LSM Apps | Privacy Policy

L.S MOBILE APPS HOLDINGS

[Last Updated: 27 December, 2022]

This Privacy Policy (“Privacy Policy”) governs the privacy practices of L.S Mobile Apps Holdings Ltd. ("Company," "we," "us" or "our") and is an integral part of our Terms of Use ("Terms"). Any definitions used herein but not defined herein shall have the meaning ascribed to them in our Terms.

This Privacy Policy details the data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

If the CCPA applies to you, additional information that supplements this privacy policy is available at the CCPA Notice.

AMENDMENTS:

Except as otherwise described herein, we may at our sole discretion and at any time amend the terms of this Privacy Policy. Such changes shall be effective within 30-days from the publication of the amended terms on our website or in the App. The latest amendment to this Privacy Policy will be reflected in the "Last Updated" heading above. Your continued use of the App, following the amendment of the Privacy Policy, constitutes your acknowledgment of such amendments to the Privacy Policy. In the event of a material change, or in the event we are required by law, we will make a reasonable effort to provide you notification of such change.

APPLICABILITY:

This Privacy Policy governs the data collected and processed from the following individuals (“you” or “your”):

“User(s)”: an individual that installs our apps, Easy Caller ID, Easy Backup, Easy Cleaner or Easy Contacts (each and collectively shall be defined as "App(s)");

“Non Users”: As part of the services, we provide the user shares its contact list with us, if you are an individual that appears on such list, this privacy policy also applies to you.

CONTROLLER AND DATA PROTECTION OFFICER DETAILS:

L.S. Mobile Apps Holding Ltd, incorporated under the laws of Israel, registration number 516463312, is the controller of your Personal Data.

You may contact us through the below means:

By Email: privacy@lsmapps.com
DPO: dpo@lsmapps.com

EU DPR:

Individuals from the EU may contact our EU representative according to Art. 37 GDPR regarding all requests related to data protection and privacy:

DP-Dock GmbH, Attn: L.S Mobile Holdings Ltd, Ballindamm 39, 20095 Hamburg, Germany.
EU DPR Email: LSM@gdpr-rep.com

UK DPR:

Our Data Protection Representative according to Art. 27 GDPR:

DP Data Protection Services UK Ltd., Attn: L.S Mobile Apps Holdings Ltd., 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom.

TYPES OF DATA WE COLLECT FROM USERS:

You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data and how it is technically processed.

The first type of data we collect is aggregated, non-identifiable, non-personal data, which may be processed via your use of the Service (“Non-Personal Data”).

The second type of data is individually identifiable data, namely data that identifies an individual, or may with reasonable effort identify an individual (“Personal Data”).

In the event that we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data for as long as it remains combined.

PURPOSE OF PROCESSING USER’S DATA AND THE LAWFUL BASIS:

The data sets we collect and process including how we process such data sets, for what purpose and what is our lawful basis to such processing activates is as follows:

Online Identifiers - When you use our App, your IP address will be collected, either directly by us or through our service providers. We use this data to enable us to audit and detect fraud. Our lawful basis is our legitimate interest.

Account Data – you may access the Services through your Facebook, Apple or Google account or by creating an account by registering and provide us with your email address. You can also use the Services without logging in. Our lawful basis is contract necessity.

Contact Information - If you voluntarily contact us for support or other inquiries, you may be required to provide us with certain information such as your name and email address. We will use this data to provide you with the support you requested or to respond to your inquiry. Our lawful basis is our legitimate interest unless you are a user seeking technical support, in which this would be part of our contract obligation to you.

Call Log – only if you use our Caller ID App you will need to accept the "call log" permission. We use this permission to identify your callers, including if this caller is active in the last 6 months for the purpose of- detect spam and fraud, accuracy and making sure the number is actually associated with a caller and is not a bot or otherwise a spammer. Any Android or iOS permissions need to be affirmatively enabled through in-app permission or the mobile settings. You may disable the permissions at any time, but depending on the permission you disable, a feature or all features may not function properly.

Contact List - In order to provide our Services, you will need to share your full contact list with us and provide with the permissions to access your contact list. The Services include enrichment, management, backup, verification, deletion of duplication of your contact list address book or a caller ID. For this, we will need your contact list. Our lawful basis is contract necessity in order to provide you with our Services. However, when we use this information through the Caller ID App, we will also use the contact list for identifying callers, this is subject to our legitimate interest in detecting spam and fraud callers.

Professional Data- for the enrichment features, we add the professional data of the contacts such as job, title and position. We obtain the data from our service providers as detailed below.

Please note that, the actual processing operation per each purpose of use and lawful basis detailed above, may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of personal data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated above.

NON-USER DATA:

We may process the Non-Users’ Personal Data which includes: name, phone number, email, job position and title, and any other information that the User has saved for that particular Contact.

We receive this information from the Users’ after disclosing our use of this data and they have affirmatively accepted.

We use this information to provide the Services, cleaning, merging and authenticating and enhancing the Users’ contact list.

However, for Easy Phone Dialer & Caller ID Users, we use the Non-User Personal Data collected from a User to potentially identify this caller for other Users. Creating the caller database allows us to build more accurate and complete contact records of individuals which result in improving and making our Caller ID services more accurate and efficient and to reduce scam and fraud worldwide.

In other words, in case you appear as a Contact of our Caller ID Users we will collect and share your Personal Data with other Users of our Caller ID App or with service providers as detailed below. In the event you wish to opt-out you may easily do so by following the link: https://www.lsmapps.com/onetrust-opt-out.

For EU individuals, we will send you a notice when we add you to our database, in this notice you will be able to easily opt out.

HOW WE COLLECT DATA:

Depending on the nature of your interaction, we may collect your information by using one or more of the following methods:

Automatically - we may use APIs software developer kit ("SDK") and other technological measures to gather some of your data automatically.

Provided by you voluntarily – we will collect your data if and when you choose to provide us with such data, for example, via our registration process, when you contact us, etc. as explained in this Privacy Policy.

Access through Android or iOS Permissions.

SHARING DATA:

We may share information solely in the following events:

Third Party Service Providers: we share all data with cloud providers for hosting purposes. We further share the Non-User Personal Data with Lusha Systems Ltd., (“Lusha”) our service provider and parent company. The purpose for sharing this data is to provide the enrichment and authentication features. If you are an EU data subject, Lusha will notify you once it receives this data and will offer you to opt-out. For more information, please see Lusha’s privacy notice here
Sharing Between Caller ID Users: To provide and improve our Caller ID App Services, we will share certain information with other Users of our Caller ID App Services, as it is necessary for the adequate performance of the contract between you and us and for performance of certain features of our Services based on our legitimate interest. Meaning, we may use the information provided by a User to identify a caller of a different User.
Legal Requirement: We may share information in order to protect legal rights (including intellectual property rights) or to comply with any applicable law, regulation, legal process or governmental request.

YOUR RIGHTS:

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Depending on your relationship with us, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data: The right to access your Personal Data that we process; the right to ensure your Personal Data is accurate, complete and up to date; the right to have your Personal Data amended (by correcting, deleting or adding information); the right to object to the processing of your Personal Data, to the extent applicable; the right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; right to Non-Discrimination and the right to cease sharing or selling your information as such term is defined under the CCPA.

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request Form (“DSR”) available here, send us the request at: DPO@lsmapps.com.

Certain rights are available within the App: you may correct and revise the Account Data, you also may delete such information from the App settings at any time, any consent provided may be easily withdraw (by unsubscribing, declining, etc.), therefore we recommend you use the technical solutions we have provided you with to exercise your rights. NOTE THAT DELETING THE APP FROM YOUR DEVICE WILL NOT RESOLVED IN DELETING YOUR DATA COLLECTED FROM YOU IF YOU WISH TO DELETE THE ACCOUNT DATA PLEASE FILL IN THE DSR OR PRIOR TO DELETING THE APP GO TO THE APP SETTINGS AND CLICK “DELETE ACCOUNT DATA” AFTER YOU RECEIVE CONFIRMATION YOU CAN PROCEED AND DELETE THE APP. WHEN YOU DELETE THE ACCOUNT DATA, WE WILL AUTOMATICALLY DELETE THE CONTACTS LIST AND THE CALL LOGS THEREFORE PLEASE MAKE SURE THIS INFORMATION IS BACKED UP PRIOR TO DELETION.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are a European Economic Area resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

DATA RETENTION & DELETION

Basically, we only keep your data as long as required to fulfill the purpose for which the data was collected, or as we are required by law.

We retain the data that we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual requests that we delete his or her Personal Data. We may, at our sole discretion, delete or amend information from our systems, without providing any prior notice to you, once we deem it is no longer necessary for such purposes.

Detailed retention period:

Users - you may request us to delete your information from any of our, and our service providers databases by submitting a request to: dpo@lsmapps.com or as deleted above. As long as you are our User we will continue to store your Personal Data, as noted above, deleting the App will not result in deletion of your Personal Data. In case you request us to delete your Personal Data we will delete your Personal Data as well as the contact lists and call logs collected from you, and we will request our service providers to delete such Personal Data as well.

Non-Users - you may request us to Opt-Out (https://www.lsmapps.com/onetrust-opt-out) or to delete your Personal Data.

Other Data Sets- correspondence information, CVs, and other information provided to use will have various retention periods depending on the request, the consents and the law requirements.

In addition, please note that in case you are an end-user requesting us to stop the collection of your data (“Opt-Out”) by either contacting us through or by switching off the collection toggles in our app, we will stop the collection of your data from the date of such request, but we will use and process the data collected from you prior to submitting the request in order to provide our services.

DATA SECURITY:

We take great care in implementing and maintaining the security of the Services and the Personal Data that we collect and process. We employ strict security procedures and policies to ensure the safety of the Personal Data we process and prevent any unauthorized use of it, as explained detailed in our Information Security Policy. If you believe that your privacy was treated in a way that was not in accordance with this Privacy Policy, or if you believe that someone may have attempted to abuse our Services, please contact us at: dpo@lsmapps.com.

Additionally, in the event of a security incident in which we discover your Personal Data may have been at risk, we will take reasonable efforts to notify you and the applicable authority (if required to do so, subject to applicable laws).

ELIGIBILITY AND CHILDREN PRIVACY:

The Services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law which with respect to the EEA is under the age of 16 and with respect to the US, under the age of 13) and we do not knowingly process children's information. We will discard any information that we receive from a user that is considered a "child" immediately upon our discovery that such a user shared information with us. Please contact us at: dpo@lsmapps.com. If you have reason to believe that a child has shared any information with us.

DATA TRANSFER:

Our data servers in which we host and store the information are located in the EU. Our HQ is based in Israel in which we may access the information stored on such servers or other systems such as the Company’s ERP, CRM, Salesforce and other systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments and or assurances from the data importer to protect your Personal Data, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes.