Dingo (“Service”) is a service provided by Dingo EU s.r.o. belonging to a company registered at Husitská, 502/36, Žižkov, 13000 Praha 3, Czech Republic. It offers you (“you” or “your” – registered user & licensee under these Terms) call-making & other connection services (“Service”) exercised via Dingo’s licensed smartphone applications (“Licensed Application” or “Product”).
Personal information is an information that can be used for the purposes of identifying or contacting an individual (i.e. – your name, address, e-mail address, phone number and other private information associated with such personal details).
By downloading and/or using the Product and the Service you acknowledge Dingo’s Privacy Policy & Terms of Use and agree with it. In case if you are disagreeing with any part of present Policy or Terms, you cannot use the Product and/or the Service.
Dingo reserves the right to make certain alterations & changes to this Policy from time to time, without notice. Dingo will always publish any changes at www.dingo.app/privacy. The changes will come into effect immediately after being published. If choosing to use our services, you automatically 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 when an amendment has been published, we will take it as your acceptance of updated Policy. If you do not agree with amended Policy, you need to terminate your relationship with Dingo. If there are any substantial changes to this Policy, we will notify you by email or as otherwise required by applicable law. Dingo will also post any adjustments to the Policy on this web page, and revised version will come into effect immediately after it has been posted (or upon a notice as applicable).
If you have any questions related to our Privacy Policy, please contact us at [email protected]
Dingo may collect Personal Information as you interact with the Product, the Services, and the Site as described below. We endeavor to collect only an information that is relevant to the purposes of processing, provide our users with all means to rectify this information and delete the information that is no longer needed for the purposes the data has been processed for.
Dingo collects Personal Information related to its current, prospective & former users, visitors and guests.
(a) An information you provide directly to Dingo by interacting with the Product, the Services, and the Site, participating in surveys, and contacting the technical support. The information is collected when you register, sign in and use our Product and Service. When you install the Dingo 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 Dingo user ID. Dingo also collects your email in order to send you important updates concerning any changes on your account, as well as payment confirmations. You may also opt in to receive an information about Dingo’s special offers and bonuses.
You may enable Dingo 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 Dingo; see which of your contacts already use Dingo; see the name of a contact as it appears in your address book when you receive or make a call; sync your contacts with the web application. In order to provide these services, the copy of your address book (names and phone numbers only) is stored on Dingo’s servers.
Since other Dingo users may add your Dingo number to their address book and see that you are registered with Dingo, we do not consider the fact that your number exists on Dingo as private information.
(b) Dingo may collect certain information automatically. Dingo may read the content of the activation SMS it has sent to you for the sole purpose of service activation. Dingo will not read the content of any other messages on your device.
Dingo keeps the phone numbers and/or other identification details of both callers and call recipients, start time, call duration, call quality, and Call Detail Record (CDR) for the calls that are made with a use of Dingo’s Product and Service. These are the industry standard records used by all phone companies for billing and statistics analysis, which contain only technical information related to calls. We never record your calls.
Dingo 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 in the Internet), cookie identifiers (“cookies”), mobile advertising identifiers, and other identifiers that are automatically assigned to your Device, location data, browser type, operating system, the 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, the information about the links you click on and pages you view on the Site, as well as 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 / to block disruptive & fraudulent use.
Dingo doesn't store the bank cards data – the bank card details are treated carefully by the payment processing system, ensuring the security & confidentiality of such information. For your convenience, you may still opt 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, in order to provide our services. Depending on the type of 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 use to collect certain types of information, you may do so by blocking, deleting, or disabling them as your browser or device permits.
(c) Dingo may also obtain an information related to you via third-party services as described below, in order to supplement the information you’ve provided us with. This additional information enables us to verify the information that you have provided to Dingo and enhance our ability to maintain a communication with you, as well as detect, investigate, prevent and respond to the fraud & other illegal activities, security or technical issues.
We may use your personal data in order to provide you with our Services, including ensuring your satisfaction and earning your 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 level). We may occasionally ask you to provide an information on your experience of using the Product and the Services. Such information is used to improve the quality of the Services.
Dingo, as well as third parties providing communication, advertising etc., may use cookies, mobile device identifiers and other technologies to collect an information through the Product, the Service and the Site automatically.
Dingo may use cookies, which are small text files stored on your device, in order to assist in the Product’s operation & provide the Service, as well as collect an information about its activities. Cookies and web beacons may be used to ensure that the system remembers your preferences, the information you’ve provided upon registration, signing-in and using our Product and Service, as well as provide targeted ads, content and marketing communications, prevent fraud, analyze site statistics and operations. By using the Product, the Service, and the Site you are automatically giving your consent to the use of cookies. You may control cookies and similar technologies with a variety of tools and browser add-ons that will prevent your browser from accepting new cookies, disable cookies, get the notifications from your browser when you receive a new cookie, etc. However, since the cookies enable you to take an advantage of useful features, we recommend you leaving them turned on.
Dingo may use Google Analytics and Yandex Metrics to collect, process and analyze trends related to the Site’s visitors 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
The Dingo iOS mobile apps use the AppsFlyer’s analytics (provided by AppsFlyer Ltd. – the mobile measurement industry standard) to track and analyze the user’s characteristics & activities, as well as upload certain data referring to downloads, impressions, clicks & mobile applications installations, mobile device use and the data concerning in-app events to AppsFlyer’s platform for such purposes. Dingo uses this platform in order to collect and analyze the data parameters,
(a) unique identifiers and technical data, such as IP address, User agent, IDFA (Identifier For Advertisers);
(b) technical data related to the user’s operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. For more information about AppsFlyer privacy policy, please visit https://www.appsflyer.com/privacy-policy/.
You can opt-out of AppsFlyer Analytics tracking by emailing AppsFlyer at [email protected] or by completing the form https://www.appsflyer.com/optout.
Dingo collects your personal information for the purposes of:
Providing our Services: we use your registration and account data to
(i) sign you up for the Product and create your Dingo user account;
(ii) create your profile & make it visible;
(iii) process your payments;
(iv) provide customer service & an information related to your account & respond to your requests;
(v) indicate which of your contacts are already using Dingo & 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 via the Service, and
(vii) sync your contacts running on different devices with Dingo.
(a) AImproving our Services: we use call log information and usage information (as described above) for better understanding of the network behavior and trends (number of calls made by users, typical destinations, call durations, network type, etc.), and to detect potential technical issues.
(b) Processing your payments: we may use your information (such as your name and phone number) to process your payments for our Services via a secured third-party service provider and to determine charges for our phone carriers and other service providers on an aggregate basis.
(c) Personalizing and optimizing our Services, promotional content and advertisements sent to you. For example, we may use the information we collect via cookies, ad identifiers and similar technologies to show you ads you may be interested in.
(d) Preventing cheating, crime or fraud: we may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use. We may use automated decisions to suspend an account based on such data in order to prevent recurring breaches. If your account has been suspended, you can contact our technical support. We may use your information and call log information to ensure a compliance with applicable laws.
(e) Communicating with you: we use your information to contact you (via message or other means) to maintain the Product’s services, comply with your stated communication preferences or provide you with any updates related to other Dingo’s services.
(f) As otherwise expressly set out in this Policy or as required by law.
In order to provide you with the Service you have requested, enhance your user experience and improve the Product and Service, Dingo may sometimes 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) if necessary. Dingo will always require these third parties to take all necessary measures to protect your personal data and to observe relevant legislation. The following is a description of how we may share your personal information with trusted third-party partners:
(a) We use third-party companies in order to send you an authentication SMS when you register with Dingo. 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.
(b) If you don’t 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 will in turn use another phone provider who may use another phone provider and so on until the call reaches you. This is the industry’s standard mechanism. The third-party partner is under the responsibility to use your phone number for the completion of the authentication phone call only.
(c) We use third-party companies in order to deliver SMS texts sent by users. These third parties are under the responsibility to use your phone number, the phone number of the receiving party, and the text message for the transmission of the text only.
(d) We use payment solution providers to process the payment and/or billing information. We require that these third parties take appropriate organizational and technical measures to protect your personal information and 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.
(e) When you use Dingo on your mobile device, Dingo may use notification services available for that device to provide you with an information on incoming calls and alerts when you are not actively using the mobile application. These services are provided by the third party. For example, messages sent to an Apple device use Apple’s Push Notification Services. Notification services may receive an information about the caller and may use this information in accordance with the privacy policy for the third-party service provider. Dingo is not responsible for the data collected by third-party notification services. If you do not want to use third-party notification services for receiving notifications about incoming calls and alerts, you can disable this function in Dingo’s application settings or in your device’s notification settings.
(f) Dingo uses third-party analytics services in order to understand how to improve your usage of our services better. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address – please see below) to Intercom R&D Unlimited Company, an Irish company with offices at 2nd Floor, Stephen Court, 18-21 St. Stephen's Green, Dublin 2, Republic of Ireland, (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our services provided to you. For more information on Intercom's use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either via email or via messages within our Product. As a part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you don’t want this information to be collected by or submitted to Intercom, please contact us.
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 Dingo’s user to legal liability. We also may share your personal information with market supervisory authorities. If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a part of our assets, personal information is likely to be among the transferred assets. As a part of such transaction, the new entity will be required to ensure the same level of protection of your Personal Information as described in this Privacy Policy.
The Site, the Product, and the Service are restricted to individuals over the age of 16. We do not knowingly collect, maintain, or use Personal Information from children under 16 (in certain countries under 13) years, and no part of the Site, the Product, and the Service is designed for children under the age of 16 (in certain countries under the age of 13). If you find out that your child has provided us with Personal Information without your consent, you may alert us at [email protected]. If we learn that we have collected any Personal Information from children under 16 (and in certain jurisdictions under 13), we will promptly take steps to delete such information and delete the account.
We don’t process your personal data for longer than it is necessary & relevant for achieving the purposes stated above or enabling us to comply with our legal data protection retention obligations. The retention period may be based on agreements with you, Dingo’s legitimate interest or applicable law (such as laws related to bookkeeping, statute of limitations, civil law, etc.). Upon a deactivation of your account, we will minimize your personal data kept in the system to only the data that we are required to keep in order to comply with laws or for other legal reasons.
We take reasonable precautions in order to protect personal information, including physical, electronic and procedural safeguards. Private information is stored on servers with limited access to controlled facilities, and payment information is protected with Secure Socket Layer (SSL) encryption when being transferred over the internet. Although we cannot guarantee that personal information will not be a subject to unauthorized access, as no method of a transmission over the Internet / method of electronic storage ensures a 100% security.
For the purposes set forth herein, we may transfer, process and store your information in Estonia, Germany or any other country where Dingo / its affiliates, subsidiaries, suppliers or agents maintain facilities. An 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. Transferring & processing personal data outside the EU/EEA can take place, provided there is a legal ground (i.e. legal requirement, exercising an agreement), as well as the client’s consent & appropriate safeguards are in place.
If you use Dingo’s Services from the EU/EEA, you have the following rights related to your personal information: to access your personal information, to rectify the information we hold about you, to erase your personal information, to restrict our use of your personal information, to object to our use of your personal information, to receive your personal information in a usable electronic format and transmit it to a third party (right to the data portability), to lodge a complaint with your local data protection authority. If you would like to understand better / exercise these rights, please contact us (contact details stated above).
Our legal grounds for processing your personal information can be the following:
(a) to fulfill our contractual obligations to you, for example to provide the services;
(b) consistent with your consent, which you can revoke at any time;
(c) to comply with our legal responsibilities to which we are a subject;
(d) to meet our legitimate interests. When we process personal information to meet our legitimate interests, we put robust safeguards in place to ensure that your privacy is protected and that our legitimate interests are not overridden by your interests or fundamental rights and freedoms;
(e) to protect the vital interests of the data subject or of another individual;
(f) necessary for the performance of a task carried out in the public interest.
We may need to 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 exact location data for the purposes other than performing the service). If we ask for your consent to process your personal information, you may withdraw it at any time by contacting us using the details stated at this Privacy Policy or by changing your setting within the Site or the Product. By withdrawing your consent for the processing of Personal Data, we will no longer process your Personal Data. However, if you have withdrawn your consent, you need to take into account that the data-processing associated with this consent will no longer be secured, and you may no longer have an access to options available previously. Consent withdrawal will not affect the legality of your Personal Data processing.
It is important for us to have a valid & up-to-date information on your personal data. If your personal data has been changed / if you have found that your personal data we’ve got is inaccurate or incomplete, we kindly ask you to inform us that we need to correct it within a reasonable period of time.
In the context of communication and cooperation, we may ask you to provide additional identification information if necessary, so that we can make sure that a communication or cooperation takes place with you (a data subject) directly, as well as that you are the person who has submitted and signed the request. If you will not provide us with additional information requested or we will have any doubts regarding the applicant’s identity, we may postpone your request until we are totally sure about your identity.
We are committed to working with you, obtaining a fair solution to any complaint or concern related to privacy issues. If, however, you believe that we have not been able to provide a reasonable solution to your complaint or concern, you have the right to make a complaint to your data protection authority.
