Last updated on February 10th, 2019

Aloha Environment Ltd.. (“Aloha” or “we”) respects the privacy of the users of its mobile application (“User” or “you”) and is committed to protect the User's information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our App.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our terms of use (“TOU”), into which this Privacy Policy is incorporated thereto by reference.

1.          YOUR CONSENT (IMPORTANT, PLEASE READ CAREFULLY!)

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE APP, AND/OR BY INSTALLING THE APP ON YOUR MOBILE DEVICE AND/OR CONNECTING TO THE APP, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE POSSIBLE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW) AND DATA AS SPECIFIED HEREIN. 

PLEASE NOTE: IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ENTER TO, CONNECT TO, ACCESS OR USE THE APP IN ANY MANNER AND YOU ARE REQUESTED TO PROMPTLY UNINSTALL THE APP FROM YOUR MOBILE DEVICE. FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.

PLEASE NOTE THAT IN ORDER TO PROVIDE YOU WITH OUR SERVICES, THE APP MUST BE LINKED WITH MOBILE TELEPHONE OPERATED BY A THIRD PARTY SERVICE PROVIDER, (THE "MOBILE OPERATOR"), AND YOU MUST GRANT US CERTAIN ACCESS PERMISSIONS TO VARIOUS FEATURES WITHIN YOUR MOBILE TELEPHONE (AS SPECIFIED BELOW). YOU HEREBY GRANT ALOHA ACCESS TO, AND THE ABILITY TO EXTRACT CERTAIN DATA INCLUDING BUT NOT LIMITED TO INFORMATION AND DATA WHICH IS HELD ON YOUR MOBILE TELEPHONE ("DEVICE USAGE DATA"), AND INFORMATION FROM YOUR MOBILE OPERATOR, AS NECESSARY. PLEASE NOTE – WE WILL EXTRACT THIS DATA SOLELY IN ORDER TO PROVIDE YOU WITH OUR SERVICES. WE DO NOT SHARE YOUR PERSONAL INFORMATION WITH ANY THIRD PARTY FOR MARKETING PURPOSES WHATSOEVER.

2.          WHICH INFORMATION WE MAY COLLECT ON OUR USERS?

We may collect two types of data and information from our Users:

a.      Non-identifiable and anonymous information (“Non-Personal Information”). Non-personal information is any unconcealed information which does not enable identification of an individual user, and which is available to us when such user installs our app and/or uses the app. Non-personal information which is being gathered and stored consists of technical information, statistical information and aggregated information processed from the User Data, including the Data Derivatives.

b.     Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature:

• We gather the Users' IP address and/or advertiser identifier (when available on a device) mainly to detect anomalies for security purposes (i.e., in order to safeguard our App). We note that Aloha may collect, use and provide access to the User's advertising identifier in accordance with the applicable platform provider's policies.  

• By installing and connecting to the App, you give us your consent to access Device Usage Data deriving from the following features within your mobile telephone: call log, address book, media files and photos, and your microphone (collectively, the "Features"). The App utilizes the Features in order to provide you with our Services. The Features are used for the following purposes: (i) access to the call log enables the App to create the default private list according to you frequently contacted contacts, (ii) your address book is used in order to receive names and telephone numbers of your contacts, enabling you edit your default private list (deleting or adding contacts  to edit your default private list) and to identify incoming and missed calls, (iii) your files are used in order to enable you to save voice messages notifying your contacts that you are unavailable.; and (iv) your microphone is used in order to enable you to record voice messages and audio recordings. This Devise Usage Data may contain data and information which is of a sensitive nature. In addition, we will have access to your mobile telephone and carrier data to show missed calls alerts while the "Aloha" mode is activated. Excluding the Non-personal Information, which may be collected and stored by us using external storage services (as further detailed in this Privacy Policy), the collection and processing of the User Data shall occur solely on the User's mobile device. Please note that Aloha has the ability to access the content of the written and audio messages, however, as Aloha does not have a need to access such content, Aloha, in practice, is not exposed to such content. Personal Data will be stored on the User's mobile telephone as well as on the Aloha serves.

• Personal Information may be collected from the details the Users provide during registration to App including, the User's telephone number.  

• Personal Information may be collected from the details the User may provide us while contacting us via the support e-mail address available herein.

FOR AVOIDANCE OF DOUBT, ANY NON-PERSONAL INFORMATION CONNECTED OR LINKED TO ANY PERSONAL INFORMATION SHALL BE DEEMED AS PERSONAL INFORMATION AS LONG AS SUCH CONNECTION OR LINKAGE EXISTS.

WE DO NOT COLLECT ANY PERSONAL INFORMATION FROM YOU OR RELATED TO YOU WITHOUT YOUR APPROVAL, WHICH IS OBTAINED, INTER ALIA, THROUGH YOUR ACTIVE ACCEPTANCE TO THE TERMS OF USE AND THE PRIVACY POLICY.

3.          HOW DO WE COLLECT INFORMATION ON OUR USERS?

There are four main methods that we use:

1. We collect information through your entry, connection, access, installation and/or use of the App. In other words, when you are using the App we are aware of it and may gather, collect and store the information relating to such usage (such as the Non-personal Information detailed above), either independently or through the help of our authorized third-party service providers as detailed below.

2. We collect information which you provide us voluntarily. We collect Personal Information during the registration process when you register to the App.

3. We collect information from your User Data, which you provide us voluntarily. We collect information and data which may be deemed as Personal Information that you have provided directly via the App, by any means.

4.          WHAT ARE THE PURPOSES OF THE COLLECTION OF INFORMATION?

Non-personal Information is collected in order to:  

• Use it for statistical, analytical and research purposes and for customization, developing and improvement of our App.  

• Enhance the User's experience while using the App.

Personal Information is collected in order to:

• Operate the App and offer its features and App Services.

• Verify the User's identity when he/she signs in to the App.

• Personalize and enhance the User's experience while using the App.

5.          SHARING INFORMATION WITH THIRD PARTIES

We acknowledge that you connect to the App very sensitive, identifiable information. Aloha will not share any Personal Information with any third party, other than in the extreme circumstances as follows: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of the App, its Users or the general public; (e) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, so long as such acquirer maintains the same privacy terms hereunder; or (f) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, Aloha may transfer and disclose Non-personal Information, including Data Derivatives, to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our App. Note, that we collect, hold and/or manage your Non-Personal Information through Aloha's authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.  

6.          THIRD PARTY SERVICE PROVIDERS AND THIRD PARTY SOFTWARE

While using the App we may be using third party service providers, who may collect, store and/or process the information detailed herein. Aloha uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such third parties may include without limitation, Twilio which its privacy policy can be found at: https://www.twilio.com/legal/privacy, UXcam which its privacy policy can be found at: https://help.uxcam.com/hc/en-us/articles/360004158171, Firebace which its privacy policy can be found at: https://firebase.google.com/support/privacy/, Asterisk which its privacy policy can be found at: https://www.asterisk.org/privacy, as well as additional third party service providers. Please read such third party service providers' terms of use and privacy policies to understand their privacy practices.

8.          MINORS

The App is intended for Users over the age of thirteen (13). Therefore, Aloha does not intend and does not knowingly collect directly Personal Information from children under the age of thirteen (13) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the App. If we learn that we unlawfully collected Personal Information from children under the age of thirteen (13) we will delete that information as quickly as possible. Please contact us at alohaprj@gmail.com if you have reasons to suspect that we unlawfully collected Personal Information from children under the age of thirteen (13) and we will delete that information as quickly as possible. It is hereby clarified that the User Data may include information regarding children under the age of thirteen (13) only in the event that the legal guardian of such child has agreed to such use, all as required under any applicable laws.

9.          LINKS TO THIRD PARTY WEBSITES

Certain links provided in the App permit Users to leave our App and enter non-Aloha sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of Aloha and it is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for any content advertising, products, services or other information on or available from such linked sites and services or any link contained in a linked site or service. Aloha reserves the right to terminate any link at any time. You further acknowledge and agree that Aloha shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resource.

Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

10.       COOKIES & LOCAL STORAGE

When you access or use the App, we and/or our third party service providers may use industry-wide technologies such as "cookies" and local storage (or other similar technologies), which store certain local information on your device ("Local Storage") which may enable, inter alia, automatic activation of certain features and make the User’s App experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored in the User's device. Aloha and/or our authorized third party service providers may access such information. Aloha and/or our authorized third party service providers may use both session cookies (which expire once you close the App) and persistent cookies (which stay on the User’s device until such User deletes them). Such Local Storage used by the App may store non-personal information (such as the different pages viewed by a User within the App) as well as User persistent identifier, which will be collected in accordance with the terms specified herein. It is easy to prohibit and/or delete the Local Storage, inter alia, via uninstalling the App from your mobile device and/or through the "Settings" option of your device. Most platforms will allow you to erase cookies from a device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option you may use the "Settings" option of your device or according to the specific instructions provided by the third party service provider's privacy policy and terms of use. However, if you block or erase cookies, or change the settings of your device, your App experience may be affected and may be limited.

11.       DELETION OR MODIFICATION OF PERSONAL INFORMATION; TERMINATING OUR ACCESS TO YOUR USER DATA

If for any reason you wish to delete or modify your Personal Information you can do so within the App. You may permanently delete your User Data, and any data processed from the Mobile Operator and other data which is stored upon your device by deleting your account. You may terminate our further access to your User Data or parts of it by uninstalling the App and contacting us by sending an email to: alohaprj@gmail.com and we will respond within a reasonable timeframe. For the avoidance of doubt, Aloha shall be entitled to retain the Data Derivatives externally restored by it indefinitely.

12.       SECURITY

We take reasonable measures to maintain the security and integrity of our App and User Data and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. The use of Aloha's App Services is intended for personal use only. Please note that in spite of our security measures, your Personal Information may be at risk in the event that you allow access to any third parties to your mobile device. We strongly recommend that in order to protect your Personal Information, you use sufficient security measures such as device locking code and fingerprint identification mechanism as applicable and/or available in your mobile device. Please note that we cannot guarantee that unauthorized access and/or use will never occur. ALOHA SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER DATA.

13.       INTERNATIONAL DATA TRANSFER

We may transfer Non-personal Information collected from your User Data pursuant to the terms herein, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such Non-personal Information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

14.       CHANGES TO THE PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the App and any information collected therein. Aloha reserves the right to change this policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the App. Such material changes will take effect seven (7) days after such notice was provided on our App. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the App on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

15.       GOT ANY QUESTIONS?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: alohaprj@gmail.com, and we will make an effort to reply within a reasonable timeframe.