Privacy Policy

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APhone Privacy Policy

The APhone service is provided by SENATEL LTD, a company incorporated under the laws of Belize, registration number 000007068, with registered office at Philip Goldson Highway, New Horizon Building, Belize City, Belize ("APhone", "us", "our", or "we"). Senatel Ltd is the data controller responsible for personal information collected through the APhone application and website.

This Privacy Policy describes how we collect, use, share, store, and protect personal information when you use the APhone application (the "App"), the website at www.aphone.app (the "Site"), and the related services (collectively, the "Services").

By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services.

Capitalized terms not defined in this Privacy Policy have the meaning given to them in our Terms of Service.

1. INFORMATION WE COLLECT

We collect the following categories of personal information:

1.1 Account information

- Email address

- Account credentials provided through Google Sign-In or other authentication methods

- Country and language preferences

1.2 Phone number and communications data

- Phone numbers purchased and assigned to your APhone account

- Call detail records (CDRs), including time, date, duration, originating and terminating numbers

- SMS metadata, including time, date, originating and terminating numbers (we do not retain the content of SMS messages beyond what is necessary to deliver them)

- Voicemail recordings stored on your account

- Caller ID information you choose to display

1.3 Device and technical information

- Device identifiers (e.g., Android ID, advertising identifier)

- Device name and model

- Operating system and version

- App version and configuration

- IP address (IPv4 and IPv6)

- Network name and network country

- Crash reports and diagnostic data

1.4 Address book contacts (with your consent)

With your permission, the App accesses your device address book to read contact names and phone numbers. This is used to correctly format international phone numbers, display contact names when calls and messages are received through the App, and present your contacts within the App interface. Contact data is stored locally on your device and is not uploaded to or retained on APhone servers, unless you explicitly use a feature that requires it.

1.5 Payment information

Payments for APhone credits and Services are processed exclusively through Apple In-App Purchase (iOS) or Google Play Billing (Android). We do not collect or store your payment card details. We do receive transaction confirmation data from Apple and Google, such as transaction identifiers, purchase amounts, and the associated Apple ID or Google account identifier.

1.6 Communications with us

If you contact our customer support, we collect the content of your communication, your contact information, and any other information you choose to provide.

1.7 Cookies and similar technologies (Site only)

Our website may use cookies and similar tracking technologies for analytics and to remember your preferences. You can manage cookies through your browser settings. Refusing certain cookies may limit some functionality of the Site. The App itself does not use cookies but may use third-party SDKs that collect technical information as described above.

2. HOW WE USE YOUR INFORMATION

We use the information we collect to:

- Provide, operate, and maintain the Services, including assigning phone numbers, routing calls and messages, and processing payments

- Authenticate your account and protect against unauthorized access

- Provide customer support and respond to your inquiries

- Send service-related communications (e.g., account notifications, security alerts, changes to terms or policies)

- Detect, investigate, and prevent fraud, abuse, and violations of our Terms of Service

- Improve the Services, including diagnosing technical issues, analyzing usage patterns, and developing new features

- Comply with legal, regulatory, and contractual obligations, including lawful requests from competent authorities

- Enforce our Terms of Service and protect our legal rights and the rights of others

3. LEGAL BASIS FOR PROCESSING (GDPR / UK GDPR)

If you are in the European Economic Area, the United Kingdom, or another jurisdiction where similar laws apply, we rely on the following legal bases to process your personal information:

- Performance of a contract: to provide you with the Services you have requested and to fulfill our obligations under the Terms of Service.

- Legitimate interests: to operate, secure, and improve the Services; to detect and prevent fraud and abuse; and to communicate with you about the Services. We balance our legitimate interests against your rights and freedoms.

- Consent: where we ask for and you give us specific consent (for example, to access your address book or to send certain communications). You may withdraw consent at any time.

- Legal obligation: to comply with applicable laws, regulations, and lawful requests from competent authorities.

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We share personal information only as described below:

4.1 Service providers and processors

We share information with trusted third parties who help us operate the Services, including:

- Cloud hosting and infrastructure providers

- Telecommunications and number-routing partners (carriers and number suppliers in each country we operate in)

- Analytics and crash-reporting providers (e.g., Google Analytics for Firebase, Firebase Crashlytics)

- Customer support and communication tools

- Payment confirmation providers (Apple, Google)

These providers are bound by contractual obligations to protect personal information and to use it only for the purposes we instruct.

4.2 Legal and compliance disclosures

We may disclose personal information when we believe in good faith that disclosure is necessary to:

- Comply with applicable law, regulation, legal process, or lawful request from a competent authority

- Enforce our Terms of Service or investigate potential violations

- Detect, prevent, or address fraud, security, or technical issues

- Protect the rights, property, or safety of APhone, our users, or others

4.3 Business transfers

If APhone is involved in a merger, acquisition, reorganization, asset sale, or insolvency, your personal information may be transferred as part of that transaction, subject to standard confidentiality protections and continued compliance with this Privacy Policy.

4.4 With your consent

We may share information with other third parties when you direct us to do so or otherwise consent to the sharing.

5. INTERNATIONAL DATA TRANSFERS

APhone is operated by Senatel Ltd, a company located in Belize. The Services rely on infrastructure, partners, and processors located in multiple countries, including outside the European Economic Area and the United Kingdom.

When we transfer personal information outside of the EEA or the UK to a country that has not been recognized as providing an adequate level of data protection, we rely on appropriate safeguards as required by applicable law, which may include Standard Contractual Clauses or equivalent mechanisms. By using the Services, you acknowledge that your personal information may be transferred to and processed in countries outside your country of residence.

6. DATA RETENTION

We retain personal information only for as long as is necessary to provide the Services and to fulfill the purposes described in this Privacy Policy, including to comply with legal, regulatory, accounting, or reporting obligations and to resolve disputes.

Typical retention periods:

- Account information: for the duration of your account, plus a limited period after closure to handle any final disputes or legal obligations

- Call detail records and SMS metadata: retained for a period required to operate the Services, support billing, and meet legal obligations (typically up to 24 months, longer where required by law)

- Voicemail recordings: retained on your account until you delete them or until your account is closed

- Payment confirmation data: retained for accounting, tax, and audit purposes for the period required by applicable law

- Crash and diagnostic data: retained for limited periods sufficient to diagnose issues and improve the Services

- Inactive account credit balances: expire 24 months after the last activity, as set out in the Terms of Service

When we no longer have a lawful purpose to retain personal information, we delete it or anonymize it.

7. YOUR RIGHTS

Subject to applicable law, you have rights regarding your personal information.

7.1 Rights under GDPR and UK GDPR

If you are in the EEA or the United Kingdom, you have the right to:

- Access the personal information we hold about you

- Request correction of inaccurate or incomplete personal information

- Request deletion of your personal information (subject to legal exceptions, such as data we are required to retain)

- Restrict or object to the processing of your personal information in certain circumstances

- Receive a copy of your personal information in a portable format (data portability)

- Withdraw consent at any time where processing is based on consent

- Lodge a complaint with your local data protection supervisory authority

7.2 Rights under the California Consumer Privacy Act (CCPA / CPRA)

If you are a California resident, you have the right to:

- Know what categories of personal information we collect, the purposes for which it is used, and the categories of third parties with whom it is shared

- Request access to the specific pieces of personal information we hold about you

- Request deletion of personal information, subject to legal exceptions

- Correct inaccurate personal information

- Opt out of the "sale" or "sharing" of personal information. APhone does not sell personal information and does not share personal information for cross-context behavioral advertising.

- Non-discrimination for exercising your privacy rights

7.3 How to exercise your rights

To exercise any of these rights, contact us at info@aphone.app. We may need to verify your identity before responding to your request. We will respond within the time period required by applicable law, typically within 30 days.

8. CHILDREN'S PRIVACY

The Services are not intended for children. We do not knowingly collect personal information from children under the age of 13 (or under 16 in the European Economic Area and the United Kingdom, or such higher age as required by the applicable jurisdiction).

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at info@aphone.app. We will promptly delete any such information and close any associated account.

9. SECURITY

We use commercially reasonable technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, or destruction. These include access controls, encryption in transit where appropriate, and secure infrastructure.

No method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are also responsible for keeping your Account credentials confidential and for promptly notifying us of any suspected unauthorized access.

10. THIRD-PARTY SERVICES AND LINKS

The Services may use third-party SDKs and services that have their own privacy policies. The principal third-party services we use include:

- Google Play Services — https://policies.google.com/privacy

- Google Analytics for Firebase — https://firebase.google.com/policies/analytics

- Firebase Crashlytics — https://firebase.google.com/support/privacy

The Site and App may also contain links to other websites or services that are not operated by us. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third parties you interact with through the Services.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will post the updated Privacy Policy on this page and update the "last updated" date below. For material changes, we will provide additional notice as required by applicable law. Your continued use of the Services after the updated Privacy Policy is posted constitutes your acknowledgment of the changes.

12. CONTACT US

If you have questions, comments, or requests regarding this Privacy Policy or our handling of your personal information, please contact us:

SENATEL LTD

Email: info@aphone.app

Address: Philip Goldson Highway, New Horizon Building, Belize City, Belize

Registration no: 000007068

Last updated: May 19, 2026