(Last Updated: February 2017)

General Information

nWise AB (“nWise”), [insert company registration no.], Salagatan 16A, SE 753-30 Uppsala, Sweden, is the Controller of Personal Data Processed within the framework of this Privacy Policy (“Policy”).

nWise only collect Personal Data that allows us to provide You with our best Services. This includes, for example, simple tasks like allowing myMMX to use Your phone’s camera and microphone to ensure Your video calls work properly and letting the Services know Your SIP-address. It also helps us to keep our Services clear of spam, and it allows us to get an understanding of what additional services may be useful to You, and all other purposes set out in this Policy below.

How To Contact Us

If You have questions about our Privacy Policy, please feel free to send us an email to info@nwise.se. You can also contact us in writing at nWise AB, Salagatan 16A, SE 753-30 Uppsala, Sweden.

 

1.     Definitions

1.1   In this Policy ‘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.

1.2.   Additionally, ‘Process’, ‘Processed’ and ‘Processing’ means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2.     Personal Data that You provide to us or that we collect

2.1.   We want You to be assured that we do not read or listen to the content of Your calls and/or messages made privately via myMMX. We always try to collect the minimum personal data required to achieve the purposes set out in this Policy (see below), and You have the ability to limit such collection, as specified below under "Your Rights". We collect the following personal data:

a)     Registration and Account Information: When You use our Services You voluntarily give us Personal Data (e.g. name, email, city, phone number) and You are not anonymous to us. When You install the myMMX app, You will also be asked to allow us access to Your mobile device's address book, camera, microphone, unit-id and call-information, device and app-history.

b)     Activity Information: You will be given a SIP-number/telephone number which is Your personal telephone number. While using the Services, we will collect information on if You are occupied in another call or blocked. Other users may receive information on this when they call You. Call information, such as length of Your calls, missed calls etc, are only accessible for You and not for other users of the Services.

c)     Logs: We log information on what calls are made (between what users) and for how long the calls last. We do not log any sounds or video pictures. We may log such information for the purpose of tracking errors and for security purposes relating to the Services but only with the affected users’ beforehand given permission. We may also log other information regarding the calls for tracking errors and for security purposes.

3.     Purposes and Legal Basis for Processing Your Personal Data

3.1.   The Personal Data we collect from You ensures You can use the Services and can be contacted on the Services. It helps us in our mission to constantly improve our Services and provide You with new experiences. As part of this mission, we may use Your Personal Data for the following purposes:

a)       Make our Services available: We use Your registration and account data to (i) register You for the app and create Your User Account for myMMX; (ii) create Your SIP-address; (iii) provide customer service, give You information about Your account, and respond to Your requests; (iv) display Your SIP-address, 10-digit number or presentation name when You make calls (v) sync Your contacts with myMMX running on Windows, Android and iOS.

b)      Improve our Services: We use call log data and usage data to better understand network behavior and trends (numbers of messages and calls made by users, call lengths, etc.), detect potential outages and technical issues (this helps us notice things like a drop in call volume in a certain geography, a shift in call length, etc.) to improve our Services. We may look into a specific call log in response to a customer support request. We use aggregate data about our users and non-personal data to analyze our Services and user behavior and prepare aggregated reports.

c)       Communicate with You: We may use Your data to contact You (via message or other means) to maintain the app, including Your User Account, to comply with Your stated communication preferences or to provide updates about other Services.

3.2   The legal basis for Processing Your Personal Data is Your consent, as You consent to this Policy before using the Services.

4.     Specific Accounts – myMMX SIP-address and/or 10-digit number

4.1.   A myMMX SIP-address allows You to connect to use the Services from different devices, using Your SIP-address and password only. Your SIP-address is generated when Your registration has been completed successfully, with all necessary Personal Data provided by You (e.g., name, email, password, city, phone number).

5.     Recipients or Categories of Recipients of Your Personal Data

5.1.   We do not sell Your Personal Data. We only share Your Personal Data with third-parties outside of the Services, for the purposes listed above, under the following circumstances:

a)       App Providers and Other Third-Parties: We may disclose Your Personal Data to service providers and other third-parties under contract who help with providing You our Services or other services provided by third-parties via our Services (such as, but not limited to, fraud and spam investigations, payment processing, providing special partnership features in our service e.g. 112-calls). They are required to secure the Personal Data they receive, so that Your Personal Data is guarded.

b)      Legal and Law Enforcement: We may disclose Your Personal Data to law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, You, or any other myMMX user to legal liability.

c)       Change of Control – New Owners: We may share Your Personal Data with another business entity, if we plan to merge with or be acquired by that business, or are involved in a transaction with similar financial effect. In such a situation, we would make reasonable efforts to request that the new combined entity or other structure follow this Policy with respect to Your Personal Data. If Your Personal Data was intended to be used differently, we would ask the new entity to provide You with prior notice.

6.     Transfer of Personal Data outside of EU/EEA

6.1.   Personal Data, such as telephone number, may be transferred to countries outside the EEA where the Services are available, such as Brazil, the US, Thailand, Japan and Dubai (where the Services are performed by nWise or a Third-Party Service Provider)in order for us to give You the best service experience. There will only be a transfer of Personal Data according to this section 6 if You call a user using the Services in one of these countries. nWise will not transfer Personal Data outside the EEA for any other reason. The legal basis for such transfer is Your consent that You give before beginning to use the Services.

7.     Personal Data Retention

7.1.   Unless otherwise specified, we retain Personal Data as long as it is necessary and relevant for us to achieve the purposes referred to above or until You have asked to leave the Service. If You wish to leave the Services Your User Account will be terminated and the address book will be deleted from our servers. We will keep Your contact details for as long as You use the Services. We retain call log data for only as long as is needed for business and/or legal purposes.

7.2.   We may retain Personal Data from closed User Accounts so that we can comply with law, prevent fraud, assist with investigations, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law.

            You consent to our retention of data for as long as permissible under applicable privacy law.

8.     Your Rights

8.1.   As a registered member, You can review and rectify Your Personal Data at any time by accessing Your User Account via Your service provider’s website. Please be sure to update Your Personal Data promptly if it changes or becomes inaccurate.

            EU Privacy Rights

8.2.   In accordance with the Swedish privacy legislation, i.e. the Personal Data Act (1998:204), You have certain rights including amongst others, the right to object to Processing of Your Personal Data, including where Your Personal Data is Processed for direct marketing purposes, the right to revoke Your consent at any time, the right to, upon Your request, have Your Personal Data corrected, blocked or deleted and the right to, upon request, obtain from us a copy of the Personal Data undergoing Processing. Such a copy shall be free of charge once each calendar year.  

8.3.   As from 25 May 2018 You may also have certain rights, in accordance with the upcoming Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), including amongst others the right to be forgotten and the right to data portability.

9.     Security of Processing

9.1.   We know that security is important to our users and we care about the security of Your Personal Data. We maintain appropriate technical and organizational measures to ensure a level of security appropriate to the risk against loss, misuse, unauthorized access, disclosure, or alteration. Some of the measures we use include firewalls, data encryption, physical access controls to our data centers and information access authorization controls. All of the Services’ core features are also secured with end-to-end encryption: myMMX calls, pear-to-pear, via agent, leaving messages, media sharing and secondary devices. This means that the encryption keys are stored only on the clients' devices and no one, not even nWise itself, has access to them.

9.2.   It is Your responsibility to make sure that Your Personal Data is accurate and that Your password(s) and Personal Data from Your account registration are secure and not shared with third-parties.

10.     Third-Party websites

10.1.  Our app may contain links to other third-party websites or You may access Apps from a third- party site. We are not responsible for the privacy practices or the content of these third-party sites.

11.     Definitions

Documentation means the manuals and guidelines found on the website www.nwise.se.

Intellectual Property Rights means all rights, title and interest in and to all respective patents, inventions, copyrights, trademarks, domain names, trade secrets, know-how and any other intellectual property and/or proprietary rights.

nWise means nWise AB - the owner and provider of the Services under these Terms.

Services means the app “myMMX” as well as the other services provided by nWise and described on the website www.nwise.se.

Terms means these Terms of Use/End-user licence agreement, our Privacy Policy, Cookies and Tracking Technologies Policy, DMCA Policy and any other policies on our policies page [www.nwise.se/terms].

Third Party Service Provider means any third party, both official authorities and private companies, which provides services in relation to the Services.

User Account means the individual account You create when using the Services.

You means the end-user of the Services.