Privacy Policy

Tragofone is an SIP (Session Initiation Protocol) phone application that runs on Android and iOS phones. User can use Tragofone credentials to register with SIP Servers/PBX/Call Processing Unit and make inbound and outbound calls over the internet. Main purpose of this dialer app is to use such VOIP providers and make VOIP calls.

This legal document is an electronic record in terms of Indian Information Technology Act, 2000, and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This legal document is published in accordance with the provisions of Rule 4 of the Indian Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008 that require publishing the privacy policy for access or usage of https://www.tragofone.com, its mobile app and other integrated systems (“Tragofone”). By using Tragofone, you clearly agree and acknowledge to be bound by terms of this policy. References in this policy to “we” or “us” or “web” or “site” or “app” or “company” are references to Tragofone and its integrated systems and “you” as user of Tragofone.

This privacy policy applies to all users of Tragofone.

By using/browsing Tragofone, clicking the “I accept/I agree” button or completing the registration process, you clearly agree and acknowledge that you have reviewed this privacy policy, given your consent and accepted this agreement.

PRIVACY PREAMBLE

While providing aforesaid online services, the issue of online privacy is extremely crucial for Tragofone which is committed to safeguarding the information provided by its users. Tragofone is dedicated to create a reasonably secured environment for its users.

Respecting privacy of its online users while providing top-of-the-line services have remained the core strategies for Tragofone. Our Privacy Policy gives users a view of the Privacy Practices followed by Tragofone and assures them of safe passage.

At Tragofone, data protection is a matter of trust and your privacy is very important to us. We use your personal information only in the manner set out in this Privacy Policy. Please read this privacy policy to learn more about our information gathering and dissemination practices.

The privacy practices of this statement apply to our services available under the domain and sub-domains of Tragofone and apply generally to our parent, affiliates, subsidiaries or joint venture of Tragofone. By visiting Tragofone, you agree to be bound by the terms and conditions of this Privacy Policy.

This Privacy Policy explains how Tragofone gathers personal information, classified as mandatory or optional as part of the normal operation of our services; and uses, discloses and protects such information through Tragofone. This detailed privacy policy enables you to take informed decisions in dealings with us. Our parent, subsidiaries and joint ventures operate under similar privacy practices subject to the requirements of applicable law.

By registering with Tragofone, you acknowledge your acceptance of the terms of this Privacy Policy, expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy and that any personal information provided by you through Tragofone is provided under a lawful contract. This Privacy Policy is incorporated into and subject to the terms of the Terms of Service/User Agreement. Note: Our privacy policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this policy periodically.

At the same time, Tragofone would like to make it clear that it may provide links to other web sites/apps/APIs that are governed by their own Privacy Policies and Tragofone does not take responsibility for the privacy/security provided by those sites/apps/APIs. Visitors to the Tragofone are urged to familiarize themselves with its Privacy Policy as well the policies of the third party that collect personally identifiable information.

When you provide us with your personal data, you are clearly agreeing to the rules and regulations stipulated under our Privacy Policy and are bound by it. If you do not agree to our Policy then please do not use Tragofone.

PRIVACY ASSURANCE

We promise that we will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. From time to time, we may reveal general statistical information about our Tragofone and visitors, such as number of visitors, number and type of Offers/Promotions and other information as given below. Your trust and confidence are our highest priority.

THE PRIVACY POLICY SHALL BE GOVERNED IN FOLLOWING AREAS:

1. Online processes & type of information collected through Tragofone
2. Use and Disclosure of personal information
3. Choice or Opt-out
4. Reasonable Security Practices& Procedures
5. Access or change your personally identifiable information
6. Grievance Redressal
7. Children’s Privacy

1. Online Processes & type of information collected through Tragofone

Online Processes
User registering at the Tragofone may go through following processes:

• User registration
• User access to app

Personal Information

Users registering at the Tragofone are requested to provide some personally identifiable information (given in below clauses) which can be used, shared, disclosed or distributed to third parties only in accordance with this Privacy Policy.

2. Use and Disclosure of personal information

Tragofone will not sell or rent or publish such personally identifiable information collected. When you use our Tragofone, we collect and store your personal information. You clearly allow and authorize us that we shall gather your personal information through various permissions (as listed in below) and other means in order to record, support and facilitate your participation in the activities you select, track your preferences, to provide you with a customized Tragofone experience, to notify you of any updated information and new activities and other related functions offered by Tragofone, keep you informed about latest content available on the Tragofone, special offers, and other products and services of Tragofone, to assist you with customer service or technical support issues, to follow up with you after your visit, to otherwise support your relationship with Tragofone or to prevent fraud and unlawful use. For the aforesaid purposes, we only collect such personal information that we consider relevant to understand you or your interests. In general, you can visit Tragofone without having to provide your personal information during which time you remain anonymous and at no time can we identify you unless you have an account on Tragofone and log on with your user name and password. Once you provide your personal information, you are no more anonymous to us.

The personally identifiable information is supplied voluntarily for some of the following purposes:

Registration Data & Other Optional Information: You will be asked to register on registration link. During registration you will be requested to complete a registration form setting out basic online contact information about yourself. Such sensitive personal information shall include but not limited to following:

• Email Address
• First Name
• Middle Name
• Last Name
• Address
• City
• State/Province
• Zip/Postal Code
• Country
• Telephone/Mobile number
• Other personal information as indicated from time to time on our online forms.

Further the fields are marked as mandatory or optional. You always have the option to not provide information by choosing not to use a particular service or feature on the Tragofone.

E-mail information: You agree and acknowledge that when we receive e-mails from you, we may retain the content of any e-mail messages sent to us, as well as details of your e-mail address. You further agree and acknowledge that Tragofone shall use your email id and mobile number information for sending promotional messages from time to time.

If you send us personal correspondence, such as letters, or if other users or third parties send us correspondence about your activities or postings on Tragofone, we may collect such information into a file specific to you.

Permissions: (Subject to your enabling of appropriate permission options)

Tragofone will need below permission on Android and iOS devices:

1. Microphone
2. Camera
3. Speaker
4. Appear on top( Android )
5. VoIP Push ( iOS)
6. Contacts

Data for analytics:

We collect small amounts of information/data contained in your browser for data analytics. Data analytics help us track your navigation so that we can tailor our offerings to your specific needs. The kind of information that may be stored on our data analytics includes registration data so that a user does not need to re-enter the information every time he/she visits a particular area, user IP address/, user ISP details, user browser, URL that you just came from (whether this URL is on our Tragofone or not), which IP address/URL you next go to (whether this IP address/URL is on our Tragofone or not), devices OS details, Current Latitude, Current Longitude, Device Token, Device Type, App Version, Date registered on, Last Logged in, Logged in Latitude, Logged in Longitude, Active, Suspend Reason, Other Reason and Last updated on.

We collect small amounts of information/data contained in your account for data analytics which include but are not limited to Call Data Record, Transition Logs of Application and Push requests made from Web Server to Mobile Application or Group of Mobile Users.

Add on to above RAW data presentation on UI, We may show some advanced reports – which may contain the Date Range, Sorting, Filters, Export data in CSV or PDF AND few Advanced summary reports may be part of this system Ex. Total Call Count vs Answered vs Abandone and other basic analytic reports. You allow us, agree and acknowledge for aforesaid data gathering and analytics so as to get personalized offerings to your specific needs.

We use data collection devices such as “cookies” on certain pages to help analyze our web page flow, measure promotional effectiveness, and promote trust and safety.

Type of information collected by cookies:

1. Account Admin Portal stores Sign In session ID information for sign In management purpose

Also, we use Google Analytics on our site/app. It is important for us to inform you that we will have limited control over Google Analytics and therefore you clearly agree and acknowledge that we shall not be held responsible for privacy issues relating to the same. Please refer to https://www.google.com/intl/en/policies/privacy for more details.

We may add facilities like message boards, chat room etc. in future. If you choose to post messages on our message boards, chat rooms or other message areas or leave feedback for other users, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

Third party Apps which are accessible from Tragofone via links, click-through or banner advertising may use Cookies. However, it is important for us to inform you that we shall have no access or control over such Cookies and therefore you agree that we shall not be held responsible for privacy issues relating to third parties.

Our use of your information

We use your personal information to facilitate the services you request. We do not sell, rent, trade or exchange any personally-identifying information of our Users. We may provide your collected information to our affiliates and service providers under contract (such as customer care, data analytics) to support the operation of Tragofone and our services. To the extent we use your personal information to market to you, we will provide you the ability to opt-out of such uses. We use your personal information to: resolve disputes; troubleshoot problems; help promote safe browsing; collect payments (if any); measure consumer interest in the services provided by us, inform you about online and offline offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our User Agreement, and in general to improve the user experience and make it comparable to other similar websites/apps; and as otherwise described to you at the time of collection. In our efforts to continually improve our product and service offerings, we may collect and analyze demographic, profile and usage data about our users’ activity on our site/app.

We use your personal information to improve our platform, improve Tragofone’s content and product offerings, prevent or detect fraud or abuses of our Tragofone and tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the site/app.

In future, we may also use your personal information to display contents and services that are targeted to your interests. By accepting the User Agreement and Privacy Policy, you expressly agree to receive this information. If you do not wish to receive these communications, we encourage you to opt out of the receipt of certain communications in your profile under My Account or by clicking unsubscribe any email communication. You may make changes to your profile at any time.

Our Disclosure of your information

Your personal information is an important part of our business and we are not in the business of selling it to others. Tragofone shares your personal information only to categories of persons that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy as more particularly described below:

Internal Service Providers

We may employ third parties services to facilitate or outsource one or more aspects of the business, product and service operations that we provide to you on Tragofone (e.g., search technology, discussion boards, bill collection, affiliate and rewards programs, and co-branded services) and therefore we may provide some of your personal information to these internal service providers. These internal service providers’ are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of your personal information for any other purpose except to facilitate the specific outsourced service. In the event of your direct involvement with the internal service provider, any additional information disclosed by you to them shall be subject to the internal service provider’s own applicable privacy policy and you agree and acknowledge that Tragofone shall not be responsible for the same.

Other Corporate Entities

We share much of our data, including personal information about you, with our parent, affiliates, subsidiaries, and joint ventures that are committed to serving your online trading needs and related services. To the extent that these entities have access to your personal information, they remain bound by the existing Privacy Policy. As we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions, customer’s personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy.

Legal Requests

We cooperate with law enforcement and regulatory inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights, to help protect you and the community from bad actors. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we may (and you authorize us to) disclose some of your personal information as is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose personal information to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce our Terms or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public.

3. Choice/Opt outs

Tragofone gives you the choice regarding the collection and usage of your personally identifiable information. Further, once you are registered at the Tragofone, you will have the option at any stage to inform us that you no longer wish to receive future e-mails and you may “unsubscribe” by contacting on unsubscribe link. Further, as per Rule 5(7) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008, you have an option to withdraw your consent for use of your sensitive personal data given earlier to us. Such withdrawal of consent shall be sent in writing to our registered address.

4. Reasonable Security Practices As per I. T. Act, 2000 and its Rules

We have implemented reasonable security practices as per Rule 8 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008.

Access to your personal account online is password protected. We will not release your account password to any person. In the event that you forget your password, you may generate an on-line request for your password to be sent to you by e-mail at the e-mail address used during registration.

Tragofone has implemented stringent, internationally acceptable standards of technology, managerial security, technical security, operational security and physical security in order to protect personally identifiable information from loss, misuse, disclosure, alteration or destruction. The data resides behind a firewall, with access restricted to authorized personnel of Tragofone.

Tragofone has implemented “Reasonable Security Practices & Procedures” as required by the Information Technology Act, 2000 rules including any amendment in the said Act and its rules. By complying with such provisions, Tragofone assures you proper care and control over its I.T. and Security operations under sections 43, 43A, 45, 66,72A & 85 of I. T. Act, 2000 and I.T.A.A, 2008 including related rules and therefore you agree that Tragofone shall not be held responsible for any activity in your account which results from your failure to keep your own password/device secured.

By using this site/app, you agree that Tragofone shall not be held responsible for any uncontrollable security attacks and in such cases you agree that Tragofone shall not be held responsible for any type of financial losses, loss of opportunity, legal cost, business losses, reputation loss, direct and indirect losses that may occur to you as per the Provisions of Section 43, 43A and 45 of Information Technology Act, 2000 including any amendments in the said Act and any other laws of India for the time being in force.

You further agree that Tragofone’s management shall not be held responsible directly or indirectly for any cyber-crime related criminal liabilities under I. T. Act, 2000 relating to your information as you have agreed and acknowledged that management of Tragofone complies with due diligence (care & controls) requirements of I.T.Act,2000 including its rules and amendments.

You clearly agree and acknowledge that our reasonable security practices & procedures include but not limited to following:

• Authentication Mechanism & Authorization
• Data validation
• Cryptography
• Identifying & Handling Sensitive Data
• Analysing Security Impact of External Component Integration
• Audit Log for Mobile Application and Web components
• OWASP Web Application Security Checklist
• Injection prevention
• Broken Authentication and Session Management
• Cross-Site Scripting (XSS)
• Broken Access Control
• Security Misconfiguration
• Sensitive Data Exposure
• Insufficient Attack Protection
• Cross-Site Request Forgery (CSRF)
• Using Components with Known Vulnerabilities
• Under protected APIs
• All the incoming and outgoing traffic will be encrypted
• Firewall to allow specific and authorised traffic
• Secure root access to server and database
• Cyber Crime, Cyber Law& Reasonable Security Awareness for Tragofone’s top management people, team and grievance officer to have managerial security practices.

Further, you also agree and acknowledge that Tragofone management shall never be held responsible regarding privacy of your sensitive personal data in case of sharing your sensitive personal data to any authorized cyber investigation agency of appropriate government authorities under sections 67C, 69, 69A, 69B, 70B, 79 and 80 of I.T.Act,2000 including its amendments and rules.

5. Access or change your personally identifiable information

To protect your privacy and security, we will verify your identity before granting access or making changes to your personally identifying information. If you have registered your profile on Tragofone, your registered user ID and Password are required in order to access your profile information.

6. Grievance Redressal

If you have any questions or grievances regarding the privacy statement, practices of the site/app, or any other transaction issue, please contact our grievance officer on grievanceofficer@ecosmob.com. We have appointed our grievance officer as per Rule 5 (9) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008 and you can contact him (Name: Krunal Patel) on aforesaid email id.

7. What about children’s privacy?

Use of Tragofone is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are under the age of 18, you shall not use Tragofone. If you wish to use the site/app then such usage may be made by your legal guardian or parents who have registered as users of the site/app.