Privacy Policy

This Privacy Policy is part of our End User License Agreement (“EULA”) and explains how Lab Mobile Product (“we,” “us,” “our”) collects, uses, shares, and protects personal data when you use our Contacts & Dialer mobile application (the “App”) and related services (the “Service”). Terms not defined here carry the meaning given to them in the EULA.

This Policy is written to address your rights under the EU General Data Protection Regulation (“GDPR”), the Brazilian LGPD, the California Consumer Privacy Act (“CCPA”), and other U.S. state privacy laws described further below.

Questions about this Policy or our data practices can be sent to labmobileproduct@gmail.com.

Part I — Privacy Notice

1. Changes to This Policy

We may revise this Policy at any time. The current version is always the one posted with the App, and the date at the top reflects the most recent update. Where a change is material, we’ll let you know and, if the law requires it, ask for your consent. Updates take effect 30 days after being posted. We recommend checking back periodically.

2. Who We Are

Lab Mobile Product acts as the controller of personal data processed through the App.

• Email: labmobileproduct@gmail.com

• If you’re located in the EEA or UK and would like details of how to reach a local representative to exercise your data rights, contact us at the email above and we’ll provide the relevant information.

3. What We Collect and Why

Non-personal data

We may collect aggregated, non-identifying technical data as you use the App — device/browser type, language preference, timestamps, general country location, and similar usage statistics. This data isn’t tied to your identity.

Personal data

Depending on how you use the App, we may collect the following. Each category below lists what’s collected, why, and its legal basis for processing.

Account/registration information — If the App requires an account, we collect your name and email to set it up and let you use the Service (performance of contract). We may also send you marketing messages about our Services based on our legitimate interest; you can unsubscribe anytime by emailing us, though we may still send service-related messages like receipts.

Contact/support information — If you reach out to us voluntarily (name, job title, company, email, etc.), we use it to respond to your inquiry.

Rewards or club programs — If you opt into any membership or rewards program, we use your contact details to send related offers, based on our legitimate interest, and may retain correspondence where legally required.

Location (GPS) — Certain features may request your location, including in the background, to help identify nearby Wi-Fi networks and improve connectivity-related features. This runs solely on your device — we do not store GPS data on our servers — and you can disable background location anytime in your device settings. We rely on your explicit, active consent (via in-app permission prompts) for this.

Push notification tokens — We may store a Firebase Cloud Messaging token to deliver notifications. This token is non-personal and doesn’t require a separate legal basis; you can stop notifications anytime via device settings or by uninstalling the App.

In-app payments — Purchases go through the applicable app store’s billing system (Google Play or Apple App Store). We don’t process or store your payment details ourselves — we only receive a non-identifiable order/user ID to fulfill the transaction (performance of contract).

Log and crash data — If the App errors out, third-party tools may collect diagnostic “log data” — IP address, device name, OS version, app configuration, and timestamps. We treat this as personal data since it could reasonably identify you, and we process it under our legitimate interest in protecting and improving the App.

Installed app list — On install, we may see a list of other apps on your device. We treat this as personal data and process it, with your consent via in-app permissions, to maintain, support, and improve the App.

Advertising/profiling data — If we show ads, our advertising partners may use SDKs to collect data for interest-based, contextual, or behavioral advertising. You can limit this through your device’s ad-privacy settings; opting out won’t stop ads entirely, just personalization. This processing relies on your consent, gathered through our in-app consent tools.

Photos and videos — If a feature lets you submit photos or videos for editing or animation, we use them only to deliver that feature, based on your consent and to perform our contract with you. We don’t store your photos/videos on our servers — processing happens on your device, and we retain the original and result only as long as you use that feature.

Microphone/audio (dialer features) — Some dialer features need microphone access. We use it solely to provide the dialer function and don’t store any audio — processing is device-side and permission-based, tied to your consent and our contract with you. You can revoke this anytime, though the relevant feature may then stop working.

Call log and contacts (dialer features) — Similarly, dialer features may need access to your call log and contacts, to identify callers. We don’t store this data on our servers; it’s processed on-device, based on your consent via in-app permissions.

Bluetooth and network information — Where relevant features need it, we may access nearby Bluetooth devices/networks and connection history, based on your in-app consent. You can revoke this permission anytime.

Calendar — Some design or personalization features may need calendar access to apply a chosen design. This is consent-based and processed on-device; disabling it may limit that specific feature.

Health-related data — If a feature processes health-related data, that processing happens solely on your device — we do not transmit or store it on our servers. This is based on your consent via in-app permissions.

We may also use personal data to prevent fraud, abuse, or illegal activity, enforce our Terms, protect the security of our systems, and defend against legal claims — all under our legitimate interest. If personal and non-personal data are combined, we treat the combined set as personal data for as long as it stays combined.

4. How We Collect Data

• Automatically — through your use of the App and the permissions you grant.

• Directly from you — when you contact us or provide information voluntarily.

• From third parties — such as service providers or platform partners.

5. SDKs and Tracking Technologies

We and our service providers use SDKs, cookies, and similar tracking technologies to operate, improve, and personalize the Service, and to measure the performance of our features and campaigns. Current SDK partners include:

• Google Play — in-app billing. Google Play Privacy Policy

• Firebase — remote config, crash reporting (Crashlytics), cloud messaging, encryption, security, A/B testing, in-app messaging, analytics. Firebase Privacy Policy

• Advertising partners, which may include AdMob, AdColony, AppLovin, Chocolate Platform, Facebook Audience Network, Index Exchange, Media.net, Mobfox, OpenX, PubMatic, Rubicon, Sharethrough, and Yieldmo (subject to change). These partners’ SDKs may track browsing activity across apps and sites to serve relevant ads, without disclosing your identity to us. Each has its own privacy policy and opt-out mechanism, generally available in its published privacy policy.

6. Who We Share Data With

• Advertising partners — online identifiers, to serve ads suited to the App.

• Service providers — hosting, analytics, marketing, payment processing, fraud prevention, and similar vendors, who are contractually limited to using data only to provide their service to us and must apply appropriate security measures.

• A business successor — if we’re involved in a merger, acquisition, or asset sale, data may transfer to the new owner, who would assume the obligations in this Policy.

• Authorities — where legally required, e.g. in response to a verified law-enforcement or government request relating to a crime, security threat, or legal liability.

Any partner receiving your data gets only what’s strictly necessary to do their job, is contractually bound to protect it, and may use non-personal data separately for their own purposes.

7. How Long We Keep Data

We keep personal data only as long as necessary for the purposes above, unless a longer period is required for legal, tax, accounting, or dispute-resolution reasons, or where litigation is reasonably anticipated. Outside of legal requirements, we’re not obligated to retain data for any set period and may delete it at any time without prior notice.

8. Security

We apply physical, technical, and administrative safeguards designed to meet applicable regulatory and industry standards, to prevent unauthorized access, use, disclosure, loss, or destruction of your data. If you believe your privacy has been mishandled, or you become aware of unauthorized access attempts, contact us — we’ll make reasonable efforts to notify you and relevant authorities where the law requires it.

9. International Data Transfers

We use cloud infrastructure with servers in the EU, US, and Asia, and some processing may occur in other countries where we or our providers operate. Where data crosses borders, we apply appropriate safeguards — including, for EU-origin data going to a country without an adequacy decision, the EU’s Standard Contractual Clauses. Contact us for more detail on these arrangements.

10. Your Privacy Rights

Subject to your jurisdiction, you may have the right to:

• access or receive a copy of the data we hold about you

• correct inaccurate data

• delete your data, where we don’t have a legitimate reason to keep it

• restrict or object to our processing

• receive your data in a portable format

• withdraw consent, where processing relies on it

• lodge a complaint with your local data protection authority

To exercise any of these, email labmobileproduct@gmail.com. We may need to verify your identity first, and locating/deleting data may take some reasonable time. See Part II below for rights specific to certain U.S. states.

11. Opting Out of Personalized Advertising

We do not sell your personal data. Some of our advertising relationships may count as “sharing” your data with third parties for personalized ads under some state laws. To limit interest-based advertising broadly, you can use:

• Digital Advertising Alliance (US): https://www.aboutads.info/choices/

• Digital Advertising Alliance (Canada): https://youradchoices.ca/en/tools

• Your Online Choices (EU): https://www.youronlinechoices.com/

• Network Advertising Initiative: https://optout.networkadvertising.org/?c=1

Opting out won’t stop all ads — you may still see ads that just aren’t personalized based on data we or our partners hold.

12. Children’s Privacy

Our Service isn’t intended for children — defined as under 16 in the EEA and under 13 in the US, unless local law sets a different age. We don’t knowingly collect data from children, and we’ll delete any such data immediately upon discovering it. If you believe a child has shared data with us, contact labmobileproduct@gmail.com.

Part II — Notices for Specific U.S. States

A. California

California residents have rights under the CCPA (as amended by the CPRA), including the right to know what personal information is collected, why, its source, who it’s shared with, whether it’s sold or shared, how long it’s kept, and how to exercise these rights. Contact us at labmobileproduct@gmail.com to submit a request or learn more.

B. Colorado

If you’re a Colorado resident acting in a personal (not commercial/employment) capacity, the Colorado Privacy Act gives you rights to:

• Know/access your personal data — request a copy by emailing us.

• Correct inaccurate data — email us or, if applicable, use your account settings.

• Delete your data — subject to limited exceptions (e.g., completing a transaction, security, legal compliance, debugging, free speech, research, or other compatible internal uses). Where an exception doesn’t apply, we’ll delete or de-identify the data.

• Portability — receive your data in a usable, transferable format.

• Opt out of sale/targeted advertising/profiling — we do not sell personal data. We may share data with partners for personalized ads; you can opt out using the tools in Section 11 above.

• Appeal a denied request — email us within a reasonable time noting you wish to appeal; we’ll respond within 60 days. If we deny your appeal, you may contact the Colorado Attorney General: https://coag.gov/office-sections/consumer-protection/ or (720) 508-6000.

• Non-discrimination — we won’t deny service, charge more, or degrade quality because you exercised these rights.

We aim to respond to verified requests within 45 days (extendable once by 45 days with notice), and no more than twice per year per person. You don’t need an account to submit a request. Responses will cover the 12 months preceding your request.

C. Virginia

Virginia residents (in a personal, non-employment capacity) have similar rights under the VCDPA — see the Colorado section above for how these rights work in practice. We respond within 45 days (extendable once by 45 days with notice). If we decline your request, you may appeal by emailing us; if the appeal is denied, you may contact the Virginia Attorney General: https://www.oag.state.va.us/consumercomplaintform.

D. Connecticut

Connecticut residents have rights under the CDPA that mirror those described in the Colorado section. We respond within 45 days (extendable once by 45 days with notice, explained to you within the initial period). Appeals follow the same process; if denied, you may contact the Connecticut Attorney General: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

E. Utah

Utah residents have similar rights under the UCPA, exercised the same way described in the Colorado section above.

F. Nevada

Nevada law lets residents opt out of the “sale” of certain personal information for monetary consideration. We do not sell personal information as defined under Nevada law, but you may still submit a verified opt-out request to labmobileproduct@gmail.com, which we’ll keep on file in case our practices change.

Contact Us

Lab Mobile Product Email: labmobileproduct@gmail.com

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Contacts: Phone & Call Dialer - Privacy Policy