When you install the Virtual SIM App or register on the Site, you will be asked to provide us with your phone number and name and to allow us access to your mobile device's address book. A copy of the phone numbers and names in your address book (but not notes or any other Personal Information in your address book) will be stored on our servers and will only be used to:

• (a) notify you when your contacts become active on Virtual SIM,
• (b) indicate which of your contacts is already a Virtual SIM user,
• (c) correctly display the name of each contact as it appears in your address book when a call is received.

The copy of your address book (names and phones) is stored on a live database. This database does not have a "historical backup". If you delete the address book from our servers (more about this below), it will be deleted instantly and permanently.

Your phone number will be used for identification purposes as your Virtual SIM user ID.

Since Virtual SIM users may add your Virtual SIM number to their address book and see that you registered to Virtual SIM, we do not consider the fact that your Virtual SIM number exists on Virtual SIM as private information.

Audio calls by users are transmitted either directly from user to user or, if direct transmission is not possible (due to, for example, firewalls), Virtual SIM servers are used to transmit the call. In the latter scenario, the information transmitted is stored briefly in volatile memory (RAM) solely to enable the transmission of the call to the other user. WE DO NOT RECORD ANY PART OF YOUR CALL.

Sharing and Disclosure of Information

We do not rent, sell, or share any information about our users with any third-parties, except as specifically described herein. We may disclose your Personal Information if we believe such action is necessary to:

• (a) comply with the law, or legal process served on us;
• (b) protect and defend our rights or property (including the enforcement of our agreements); or
• (c) act in urgent circumstances to protect the personal safety of users of our Service or members of the public.

In order to provide you with Virtual SIM products you have requested, Virtual SIM may sometimes, if necessary, share your Personal Information (excluding your address book and related information) and traffic data with trusted partner service providers and/or agents, for example: banking organizations or other providers of payment and analytical services, customer support, or hosting services. Virtual SIM will always require these third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to observe the relevant legislation. Virtual SIM will never share your address book information with any third party, except as may be required by law (see below).

The following is a description of how we may share your Personal Information with trusted third party partners. Should we add additional partners, we will immediately update this description:

1. We use third party companies in order to send you an authentication SMS when you register with Virtual SIM. In order to send you the SMS, we send one of these third party companies your phone number and the authentication message. These third parties are contractually obligated to only use your phone number for the transmission of the authentication SMS.
2. We may use Push Notification Services to notify you about various events related to the app. If we do, the phone number or the name of the person calling you or sending you a message may be part of the notification. This message is sent to the push notification service provider, for delivery to your device.
3. We use third parties to process the payment and/or billing information that you submit on our Site or through the Virtual SIM App to facilitate payment transactions. We require that these third parties take the appropriate organizational and technical measures to protect your personal data and traffic data and to comply with relevant laws, but we are not liable or responsible for these third party transactions. Therefore, you should review such third party terms and conditions before providing your payment or billing information.

We may disclose information about you if we determine that for national security, law enforcement, or other issues of public importance that disclosure of information is necessary. We may from time to time ask you to provide information about your experiences, which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the Site or any survey that you accept to take part in is used for the purposes of reviewing this feedback and improving the Virtual SIM software, products and websites.

We may contact you to send you messages about faults and service issues. Furthermore, we reserve the right to use email, the Virtual SIM software or SMS to notify you of any eventual claims related to your use of our software, websites and/or products, including without limitation claims of violation of third party rights.

We may send you alerts via the Virtual SIM software to notify you when someone has tried to contact you. We may also use the Virtual SIM software to keep you up to date with news about our software and related information.

Children's Privacy

Virtual SIM websites and software clients are not intended for or designed to attract anyone under the age of 13 and we do not intentionally or knowingly collect Personal Information on our sites from anyone under the age of 13 (or older in some jurisdictions). We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission.

Security

We take reasonable precaution to protect Personal Information from misuse, loss and unauthorized access. Although we cannot guarantee that Personal Information will not be subject to unauthorized access, we have physical, electronic, and procedural safeguards in place to protect Personal Information. Personal Information is stored on our servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

Changes to Policy

From time to time, we may revise this Policy. We reserve the right to update or modify this Policy, or any other of our policies or practices, at any time with or without notice. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt-out of such differing uses. We will post the revised Policy on the Site, so that users can always be aware of what information we collect, how the information is used and under what circumstances such information may be disclosed. You agree to review the Policy periodically so that you are aware of any modifications. Your continued use of the Site indicates your assent to any changes and signifies your agreement to the terms of our Policy. If you do not agree with these terms, you should not use the Site, the Virtual SIM App, or any other Service.