Users of the App Momo Voice, available for Android devices Android

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This Privacy Policy applies to the data processing carried out by the Momo Voice application, which allows making phone calls and sending SMS, as well as offering additional features.

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Minimum version

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L’APP Momo Voice si configura nella tipologia così detta “dialer”, ed offre funzionalità per la gestione della Lista chiamate, Messaggi, Rubrica, Tastierino numerico.Momo Voice APP is configured as a "dialer" and offers functionalities for managing Call List, Messages, Contacts, and Numeric Keypad.

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Permissions requested by the Momo Voice App

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Contacts

The Momo Voice App requires permission to access the phone's contacts.

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Phone

The Momo Voice App requires permission to access call management and phone status, as well as permission to manage the ND mode.

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Call Log

The Momo Voice App requires permission to access the call log and permission to filter incoming calls.

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Data

The Momo Voice App requires permission to access aggregated data traffic.

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SMS

The Momo Voice App requires permission to send/read SMS.

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FUNCTIONALITY WITHOUT ACTIVATION

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The user who installs the Momo Voice APP can autonomously use the service to make/receive phone calls or SMS with a single application tool, as well as to use functionalities to manage the call list, messages, contacts, and numeric keypad.

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In this mode, the app does not communicate or transfer data externally or to other apps on the device. The data controller does not process data regarding the app's operation.

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The only data the Data Controller comes into contact with are any reviews that users make about the APP, which are managed directly by the Google PlayStore, which in this case acts as an independent Data Controller.

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Data Controller

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The data controller is "FBL MOBILE COMPANY SRL", with a registered office and operational headquarters at Via Molveno, 5 - 48015 Cervia (RA), VAT /Tax Code: 02666220393. The website www.fblmobilecompany.com provides further information regarding the privacy policies adopted.

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Data Processor

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The Data Controller has appointed "TECHNACY SRL" as the data processor, with a registered office and operational headquarters at Via Molveno, 5 - 48015 Cervia (RA), VAT /Tax Code: 02399920392.

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Purpose of processing

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To allow the user to make/receive phone calls or SMS, traffic data with a single application tool, as well as to use functionalities to manage the call list, messages, contacts, and numeric keypad.

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Data processing for the purposes

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In this mode, the APP does not communicate or transfer data externally, or to other APPs on the device.

The only data the Data Controller comes into contact with are any reviews that users make about the APP, which are managed directly by Google PlayStore, which in this case acts as an independent Data Controller.

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Recipients

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Personal data (the reviews only) resulting from the use of the Momo Voice APP will be processed exclusively by competent and duly appointed subjects, or identified as data processors for the correct management of the service, with a guarantee of protection of the data subject's rights. These subjects are distinguished as:

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• Data Processors: Technacy srl and any other IT service providers;

• Within the company structure: data will be processed by personnel expressly authorized by the Data Controller.

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Retention period

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No personal data are retained.

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FUNCTIONALITY WITH ATTIVATION

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By proceeding with the activation of the APP, the user, previously authorized by their Company, uses the service within the corporate context based on the policies defined by the above-mentioned company.

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Data Controller

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The Company that uses the Momo Voice service, which defines the purposes and means for data processing.

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Data Processor

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The data processor is "FBL MOBILE COMPANY SRL", with a registered office and operational headquarters at Via Molveno, 5 - 48015 Cervia (RA), VAT / Tax Code: 02666220393. The website www.fblmobilecompany.com provides further information regarding the adopted privacy policies

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Purpose of processing

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• To allow the user and the company to have control and greater awareness in quantitative terms about voice/SMS/data traffic consumption generated in Italy and abroad.

• To display thresholds and usage of incoming and outgoing calls, sent and received SMS, and data traffic based on the policies defined by the company on the Momo Voice dashboard.

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Data processing for the purposes

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Once the APP is installed, it can be activated through the available functionalities. The APP will verify if the user's phone number has been enabled by the company; if not, it will continue to function in "WITHOUT ACTIVATION" mode, deleting the acquired phone number. If the user's phone number has been enabled, the APP will obtain the corporate functionalities described in the purposes. The APP counts the minutes and the number of SMS sent and received and counts the data traffic, distinguishing them according to the tariff plans subscribed to by the company with the mobile network operator and configured through its own dashboard. Such data and information are subsequently available on the corporate dashboard to ensure correct accounting and monitoring.

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The application doesn't send detailed information about individual calls, SMS, or data traffic to the corporate dashboard. However, the app detects this information for consumption accounting purposes only and it's not visible on the corporate dashboard. The detected information includes an anonymized phone number of the recipient, date and time of the call or SMS, call/SMS type (incoming or outgoing), duration of the call or SMS, time of the answer (for calls only), answer time (for calls only), telephone operator, countries of origin and destination of the call or SMS, and aggregated information on data traffic over a period of time.

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When a device has multiple SIM cards, both corporate and personal, only the corporate SIM card is used to detect call/SMS data and data traffic. The app operates in "WITHOUT ACTIVATION" mode for any calls/SMS or data traffic made through personal SIM cards, meaning it does not transfer any information.

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Recipients

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Personal data resulting from the use of the Momo Voice APP will be processed exclusively by competent and duly appointed subjects, or identified as data processors for the correct management of the service, with a guarantee of protection of the data subject's rights. These subjects are distinguished as:

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• Data Processors: FBL Mobile Company and any other IT service providers;

• Within the company structure: data will be processed by personnel expressly authorized by the Data Controller.

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Retention Period

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Personal data will be retained at least until the end of contractual relationships, and for any further period as provided by such agreements.

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Ancillary finality

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The collected information will also be used for ancillary purposes necessary to ensure the proper functioning of the service, such as maintenance, support, and transmission security.

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Procedures and security of processing

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Personal data are processed electronically and telematically. Each processing is carried out in compliance with the methods referred to in Articles 5, and 32 of the GDPR and by adopting appropriate security measures.

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Transfer of data to third countries

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The MOMO VOICE service does not transfer personal data to non-EU countries.

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Disclosure

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Your data will not be disclosed in any way.

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Data Subject Rights - EU Regulation 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22

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1. The data subject has the right to obtain confirmation of whether or not personal data concerning them exists, even if not yet recorded, and their communication in an intelligible form.

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2. The data subject has the right to obtain information about:

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a) the origin of the personal data;

b) the purposes and methods of processing;

c) the logic involved in any electronic processing;

d) the identity of the controller, processors, and designated representative under Article 5, paragraph 2;

e) the recipients or categories of recipients to whom the personal data may be disclosed, as designated representatives in the territory of the State, processors, or authorized personnel.

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3. The data subject has the right to obtain:

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a) he updating, rectification, or, when interested, supplementation of data;

b) the erasure, anonymization, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which it was collected or subsequently processed;

c) notification that the operations referred to in points (a) and (b) have been communicated, including regarding their content, to those to whom the data was disclosed or disseminated unless this proves impossible or involves a disproportionate effort compared to the right being protected;

d) data portability.

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4. The data subject has the right to object, in whole or in part:

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a) for legitimate reasons, to the processing of personal data concerning them, even if relevant to the purpose of the collection;

b) to the processing of personal data concerning them for the purposes of advertising or direct marketing, market research, or commercial communication.

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Data subjects, where applicable, also have the right to make a complaint with the supervisory authority, the Garante, according to the prescribed procedures. For any further information, and to exercise the rights recognized to you by the European Regulation, you may contact the data controller at the above-mentioned references.

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Rev. 2/2024 – 11/03/2024

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FBL Mobile Company SRL

via Molveno, 5 

48015 Cervia (RA)

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