Privacy and Security

Introduction

DID Logic is a provider of telecommunications, VoIP, DID number provisioning, SIP routing, cloud communications and related services (hereinafter referred to as the “Services”).

This Privacy Policy applies to:

DID Logic PTE. LTD., 15 Scotts Road #04-08, 228218 Singapore, Registration No. 201813377H

and/or

DID Logic Inc., 906 W 2nd Ave Ste 100, Spokane, Washington 99201, United States

(together referred to as “DID Logic”, “we”, “us”, or “our”).

This Privacy Policy should enable our users (hereinafter referred to as the “you” and/or “User”) to better understand how we keep your personally identifiable information (hereinafter referred to as the “Personal Information”) confidential as well as the treatment of such information and any rights deriving from such control and processing, when you:

• Use our services
• Visit our website (https://didlogic.com)
• Enter into agreements with us
• Communicate with us

We process personal data in accordance with applicable laws including:

• General Data Protection Regulation (GDPR)
• UK GDPR (where applicable)
• Singapore Personal Data Protection Act (PDPA)
• Other applicable regulations

Scope of this Policy

This Privacy Policy applies to, customers, business representatives, end users (where applicable), website visitors and service users.

DID Logic primarily acts as a data processor when providing telecommunications services to customers and as a data controller for its own business operations.

Privacy Principles

We process personal data according to the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality.

Privacy Statement

To make this policy easier for understanding and to briefly inform you about our privacy priorities, we decided to make the following statement on our data privacy policy:

• Data collection:

We will collect and store your Personal Information, which is also known as “personal data” only if and when we will have legal grounds to do so.

• Keeping confidentiality

We take our responsibility to protect the privacy and confidentiality of any personal data very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable legal security standards to store and secure the client information from unauthorized access and use, alteration and destruction. However, in some cases government and other regulatory authorities including but not limited to courts and police, may request access to your personal details without your authorization or prior notification, so we may disclosure your personal data for compliance reasons and for legal purposes, when and if it is required by the laws.

• Appropriate usage

We will collect, use and maintain client information only for appropriate purposes, and only for the allowed timeframe in accordance with applicable law requirements.

• Data Minimization and Limitation of Data Retention

We will strive to collect the minimum number of personal information and data and process and maintain such for the shortest possible time.

• No Spam

We will keep your e-mail address data confidential and will provide you with option of managing the advertising and marketing communications.

• Right to be informed

We will inform you about the collection , usage process and storing of your personal data in details.

Definitions

“Personal Information” or “Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Account” means an account, which required for the access and (or) using of the specific functional of our Platform(s) and (or) Services.

“Services” means collectively all services and/or solutions, including ancillary services provided through the Platform, such as Telecommunications, DID provisioning, SIP routing, voice services, messaging services and related services.

“Platform” means the collection of web pages, owned and (or) operated by DID Logic and placed by the following address in the Internet: https://didlogic.com.

“Visitor” means a visitor, who opens/visit/was attracted or redirected to our Platform.

“User” means Visitor and/or any legal entity or natural person, created the account in order to get access and (or) to use the specific functionality of our Platform and (or) Services.

“User Owned Data” means any messages, data and content, which User transmits, proceed, access or store using our Services.

“Third Party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Personal Data We Collect

• We may receive, collect and store the following categories of Personal Data:

Identity Information, Full name, Company name, Registration information, Identification documents (for compliance), Contact Information, Email address, Phone number, Business address, Account Information, Account credentials, Customer identifiers, Service configurations, Financial Information, Billing details, Payment records, Transaction information, Technical Information, IP address, Browser type, Authentication logs, Device identifiers, Access timestamps, Telecommunications Metadata,

• As part of providing telecom services we may process:

Calling numbers, Called numbers, Call timestamps, Routing data, SIP signaling data, Traffic destination data, Service usage metrics

• Important:

DID Logic does not monitor call content unless explicitly required for lawful recording services requested by customers.

• Compliance Information, where required:

KYC documentation, Fraud monitoring records, Sanctions screening information

Regulatory compliance records.

Please note, that not all categories will be collected about every individual, because Personal Information collected depends on business, operational and legal necessity.

 

How We Collect Personal Data

There are several ways, by which we collect your Personal Data, we collect date through:

• Direct interactions: when you register for services, contact support, enter agreements, request information, submit forms.
• Automated collection: when using our services, through system logs, network monitoring, platform activity tracking, security monitoring tools.
• Third parties: we may receive data from, payment processors, identity verification providers, fraud prevention providers, telecom partners, regulatory databases.

How We Use Personal Data

In general, we use your Personal Data to provide you with our Services and to improve our level of customer service or to meet a legal obligation of applicable laws.

We process personal data for:

Service provision, Providing telecommunications services, Managing accounts, Routing communications, Contract performance, Billing and payments, Customer support, Service management, Security purposes, Fraud detection, Abuse prevention, Network monitoring, Risk management, Legal compliance, Telecom regulations, Financial regulations, Law enforcement requests, Dispute management, Business operations, Improving services, Analytics, Service optimization, Customer relationship management, Communications, Service notifications, Technical alerts, Administrative messages, Marketing

 

Legal Basis for Storage and Processing of Personal Information (GDPR)

The legal basis for any operation(s) with your Personal Information will depend on the type of your personal data and the context in which it used. We warrant and represent you the following:

Any processing of your Personal Information will start and continue only when we have the valid legal basis (or bases) for such data processing and only for specific, explicit and legitimate purpose.

We will check that the processing is necessary for the relevant purpose, and that there is no other reasonable way to achieve that purpose without processing of your Personal Information, whereas such processing shall be adequate, relevant and limited to what is necessary in relation to the purpose for which the Personal Information is processed

Any Personal Information collected shall be processed lawfully, fairly and in a transparent manner.

Any collection, processing and storing of Personal Data shall be accurate and, where necessary, kept up to date, whereas every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased, or rectified without delay.

Any Personal Information shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

Any Personal Information collected shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

At least one of these legal grounds will apply when we will process your Personal Information:

(a) your consent to collect and process Personal Information;

(b) performance of a contract with you;

(c) our legitimate interests or the legitimate interests of a third party;

(d) the processing is necessary for us to perform a task in the public interest or for our official functions and/or the task or function that has a clear basis in law;

(e) necessity for compliance with our legal obligations;

(f) the processing is necessary to protect someone’s life or vital interests.

Disclosure of Your Personal Information (Data Sharing)

We may disclose your information for certain purposes and in the certain circumstances to the third parties as described below:

(a) The companies of which belong to the same group of companies as DID Logic either such company exists and operates within the European Union or outside of the Union. We will share your Personal Information for the purposes of data proceeding and storage in our corporate group;

(b) Service Providers. We may transfer your personal data to our service provider in order to execute our contract obligations, to carry out any some business activity on our behalf and/or to assist us with the provision of services to you. For example, we may store of some of your Personal Information on the rented servers.

(с) Competent Government Agencies. We may provide your User Owned Data and / or Personal Information under response to the legitimate request from the competent government authorities or agencies (“Government Data Request”).

International Data Transfers

We are an international Group of companies and through international nature of our business your Personal Information may be stored and transferred to countries outside of the EU and EEA for the execution of purposes described in this Privacy Policy. In any such case, we will take appropriate measures to ensure that the Personal Information is transferred, processed, and protected in accordance with this Privacy Policy and all applicable data protection and security laws.

Your acceptance of this privacy policy constitutes your explicit consent for such data transfer.

How Long We Will Keep Your Data? (Data Retention)

We will hold and process your Personal Information only for as long as reasonably necessary to carry out the purposes for which it was collected. For example, if you would wish to terminate our services, we will terminate the processing of your Personal Information, unless otherwise required by the applicable laws.

 

Children’s Personal Information

We recognize the importance of children’s safety and privacy. Our Platform is designed for professional business and for adult individuals only (at the age of 16, or another applicable legal age). If you believe that we store and (or) process Personal Data about children without direct authorization of their parents or legal guardians, you may contact us.

Your Privacy Rights

Hereby we notify you that the GDPR or any similar applicable laws provides you with the following rights:

DID Logic will post the new Privacy Policy on the official website (https://didlogic.com). Posting the information on the website is equal to public sharing or notification of any client of changes made to the policy.

Right of access.You have the right to obtain the detailed information about your Personal Information that we store and process, including the purposes of such data proceeding.

Right to rectification.You may update or correct the personal information about yourself available with us, which you believe is an inaccurate, incomplete or no longer be relevant.

Right to erasure (“right to be forgotten”).You have the right, in certain circumstances, to request data deletion concerning your personal data that we hold and process. Please note, that in some cases we may process your personal data even you request the data deletion, where the legal ground or obligation for such proceeding exists. You will be notified of the continuation of such processing and the reasons for its continuation, in the event that we need to continue processing your personal data.

Right to restriction of processing.You have the right to restrict the processing of your personal data if there is a particular reason for wanting the restriction. This right may be concerned as alternative to the right to be forgotten and can be applied, for example, in the situation when the personal data should not be deleted, but the proceeding of personal data should be paused or limited.

Right to object.You have the right to object to the storage and (or) processing of your personal information in certain circumstances, for example when the personal data is no longer to be proceeded or if you suspect that the personal data has been unlawfully processed.

Right to data portability.You may request a copy of your personal data for the view and (or) data transfer purposes and we will provide you with your personal data information in structured and commonly used format. You shall have the right to ask us to transfer such personal data copy to the third party by the direct communication, if this technically possible.

Right to lodge a complaint.Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority. For example, if you are a British citizen, you can complain to the ICO, if you are a citizen of France, you can complain to the CNIL, if you are a Cypriot, than you may make a complaint to the Office of the Commissioner for Personal Data Protection.

Right in Relation to Automated Decision-Making and Profiling.You have the right to be free from decisions based solely on automated processing of your Personal Data.

Please note, that this list is provided only for your convenience and better understanding of your rights. This list does not limit your rights granted by the GDPR and/or applicable laws, when applicable data privacy laws provide you with any additional rights.

Right to Manage Marketing Letters

You also can prevent or discontinue e-mail marketing communications by utilizing the unsubscribe options in marketing e-mails or manage your consent to the receiving of electronic marketing messages by the account settings. Please note, that withdrawing marketing consent does not mean that we will be prohibited to contact you for important matters like billing, technical notifications and other relevant communications.

If you want to realize your personal data privacy rights or if you have some questions about how we process your personal data, please contact us.

Security of your Personal Data

We use appropriate level of technical and organizational measures such as encryption, access controls, monitoring, logging, and other organizational safeguards, in order to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed. Nevertheless, we consider ourselves obliged to notify you that the processing and transmission of personal data over the Internet still carries certain risks, but we will take reasonable measures to mitigate them. For example, we will try to implement the commercially reasonable best industry practices to keep the personal data more secure.

Links to Other Sites and Informational Platforms

Our Platform may contain links to other sites and information platforms that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third party’s website. DID Logic does not hold any liability for the information distributed or collected by third-party Platforms. The information practices and the content of such other Platforms are governed by the privacy statements of such other Platforms. We encourage you to review the privacy statements of any such other Platforms to understand their information practices.

Cookies Policy

Please read the following notice about the types of cookies and/or other trackers we use for the purposes specified in the Cookies Policy.

Changes and Updates of this Policy

This Policy may be updated from time to time to reflect changing legal, regulatory, technical or operational reasons. We encourage you to periodically check this page for updates. At any case, we will specially inform you in the case of substantial changes of this Policy, that may seriously affect your rights and interests.

We will disclose the updates of this Privacy Policy on our official Platform available by the following link: https://didlogic.com/privacy-and-security/ Posting such information on the Platform shall be considered to the equal public sharing or notification of any User of changes made to the Privacy Policy.

 

Contact Information

If you have any questions, please contact our Data Protection Officer at [email protected].