Privacy Policy

Welcome to Call Curb. This Privacy Policy explains how we collect, use, store, and protect your information when you use the Call Curb App. We understand that your call data and personal information are sensitive. Our goal is to be transparent about what information we collect, why we collect it, and how it is used. We only collect the information that is necessary to provide the caller identification and spam protection features of the app and to operate the service effectively.

This Privacy Policy applies to all users of the Call Curb app in countries where the app is available. By creating an account or using the app, you agree to the practices described in this Privacy Policy. If you do not agree with this Policy, you must not use the app.

This Policy applies only to the Call Curb app and related services provided by Responsive IP LLC. It does not apply to third-party platforms such as the Apple App Store or Google Play, which have their own privacy policies and practices.

Company Information:

Company Name: Responsive IP LLC

Registered Office: 8 The Green Suite 12062, Dover, DE 19901

If you have any questions about this Privacy Policy or how your information is handled, you can contact us at support@callcurb.com or by mail at 8 The Green Suite 12062, Dover, DE 19901.

1. INFORMATION WE COLLECT

• Information You Provide Directly: When you create an account, you must provide your name, email address, and phone number. If you contact support, you may also provide additional information in your message. This information is used to create and manage your account and to communicate with you about the service.
• Call Data We Process: In order to identify callers and detect spam, the app processes certain call-related information. This includes incoming and outgoing phone numbers, call time, call duration, and call frequency. This data is uploaded to our servers to compare it against our spam database and improve caller identification accuracy. Call Curb does not record, listen to, monitor, or store the content of your phone calls, voice recordings, SMS messages, or any other communication content. We process only limited call metadata necessary to provide spam detection and caller identification services. We do not own phone numbers and we do not claim any rights over them. We process them only for spam detection and call protection purposes.
• Contact List Access: The app accesses your contact list to help distinguish between known contacts and unknown callers. This allows the app to avoid labelling saved contacts as spam and to improve caller identification accuracy. Contact information is used strictly for this functionality.
• Spam Reports and User-Generated Content: Users can report numbers as spam and label numbers within the app. When you submit a report or label, we collect the phone number involved and the information you provide in the report. This helps improve the shared spam detection database for all users.
• Subscription Information: Subscriptions are managed through the Apple App Store or Google Play. We do not collect or store your payment card details. Payment processing is handled directly by Apple or Google in accordance with their own privacy policies.
• Push Notification Data: When you enable push notifications, we may send alerts related to call protection, security updates, or important service messages. We may process a push token and notification preferences that are necessary to deliver these notifications.
• Advertising and Device Data: Users without a verified subscription may receive banner advertisements and may choose to watch rewarded advertisements to temporarily access an eligible feature. Appodeal and its advertising partners may process an advertising identifier, IP address, device and network information, general location inferred from IP address, consent choices, app interaction data, and ad interaction data. We do not provide call content, contact-list data, SMS content, phone numbers, or account credentials to advertising partners.

2. LEGAL BASIS FOR WHICH WE USE YOUR INFORMATION

We process your personal information only when we have a valid legal reason to do so. The legal basis depends on how you use the app and where you are located.

• Performance of a Contract: When you create an account and use Call Curb, we must process your information to provide the core features of the app. This includes processing your name, email address, phone number, and call data to identify callers, detect spam, manage your account, and provide customer support.

Without this processing, we cannot deliver the service you signed up for.

• Legitimate Interests: We process certain information to protect users from spam, fraud, and scam calls, and to improve the accuracy of our spam detection database. This includes analysing reported numbers and call patterns. We do this in a way that balances our interests in improving the service with your privacy rights.
• Consent: In some cases, we rely on your consent. For example, you must grant permission for the app to access your contacts and call data on your device. Where required, Appodeal presents advertising consent choices before serving ads. You can change required advertising choices through Ad privacy options in the app’s Settings and withdraw device permissions at any time through your device settings, although doing so may limit some functionality.
• Legal Obligations: We may process or disclose your information if we are required to do so by law, regulation, court order, or valid request from a government authority.

3. HOW WE USE YOUR INFORMATION

• To Provide Caller Identification and Spam Protection: We use call data such as phone number, call time, and call duration to identify incoming calls and compare them against our spam database. This allows us to show you relevant caller information and help block or flag suspicious numbers.
• To Maintain and Improve the Spam Database: When users report numbers as spam or label numbers, we use that information to strengthen and update our shared spam detection system. This helps improve accuracy for all users.
• To Manage Your Account: We use your name, email address, and phone number to create and manage your account, verify your identity, respond to support requests, and communicate important information about your subscription or service updates.
• To Send Push Notifications: We may send push notifications related to call alerts, spam warnings, security notices, and important service announcements. You can control push notifications through your device settings.
• To Provide and Measure Advertising: We use Appodeal to provide banner ads and user-initiated rewarded ads to users without a verified subscription. Appodeal and its advertising partners may use device, network, consent, app interaction, and ad interaction data to deliver and measure ads, control frequency, prevent fraud, and, where you consent, personalize advertising. Rewarded ads play only after you explicitly choose to watch one.
• To Provide Customer Support: If you contact us, we use the information you provide to respond to your request, investigate issues, and resolve technical problems.
• To Enforce Our Terms and Protect the Service: We may use your information to detect misuse of the app, prevent fraud, enforce our Terms of Service, and protect the rights, safety, and security of our users and our company.
• To Send Service Updates and Optional Promotional Messages: We may use your email address or send push notifications to inform you about important service updates, new features, security alerts, and improvements to the app. We may also send limited promotional or product-related messages about Call Curb. You can opt out of promotional emails at any time by using the unsubscribe link in the email. You can control push notifications through your device settings.

4. RETENTION AND DELETION

We keep your personal information only for as long as it is necessary to provide the Call Curb service and to meet our legal obligations.

• Active Accounts: While your account is active, we retain your account information, call data, and related records so that the app can function properly. This includes maintaining your caller identification history and spam reporting activity.
• Account Deletion: You can delete your account at any time through the app. Once you request deletion, your personal data associated with your account will be deleted from our active systems.
• 30-Day Retention Period: After your account is deleted, we retain your data for up to 30 days. This period allows us to complete technical processes, resolve any pending issues, and comply with legal requirements.

After this period, your personal data is permanently deleted from our systems.

• Anonymized or Aggregated Data: We may retain information that has been anonymized so that it no longer identifies you. This type of data may be used to improve our spam detection systems and analytics, but it cannot be linked back to you.

Information processed independently by Appodeal or its advertising partners is retained under their respective privacy policies and applicable legal requirements. If you have questions about data deletion or need assistance with account removal, you can contact us at support@callcurb.com.

5. INFORMATION SHARING

We do not sell your personal information for monetary consideration. The ad-supported tier uses Appodeal and its advertising partners as described below. We do not provide those partners with call content, contact-list data, SMS content, phone numbers, or account credentials.

• Service Providers: We use trusted service providers to operate the app. For example, our data is hosted on Google Cloud, and Appodeal provides advertising mediation for the ad-supported tier. Appodeal and mediated advertising partners may process device and advertising data under their own privacy terms. You can review the

Appodeal Privacy Policy at https://www.appodeal.com/privacy-policy. Other providers must process data only for the services they provide and protect it with appropriate security measures.

• Legal Requirements: We may disclose your information if we are required to do so by law, court order, subpoena, or valid request from a government authority. We may also disclose information if necessary to protect our legal rights, enforce our Terms of Service, or prevent fraud or abuse.
• Business Transfers: If Responsive IP LLC is involved in a merger, acquisition, restructuring, or sale of assets, user information may be transferred as part of that transaction. If this happens, we will ensure that your information remains protected under similar privacy standards.
• Aggregated or Anonymized Information: We may share information that has been aggregated or anonymized so that it does not identify you personally. This may be used for research, analytics, or improving spam detection systems.

6. DATA STORAGE AND SECURITY

Your information is stored on secure servers provided by Google Cloud. Our systems are designed to protect your data from unauthorized access, misuse, loss, or alteration. We use reasonable technical and organizational measures to safeguard the information we process.

Access to personal data is limited to authorized personnel who need the information to operate, maintain, or support the Call Curb service. These individuals must handle your data responsibly and in line with our internal security practices.

While we take data protection seriously and work to maintain strong security standards, no system can guarantee absolute security. For this reason, we encourage users to keep their account credentials secure and to notify us immediately if they believe their account has been compromised.

We regularly review our security practices to ensure that your information remains protected as technology and risks evolve.

7. INTERNATIONAL DATA TRANSFER

Call Curb is operated by Responsive IP LLC in the United States, and your information is stored and processed on servers provided by Google Cloud. Appodeal and its advertising partners may also process advertising-related data in the United States or other countries where they operate. If you use the app from outside the United States, your data may be transferred to and processed in countries where our service providers operate. These countries may have different data protection laws than your home country. By using the app, you understand and agree to this transfer. We take reasonable steps to ensure that your information remains protected in accordance with this Privacy Policy, regardless of where it is processed.

8. THIRD-PARTY LINKS

The Call Curb app may contain links to third-party websites, services, or platforms, such as the Apple App Store or Google Play. If you click on a third-party link, you will be directed to a service that is not operated by Responsive IP LLC. We are not responsible for the privacy practices, content, or policies of any third-party services. Each third party has its own privacy policy and terms, and you must review those policies before providing any personal information.

We encourage you to read the privacy policies of any external services you access through our app.

9. RIGHTS OF EU, EEA, SWITZERLAND, AND UK USERS

This section supplements the other provisions of this Privacy Policy and applies to users located in the European Union (EU), the European Economic Area (EEA), Switzerland, or the United Kingdom. For the purposes of applicable law, your DATA CONTROLLER for the data collected by us to provide you with our services is:

Company Name: Responsive IP LLC

Registered Office: 8 The Green Suite 12062, Dover, DE 19901

ALL YOUR USER INFORMATION WILL BE COLLECTED, STORED, PROCESSED AND SHARED STRICTLY IN ACCORDANCE, IN LINE AND FULL COMPLIANCE WITH THE FOLLOWING

REGULATIONS

EU and EEA

• General Data Protection Regulation (GDPR)
• ePrivacy Regulation
• Law Enforcement Directive

Switzerland

• Federal Act on Data Protection (FADP)

United Kingdom (UK)

• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018
• Privacy and Electronic Communications Regulations (PECR) We process personal data under the lawful bases specified in Section 2 above.

Where we transfer personal data outside the EEA, UK, or Switzerland, we ensure an adequate level of protection by relying on appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms approved by regulators.

Depending on the applicable law, you may have one or more of the following rights in respect of your personal information:

• Right to obtain information: to obtain information about how and on what basis your personal information is processed and to obtain a copy;
• Right to rectification: You have the right to have any incomplete or inaccurate information we hold about you rectified and corrected.
• Right of Erasure: to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us;
• Right of restriction: to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim or (d) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
• Right to object: to object to decisions which are based solely on automated processing or profiling;
• Right to ask for a copy: where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or to obtain a copy of or access to safeguards under which your personal information is transferred outside of the UK or EEA.
• Right to withdraw your consent. You have the right to withdraw your consent on using your personal data.

If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our services.

• Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data.

Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.

In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.

We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee, where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

To make such requests, please contact us at support@callcurb.com.

Estimated Timeframe for Response: We aim to respond to all valid privacy-related requests within one (01) month of receipt, or within a longer period if the request is complex or involves multiple records. In such cases, we will inform you of the delay and explain the reason for it. Exercising your rights is free of charge, unless the request is manifestly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or refuse to act on the request.

Complaints

If you are located in the European Union, the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with your local data protection authority if you believe your personal data has been handled in a way that breaches applicable laws. Examples of supervisory authorities include:

• United Kingdom: Information Commissioner’s Office (ICO) – www.ico.org.uk
• European Union: Data Protection Commission (Ireland) – www.dataprotection.ie
• Switzerland: Federal Data Protection and Information Commissioner (FDPIC) – www.edoeb.admin.ch
• Other EEA countries: You can find your national data protection authority via the official EU website at https://edpb.europa.eu/about-edpb/board/members_en We encourage you to contact us first at support@callcurb.com so we can address your concern promptly before you reach out to a supervisory authority.

10. RIGHTS OF USERS FROM CALIFORNIA

This privacy notice section for California residents supplements the information contained in our Privacy Policy. It applies solely to all visitors, users, and others who reside in the State of California where and to the extent that the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), applies to Call Curb.

If the CCPA/CPRA applies to us, California residents are entitled to certain additional rights regarding their personal information, as explained below. If the law does not apply to us, we will still handle your information in line with our Privacy Policy and industry best practices – however the additional rights specified in this Section will then not be available to you.

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and processing of their personal information.

In compliance with the California Consumer Privacy Act (CCPA), we are required to disclose the categories of personal information we collect from users. The following outlines the categories of information we collect, along with examples and purposes for which the information is used.

Categories of Personal Information We Collect

The following outlines the categories of personal information we collect, along with examples and how we use them:

Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request.

Upon verification, we will disclose to you:

• The categories of personal information we have collected about you.
• The categories of sources for the personal information we have collected about you.
• The specific pieces of personal information we have collected about you.
• Our business or commercial purpose for collecting or “selling” your personal information as defined by the CCPA.
• The categories of third parties to whom we have sold or shared your personal information, if any, and the categories of personal information that we have shared with each third-party recipient.

Your Right to Opt-Out of “Sale” or “Sharing” of Personal Information: California residents have the right to opt out of the “sale” or “sharing” of their personal information as defined by the CCPA. Where applicable, you may use Ad privacy options in the app’s Settings to change advertising choices, use Appodeal’s available privacy controls, or contact us at support@callcurb.com. We do not knowingly sell personal information for monetary consideration.

Your Right to Limit Use of Sensitive Personal Information: California residents may have the right to request that businesses limit the use of any sensitive personal information to those uses which are necessary to perform the Services or for other specifically-enumerated business purposes under the CCPA, as amended by the CPRA. Please note that we do not use sensitive personal information other than as necessary to perform the Services or as specifically permitted under the CCPA.

Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, we will delete, and direct our service providers to delete your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA.

Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA. To exercise any of your rights, please contact us at support@callcurb.com.

Authorized Agent: California residents may designate an authorized agent to submit CCPA/CPRA requests on their behalf. If you use an authorized agent, we may require proof of your authorization and may still ask you to verify your own identity before we act on the request.

Response Time and Verification: We will acknowledge receipt of your request within ten (10) business days and respond to verified requests within forty-five (45) days of receiving them. If additional time is required, we will notify you and explain the reason for the delay, which will not exceed an additional forty-five (45) days. We may need to verify your identity before fulfilling your request by asking for limited information to match against our records. If you submit a request through an authorized agent, we may require proof of your authorization.

11. NOTICE FOR USERS FROM NEVADA

Under Nevada law (NRS Chapter 603A), certain Nevada residents have the right to opt out of the sale of their “personally identifiable information” for monetary consideration to a person who then licenses or sells such information to additional persons.

“Personally identifiable information” includes details such as your first and last name, address, email address, phone number, Social Security number, or any identifier that allows a specific person to be contacted physically or online.

Call Curb does not sell your personal information to anyone. However, if you are a Nevada resident and wish to exercise your statutory right to opt out of any future potential sale of your personal information, you may submit a request to support@callcurb.com.

12. RIGHTS OF USERS FROM OTHER STATES AND COUNTRIES

Your data controller with respect to the personal information collected on the App is:

Company Name: Responsive IP LLC

Registered Office: 8 The Green Suite 12062, Dover, DE 19901

Depending upon the laws of your specific country, you may be eligible for some or all the following rights in respect of your personal information:

Right to obtain information: You may have a right to obtain information about how and on what basis your personal information is processed and to obtain a copy.

Right to rectification: You may have the right to have any incomplete or inaccurate information we hold about you rectified and corrected.

Right of Erasure: You may have the right to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us.

Right of restriction: You may have the right to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim or (d) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.

Right to object: You may have the right to object to decisions which are based solely on automated processing or profiling.

Right to ask for a copy: Where you have provided your personal information to us with your consent, you may have the right to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or to obtain a copy of or access to safeguards under which your personal information is transferred outside of your jurisdiction.

Right to withdraw your consent. You may have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our services.

Request the transfer of your Personal Data. If you so have this right, we will provide to you, or to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right may only apply to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

To make such requests, please contact us at support@callcurb.com. Please note, we reserve the right to reject the request if you are not entitled to the right that you request to enforce.

13. RESPONDING TO LEGAL REQUESTS

We may access, preserve, or disclose your personal information if we are required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that such action is necessary to comply with applicable legal obligations, enforce our Terms and Conditions, protect our rights and property, investigate fraud or security concerns, or ensure the safety of our users and the public. Any disclosure will be limited to what is legally required, and we will make reasonable efforts to notify you where permitted by law before releasing your information.

14. CHILDREN PRIVACY

The App is not intended for use by children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information as soon as possible. Please contact us at support@callcurb.com if you believe we knowingly or unknowingly collected information described in this Section.

15. OPTING OUT

You have control over certain uses of your information and how the app interacts with your device. You may disable access to your contacts or call data at any time through your device settings. Please note that certain features of Call Curb, including caller identification and spam detection, will not function properly without this access.

You may disable push notifications through your device notification settings if you no longer wish to receive alerts from the app. Where required, you may change advertising consent or opt-out choices through Ad privacy options in the app’s Settings. You may also adjust advertising-ID or personalized-ad settings through your device and review Appodeal’s privacy and opt-out information at https://www.appodeal.com/privacy-policy and https://appodeal.com/sdk-opt-out/.

You may opt out of marketing or promotional emails by following the unsubscribe instructions included in those emails. Service-related messages about your account or subscription cannot be opted out of, as they are necessary to provide the service.

If you wish to stop all data processing related to your account, you must delete your account through the app. Once your account is deleted, your personal data will be removed in accordance with Section 4 (Retention and Deletion) of this Privacy Policy.

16. GOVERNING LAW AND DISPUTE RESOLUTION

This Privacy Policy is governed by and shall be interpreted in accordance with the same governing law and dispute resolution provisions set out in our Terms of Service. Any dispute arising out of or in connection with this Privacy Policy shall be resolved in accordance with those Terms.

17. QUESTIONS ABOUT THIS PRIVACY POLICY

In the event you have any grievance regarding anything related to this Privacy Policy, or with any content or service of Call Curb, you may write to the Grievance Officer/Designated Representative using the contact details below:

• Email: support@callcurb.com
• Postal Address: 8 The Green, Suite 12062, Dover, DE 19901

18. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our business practices, legal obligations, or the way we handle your personal information. When we make changes, we will revise the “Last updated” date at the bottom of the Policy and, if the changes are significant, we may notify you by email or through a notice on our App.

We encourage you to review this Privacy Policy periodically so you stay informed about how we protect your information and your rights. Your continued use of the App after any changes to this Policy will constitute your acceptance of those changes.

19. WELCOMING OF SUGGESTIONS

We welcome your comments regarding this Privacy Policy. Please write to us at support@callcurb.com.