(Last updated on March 20, 2012)

IPCOM Solutions GmbH. (VPHO or we or us or our or other similar pronouns) takes your privacy matters very seriously. Please read the following to learn more about our Privacy Policy (Policy). This Policy details how we receive, collect and use information in connection with our website located at VPHO.com (the Site), the VPHO VoIP software (VPHO App), and other products and services provided on the VPHO.com website (all of the foregoing, collectively, the Services).

1. Collection and Use of Information

VPHO Application

When you install the VPHO App and register on the Site, you will be asked to provide us with your phone number and to allow us access to your mobile devices address book (collectively, Personal Information). A copy of the phone numbers and names in your address book (but not emails, 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 VPHO,

(b) indicate which of your contacts is already a VPHO user,

(c) correctly display the name of each contact as it appears in your address book when a call is received.

In addition, we may also create a function in the future that will use this data to synchronize your address book across your multiple devices.

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, which will be verified via a text message that will be sent to you, will be used for identification purposes as your VPHO user ID.

Cookies, Clear GIFs and Other Automatically Collected Data

If you have permitted your computer to accept cookies, we may use cookies on the Site. Cookies are pieces of information that a website transfers to an individuals hard drive for record-keeping purposes. Cookies make web-surfing easier by saving preferences and browsing patterns while you are at the Site. Cookies may be used to analyze the Site usage, improve content, customize the Sites content and layout and for other customer service purposes. A cookie may enable us to relate your use of our Site to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Site. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, if you have a Flash player installed on your computer, your Flash player can be set to reject or delete Flash cookies. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Site or certain areas or features of the Site.

We may use clear GIFs (aka Web beacons or pixel tags) or similar technologies, in the Site and/or in our communications with you to enable us to evaluate Site usage information about visitors to the Site, target campaigns, upgrade visitor information, and know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individuals viewing or receipt of a Web page or message. A clear gif may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your Personal Information.

Our servers may automatically collect data about your Internet address when you visit us. This information, known as an Internet Protocol address, or IP Address, is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet. When you request pages from our Site, our servers may log your IP Address and, if applicable, your domain name. Your IP Address is used to help identify you and to gather demographic information about our members and users as a whole, but does not include personally identifiable information. Our server may also record the referring page that linked you to us (e.g., another web site or a search engine); the pages you visit on this Site; the web site you visit after this Site; the ads you see and/or click on; other information about the type of Web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Site or a referral site; and other Web usage activity and data logged by our servers. We use this information for internal system administration, to help diagnose problems with our servers, and to administer our Services. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider.

We will not link any Personal Information, including e-mail addresses, with aggregate data of our users.

Any or all of these activities with regard to Site usage information may be performed on our behalf by our services providers, including, for example, our analytics vendor(s) and our e-mail management partner(s).

Third-Party Sites and Privacy Practices

You may arrive at our Site and/or download the VPHO App from another website. In addition, our Site may contain links that will let you leave our Site and access another website. Websites linked to or from our Site are not under the control of VPHO and it is possible that these websites have a different privacy policy. Our Policy applies solely to Personal Information that is acquired on the Site or through your use of our Services, and/or your relationship with VPHO. We urge you to be careful when you enter any personal information online. We accept no responsibility or liability for these other websites.

2. Sharing and Disclosure of Information

We do not rent, sell, or share any information about the user with any third-parties. 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 services or members of the public.

In order to provide you with VPHO products you have requested, VPHO 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. VPHO 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. VPHO 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 three separate third party companies in order to send you an authentication SMS when you register with VPHO. 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. If we fail to send you an SMS (this happens in certain cases) you may ask us to call you and read you the authentication code on the phone. This is done using a third party automated phone system. In order to call you, we provide this third party partner with your phone number and send the audio content of the call to them. The third party partner in turn will typically use another phone provider who may use another phone provider and so on until the call reaches you. This is an industry standard mechanism for the transmission of phone calls. The third party partner is contractually obligated to only use your phone number for the completion of the authentication phone call.

3. We may use Apples Push Notification Service to notify you about phone calls. If we do, the phone number or the name of the person calling you may be part of the message. This message is sent to Apple Inc., for delivery to your iPhone.

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 on 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 VPHO 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 VPHO 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 VPHO software to notify you when someone has tried to contact you. We may also use the VPHO software to keep you up to date with news about our software and products that you have purchased and/or to inform you about other VPHO products and related information.

3. Childrens Privacy

Protecting the privacy of the very young is especially important. We operate our Site in compliance with the Childrens Online Privacy Protection Act (COPPA). We never knowingly, directly or indirectly, collect or maintain Personal Information at or on our Site from those we actually know are under 13, and no part of our Site is directed at or structured to attract anyone under 13. Visitors younger than 13 years of age may NOT use the Services (including the VPHO App) and must LEAVE immediately.

4. 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.

5. Business Transitions

In the event that we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, Personal Information will likely be among the assets transferred. As part of such a transaction the new entity will be required to commit to the same level of protection of your Personal Information as described in this Privacy Policy. If we cannot obtain such a commitment, we will not perform the business transition.

We will post a notice on this Site of any such change in ownership or control of the Personal Information we may have prior to such transfer.

6. 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. 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 VPHO App, or any of the other Services.

7. Change or Removal of Information

If you provided your e-mail address to us and wish to update it, you may do so by sending an e-mail to support@VPHO.com

If you no longer wish to receive e-mail communication from us, such as offers, updates and newsletters, you may opt-out of receiving such communications by following the instructions included in each newsletter or communication. In addition, you can remove your e-mail address at any time by sending an e-mail with the subject line of UNSUBSCRIBE to unsubscribe@VPHO.com.

If you wish to delete your account completely, you can go to the More tab in the VPHO app, and tap the Deactivate Account option. Please note that this will remove your data from VPHO, and deactivate VPHO on your device. If you have additional concerns and/or requests, you can contact VPHO at support@VPHO.com.