Dial09 provides and operates an instant messaging and voice/video over IP (VoIP) telecommunication service, called “dial09 free SIP service” (“the Service”), and distributes a VoIP application for mobile and desktop platforms, called dial09 (“the Application”), to any individual user, whether for personal or professional purposes.

This Service and Application, as well as other associated support, maintenance or development services, and more generally all products and services provided by Dial09, are fully described on Dial09’s website, available at https://www.dial09.com/ (“the Site”).

For the purposes of receiving information on Dial09’s products and services, Internet Users visiting the Site may contact the company through our contact form, or subscribe to our newsletter.

This Privacy Policy describes, as required by Art.13 of GDPR, how Users‘ personal data are collected and processed by Dial09 when Users visit the Site, contact the company, or subscribe to the newsletter, as well as their rights and ways to exercise them.

This Policy, as well as any amendment thereof, is published on the Site and shall be subject to acceptance by all Users upon subscribing to the Newsletter or filling out the contact form.

1. DEFINITIONS 

As used in this Policy, the following terms shall be defined as follows:

– Application: Dial09 application for iOS, Dial09 application for Android, and Dial09 application for desktop platforms; downloadable on the User’s Terminal; published by Dial09;

– Personal Data (or “Data”): personal data of the User, processed by Dial09 for the purposes set forth in this Policy;

– Dial09: SARL Dial09, whose head office is located at 12, Allée des Genets 38000 GRENOBLE, registered with RCS of Grenoble under the number 520 318 437.

– Service: Dial09’ VoIP service for audio/video calling and instant messaging, using the open protocol SIP (Session Initiation Protocol), allowing Users to create a free SIP account with the SIP domain sip.https://www.dial09.com/, and that is made available for free online or via the Application, under the conditions set forth in dial09 T&Cs;

– Mailing List: one of Dial09’s mailing lists, to which any User may subscribe, directly on the Site, for the purposes of getting information or support on the Application or the Service.

– Newsletter: electronic document containing information about the recent activities of Dial09, and sent by email to the Users;

– Site: https://www.dial09.com/ website, published and operated by Dial09, describing and updating the features and requirements of the Application and the Service;

– Device: a mobile or fix telecommunication device with Internet access, such as a smartphone, tablet, or personal computer (PC), which allows the Application to be downloaded and the Service to be used, in accordance with the prerequisites indicated at the time of download;

– User: natural person visiting the Site, subscribing to a Mailing List, subscribing to dial09’s newsletter, contacting Dial09 through the contact form on the Site, having downloaded and using the Application for personal or professional purposes, or having created an account on the Service.

2. WHO IS THE DATA CONTROLLER?

The Data Controller is Dial09 whose head office is located at 17 Cobblers Cr, Franklin Park, NJ 08823

All requests regarding this Policy and GDPR may be sent, by mail to its postal address: 17 Cobblers Cr, Franklin Park, NJ 08823 or by email- Accounts@dial09.com

3. WHO ARE THE DATA SUBJECT?

The Data Subject, as defined under art.4 of GDPR, and concerned by this Privacy Policy, are the Users, as defined under Section I.

4. WHAT KIND OF PERSONAL DATA ARE PROCESSED?

For the purposes of providing the Service, the Application, and related services, the following Personal Data are processed by Dial09:

4.1. Contact Form:

Name
Email address
Company
Country
Type of request, and full text of the request; and more generally, all information given to Dial09 on its specific needs or its project;

4.2. Mailing Lists:

Email address
Name (optional)
All messages exchanged with other Users, whether new topics or responses to opened topics;

4.3. Visiting the website:

IP address
Cookies

4.4. dial09 free SIP service:
4.4.a. User subscription data:

Name
Email address
IP address used while subscribing
User’s password stored as a MD5 or SHA256 hash, used for SIP digest authentication.
User’s international phone number, for Users subscribing from the mobile application.
User-agent used for subscription: it can be the browser’s user-agent string, or Dial09 app user-agent string. The user-agent string of mobile apps includes an identifier of the device, for example “Moto G7”, “Samsung SM518”, “Apple Ipad 2”, which is used to allow users to easily track the devices on which they have used their SIP account.

4.4.b. User activity data:

Calls logs. They comprise: caller’s SIP address, callee’s SIP address, date, time, status (completed or not), duration.
Chat message logs: sender’s SIP address, recipient’s SIP address, date, time, status (delivered or not), type (content or delivery notification). For clarity, the actual content of these messages is not stored.
Registration logs: these logs represent the instants when a user apps connects to the service through the network. They contain: date, time, status, IP address.
Telephone numbers of User’s mobile phone address book,

4.4.c. Group chat activity data:

User’s membership to group chat and secure one to one chatrooms, including User’s device identification (thanks to user-agent string) actually joined to the IM session. It also contains date and time where the User has joined or left a chatroom.
Subject entered by the User while creating a group chat.

4.4.d. Debug logs:

For the sole purpose of troubleshooting, Dial09 reserves the right to activate the debug logs in the Application and in the software used to provide the Service. Such debug logs contain full protocol information for the calls, chat messages and other protocol events generated by the Users.

5. WHAT ARE THE PURPOSES OF DATA PROCESSING?

We decided to list processing purposes, for each type of Data processed under Section IV.

Contact Form Data

Answer to User’s request for information on Dial09’s products or services
Issuing quotes to Users on specific licenses and services;

Newsletter

To provide Users with up to date information on the Service, the Application, and on Dial09’s latest news and activities;

Mailing List

Provide User with sources of information on the Application, its use, its development, or any needs for support;
Enable Users to exchange with other users on the Application, or any service provided by Dial09
Visiting the Site Audience and statistical purposes
Dial09 free SIP service data

a. User subscription Data:

User’s subscription to the Service;
User’s operation of the Service;

b. User activity Data:

Compliance with Dial09’s legal obligations
Ability to proceed with requests from legal or regulatory authorities, regarding User identification or use of the Service;
Statistical analysis on use of the Service by Users; such as call peaks, interaction with third party software, volume and nature of data exchanged by time of day; based on fully anonymized data of Users; in order to improve the Service’s operation and functionalities;

c. Group chat activity data:

providing group chat and secure one to one chat services: data collected are necessary to enable delivery of a message sent by a User to other Users, members of the group.

d. Debug Logs:

Support and troubleshooting services;
Correct operation of the Service

6. WHAT ARE THE LEGAL BASIS FOR SUCH PROCESSING?

Once again, we thought it would be clearer to present such legal basis for each kind of Data processing.

Contact Form Data
User consented to the processing;
Processing is necessary to take steps at the request of the User prior to entering into a contract;
Processing of the Data is in accordance with our legitimate interest since it enables us to increase our customer and prospect base for marketing purposes;
Newsletter
User consented to the processing;
Mailing List
User consented to the processing
Processing of the Data is in accordance with our legitimate interest since it enables us to improve performance of the Service and of he Application;
Visiting Data
Processing of the Data is in accordance with our legitimate interest since it enables us to measure the audience of our Site;
dial09 free SIP service data

a. User subscription Data:

User consented to the processing;
Processing is necessary to operate the Service, and therefore for the performance of the agreement with the User (Terms and Conditions of Service);

b. User activity Data:

Processing is necessary to comply with our legal obligations;

c. Group chat activity data:

Processing is necessary to operate the Service and therefore for the performance of the agreement with the User (Terms and Conditions of Service);

d. Debug Logs:

Processing is necessary to perform the Service or support agreement with the User;
Processing of the Data is in accordance with our legitimate interest since it enables us to improves performance of the Service;

7. HOW ARE MY DATA PROTECTED?

Dial09 is a paid SIP service on machines hosted on Freepbx with monthly a subscription to its customers in place in USA

The machines are secured, only Dial09 employeed and users whos domain are registered can login with provided credentials.

For all other requests, please send us an email to: accounts@dial09.com

Service: Dial09 VoIP service for audio/video calling and instant messaging, using the open protocol SIP (Session Initiation Protocol), Dial09 does not allow Users to create a free SIP account and services are only paid and controlled by customers admin team or Dial09 support team

8. HOW LONG ARE MY DATA PROCESSED?

Contact Form Data
Data are retained for a period of 3 years from User’s last contact, in accordance with CNIL’s reference guide on commercial management;
Newsletter
Up to un-subscription from the Newsletter by User;
Mailing List Data
Until the Mailing List, or a specific topic is closed; in which case, messages exchanged (threads) are archived for 10 years, in order to keep specific knowledge available to other Users;
Visiting Data
13 months, from the first date of collection
dial09 free SIP service data

a. User subscription Data:

Until closing or deletion of User’s account;
Data are deleted from active database, but stored for one year from closing or deletion of User’s account, pursuant to the provisions of Decree No. 2011-219 of February 25, 2011 relating to the storage and communication of data allowing the identification of any person having contributed to the creation of content published online

b. User activity Data:

12 months after collection; i.e. call logs and chat message logs are retained for 12 months from their registration in BELLEDONNE’s systems;

c. Group chat activity data:

as long as the chat session (chatroom) is alive, i.e. as long as there is a User Device joined to the chatroom. When all Device from all users have left a chatroom, all data associated to the chatroom are deleted from active data base.

d. Debug Logs:

1 month

9. DO WE DISCLOSE ANY INFORMATION TO THIRD PARTIES?

We do not sell, trade, or otherwise transfer to outside parties your Personal Data, or all type of content that you may upload or send with dial09 (e.g. text conversations, calls, videos, photos; etc.), unless specifically requested by legally competent authorities, under a judicial or administrative order (see IV.2 and IV.3).

10. DO WE USE COOKIES?

We only use audience cookies, i.e. Google Analytics.

A consent pop-up is displayed when accessing the Site, enabling you to accept or refuse such cookies.

They also may be disabled at any time through your browser’s settings.

11. WHAT ARE MY RIGHTS AND REMEDIES?

11.1. User’s rights on Personal Data

As a User, you have the right to obtain from us:

confirmation that personal data concerning you are or are not being processed, and if necessary, to have access to them;
the correction of personal data concerning you that are inaccurate or incomplete;
the deletion of your personal data, under the conditions set forth in art.17 of GDPR; you may, for instance, delete your user account directly via the Service online, which will stop processing of all Personal Data, subject to the exceptions set forth in Section VIII;
the portability of your personal data to any similar digital audio/video service, under a standard and structured readable format; these requests may only deal with data provided by you, or in direct link with your activity (such as Data mentioned in IV.4.b. and IV.4.c.), to the exclusion of (i) any value-added data that we may process (such as profile-based recommendations, or statistical data), and (ii) any data or content generated by the User when using the Service, such as call history, messages, chat messages; which are exclusively stored on his Device.
organizing the fate of your personal data in the event of your death (storage, deletion, or communication to a designated person).
to oppose, under certain conditions, the processing of your personal data.
You may also, at any time, object to the processing of your data for commercial prospecting purposes by unsubscribing to our Newsletter.

11.2. How to exercise them

You may unsubscribe to a Mailing List by clicking on the “unsubscribe” link on any email, or changing your settings in the Mailing List homepage.

You may unsubscribe to our Newsletter by clicking on the “unsubscribe” link at the end of one of our Newsletter emails.

You may delete your account via the online Service.

For all other requests, please send us an email to: Info@JPnetsols.com,

indicating the subject of your request, your name(s) and first name(s);
enclosing a photocopy of both sides of your identity card or passport, to enable us to verify your identity and any information that would be useful in processing your application.
We will get back to you as soon as possible, at the latest within one month of receiving your application.

We remind you that you have the right to file a complaint with the CNIL if you feel that your rights have not been respected. For more information on your rights with regard to your data, we invite you to consult the following webpage: https://www.cnil.fr/fr/plaintes.

What This Privacy Policy Covers

• This policy covers how dial09 treats personal information that dial09 collects and receives, including information related to your purchase and use of dial09 products and services. Personal information is information about you that is personally identifiable like your name, address, email address, or phone number, and that is not otherwise publicly available.
• By using any dial09 pages, in any way accessing dial09, or using other services of dial09, you are accepting the practices described in this policy and our terms of use.
• This policy does not apply to the practices of companies that dial09 does not own or control, or to people that dial09 does not employ or manage.

Privacy.

dial09 utilizes the public Internet and third party networks to provide fax, voice and video communication services. Accordingly, dial09. cannot guarantee the security of fax, voice and video communications of Purchaser. dial09. is committed to respecting the Purchaser’s privacy.

Once Purchaser chooses to provide personally identifiable information, it will solely be used in the context of the Purchaser’s relationship with dial09. and its Vendor. dial09 will not sell, rent or lease Purchaser personally identifiable information to others. Unless required by law or subpoena or if Purchaser’s prior permission is obtained, dial09. will only share the personal data Purchaser provides with other dial09. entities, Vendor and/or business partners that are acting on dial09’s behalf to complete the activities described herein. Such dial09. entities and/or national or international business partners are governed by. dial09’s privacy policies with respect to the use of this data. dial09. is required to file numerous reports with different administrative bodies. As such, dial09. may provide aggregate statistics about customers, sales and traffic patterns. None of these reports or statistics will include personally identifiable information.

However, dial09. reserves the right to use personally identifiable information to investigate and help prevent potentially unlawful activity that threatens either dial09. or any company affiliated with dial09

Moreover, upon the appropriate request of a government agency, law enforcement agency, court or as otherwise required by law, dial09. may disclose personally identifiable information.

Information Collection and Use:

• dial09 may collect personal information when you (a) visit dial09 pages or the pages of dial09 business partners, (b) request information from dial09, (c) join dial09 as a member, (d) use dial09 services, or (e) purchase dial09 products. dial09 may combine information about you that we have with information we obtain from business partners or other companies.
• When you register we ask for information such as your name and contact information. In connection with purchases we may also ask for credit card numbers, or other financial information. Once you register with dial09 and sign in to our services, you are not anonymous to us.
• dial09 collects information about your transactions with us and with some of our business partners, including information about your use of services and purchase of products that we offer.
• dial09 may automatically receive and record information on our server logs from your browser, including your IP address, dial09 cookie information, and the page you request.
• dial09 may use information we receive from you for any business purpose, such as to (a) fulfill your requests for products and services, (b) improve our services and customize the advertising and content you see, (c) provide our business partners and others with the ability to contact you and offer additional products and services you may be interested in, (d) conduct research, troubleshoot problems, resolve disputes, or enforce the dial09 policies, or (e) provide reporting for internal and external clients.
• You consent to the collection and use of your personal information, including the transfer of information within and outside of Canada for storage, processing, and use as set forth in this privacy policy.

Information Sharing and Disclosure

• dial09 may sell, rent, or share personal information about you with our business partners, affiliated companies, nonaffiliated companies. Your personal information may be used to, among other things:
• Provide products, services or information you’ve requested.
• Provide you with information about additional products and services you may be interested in.
• Communicate with you about offers from dial09 and our marketing partners via direct mail, email, telemarketing or other direct marketing.
• We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
• We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of dial09’s terms of use, or as otherwise required or permitted by law.
• We transfer information about you if dial09 is acquired by or merged with another company.
• dial09 may employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. They may have access to personal information about you needed to perform their functions.
• dial09 works with vendors, partners, advertisers, and other service providers in different industries and categories of business.
• We reserve the right to send you certain communications relating to the dial09 service, such as service announcements and administrative messages, that are considered part of your dial09 membership, without offering you the opportunity to opt-out of receiving them.

Cookies

• Cookies are alphanumeric identifiers that dial09 may transfer to your computer hard drive through your Web browser.
• dial09 may set and access cookies on your computer.
• dial09 may use IP addresses and cookies to analyze trends, administer the site, track member and user movements, and gather broad demographic information for aggregate use.
• dial09 may also use web beacons to access dial09 cookies inside and outside our network of web sites and in connection with dial09 products and services.

Confidentiality and Security

• Sensitive financial information, such as credit card information, is encrypted and protected online for your privacy and security.
• Personal information collected by dial09 is stored in secure databases, accessible only by dial09, our affiliated companies and service providers, and others authorized to have access.
• We have physical, electronic, and procedural safeguards that comply with applicable regulations to protect personal information about you.

Changes to this Privacy Policy

• dial09 may modify, cancel or update this policy at any time in its sole discretion. Any changes will become effective immediately, and will apply to all personal information then in dial09 possession, custody or control, including all previously-collected information.
• dial09 may notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your dial09 account, by placing a notice on our site, or by posting the revised policy.

Updating Personal Information

• If your personal information changes dial09 members may update their account information by contacting customer service.