Privacy Policy

This application needs to access the following items to benefit from all features on your smartphone: contacts, camera, microphone and phone. Please note that this information is not stored on any external server and only used locally in the application, except for the case described below under “Collected Data”. The information gathered by the app is not forwarded, stored or used by any third party for any kind and is only used for the purpose to make a personal initiated call, except for the case described below under “Collected Data”. By registering for this application, you consent to our using it in the manner described in this policy. You may withdraw your consent at any time by deregistering from the service. To do so, go to “settings” and activate “Reset application”.

Identity of Personal Data Controller

The controller of the personal data as defined in Article 4.7 of GDPR and the Data Protection Officer can be contacted at info@commonground.work

Lawful Purpose

For the correct functionality of the service, certain data fulfilling the definition of “personal data” given by paragraph 4.1 of GDPR needs to be processed. This data is stored and processed solely for the purpose of enabling the features of the Service. By accepting this EULA, you are entering a contract and personal data is lawfully processed in accordance to paragraph 6.1.b of GDPR.

Location

The Personal Data is stored on servers within the European Union and the United States of America. In case the servers are located in the USA, they are always hosted at centers which participate in EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce and the European Commission.

Time Period

The Personal Data is necessary for the correct operation of the Service. They will be processed as long as the service is in use. In case you decide to stop using the Service and uninstall the related apps, all Personal Data will be removed from our servers within a period of 7 days, with the exception of data we are required to hold for compliance with a legal obligation which requires processing by Union or Member State law, as specified in GDPR Article 17.3.

Right to be forgotten, Rectification of Personal Data

You have the right to request erasure of your Personal Data by GDPR Article 17 and 18). To do so, uninstall the apps and the data will be removed automatically as specified in the “Time Period” paragraph. The service depends on the Personal Data being processed and can not work correctly without it. The Personal Data originates from the input given by the user; rectification can be done by editing the data within the app at any time.

Collected Data

1. SIP Account Credentials
   Required for Push Notifications and WebRTC app to work. They are being used to register the account on the server and forward any incoming calls and messages to the device via Push Notifications.
2. Address Book Data
   Required for “Contact Sync” and “Smart Contacts” feature to work. A copy of your Address Book is kept on the server and used to show your address book in WebRTC app and to notify you about your contacts that also use the Service. This optional feature may not be activated in your app. Ask your provider if this feature is activated.
3. IP Addresses
   When using features which require server components, like Push Notifications or Contact Sync and Smart Contacts, or any web services, the IP address and browser information may be logged by the servers. The logs are automatically rotated and the information in them is only processed when troubleshooting specific issues, or when required by law.
4. Usage Data
   The servers collect information whether the app has been actively used within the current month, for accounting/billing purposes. The data has a form of pseudonymized identifier which is reported by the app when it is used and the time since the last report is more than 14 days.

Data Portability

You have the right to request a copy of your Personal Data in a portable format.