Privacy policy

 

Last updated January 25, 2024 

 

This privacy notice for Challenger Mobile Technology AB (doing business as Challenger Mobile) (‘we‘, ‘us‘, or ‘our‘), describes how and why we might collect, store, use, and/or share (‘process‘) your information when you use our services (‘Services‘), such as when you: 

  • Download and use our mobile application (TrustCall), or any other application of ours that links to this privacy notice 
  • Engage with us in other related ways, including any sales, marketing, or events 

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@challengermobile.com. 

 

 

SUMMARY OF KEY POINTS 

 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. 

 

Do we process any sensitive personal information? We do not process sensitive personal information. 

 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. 

 

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. 

 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. 

 

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. 

 

1. WHAT INFORMATION DO WE COLLECT? 

 

Personal information you disclose to us 

 

In Short: We collect personal information that you provide to us. 

 

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. 

 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: 

  • phone numbers 
  • email addresses 
  • usernames 
  • passwords 
  • job titles 
  • names 

Sensitive Information. We do not process sensitive information. 

 

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission: 

  • Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings. 
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, camera, contacts, microphone, sms messages, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings. 
  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed. 
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings. 

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. 

 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. 

 

2. HOW DO WE PROCESS YOUR INFORMATION? 

 

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. 

 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including: 

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. 
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. 
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. 
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user. 
  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm. 
 

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION? 

 

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests. 

 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: 

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. 
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you. 
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. 
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. 

 

4. HOW LONG DO WE KEEP YOUR INFORMATION? 

 

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law. 

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than six (6) months past the termination of the user’s account. 

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

 

5. HOW DO WE KEEP YOUR INFORMATION SAFE? 

 

In Short: We aim to protect your personal information through a system of organisational and technical security measures. 

 

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment. 

 

6. DO WE COLLECT INFORMATION FROM MINORS? 

 

In Short: We do not knowingly collect data from or market to children under 18 years of age. 

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@challengermobile.com. 

 

7. WHAT ARE YOUR PRIVACY RIGHTS? 

 

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. 

 

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (vi) if applicable, to data portability; and (vii) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided below. 

 

We will consider and act upon any request in accordance with applicable data protection laws. 

 

Account Information 

 

If you would at any time like to review or change the information in your account or terminate your account, you can: 

  • Contact us using the contact information provided. 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. 

 

If you have questions or comments about your privacy rights, you may email us at info@challengermobile.com. 

 

8. DO WE MAKE UPDATES TO THIS NOTICE? 

 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. 

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. 

 

9. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 

 

If you have questions or comments about this notice, you may email us at info@challengermobile.com or contact us by post at: 

 

Challenger Mobile Technology AB 

Kistagången 20b 

Kista, Stockholm 16440 

Sweden