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FroggyTalk Privacy Policy

FroggyTalk Privacy Policy

1. Who we are

FroggyTalk is operated by Appbeam Technology B.V. trading as FroggyTalk, registered with the Dutch Chamber of Commerce under number 97711160 (“FroggyTalk”, “we”, “us” or “our”). Our registered address is Koninginnegracht 10, 2514AA The Hague, the Netherlands.

Our privacy contact can be reached at support@froggytalk.com.

We are the “data controller” for the processing of your personal data as further described in this Privacy Policy (“Privacy Policy“), unless stated otherwise. This Privacy Policy explains how we collect, use, share and protect personal data when you use the FroggyTalk website https://froggytalk.com/, the mobile app with all its features and services.

2. Personal data we collect

Personal data you provide. We collect personal data if you create an account to use our services or if you communicate with us:

  1. 2.1 Account information and contact details – when you create an account via our website or mobile app we may collect: phone number, email address, first and last name, username, country, profile image, language, user ID and account preferences.
  2. 2.2 Support and communications data – when you request our support and/or communicate with us, we collect: name, phone number, email address, call logs, transaction details, attachments and other information you provide to us when you contact us.
  3. 2.3 Contacts data – when you choose to enable contact access, the FroggyTalk app may process names and phone numbers from your device address book to provide contact-based calling or related features. We do not use your device contact list for marketing.
  4. 2.4 User content and moderation data – when you use our services such as our radio chat or other community features, we collect personal data that you provide in the input to our services, including your username, preferences, country, station or programme information, reports, moderation flags, moderation decisions and related account identifiers and other information that you share through the use of such services. Content may be reviewed using automated tools and, where appropriate, human review.
  5. 2.5 Payment and billing data – when you make a purchase via our website or mobile app, we collect information relating to: username, top-ups, credit purchases, Calling Credit balance and expiry status, payment status, refunds, chargebacks, transaction references and limited payment metadata. Full card or bank details are normally handled by our payment providers.
  6. 2.6 Auto-Refill data – if you enable Auto-Refill, we may process your Calling Credit balance and selected threshold, refill amount, Auto-Refill status, eligible payment-method reference or token, applicable spending or frequency limits, payment retry or failure events, and related notification records. Auto-Refill is optional and the associated automatic payment processing applies only after you enable the feature.
  7. 2.7 Bill-payment and Bill Payment Subscription data – when you use the Bill Payment Solution, we may process the Service Provider, product, bill or recipient details, customer, account or meter numbers, phone numbers, amounts, payment status, fulfilment records, support messages and dispute information. If you create a Bill Payment Subscription, we may also process the selected plan, Commitment Period, Scheduled Payment Date, Subscription Discount applied to the first successfully completed scheduled payment, the discounted first-payment amount, subsequent scheduled payment amounts or the basis on which they are determined, recurring-payment authorisation or reference, cancellation status, failed-payment or retry status, and reminder or receipt records.

Personal data we receive from your use of our services. When you visit, use or interact with our services, we receive the following information:

  1. 2.8 Device, app and technical data – when you visit our website, mobile app or use our services, we collect information that your browser or device automatically sends, such as: IP address, device identifiers, operating system type, app version, browser type, language settings, crash logs, diagnostics and security logs.
  2. 2.9 Security, fraud and compliance data – we may generate or receive risk indicators, transaction patterns, device or network information, security events, account-verification information and other data needed to detect and prevent fraud, abuse, unauthorised access, sanctions breaches, chargeback abuse or other unlawful activity, and to comply with legal or regulatory requirements where applicable.
  3. 2.10 Radio usage data – when you use our radio access service, we collect: station selection, listening duration and related usage data, especially where this is linked to your account or device.
  4. 2.11 Calling data – when you use our services to perform calls, we collect: first and last name, phone number, dialled numbers, destination country, call start time, duration, tariff information, call credit usage, route information and billing records. We do not record call content or call audio unless we tell you separately and obtain any required consent.
  5. 2.12 Marketing, consent and other usage data – for marketing, analytics, and related communications, we collect personal data related to: consent status, opt-outs, campaign source, push tokens, open/click data, engagement with in-app events, audience membership and engagement with FroggyTalk campaigns and automatically collected personal data through the use of cookies or similar technologies.

Other personal data. We also collect the following personal data:

  1. 2.13 Job applicants – when you apply for a position with us, we collect: name, address and contact details; your latest and desired salary; interview notes, if applicable; CV, employment history, qualifications.
  2. 2.14 Service providers – when you provide services to us as a service provider, we collect: contact person’s name, business email address and/or phone number.

If you choose to provide us with additional personal data, we recommend that you limit the provision of such data to the absolute minimum, and we advise against providing us with sensitive or special categories of personal data.

3. How we use personal data

The personal data as mentioned under section 2 will be processed for the following purposes:

  • To offer you our website, our mobile app, and our services, to measure your use thereof and to improve them (see 2.1; 2.3; 2.4; 2.5; 2.6; 2.7; 2.8; 2.9; 2.10; 2.11);
  • To promote our own products and services to you, based on your consent or, where the law allows marketing to existing customers, our legitimate interest; and to promote products and services of our group companies, only with your consent (see 2.1; 2.10; 2.12);
  • To inform you about new items which may be of interest to you based on your previous use of our website, mobile app or services (see 2.1; 2.10; 2.11; 2.12);
  • To administer Calling Credit, maintain and reconcile your Calling Credit balance, calculate the applicable Calling Credit expiry date, and provide expiry notifications in accordance with our Terms and Conditions (see 2.5; 2.6; 2.11);
  • To execute any other agreement between FroggyTalk and you;
  • For internal administrative purposes;
  • To fulfil our obligations under statutory law, such as the fiscal retention obligation;
  • To secure our employees and our assets;
  • To detect and prevent fraud, abuse and unlawful activity and to keep our services secure (see 2.8; 2.9);
  • To handle any requests you may have submitted to us (see 2.2);
  • To assess and review your job application (see 2.13);
  • To receive services from you or to collaborate with you (see 2.14).

We collect personal data directly from you, from your use of our services, or from the organisation you represent. We also receive limited personal data from third parties involved in providing the services, such as payment providers, app stores, telecom carriers, bill-payment Service Providers, fraud-prevention providers and, where you have consented, advertising partners. We do not collect personal data from public sources unless this Privacy Policy states otherwise.

4. Lawful bases of the processing

For the processing of your personal data as listed under 2, we rely on the following lawful bases for processing:

  • The necessity of the processing for the performance of an agreement to which you are a party or to take measures at your request prior to the conclusion of an agreement (see 2.1, 2.3, 2.5, 2.6, 2.7, 2.11, 2.13 and 2.14);
  • To comply with any statutory provisions applicable to us;
  • The necessity of the processing to serve a legitimate interest of ours that outweighs your privacy interest, which is our interest in measuring website usage, to secure our personnel and assets, to improve our products and services and to promote our products and services to you;
  • Your consent, where we ask for it. For example, we may ask for consent for marketing communications (except where applicable law does not require consent), personalised ads, marketing cookies, contact-list access or push notifications. You can withdraw consent at any time.

5. Marketing, retargeting and ad networks

We want to make marketing simple and transparent. If you give your consent / opt in to marketing, or where existing-customer marketing is allowed by law, we may contact you by email, SMS, push notification, in-app message, phone or similar channels about FroggyTalk products, offers, features, promotions, reactivation, surveys and updates. Every marketing message will include a way to opt out where required.

If you accept marketing cookies or otherwise consent to personalised advertising, we may use cookies, pixels, device IDs, advertising IDs, hashed email addresses or hashed phone numbers to measure campaigns, show you relevant FroggyTalk ads, create custom audiences, find similar audiences, exclude existing users from campaigns, and understand whether our advertising works.

6. Cookies and similar technologies

We use cookies, pixels, SDKs, local storage and similar technologies on our website, mobile app and in messages. Necessary technologies keep the service working and secure. Non-essential analytics, preference, marketing, social media and retargeting technologies are used only where permitted by law and, where required, with your consent. Please read our Cookie Policy for more detail and to manage your choices.

7. Contact-list, device and app permissions

Some features require device permissions, such as contacts, microphone, notifications or similar app permissions. You can choose whether to grant these permissions and can change them in your device settings. If you disable permissions, some features may not work as intended.

8. Who we share personal data with

To the extent necessary for any of the aforementioned purposes of processing, we can share your personal data with third parties (“recipients“). The following categories of recipients may have access to your personal data:

  • Affiliated group companies, if necessary for compliance, internal reporting, audit or security purposes, or for the performance of an agreement with data subjects. For example, Appbeam Technology Limited in Nigeria, where its personnel support the platform, customer operations, technical maintenance, bill-payment operations or related services under our instructions and safeguards;
  • IT service providers we use for our systems or for our website, such as telecom, routing and network providers needed to connect calls and operate the calling service;
  • Service providers assisting us in executing the agreement with you or assisting us with fraud-prevention, such as bill-payment service providers needed to fulfil bill payment requests;
  • Radio stations and radio content providers or aggregators that supply the streams you choose to play. Because the stream is delivered from their servers, they receive your IP address and technical information about your device and listening session. Where they use this data for their own purposes, they act as independent controllers under their own privacy terms;
  • Our auditor, legal advisors and other professional service providers engaged by us for compliance reasons;
  • Government agencies, courts, supervisory authorities, law enforcement or intelligence agencies, if we have a legal obligation to provide personal data to them;
  • Third parties buying or interested in buying (a stake in) FroggyTalk and professional service providers involved.
  • Advertising networks and social media platforms such as Google, Meta, TikTok, Snapchat or similar providers where you consent to marketing cookies, personalised advertising, custom audiences or retargeting.

Some parties we work with, such as payment providers, app stores, telecom operators, bill-payment Service Providers and advertising platforms, act as independent controllers for their own processing. Their own privacy terms apply to that processing, and FroggyTalk is not responsible for it.

9. International transfers

FroggyTalk is based in the Netherlands, but we may use service providers, group personnel or technology partners in other countries (for example: Appbeam Technology Limited is based in Nigeria). Where personal data is transferred outside the European Economic Area, we will always comply with the statutory requirements for such data transfers and use appropriate safeguards where required, such as adequacy decisions, Standard Contractual Clauses, transfer assessments, data minimisation, access controls and contractual confidentiality obligations. You may consult the SCCs we have concluded with recipients by sending an email to support@froggytalk.com.

10. How long we keep personal data

Your personal data will not be kept longer than necessary for the purpose for which it was collected, unless a longer period is required or permitted by law, tax rules, fraud prevention, dispute handling or legal claims. We may anonymise data and keep aggregated statistics for longer where individuals can no longer be identified.

11. Security

We use appropriate technical and organisational measures to protect your personal data, including but not limited to access controls, encryption where appropriate, secure hosting, logging, staff confidentiality, vendor controls and internal privacy rules.

12. Your rights

Your right to object

You have the right to object to the processing of personal data because of your specific situation, but only insofar as this processing is carried out on the basis of one of our legitimate interests. We will then cease processing your personal data unless our interest in processing your data outweighs your interests or when our interest is related to the establishment, exercise or enforcement of a legal claim. Furthermore, you have the right to object to the processing of your personal data for marketing purposes, for example the promotion of our products and services.

You can exercise your rights by contacting support@froggytalk.com. We may need to verify your identity before responding. Under GDPR, we normally respond within one month, unless an extension is permitted by law.

Other rights regarding the processing of your personal data

  • Right of access – You have the right to request access to the personal data we process about you, more specifically about the purposes, the categories of personal data concerned, the (categories of) recipients, the retention periods or the criteria for establishing them, the source of the personal data and the appropriate safeguards in case of transfer of the data outside the EEA.
  • Right to rectification of data and restriction of processing – You have the right to have incorrect data that we process about you rectified and to have incomplete data completed by us. Furthermore, you have the right, at your request, to restrict data processing in the following cases:
    • If you dispute the accuracy of the data, you may ask us to restrict the data processing for the period during which we verify the accuracy of the data;
    • If the processing is unlawful and you request us, instead of deleting the data, to restrict the use of the data;
    • In case we no longer need your personal data for the processing purposes, but you still need them for the establishment, exercise or substantiation of a legal claim;
    • If you have objected to the processing of your data, and you are awaiting our response as to whether our legitimate interests outweigh your interests.
  • Right to the deletion of data – In the following cases, you may have the right to have personal data deleted by us at your request:
    • If we no longer need the data for the purposes for which it was collected or obtained;
    • If you have withdrawn your consent, insofar as your data are processed on the basis of consent, and we also have no other legal basis for processing your data;
    • If you have objected to the processing of your data and we have no overriding interest, or if you have objected to the processing of your data for direct marketing purposes;
    • If we need to delete personal data in order to comply with a statutory obligation.

Please note that the above does not apply in all cases. We do not have to delete your personal data if we need it for, for example, the establishment, exercise or substantiation of a legal claim.

  • Right to data transfer – If we process your personal data pursuant to your consent or in execution of an agreement with you and the processing is automated, you have the right to obtain your data from us or have us transfer it to a third party in a commonly used file format.
  • Right to withdraw given consent – If your personal data is processed on the basis of consent, you have the right to withdraw your consent. Please note that withdrawing consent does not affect data processing that took place before you withdrew your consent.

You can exercise all of the aforementioned rights by sending an email to support@froggytalk.com clearly describing your request. Please note that we need to establish your identity before we can respond to your request. How we do this depends on your specific situation.

  • Right to file a complaint – If you disagree with the way FroggyTalk processes your personal data, you have the right to file a complaint with the competent Data Protection Authority. In the Netherlands, the competent authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

13. Automated decision-making and profiling

We may use automated tools to support fraud prevention, security, service personalisation, analytics, marketing segmentation and advertising audiences. We do not make decisions based solely on automated processing that produce legal or similarly significant effects on you, except where permitted by law and with the safeguards it requires.

14. Children

FroggyTalk is not intended for anyone under 18. If we learn that we hold personal data of someone under 18, we will take reasonable steps to delete or restrict that data.

15. Third party websites

This Privacy Policy does not apply to third-party websites that are connected to our website by hyperlinks. In addition, ad networks and social media platforms may receive or collect data as independent controllers under their own privacy terms. We cannot guarantee that these third parties will handle your personal data in a reliable or secure manner. We advise you to read the privacy statement of these websites before using them.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version will be available on our website or in the app. If changes are material, we will take reasonable steps to inform users or request renewed consent where required.

17. Contact

Appbeam Technology B.V. trading as FroggyTalk

Koninginnegracht 10, 2514AA The Hague, the Netherlands

KVK number: 97711160

Website: https://froggytalk.com

Privacy contact: support@froggytalk.com