At innexum (“we,” “us,” or “our”), we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how MyOwnSIM (“the App”) collects, uses, stores, and shares information when you use our SMS gateway and business communication platform.

1. Information We Collect

1.1 Information You Provide

When you use MyOwnSIM, we collect the following information:

• Account Information: Your user ID, location ID, and CRM subaccount credentials provided through QR code scanning
• SIM Card Information: Phone numbers, subscription IDs, carrier names, SIM slot indices, and whether the SIM is an eSIM
• Device Information: Device model, operating system version, and Firebase Cloud Messaging (FCM) tokens for push notifications
• Contact Information: Access to your device contacts for matching with your CRM database

1.2 Information Automatically Collected

• SMS Messages: Content, sender information, recipient information, timestamps, and delivery status of messages sent and received through the App
• Call Information: Incoming and outgoing call logs, including phone numbers, call duration, timestamps, and call direction (for missed call text-back feature)
• Usage Logs: Application logs stored locally on your device to troubleshoot issues and improve performance
• Tool Settings: Your preferences for SMS Gateway, Missed Call Text Back, and Smart Dialer features per SIM card

1.3 Third-Party CRM Data

When you link MyOwnSIM with your CRM system, we may access and display:

• Contact names, email addresses, company names, addresses (city, country, full address)
• CRM notes, tasks, appointments, and custom fields associated with contacts
• Any other information your CRM system provides through its API

2. How We Use Your Information

We use the collected information for the following purposes:

• SMS Gateway Functionality: To route incoming SMS messages to your CRM system and send outgoing messages from your CRM through your device’s SIM cards
• Missed Call Text Back: To automatically detect missed calls and trigger automated text responses configured in your CRM
• Smart Dialer Integration: To display CRM contact information when receiving calls from known contacts
• CRM Synchronization: To match phone numbers with your CRM contacts and display relevant customer information
• Push Notifications: To deliver real-time notifications for incoming messages and calls requiring action
• Service Improvement: To analyze usage patterns, troubleshoot issues, and improve App functionality
• Authentication: To verify your identity and maintain secure connections with our backend services

3. Data Storage and Security

3.1 Local Storage

• Device Storage: SIM settings, tool configurations, and application logs are stored locally on your device using SharedPreferences and SQLite databases
• Contact Cache: Contact information from your device is temporarily cached in memory for performance but not permanently stored by our servers

3.2 Cloud Storage

• Backend Services: We use Amazon Web Services (AWS) DynamoDB in the EU-North-1 region to store user credentials, SIM configurations, and message routing information
• Firebase: FCM tokens are stored by Google Firebase for push notification delivery
• Message Content: SMS message content is transmitted through our servers but not permanently stored. Messages are immediately forwarded to your CRM system

3.3 Security Measures

We implement the following security measures to protect your information:

• HTTPS encryption for all data transmission between the App and our servers
• Secure API endpoints with authentication tokens
• Regular security audits and updates
• Limited access to personal data by our technical team on a need-to-know basis
• Compliance with Android security best practices, including ProGuard code obfuscation for release builds

4. Information Sharing and Disclosure

We share your information only in the following circumstances:

• With Your CRM Provider: SMS messages, call logs, and contact information are shared with your connected CRM system as necessary to provide the service functionality
• Service Providers: We use AWS for backend infrastructure and Firebase for push notifications. These providers have access to your data only to perform services on our behalf and are obligated to protect your information
• Legal Requirements: We may disclose your information if required by law, court order, or governmental request
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

5. Permissions and Access

MyOwnSIM requires the following Android permissions to function:

• SMS Permissions (READ_SMS, SEND_SMS, RECEIVE_SMS): To read, send, and receive SMS messages
• Phone Permissions (READ_PHONE_STATE, CALL_PHONE): To detect calls, read SIM card information, and make calls
• Contacts Permission (READ_CONTACTS): To access your contact list for CRM matching
• Notification Permission: To display notifications for incoming messages and calls
• Default Dialer Role: To enable Smart Dialer functionality and display CRM information during calls

You can manage these permissions in your device settings at any time. However, disabling certain permissions may limit App functionality.

6. Data Retention

• Account Information: Retained as long as your account is active or as needed to provide services
• Message Routing Logs: Retained for 90 days for troubleshooting and service improvement
• Local Logs: Stored on your device and can be cleared through the App settings
• SIM Configuration: Retained until you remove a SIM card from the App or delete your account

You can request deletion of your data at any time by contacting us at innexumtech@gmail.com.

7. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information
• Portability: Request transfer of your data to another service
• Opt-Out: Disable specific features (SMS Gateway, Missed Call Text Back, Smart Dialer) through App settings
• Withdraw Consent: Revoke permissions granted to the App through your device settings

To exercise these rights, contact us at innexumtech@gmail.com.

8. Children’s Privacy

MyOwnSIM is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately, and we will delete such information.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. Our backend services are hosted in the EU (AWS EU-North-1 region). We ensure appropriate safeguards are in place to protect your information in compliance with applicable data protection laws.

10. Third-Party Services

MyOwnSIM integrates with third-party services:

• Google Firebase: For push notifications. See Firebase Privacy Policy
• Amazon Web Services: For backend infrastructure. See AWS Privacy Notice
• Your CRM Provider: Subject to your CRM provider’s privacy policy

We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

11. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by:

• Posting the updated policy in the App
• Updating the “Last Updated” date at the top of this document
• Sending you a notification through the App or email for material changes

Your continued use of MyOwnSIM after changes become effective constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: innexumtech@gmail.com
• Company: Innexum OÜ
• App Name: MyOwnSIM