app/user-privacy-en-US | Habla Sin Pin

1. GENERAL

This Habla Sin Pin User Privacy Policy (the “Policy”) sets forth the user data we collect from you when you use our Habla Sin Pin calling application (the “HSP App”) and how we use that data. When we refer to The Hosting Company or “us,” or “we,” we’re talking about The Hosting Company, LLC.

We may update this Policy from time to time and you should review it periodically for changes. Any updated Policy will be posted in the HSP App.

2. USER DATA WE COLLECT

The Hosting Company receives and collects the following user data from you when you use the HSP App and the services and products offered through the HSP App (collectively, the “Services”).

A. Data You Provide. You provide your name, address, email address, mobile phone number, and possibly payment information (including credit or debit card details) to us. You also provide and we collect the phone numbers in your mobile address book on a regular basis, including those of both the users of our Services and your other contacts. Your mobile address book is stored in our system to facilitate the use of our Recarga International Top Up Service. When you cancel your service, all collected mobile address book information is deleted from our system.

B. Data We Collect. We collect data regarding your use of the HSP App and the Services including (i) call records, frequently called numbers and network traffic data, (ii) messages sent with the HSP App or Services, including chats, photos, videos and voice messages, and (iii) HSP App feature usage information and stored content. We also collect from you technical data and related information, including but not limited to, information about your mobile device, system and application software that is gathered periodically to facilitate our provision of the HSP App, the Services, software updates and service support. We collect service-related, diagnostic, and performance information. This includes information about your activity (such as how you use our Services, how you interact with others using our Services), log files, and diagnostic, crash, website, and performance logs and reports. We collect device-specific information when you install, access, or use the HSP App and our Services. This includes information such as hardware model, operating system information, browser information, IP address, mobile network information including phone number, and device identifiers. We collect device location information if you use our location features, such as when you choose to share your location with your contacts, view locations nearby or those others have shared with you, and for diagnostics and troubleshooting purposes such as if you are having trouble with the HSP App’s location features.

3. HOW WE USE DATA

We use all the data we collect and receive to help us operate, provide, improve, understand, customize, support, and market the HSP App and our Services. In addition, we use your data for general, operational and administrative purposes, including maintaining your account, authenticating you and contacting you. As used in this Policy the terms “use,” “using and “processing” data includes processing such data with various technologies on a computer/phone/device, subjecting the data to statistical or other analysis and using or handling data in any way, including but not limited to, scanning, collecting, storing, evaluating, aggregating, modifying, deleting, using, combining, disclosing and sharing data among our affiliates both in and outside the United States and to select third parties. We analyze how our customers use our Services and use that data to evaluate and improve our Services, to research, develop, and test new services and features, and to conduct troubleshooting activities. We engage certain third parties who use mobile software development kits to passively collect information from users of the HSP App. We use this data primarily to help us deliver personalized notifications and to identify you in a unique manner across other devices or browsers for the purposes of customizing advertisements or content. Finally, we may digitally scan content stored in the HSP App, including without limitation, your user information and message content, and use this information to provide you with targeted information and advertising.

4. OTHER INFORMATION

A. Changes to this Policy. We reserve the right to make changes to this Policy, so please check the HSP App periodically for changes. You will be able to see that changes have been made by checking to see the effective date posted at the beginning of the Policy.

B. Privacy. THE HOSTING COMPANY is committed to protecting the privacy of your data. Your data is protected by the terms of our Privacy Policy which can be found in the HSP App.

Effective as of October, 2021