Virtual Mobile is committed to ensuring the confidentiality and privacy of our Subscriber’s personal information. We are guided by the Customer Proprietary Network Information (CPNI), Children's Online Privacy Protection Act (COPPA), General Data Protection Regulation (GDPR) (EU), and other applicable data protection laws.
This Data Protection and Privacy Policy below describes the principles and practices that apply to the Personal Information (defined below) that we collect and hold from individuals online or offline (visitor or you), such as individuals who browse through our Site (defined below), register on the Site, use the online services provided on the App/Site, interact with the Site, communicate with us through telephone, email, text or other means, participate in our interviews, surveys or promotions, or read or receive our newsletters.
We made best efforts to make sure that we meet the requirements of CPNI and GDPR, PIPEDA (Personal Information Protection and Electronic Documents Act 2019), and with Indian Privacy and Information Technology Act:
to the best of our knowledge to protect the security of your Personal Information. We will only use and disclose your personal information for the primary purposes of our business when you have given express consent to do so. We do not disclose your personal information to any third party.
In this Privacy Policy, the following terms are defined as set out in this section:
Subscriber means an individual, who subscribed to Virtual Mobile Services.
Personal Information means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether that information is true or not and whether recorded in material form or not. This includes name, date of birth, gender, business/company name, job title, profession, email address, mailing address, telephone number, billing information, account information, and other information incidental to providing or receiving Services.
Site means any of the following websites (or any other websites that Virtual Mobile may develop or have developed from time to time): www.virtualmobile.com.
ABOUT US
Virtual Mobile was formed in the state of Washington, USA. Virtual Mobile enables people to connect with their families, friends, and colleagues anywhere in the world at any time by leveraging cloud and VoIP technologies. Virtual Mobile offers communication products and services handling voice, video, chat, and SMS that connect the legacy with the future by providing reliable services at an economical price.
DATA WE COLLECT OR RECEIVE
In order to provide our Services, we collect device information and contacts from the mobile device. For any interaction on social media, we may verify user data and other information that we receive directly from the social media platforms such as Facebook, Twitter, LinkedIn, and others or via APIs. Such data may include non-personal data such as various statistics and personal data of the platform’s users. We determine the purpose of processing, which is for developing and constantly enhancing our Services and offering them to our Users on a worldwide basis, via our Web and App platform.
The data we collect can include the followings:
Settings. Most of the settings you provide on the "Settings" section of the application will be stored only locally and will never leave your device. However, some settings are required to interact with the Virtual Mobile server, and these might be sent with the SIP signaling or separate channels (usually via secure HTTP). The submitted details are listed in the below points.
Credentials. We collect your username and password for the service you wish to use to be able to login to the Virtual Mobile servers.
Name and contact data. We might collect the user’s name, email address, and other similar contact data to enhance the user experience. These details are not submitted to us during a call but might be collected during signup. Some information like Caller ID is presented in the SIP signaling to be presented to the other end (Called party).
Contact list. Your contact list is displayed within our app to make it easy to call. Your contact list is accessed for the purpose of supporting calls.
Audio and camera. The application must have access to mic and/or camera to be able to fulfill its basic functionality of making calls.
Location data. The website/app might automatically submit user’s location as part of the verification which might be processed by the Virtual Mobile server or VoIP gateway service provider or other service providers. Service providers can also locate users by the IP address from where users connect to the server.
Device ID. The software might generate a GUID for the user’s device which might be used for several features such as auto sign-up (to prevent multiple accounts).
Phone status. Our website/app collects information about the user’s device such as Internet connection type or idle status to determine the best suitable connection method, codec, retry interval, and other details necessary for proper functionality. This information is not submitted anywhere but might be present in the logs.
Logs. Application logs might contain sensitive information such as your VoIP server address and username. We treat all these logs as confidential.
Content. We collect the content of the user’s communications when necessary to provide the user with the services used. For example, if the user receives a message using a Virtual Mobile hosted messaging service, the content of that message is collected in order to deliver it to the end user, display it to the user, enable users to reply to it, and store it for the user until the user chooses to delete it or as applicable. Examples of this data include the content of instant messages, documents, photos, music, and videos user transfers using Virtual Mobile services.
We also collect the content of messages users send to us, such as feedback and product reviews, questions, or information provided to customer support. When you contact us, such as for customer support, emails and/or chat sessions with our representatives may be monitored and recorded.
By using the Site/App and/or submitting Personal Information to us, you consent to the practices described in this Privacy Policy and agree that we may collect, use, disclose, store, transmit, or process such Personal Information in accordance with this Privacy Policy or as required by law.
By providing your Personal Information to us, you acknowledge and agree that:
If you register or create an account – If you register or create an account on the Site/app, we require that you sign up to register with us. We collect your name, contact information and other information, and may ask you for other optional information that helps us serve you better.
If you subscribe for Services – If you subscribe for Service, we collect your contact information as necessary to fulfill the order (such as name, location, email address, telephone number) and any optional information if you provide it.
If you pay for Services – When users pay for our Service, information is redirected to our secure payment processor’s website, which directly collects your payment information. Virtual Mobile only receives a notice of the receipt of the payment, a confirmation number (for verification purposes), the name and contact information of the recipient of the Service, and the name and contact information of the cardholder if different from the name of the person receiving the Services.
If you pay for a Service over the phone or by fax – If we take an order over the phone or by fax, we collect the payment information directly from the person placing the order, transfer it to the payment card processor, and, after receiving confirmation of the payment from the payment card processor, we may retain this payment information under your user account and in accordance with our internal record retention policy.
SOCIAL NETWORK USER DATA
The type and scope of personal data obtained from social media platforms depends on the type of the APIs and permissions set out by the respective platforms, and on the administrative permissions granted to us by our Users, where applicable
Below are the most typical examples of data that may be collected about social media platform users:
We only process data that the social network users made available to the general public, pursuant to the relevant platforms’ terms, and that are generally accessible via the social network APIs, or data that our Users grant us permission to access.
If you participate in a survey – If you choose to participate in one of our surveys, we may collect Personal Information such as your name, email address (to avoid duplicate responses), as well as any other Personal Information that you may provide in your survey responses.
If you sign up to receive a Virtual Mobile newsletter– If you sign up to receive a Virtual Mobile newsletter, we may collect information on the open rate of the newsletter, and whether a specific individual has clicked on a link contained in a particular issue of our newsletter.
If you participate in our blogs or forums or if you write to us – We may collect the Personal Information that you provide in your correspondence and communications with us, or through your participation in surveys, blogs and forums.
If you interact with third parties regarding our products or services – We may receive Personal Information about the user from third parties, such as from websites where we advertise, business partners and service providers. Some of this information pertains to a specific individual; other information can only be linked to an access point or a device.
We use Personal Information in order to provide and enhance the Services that we offer, as explained below:
To facilitate the use of the Service – We may use the Session Data to ease navigation through the Site/App, to enhance navigation (such as to determine the language of the country where the user is located), keep track of login name and password in order to avoid requesting identity information when the user moves from page to page, and in general, to enhance the quality of our Site/App, service and the content provided on the Site/App.
To provide our Services – The Personal Information collected from subscriber order forms is used for user profile creation and for billing purposes. The limited payment information that we receive from our payment processors is used to verify that a Service has been paid for. We recommend that you read the privacy policies and statements that are posted on the relevant third parties websites to understand their procedures for collecting, using, storing, and disclosing Personal Information.
For research purposes – We may use aggregated session data to better understand how our Site is navigated, how many visitors arrive at specific pages, which pages have content attracting more viewers, the length and frequency of stays at our Site, the different types of searches of our Site content and databases, the types of browsers and computer operating systems that our visitors use, and the IP addresses from which visitors connect to our Site, in order to improve our Site and enhance our content.
Use of IP addresses to collect information – Either Virtual Mobile or third-party service providers use the IP information that is not associated with any specific individual. The IP addresses are then disposed of in accordance with our record retention policy. In some cases, the IP address information is used for security purposes.
For maintenance purposes – We may use IP addresses and session data to diagnose problems with our Service and to administer our Site.
For marketing purposes – We may use email addresses or other contact information to send mailings (e.g. for monthly recurring bill in case of a subscription), newsletters. We may use your telephone number to contact you for support and/or marketing purposes. Additional metrics are collected to understand the effectiveness of the communications that we send.
For survey analysis – The information that we collect through our surveys (including surveys administered by our related companies) is not used other than to garner survey results and statistical analysis.
From time to time, we may disclose Personal Information to someone other than the individual who provided this information, as follows:
To defend or enforce our rights – Virtual Mobile may use Personal Information to protect itself or to protect the Site, to respond to a breach of its terms and conditions, to prevent fraudulent activity, or where it is necessary to pursue available remedies.
Related entities – We may disclose any Personal Information we collect to our related entities or may store or process Personal Information using systems which are shared with our related entities.
Merger, acquisition or bankruptcy – If any or all of the Virtual Mobile assets are acquired by, or merged with those of another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all of our users’ Personal Information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing services to our users. If the recipient of the Personal Information has personal information practices that do not meet the substance of this Privacy Policy, you may be given the opportunity to exercise your rights with respect to your Personal Information or you may not use continue to use the service.
Law enforcement and litigation – Certain local, overseas or other government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the information required under applicable law, such as in response to a valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information:
Aggregated data – Other than as stated above, if Virtual Mobile provides a third party with Personal Information, it will be in the form of aggregated data and used for product development, research or statistical analysis. Aggregated data is created from records that are stripped of all personal identifiers, such as a combination of answers to survey questions and instrument responses.
Service providers - In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we share your personal data with service providers who provide certain services or process data on our behalf. Service providers include SIP trunk providers, User relationship management providers, email providers, data storage and hosting providers, our accountants, accounting systems and legal representatives, analytics providers, and User support system providers.
Affiliates - In certain circumstances, we share your personal data with any of our current or future affiliated entities, subsidiaries, and parent companies in order to streamline certain business operations, improve personalization, and develop products and services that better meet the interests and needs of our Users, and provide you with information we believe will be of interest to you.
Social Media - In order to improve personalization, deliver more relevant advertisements, and develop better products and services, in certain circumstances and where permitted by applicable law, we share certain personal data with current or future affiliated entities and trusted third parties that provide marketing, advertising, or similar promotional services , and in certain circumstances we will allow third parties (such as Facebook, Google, ad exchanges, data management platforms, or ad servers) to operate on our Site and process data for behavioral advertising.
Corporate Events - Your personal data will be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, it is possible that personal data will be part of the assets transferred or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
We retain information associated with the user ID or transactions that our Users provided us in accordance with our internal record retention policy and/or as per mandates by the state or federal government. Thereafter, we retain the Subscribers records in an anonymized format for as long as the information is needed for legal purposes, our research, statistical analysis or product development.
Security – We follow generally accepted industry standards such as CPNI and GDPR to protect personal information, during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect it from unauthorized access, loss, misuse, disclosure, alteration or destruction.
Encryption - Any data collected by Virtual Mobile. for the purposes of assessments and to provide its Services may be protected by encryption. This means we may keep data in an unreadable state unless a user or process presents the appropriate key. In accordance with data protection regulations, this simple control method restricts data processing only for authorized use and restricts the amount of time that you are identifiable by your data. Our data may be encrypted at rest and in transit. Encryption prevents unauthorized data manipulation; limits data access to authorized users and monitors key usage to ensure that the data cannot be changed without authorization. Virtual Mobile ’s use of encryption together with our access controls provides users to have confidence in their data’s integrity.
Transit – When we need to transfer information out of our firewall, we may use encryption methods to protect your data while in transit through the Internet. We may use encryption and a comprehensive authentication protocol to provide reasonable security. Therefore, while we use the highest standards commercially available to protect your personal information, no method of transmission over the Internet or method can ever guarantee its absolute security.
Identity theft – Identity theft and the practice currently known as 'phishing' are of great concern to us. Please understand that you also have a responsibility in protecting your information. The only time when Virtual Mobile associate may contact you (via electronic communication, telephone, etc.) about your credit card or payment information is in connection with a transaction that you have initiated. Otherwise, no one from Virtual Mobile will contact anyone to request your credit card information, national identification number, or other identifier or sensitive information in a non-secure or unsolicited email or telephone communication.
While providing Services to you, we collect and maintain certain Customer Proprietary Network Information (“CPNI”). CPNI includes the types of services you currently purchase, related usage and billing information for those services. We value our relationships with our Users and are committed to respecting and protecting your CPNI and to comply with applicable law regarding CPNI. Accordingly, we do not sell, trade or share your CPNI, including your calling records outside of Virtual Mobile’s group of companies, including our Affiliates, or with anyone not authorized to offer our products or services, or to perform functions on our behalf (e.g. operational service providers) except as authorized by you or required by law. Generally, we can use your CPNI to offer additional services to you, and for billing and collections purposes. We can also disclose your CPNI for legal or regulatory reasons, including in response to subpoenas, court orders and the like. We can also use CPNI to investigate fraud and to prevent violation of our policies and agreements and unlawful use of our network and services.
We will exercise reasonable efforts to keep your Personal Information accurate. However, we need your help in making sure that your Personal Information is correct in our systems. Please notify us of changes to information that you have previously provided by contacting us as indicated in the Contact Us section (below).
INTERNATIOANL DATA TRANSFER
Whenever we transfer your personal data out of the European Economic Area (EEA) to provide an adequate level of personal data protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal data, where required by EU data protection legislation:
• Contracts approved by the European Commission which impose data protection obligations on the parties to transfer. For further details, see European Commission Model contracts for the transfer of personal data to third countries.
• For transfers to third parties in the United States, ensuring they participate in the E.U.-U.S. Privacy Shield Framework.
EU-US privacy shield - Virtual Mobile complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries. Virtual Mobile adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability with respect to all personal data received from the EU in reliance on the Privacy Shield program. Furthermore, we require any third-party recipients of EU citizens’ personal data to agree to respect these principles, and we accept liability for third parties’ processing of EU citizens’ data to the extent required by law.
If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov.
Right of access, modification – In general, you have the right to access your Personal Information and to correct or update the Personal Information that you have provided to Virtual Mobile. If you wish to do so, please contact us with proof of identity, as provided in the Contact Us section (below). You can expect a response to your request within a reasonable period of time.
If you are a Subscriber to the Service and you wish to have access to a copy of your responses to an Assessment or a copy of the Assessment Report that Virtual Mobile prepared from the evaluation of your responses, please contact the Virtual Mobile support personnel who is managing your specific Assessment.
Right to be forgotten – If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us with proof of identity, as provided in the Contact Us section (below). We will accommodate your request to the extent practicable and to the extent that it does not otherwise conflict any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Right to opt-out of the use of your Personal Information – If you wish to opt-out of direct communications, you can always do so by contacting us as set out in the Contact Us section (below) or may not continue to use the service. In some cases, we may not be able to remove your Personal Information, in which case we may let you know. You may also unsubscribe from receiving a newsletter by contacting us as set out in the Contact Us section (below) or clicking on the unsubscribe link provided in the newsletter.
CHILDREN (COPPA)
The Virtual Mobile Services are not intended for use by children and Virtual Mobile does not knowingly collect or solicit personal data from children. In the US, for data protection purposes, a child is anyone under the age of 13. In the EU, a child is anyone under the age of 16.
If you are a child, you may not attempt to register for the Virtual Mobile Services or send any information about yourself to Virtual Mobile, this includes name, email address or phone number. In the event that we confirm that we have collected personal data from children without verification of parental consent, we will delete that information. If you are a parent or legal guardian of a child and believe that we might have any information from or about such child, please contact us at support@Virtual Mobile.
If you have questions or complaints regarding our privacy policy or practices, you should first contact Virtual Mobile as indicated in the Contact Us section (below). We will respond to you within a reasonable period of time and will attempt to resolve all complaints promptly.
If we are unable to satisfactorily resolve your concerns about the privacy or handling of your Personal Information, you can contact the respective governing agency to submit a complaint.
From time to time we will revise and change this Privacy Policy. If we make material changes, we may place a prominent notice on the Site or may send you a notice to the email address that you provided to us.
If you have any questions or complaints about (i) this Privacy Policy, (ii) the collection, use, management, or disclosure of your Personal Information, or (iii) accessing or modifying your Personal Information please contact us as indicated below. We will attempt to respond to your questions or concerns in a timely manner after we receive them.
By email: support@virtualmobile.com
CONSENT
By using our Website or App, you hereby consent to our Privacy Policy and agree to its Terms and Conditions.