1.Introduction
We, PremaTel Ltd. (“PremaTel,”“we,”“us,”or“our”), believe your privacy is important.

To fulfill our commitment to respecting and protecting your privacy, we will adhere to the following principles:

1.We will inform you of the personal information that will be collected, and, where appropriate seek your consent to collect, process, use, or disclose your personal information.
2.We will identify the purposes for which we will collect and further process your personal information.
3.We will only collect information that is necessary to carry out the identified purposes of use.
4.We will use or disclose your personal information only for the purposes for which it has been collected, except with your consent, or as required or permitted by applicable law, and we will retain your information only as long as necessary to fulfill those purposes.
5.We will endeavor to ensure that your personal information is accurate, complete, and up-to-date.
6.We will implement appropriate technical and organizational measures to protect your personal information.
7.We will make our policies and practices for the handling of your personal information as transparent as is reasonably possible.
8.You will have access to your personal information and will be able to correct your personal information as appropriate in accordance with your rights under applicable law.
9.We will be accountable to you. We are interested in hearing your opinion regarding our compliance with these principles, this Privacy Policy, and applicable laws.

2.Scope of This Privacy Policy

a.Purpose of This Privacy Policy
This Privacy Policy explains how PremaTel will process and safeguard your personal information, and the rights and choices you have with respect to your personal information. This Privacy Policy applies to: personal information you provide us when you use the PremaTel communication app (“PremaTel App”), optional services made available within the PremaTel App, and other apps that integrate with or work in conjunction with the PremaTel App (collectively “Apps”); personal information we collect when you visit websites maintained by us relating to our Apps (“Websites.” Apps and Websites are collectively referred to as “Services”); and personal information about you provided by other users of the Service.

b.What Privacy Policy Applies to Other PremaTel Services?
Users may request additional services from PremaTel or PremaTel affiliates (“Additional Services“). Because the needs and choices of each user may vary, we provide separate privacy policies or addendums to this Privacy Policy for certain Additional Services. The separate privacy policies and addendums explain the types of information we collect, their purposes of use, and other policies that may apply to the relevant Additional Services. When you choose to use an Additional Service, you will be informed of the applicable privacy policy or addendum, which supplements or modifies this Privacy Policy before you can access that Additional Service.

3.Types of Personal Information We Collect

a.What Personal Information Does PremaTel Collect?
When you create an account and use Services, PremaTel collects, uses, and transfers the following types of information:

i.Information Concerning Your Account
When you create a PremaTel account in order to access the Services (an “Account”), PremaTel will ask you to provide your phone number. This information is necessary because we may send a text message via SMS to the phone number you provide, as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of or abuse of Services. We may also use your registered phone number to provide you important information about Services.

If you choose to enable the “Allow Others to Add” feature, your phone number is used to let other users who have your phone number in their address books add you as a PremaTel Friend, and to allow other PremaTel users who have your phone number to find you. Please note that you can at any time choose to enable or disable this “Allow Others to Add” feature in the App, in “Settings” > “Friends”.

ii.Device Information and Access Logs When You Use Our Service
When you use Services, we may obtain and maintain certain electronic identification or log data that is automatically provided by your device such as: device type, OS type, IP address, browser information including type and language settings, device identifier, cookie data, advertising identifier or mobile application identifier.
This information is necessary as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of, or abuse of, Services, as well as to provide you with customized options, and optimize the Service for your device. Also, please note that a third party advertising identifier may be associated with your Account through our internal identifier.

b.What About Information I Create About Myself and Share With Others?

i.User-Generated Content [OPTIONAL]
In addition to the information described above, you may choose to set your profile information (e.g., PremaTel ID, “display name,” profile picture, the phrase you choose to show under your status message, date of birth, etc.) and show who you are to other PremaTel users or corporate account administrators within Services. Furthermore, you may choose to create “user-generated content” such as text and audio messages, photos, videos, geolocation data, or the contact information of your PremaTel friends, and share this user-generated content with other users. For some of the profile information, such as date of birth, you may choose whether or not to make it public. You may also choose how much or little of your user-generated content to share, and with whom you share it, when you create messages by selecting the recipients of your user-generated content and/or through the privacy settings in the PremaTel App.

Please note that the profile information and user-generated content you share with others can be copied, stored, or disseminated by the recipients and potentially accessed by unintended third party recipients due to the nature of digital data. We encourage you to be very attentive and cautious when you generate and share your personal information or content with others.

Furthermore, corporate account administrators that you have added as friends view your information and may store your data in servers located in their respective countries or regions. Please note that some of the countries or regions where your data is transferred to do not have the data protection laws at the level that is required in your country or region. If you do not wish your data to be transferred, you may at any time block such corporate accounts.

4.Your Choices, Your Rights

There is a possibility that PremaTel may obtain personal information relating to individuals who are currently not users of Services. Please note that, regardless of whether or not you are a user of Services, you have the choices and rights set out in this section if we hold your personal information.

a.How Do I Control My Information?
Subject to applicable law (including any exemptions or derogations under such law), you may have a right to access your personal information, to have errors in your personal information rectified, to object to the processing of your personal information on legitimate grounds, data portability, etc. You can exercise some of these rights directly within the PremaTel App at any time. For example:
•under your “Profile” in “Settings” in the App, you can confirm and/or revise your phone number, and you can confirm and revise your display name and profile picture.

5.Other Important Information

a.A Special Note about Children in the United States of America or in Europe
The Service is intended for a general audience and is not directed at or intended to be used by minors under the age of 13 (under the age of 16 in Europe) (“Children”).

We understand the special necessity to protect Children's online privacy, and we do not knowingly collect any personal information from Children.

If, however, you believe we have collected any personal information from Children, then please let us know via the Contact Form. If you would like to send us a written request, please refer to Section 6.b for our mailing address.
If we learn that we have inadvertently collected personal information from Children, we will deactivate the relevant Account(s) and will take reasonable measures to promptly delete such personal information from our records.

b.Changes to This Privacy Policy
We may modify our Privacy Policy from time to time for various reasons including to improve our privacy practices, to reflect changes to our Service, and to comply with relevant laws.

When we make any material changes to our Privacy Policy, we will notify you on our Services, or by other reasonable means. We encourage you to review changes carefully. If you agree to the changes, then please continue to use our Service. If, however, you do not agree to any of the changes and you no longer wish to use our Services, you may choose to close your Account. Continuing to use our Services after a notice of changes has been communicated to you or published on our Services constitutes your acceptance of the changes and consent to the modified Privacy Policy. We seek your consent when applicable law requires.

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