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Privacy Policy

How we collect, use, and protect your information

Last Updated: February 2025

At Calam, we take your privacy seriously. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our application and services.

1. Data Controller

ZOALTECH LIMITED (registered in Ireland with company number 805958 and registered address at 1 McElwain Terrace, Newbridge, Co. Kildare, W12 C434, Ireland), trading as Calam ("we," "us," or "our"), is the data controller responsible for your personal data collected through the Calam application ("App") and related services.

Contact: privacy@calam.app

2. Information We Collect

Account Information

When you register for Calam, we collect:

  • Phone Number: Required for account verification. Your phone number serves as your Calam account identifier.
  • User ID: A unique identifier assigned to your account
  • Country: Derived from your phone number for service and pricing purposes

Payment Information

When you add credit to your wallet, payment is processed securely by a PCI DSS Level 1 compliant payment provider. We do not store credit card numbers or bank account details. We only receive confirmation of successful payments and maintain internal records of your transactions (top-ups and call charges) for accounting and support purposes.

Call Data

To provide the calling service, we collect:

  • Phone numbers you call (sent to our servers to set up the call)
  • Call duration and timestamps
  • Call status (completed or failed)

Important: We do not record or store the audio content of your calls. All voice data is transmitted in real-time through our telecommunications partner and is not retained by us.

Device and Technical Information

We automatically collect certain technical information when you use the App:

  • Device Information: Device model, operating system version, unique device identifiers
  • IP Address: Used for security, fraud prevention, and approximate location for service provision
  • App Version: To ensure compatibility and provide support

Contacts

If you grant permission, the App accesses your device's contacts to make it easier to find and call people. Your contacts are accessed on-device only and are not transmitted to or stored on our servers. When you make a call, only the dialed number is sent to our servers to establish the connection.

Diagnostics and Analytics

We use third-party analytics services to collect diagnostic information to improve App stability and performance:

  • Crash Data: Information about app crashes to help us fix bugs
  • Performance Data: App launch times and general performance metrics
  • Usage Analytics: How features are used to improve the app

This diagnostic data is collected in a way that does not directly identify you.

3. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

  • Contractual Necessity: Processing necessary to provide you with the calling service, manage your account, and process payments (Article 6(1)(b))
  • Legitimate Interests: Processing for fraud prevention, security, service improvement, and analytics, where our interests do not override your fundamental rights (Article 6(1)(f))
  • Legal Obligation: Processing required to comply with applicable laws, such as financial record-keeping (Article 6(1)(c))
  • Consent: Where you have given consent, such as for contacts access (Article 6(1)(a))

4. Third-Party Services

We use the following categories of third-party service providers to operate Calam:

  • Cloud Infrastructure Providers: For authentication, database hosting, crash reporting, and analytics
  • Telecommunications Providers: For voice call infrastructure
  • Payment Processors: For secure payment processing (PCI DSS Level 1 compliant)

These service providers process your data on our behalf and are contractually obligated to protect your information in accordance with applicable data protection laws.

5. How We Use Your Information

We use the information we collect to:

  • Provide and maintain the calling service
  • Process payments and manage your account balance
  • Display your call history within the App
  • Improve our service quality and fix bugs
  • Detect and prevent fraud, abuse, or security threats
  • Comply with legal obligations

6. Data Sharing

We share your information only as necessary to provide our service:

  • Telecommunications Providers: To route your calls
  • Payment Processors: To securely process your payments
  • Cloud Infrastructure Providers: To host and operate our service

We may also share information:

  • With Legal Authorities: When required by law, court order, or to protect our rights and safety
  • In Business Transfers: If Calam is involved in a merger, acquisition, or sale of assets, your data may be transferred. You will be notified of any such change.

We do not sell your personal information to third parties. We do not use your data for advertising or behavioral tracking purposes.

7. Lawful Interception and Government Access

As a telecommunications service provider, Calam is required to comply with valid legal requests from law enforcement and regulatory authorities in Ireland and other jurisdictions where we operate. This may include:

  • Court orders and subpoenas
  • Valid requests from telecommunications regulatory bodies
  • National security requests as required by law

What We May Disclose

When legally compelled, we may disclose:

  • Account registration information
  • Call detail records (numbers called, times, durations)
  • Payment transaction records
  • IP addresses and device information

What We Cannot Disclose

We do not record or retain voice call content, so we cannot provide audio recordings or transcripts of your conversations.

Notification

Where legally permitted, we will notify you of government requests for your data before disclosure.

8. International Data Transfers

Your personal data may be transferred to and processed in countries outside of Ireland and the European Economic Area (EEA), including the United States, where our service providers operate.

When we transfer data outside the EEA, we ensure appropriate safeguards are in place:

  • EU-US Data Privacy Framework: Our US-based service providers are certified under the EU-US Data Privacy Framework, which provides an adequate level of data protection as recognized by the European Commission.
  • Standard Contractual Clauses: Where applicable, we rely on EU-approved Standard Contractual Clauses to protect your data.

By using Calam, you consent to the transfer of your information to these countries for the purposes described in this policy.

9. Data Security

We implement industry-standard security measures to protect your data:

  • All data in transit is encrypted using TLS (Transport Layer Security)
  • Voice calls are encrypted during transmission
  • Payment information is processed by a PCI DSS Level 1 compliant provider
  • Access to user data is strictly controlled and logged
  • Database access is protected by security rules and authentication
  • Regular security monitoring and incident response procedures

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

10. Data Retention

We retain your personal data only for as long as necessary for the purposes outlined in this policy:

  • Account Information: Retained while your account is active and for up to 12 months after account deletion for legal and fraud prevention purposes
  • Call History: Retained for 90 days to allow you to view recent calls, then deleted
  • Payment Records: Retained for 7 years to comply with financial record-keeping requirements
  • Diagnostic Data: Retained for up to 90 days

You may request deletion of your account and associated data at any time (see Your Rights below).

11. Cookie Policy

Our website uses cookies and similar technologies to enhance your experience. This section explains what cookies we use and how you can manage them.

What Are Cookies

Cookies are small text files placed on your device when you visit our website. They help us provide you with a better experience and allow certain features to function properly.

Cookies We Use

Essential Cookies (Always Active)

These cookies are necessary for the website to function and cannot be disabled. They include:

  • Session management cookies
  • Security and fraud prevention cookies
  • Load balancing cookies

Analytics Cookies (With Your Consent)

These cookies help us understand how visitors interact with our website:

  • Google Analytics / Firebase Analytics
  • Performance monitoring
  • Error tracking

Managing Cookies

You can manage your cookie preferences through:

  • Browser settings (to block or delete cookies)
  • Cookie consent banner when you first visit the site
  • Device settings for mobile apps

Please note that disabling certain cookies may affect website functionality.

Third-Party Cookies

We use the following third-party services that may set cookies:

  • Firebase (Google): For analytics and crash reporting
  • Payment Processor: For fraud prevention

For more information about how these providers handle your data, please refer to their respective privacy policies.

12. Your Rights

Under the GDPR and Irish Data Protection Act, you have the following rights regarding your personal data:

  • Right to Access: Request a copy of the personal data we hold about you
  • Right to Rectification: Request correction of inaccurate or incomplete data
  • Right to Erasure: Request deletion of your data ("right to be forgotten")
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Restrict Processing: Request limitation of how we use your data
  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, contact us at privacy@calam.app. We will respond to your request within one (1) month.

Account Deletion: You can delete your account directly within the App from Settings > Account > Delete Account. This will remove your account and personal data, subject to our retention requirements for legal compliance.

13. Right to Complain

If you are unsatisfied with how we handle your personal data, you have the right to lodge a complaint with the Irish Data Protection Commission:

  • Address: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
  • Phone: +353 (0)1 765 0100 / +353 (0)57 868 4800
  • LoCall: 1800 437 737
  • Email: info@dataprotection.ie
  • Website: www.dataprotection.ie

We would appreciate the opportunity to address your concerns before you contact the regulator. Please reach out to us first at privacy@calam.app.

14. Children's Privacy

Calam is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at privacy@calam.app, and we will take steps to delete such information.

15. Third-Party Links

Our App or website may contain links to third-party websites or services. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. For material changes, we will notify you through the App or by email at least 30 days before changes take effect.

The "Last Updated" date at the top of this policy indicates when it was last revised. Your continued use of Calam after changes constitutes acceptance of the updated policy.

17. Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or have concerns about how we handle your information, please contact us: