Privacy Policy

Effective Date: September 30, 2025

AffinityClick Inc. (“DialAppify,” “we,” “our,” “us”) values your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our mobile applications, websites, and related services (collectively, the “Services”).

By using the Services, you agree to this Privacy Policy. If you do not agree, you must not use the Services.

1. Information We Collect

We collect the following categories of personal information:

• Account Information: Name, email address, password, billing address, and payment details.
• Identity Verification (KYC) Data: Government-issued ID, proof of address, biometric or liveness checks, and verification outcomes. Required to comply with telecommunications regulations in the UK, US, and Canada.
• Phone Number & Usage Data: Numbers you purchase or use, call and message metadata (e.g., time, duration, counterpart number). We do not record or store the content of calls or messages.
• Device & Technical Data: IP address, operating system, device type, browser or app version, log files, and interactions with the Services.
• Optional Data: Information you provide voluntarily, such as customer support requests, surveys, or use of additional features.
• Cookies & Tracking Technologies: When you visit our website, we may use cookies and similar technologies to analyze usage, improve performance, and provide tailored experiences.

2. How We Use Your Information

We use your information for the following purposes:

• Provide, operate, and improve the Services.
• Assign and manage phone numbers, calls, and messaging features.
• Verify identity and comply with telecom, anti-fraud, and anti-spam regulations.
• Process payments, credits, and subscriptions.
• Detect, prevent, and investigate fraud, abuse, or illegal activity.
• Troubleshoot and personalize your user experience.
• Communicate important service announcements, security notices, or policy updates.
• Send marketing communications if you have opted in (you can opt out at any time).

3. Legal Bases for Processing (UK/EU Users)

We process personal data under the following legal bases:

• Contract: To deliver the Services you request.
• Legal obligation: To comply with telecom, fraud-prevention, and financial reporting regulations.
• Legitimate interests: For security, product improvement, and business operations, provided your rights are not overridden.
• Consent: For marketing and optional features.

4. Sharing of Information

We do not sell or rent your personal information. We may share it only as follows:

• Service Providers: With vendors who process payments, provide cloud hosting, KYC/identity verification, analytics, or support services on our behalf.
• Telecom Partners & Regulators: To provision numbers, meet regulatory obligations, or prevent fraud.
• Legal & Law Enforcement: To comply with lawful requests, subpoenas, lawful intercept obligations, or government investigations.
• Business Transfers: In connection with mergers, acquisitions, or sales of assets.
• With Your Consent: When you authorize us to share your information for a specific purpose.

5. Data Retention

We retain personal information only as long as necessary for the purposes set out in this Policy and to comply with legal obligations:

• Account information: While your account is active, and up to 7 years after closure for tax and audit purposes.
• KYC/identity verification data: 3–6 years, as required by telecom and financial regulations.
• Call/message metadata (CDRs): 12–24 months, depending on jurisdiction and regulatory requirements.
• Payment records: 7 years or longer if required by tax law.
• Promotional/optional data: Until no longer needed or until you withdraw consent.

6. Security

We implement appropriate technical and organizational safeguards, including encryption, secure servers, firewalls, and access controls. However, no method of transmission or storage is 100% secure. You use the Services at your own risk.

7. International Transfers

We may process and store your information in Canada, the United States, the United Kingdom, or other jurisdictions.

When transferring data from the UK/EU, we rely on adequacy decisions, Standard Contractual Clauses (SCCs), or equivalent safeguards to ensure protection consistent with GDPR requirements.

8. Your Rights

Depending on your location, you may have the following rights:

• UK/EU (GDPR/UK GDPR): Right to access, rectify, erase, restrict, or object to processing; right to data portability; right to withdraw consent; right to lodge a complaint with a supervisory authority (e.g., ICO in the UK).
• Canada (PIPEDA): Right to access and correct personal information; right to withdraw consent, subject to legal restrictions.
• United States (CCPA/CPRA – California Residents): Right to know what personal information we collect; right to delete personal information; right to opt out of the “sale” or “sharing” of personal information; right to non-discrimination for exercising your rights.
• Other regions: You may have additional rights under local law.
• Promotional/optional data: Until no longer needed or until you withdraw consent.

To exercise your rights, contact us at Media@dialappify.com. We may request identity verification before responding.

9. Children’s Privacy

The Services are not intended for children under 13 (or the minimum legal age in your country). We do not knowingly collect information from children. If we learn that a child’s data has been collected, we will delete it promptly.

10. Cookies & Tracking

We use cookies and similar technologies to improve website performance, analyze traffic, and personalize experiences. You can manage cookies through your browser settings.

Where required (e.g., UK/EU), we will request your consent before setting non-essential cookies.

11. Changes to This Policy

We may update this Privacy Policy periodically. If we make material changes, we will provide notice (e.g., email, in-app notification, or website banner). The updated version will be effective as of the “Effective Date” above.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, contact us:

DialAppify LLC.

Email:Media@dialappify.com

If you are located in the UK or EU, you also have the right to contact your local data protection authority.