Last updated: October 2024
Privacy Policy

WE HAVE CREATED THIS PRIVACY POLICY BECAUSE WE HIGHLY VALUE YOUR PERSONAL DATA.
THIS PRIVACY POLICY INCLUDES IMPORTANT INFORMATION IN RESPECT TO YOUR PERSONAL DATA.

1. Privacy Statement
Callup Net Ltd. (“Callup” or “we”) develops and provides Mobile Device Management products and solutions for the telecom industry (the “Products” and / or “Services”).

THIS PRIVACY POLICY REFERS TO THE PRODUCTS AND RELATES TO CALLUP’S CUSTOMERS, POTENTIAL CUSTOMERS, END-USERS WHO ACQUIRE PRODUCTS AND CALLUP’S EMPLOYEES.

1.1. This Privacy Policy sets forth Callup's policy with respect to:
1.1.1. “Personal Data” - Any Information that can be associated with or which relates to a person and/or could be used to identify a person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, all as defined by the General Data Protection Regulation (GDPR) (EU) 2016/679. 
1.1.2. "Non-Personal Data" is therefore any information that does not relate to an identified or identifiable natural person.
1.2. The limitations and requirements in this Privacy Policy relate only to our gathering, use, disclosure, transfer and storage/retention of Personal Data, but do not apply to Non-Personal Data.
2. DATA WE COLLECT OR RECEIVE
2.1. Using, receiving, collecting, processing or storing Personal Data is not our primary purpose and is processed on customers premises and / or cloud.  Callup uses, receives, collects, processes or stores only Personal Data necessary to provide the Products and operate its business. However, in the course of running our business, we might use, receive, collect, process or store Personal Data relating to potential and actual customers, end-users, service providers and suppliers, employees, and/or others.
2.2. Types of Personal Data.
2.2.1. Personal Data on potential, actual customers, service providers and suppliers may include names, contact details such as, phone numbers, email addresses, addresses, financial information (i.e. billing information, bank account information, payment information), information as to how the Products are accessed and used including information such as computer IP addresses, browser types or versions, the times and dates of visits, the time spent on each page, unique device identifiers and other diagnostic data and ticketing information as per IT support process.
2.2.2. Employee and candidate data may additionally include social network contact accounts, employee’s health information, employee and candidate CVs and other related employment information.
2.2.3. Personal Data on end users data may include phone number, product password such as, voicemail password, Traceability logs of changes, Product usage such as audio recordings and transcript of a voice messages created within the Products.
2.3. Categories of sources. We obtain the categories of personal information listed above from the following categories of sources:
2.3.1. Directly from you. For example, through information we ask from you as a customer engaging our Services.
2.3.2. Directly from our customers or their agents. For example, from information our customers provide to us related to the Services for which they engage us.
2.3.3. From Third Parties that contract with us or interact with us in connection with the services we provide. For example, from (i) vendors and/or partners that help us to build contact lists, supplement or update your information in our database, or confirm/verify our records and information are accurate and up to date (ii) third parties (including, other B2B contact providers) that integrate their services with ours or provide us access to their services.
2.4. Legal Basis for the Processing of Personal Data. This Information provided to us voluntarily and/or through the data owner’s consent to collect and process it, and/or the processing thereof is necessary to meet contractual obligations entered into by the data owner and Callup, and/or the processing thereof is necessary for Callup to comply with its legal obligations, and/or the processing thereof is for the purposes of legitimate interests pursued by Callup.
3. USE AND PROCESS OF DATA.
3.1. We use this Personal Data in a manner that is consistent with this Privacy Policy and applicable laws and regulations. We may use the Personal Data for purposes as follows:
3.1.1. Processing and analyzing.  in order to provide the Products and conduct its business, Callup may use Personal Data for processing and analyzing purposes.
3.1.2. Specific Purpose. if you provide Personal Data for a certain purpose, Callup may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact Callup by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
3.1.3. Internal business. we may use your Personal Data for internal business purposes, including helping us improve the content and functionality of the Services, to better understand our customers and users, to improve our Services, to protect against, identify or address wrongdoing, to enforce our contracts and this Privacy Policy, to provide you with customer service, and generally to manage and operate our business.
3.1.4. Marketing. Personal Data provided to us by you may be used by us to contact you in the future for our marketing and advertising purposes, including informing you about new products we believe might be of interest to you and developing and delivering promotional or marketing materials. If by mistake you receive direct marketing without your specific consent or wish to opt-out, please contact us at [email protected].
3.1.5. Statistics. Personal Data provided to us by you may be used by us for statistical reports containing aggregated information.
3.1.6. Security and dispute resolution. we may use Personal Data to protect the security of our Products, to detect and prevent cyber-attacks, fraud, phishing, identity theft, data leakage, to confirm the validity of software licenses, to resolve disputes and to enforce our agreements.
3.1.7. Development and customer support team. we may need to share Personal Data with our development and customer support team. For example, to provide customer support or to assist in protecting and securing our systems and services, our development and customer support team may have access to Personal Data. In such cases, we ensure that our development and customer support team is bound to maintain the Personal Data in accordance with this Privacy Policy.
3.1.8. Law Enforcement. In order to, for example, respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Website and Services or the public, or (e) protect against legal liability
3.1.9. Other Purposes. If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is processed.
3.2. IF YOU HAVE A REASONABLE BASIS TO ASSUME OR YOU KNOW THAT ANY OF THE ABOVE MENTIONED IS NOT MET, YOU ARE REQUIRED TO PROMPTLY INFORM US, WITHOUT DELAY, BY SENDING US AN EMAIL TO: [email protected].
3.3. Non-Personal Data: Since Non-Personal Data cannot be used to identify you, we may use such data in any way permitted by law.
4. TRANSFER, SHARE, DISCLOSE AND SALE OF DATA
4.1. General. We may share your Personal Data with our affiliates, partners, contractors and service providers who process Personal Data on Callup's behalf to perform certain business-related functions. When doing so, we ensure that they are bound to maintain the Personal Data in accordance with this Privacy Policy.
4.2. Corporate Sale, Merger, Reorganization, Dissolution or Similar Event. Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Callup (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.  
4.3. By Law. We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Products, (d) act in urgent circumstances to protect the personal safety of users of the Websites and  Products or the public, or (e) protect against legal liability.
4.4. Personal Data may be processed by third party service providers. We transfer to such providers only the minimum data that is necessary for conducting our services. The data is transferred only to suppliers approved by us that allow compliance with the GDPR.
5. INTERNATIONAL DATA TRANSFERS.
• Personal Data may be transferred stored and processed in countries outside the EU or European Economic Area (EEA). Such transfer to third countries may include countries that do ensure the same level of data protection laws as required by EU privacy laws. In such cases, we implement information security techniques and technical measures or third parties' contractual obligations to maintain such Personal Data at the same security level as other Personal Data that Callup administers.      
• We may transfer Personal Data to Israel and maintain it there. Callup's headquarters are in Israel. Israel's data protection law is considered by the EU as adequate.  
6. DATA RETENTION AND ARCHIVES.
6.1. We retain and archive Personal Data so long as it is necessary to operate our business and maintain our Services, meet contractual obligations, laws and regulations, and are subject to our retention policies and this Privacy Policy.
6.2. We may retain your Personal Data for any period permitted or required under applicable laws. Even if we delete your Personal Data, it may remain stored on backup or archival media for an additional period of time due to technical issues or for legal, tax or regulatory reasons, or for legitimate and lawful business purposes.
7. PERSONAL DATA SECURITY
7.1. We are strongly committed to the protection of your Personal Data, and we will take commercially reasonable technical steps, of the sort commonly accepted in our industry, to keep your Personal Data secure and to protect it from loss, misuse or alteration. However, no network, server, database, Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you disclose.
7.2. If you notice a risk or any security violations, please report to us on [email protected], so that we can attempt to resolve it as soon as possible.
7.3. We recommend that you use, disclose and share your Personal Data with caution and don’t give out Personal Data unless it is necessary, as we cannot guarantee the security of data over the Internet and cannot control actions of other users of the Products with whom you choose to share Personal Data.
7.4. Callup implements legal, technical and organizational information security measures, based on the ISO certification mechanism method of ISO 27001:2013 - Information Security Management System. Callup is ISO 27001 certified.
8. YOUR RIGHTS.
8.1. You may have the right to request access to some of your Personal Data being stored by us; you can also ask to correct, update or delete any inaccurate Personal Data that we process about you – all are subject to our policies and to applicable law and regulations. In order to exercise these rights, please contact us at: [email protected].
8.2. You may have the right to restriction of processing if one of the following apply:
8.2.1. The accuracy of the Personal Data is contested by you;
8.2.2. Unlawful processing has occurred and you object to deletion of the Personal Data and requests restriction of its use instead;
8.2.3. Your service provider no longer needs the Personal Data for the purposes of the original processing, but the data is required by you for the establishment, exercise or defense of legal claims;
8.2.4. You have objected to processing pending verification whether the legitimate grounds of your service provider override yours.
8.3. If you wish to object to processing, please contact us at [email protected].
8.4. If you have the right to lodge complaints with supervisory authorities, we would appreciate your contacting us first in order to solve the issue for the benefit of all parties. Please contact us by email to [email protected] Our supervisory authority is the Israeli data protection authority.
9. General
9.1. This Privacy Policy applies only to Personal Data that you provide to us.
9.2. This Privacy Policy applies only to the Products. It does not apply to third party’s websites or services, even if they link to our Products. The existence of a link from a third party’s website or services does not imply that we endorse or have reviewed the third-party's websites or services. We suggest contacting such third parties directly for information on their privacy policies.
9.3. You provide Personal Data to us consensually either on a case-by-case basis or in a broader contractual context.
9.4. We will use your Personal Data in a manner that is consistent with this Privacy Policy and applicable law and regulations.
10. Changes in terms
10.1. The Products and our business and the regulatory environment in which they function may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time. Modifications to this Privacy Policy will be posted to the Websites with a change to the “Last updated” date at the top of this Privacy Policy.
10.2. Please review this Privacy Policy periodically, and especially before you provide any Personal Data or information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Products following the effectiveness of any modifications to this Privacy Policy constitutes acceptance of those modifications. If any modification to this Privacy Policy is not acceptable to you, your sole remedy is to cease accessing, browsing and otherwise using  our Products. 
11. Dispute Resolution.
11.1. If you have a complaint about Callup’s privacy practices, please write to us at: [email protected] We will work with you to attempt to resolve your complaint.
11.2. The laws of the State of Israel govern this Privacy Policy. The competent courts in the district of Tel Aviv in Israel have exclusive jurisdiction with regard to any dispute that may arise in connection with this Privacy Policy.
11.3. If you have a complaint about Callup’s privacy practices, you should write to us at: [email protected].
11.4. EU Representative - Our representative in the European Union is “Stanga AD”. You may contact our representative at:
Address: 43, Cherni Vrah Blvd, 1407 Sofia, Bulgaria.
Tel:  +359 897 818 277
Email: [email protected]