Yolla (correspondence, be it questions, complaints or compliments submitted via our apps, website or extensions)
However, Yolla does NOT store any logs that can identify or help in monitoring the User’s activity (information is processed only as it is needed to provide the service). None of the following records are stored:
- Browsing activity
- Identifiable connection logs
- Records of assigned IPs
- Connection time
- Browsing history
- Sites visited
- Outgoing traffic
- Content or data accessed
- DNS queries generated by the user
Yolla engages data processors for carrying out specific processing activities on behalf of Yolla imposing strict data protection obligations as set out in the applicable data protection laws. Where the performance of the services involves an international transfer of personal data, we ensure that strict data protection agreements are in place with all providers.
We may disclose your personal 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 Yolla’s user to legal liability. We also may share your personal information with market supervisory authorities.
3. Children’s Privacy
We do not knowingly collect personally identifying information from anyone under the age of 16 (in some jurisdictions 13). Unless we have parental consent, we will not contact a child under the age of 16 for marketing purposes. We may collect, use or share information about customers who log onto our websites and/or email accounts as described in this Policy. You can manage your account by logging on.
Information collected from devices or services purchased by adult subscribers that are used by children without our knowledge will be treated as the adult’s information under this Policy.
If a parent or guardian becomes aware that his or her child under the age of 16 has provided us with Personal Data without their consent, he or she should contact Yolla at firstname.lastname@example.org. We will delete such Personal Data from our files within a commercially reasonable time, but no later than required under the applicable law relating the minor’s country of residence.
4. Data Retention Periods
We process your personal data no longer than 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. The retention period may be based on agreements with you, the legitimate interest of Yolla or applicable law (such as laws related to bookkeeping, statute of limitations, civil law, etc.). 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 take reasonable precautions to protect personal information including physical, electronic, and procedural safeguards. Private information is stored on servers with limited access in controlled facilities, and payment information is protected with Secure Socket Layer (SSL) encryption when transferred over the internet. Although we cannot guarantee that personal information will not be subject to unauthorized access as no method of transmission over the Internet, or method of electronic storage, is 100% secure.
6. Geographical Area of Processing
We may, for the purposes set forth herein, transfer, process and store your information in Estonia, Germany, or any other country in which Yolla or its affiliates, subsidiaries, suppliers or agents maintain facilities. Information collected within the European Union/European Economic Area (EU/EEA) may, for example, be transferred to and processed in a country outside of the EU/EEA, which may not provide the same level of protection for personal data as within the EU/EEA. Transfer and processing of personal data outside the EU/EEA can take place provided there is a legal ground, i.e. legal requirement conclusion or performance of an agreement or client’s consent and appropriate safeguards are in place.
7. Your Rights
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data.
- The right to access the personal data we hold about you.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us at email@example.com
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your data protection authority.
8. Email Marketing
For email marketing to an individual subscriber (that is, a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing.
Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal.
You have the right to opt out of receiving email marketing communications from us at any time by:
- contacting our Data Protection Department at firstname.lastname@example.org
- using the “unsubscribe” link in emails.
9. Legal Basis for Processing Your Personal Data
Our legal basis to process your personal information will be one of the following:
- to fulfill our contractual obligations to you, for example to provide the services;
- consistent with your consent, which you can revoke at any time;
We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to Cookies or when we process accurate location data for purposes other than performing the service).
- to comply with our legal obligations to which we are subject;
- to meet our legitimate interests. 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.
It is important for us that we have truthful and up-to-date information about your personal data. If your personal data has changed, and if you have found that we process inaccurate or incomplete your personal data, we ask you within a reasonable period of time to inform us about the need to make corrections.
Yolla may make some changes to this Policy from time to time without notice. Yolla will publish the changes at www.yollacalls.com/privacy. The changes will be effective when published. You agree to review the Policy periodically so that you are aware of any modifications. If you continue to use the Product and the Service after the date of amendment publication, it shall constitute that you accept the updated Policy. If there are any material changes to this Policy, we will notify you by email or as otherwise required by applicable law. Yolla will also post any adjustments to the Policy on this web page, and the revised version will be effective immediately when it is published (or upon notice as applicable).
11. Your California Privacy Rights
For Information on your California Consumer Rights, please see: California Consumer Privacy Rights Notice (“Notice”).
12. Contact Us
If you have any questions, please contact us at: Yolla Calls International OÜ, Attention: Data Protection Department, Rävala pst 6-404A, Tallinn city, Harju county, Estonia or by email at email@example.com