This Thrutu Privacy Policy applies to the Thrutu application and the Thrutu Website available at http://www.thrutu.com offered by Data Connection Ltd. doing business as Metaswitch Networks (“Metaswitch”). Metaswitch is a global organisation committed to protecting and respecting your privacy.

Please read this Thrutu Privacy Policy which (together with the Thrutu End User License Agreement, the Thrutu Website  Terms of Use available at http://thrutu.com/thrutu-website-terms-of-use/ and any other documents referred to on it) sets out the basis on which we will use and protect information we collect from you through the Thrutu application, the Thrutu Website, and the Thrutu Buttons, which are buttons developed by us or third parties that we may make available to you for download through the Thrutu application. We may change the Thrutu Privacy Policy from time to time so please check for updates regularly. If you have any questions in relation to this Thrutu Privacy Policy please contact us at:

ATT: Thrutu Privacy Policy, Metaswitch, 100 Church Street, Enfield, EN2 6BQ UK

Tel: +44 20 8366 1177
Fax: +44 20 8363 4478
Email: privacy@metaswitch.com

Information we may collect from you

We may collect and process the following information about you:

• Personal Information. When you download the Thrutu application or use the Thrutu Website, we may collect personal information. We may combine the personal information we collect with information from wireless carriers or other third parties in order to provide you with a better experience and to improve the quality of our services. We may retain information you choose to provide to us through one of our interactive features.
• User communications. We may also ask you for information when you report a problem with the Thrutu Website or the Thrutu application. If you contact us, we may keep a record of that correspondence.
• Survey data. We may also ask you to complete surveys or otherwise provide feedback that we may use for research purposes, although you do not have to respond to any surveys or provide feedback.
• Log information. We may keep information about your usage of and interaction with the Thrutu application, the Thrutu Website and Thrutu Buttons, including but not limited to computer or mobile device and connection information, telephone number, device capability, bandwidth, wireless carrier, statistics on page views, traffic to and from the Thrutu Website, weblogs, cookies and other communication data and the resources that you access.
• Thrutu Button data. We may make available the ability to download Thrutu Buttons through the Thrutu application. The information collected by us when you download and enable a Thrutu Button is processed under the Thrutu Privacy Policy. The information collected by the Thrutu Button provider is governed by the Thrutu Button provider’s privacy policy.
• Traffic data. We may keep data processed for the purpose of the conveyance of the Thrutu communication including but not limited to the duration of the call, the telephone number calling and the telephone number called.
• Location Data. The Thrutu application offers location-enabled services, such as the “Share My Location” feature. If you use a location-enabled service, we may receive information about your actual location (such as GPS signals sent by your mobile device) or information that can be used to approximate a location (such as a cell ID).
• Information you provide about others. When you share the Thrutu application with family and friends using the functionality provided within the Thrutu application, we may collect the personal information you provide about those people, such as telephone number and/or email address.

We do not knowingly collect personal information from children under thirteen (13) years of age. If we learn that we have collected the personal information of a child under 13 we will take steps to delete the information as soon as possible.

IP addresses and cookies

We may collect information about your computer and/or mobile device, including where available your Internet Protocol (IP) address, operating system and browser type, for system administration and to help us improve the Thrutu Website. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information.

For the same reasons, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer and/or mobile device or through other technologies such as web beacons, widgets and server log files. The use of such technologies helps us to improve the Thrutu Website and to deliver a better and more personalised service. They enable us to estimate our user numbers and usage pattern; to store information about your preferences, and so allow us to customise the Thrutu Website according to your individual interests; to speed up your searches; and to recognise you when you return to our site. This information may be analyzed by third parties on our behalf.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Thrutu Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Thrutu Website.

Information Sharing

In order to provide you with access to the Thrutu application and Thrutu Buttons, we may sometimes, if necessary, share your personal information and traffic data with Metaswitch’s group companies and offices, wireless carriers, providers of Thrutu Buttons and analytical and other third party service providers and/or agents around the world. We will require these third parties to take appropriate organizational and technical measures to protect your personal information and traffic data. In relation to any other third parties, we will only disclose your personal information and traffic data where you have given your consent or where it is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request; (b) enforce applicable Terms of Service or the Thrutu End User License Agreement, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; or (d) protect against harm to the rights, property or safety of Metaswitch, Thrutu users or the public as required or permitted by law. View further information about our group companies and offices at http://www.metaswitch.com/company/locations.aspx.

As Metaswitch continues to develop its business, Metaswitch might sell or buy group companies or business units. In such transactions as well as in the event Metaswitch or substantially all of its assets are acquired by a third party, personal information and traffic data of Thrutu end users will generally be one of the transferred business assets. We reserve the right to include your personal information and traffic data, collected as an asset, in any such transfer to a third party.

Uses made of the information

Our primary purpose in collecting information is to provide you with a safe, smooth, efficient and customized experience with the Thrutu application and the Thrutu Website. We collect and use, or have third party service providers or wireless carriers acting on our behalf collect and use, personal information and traffic data relating to you, as permitted or necessary to:

• provide, maintain, protect and improve the Thrutu application and Thrutu Buttons and to develop new features and functionality for the Thrutu application and Thrutu Buttons;
• deliver customized content and advertising that may be of interest to you;
• ensure that content on the Thrutu Website is presented in the most effective manner for you and for your computer and/or mobile device;
• process your Thrutu application and/or Thrutu Button downloads and subscriptions;
• provide you with information, products or services related to the Thrutu application, including Thrutu Buttons, where you have consented to be contacted for such purposes;
• allow you to participate in interactive features of the Thrutu Website, when you choose to do so;
• notify you about changes to the Thrutu application and Thrutu Buttons;
• communicate with you about Thrutu service updates, offers and promotions;
• carry out market research and to request feedback or participation in surveys;
• correspond with you; and
• protect your and Metaswitch’s interests, including without limitation to enforce our Thrutu Website Terms of Use and the Thrutu End User License Agreement, address network integrity and security issues and to investigate, prevent or take action regarding illegal activities.

Security

We take appropriate administrative, technical and physical security measures to protect against unauthorized access to or unauthorized disclosure or destruction of data transmitted to the Thrutu Website and through the Thrutu application. These include up-to-date data storage, processing, transmission and security techniques, including encryption, to protect your information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss.

All our employees and any third parties we engage to process your personal information are obliged to respect the confidentiality and protect the security of your personal information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee that your personal information will never be disclosed in a manner inconsistent with this Thrutu Privacy Policy (for example, as the result of unauthorized acts by third parties that violate the law or this Thrutu Privacy Policy).

Contacting you

We may from time to time ask you to provide information on your experience with the Thrutu application which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the Thrutu Website or any survey that you accept to take part in is used for the purposes of reviewing this feedback and improving the Thrutu application, Thrutu Buttons and the Thrutu Website.

We may also contact you to send you messages about faults and service issues and any claims related to your use of the Thrutu application, Thrutu Buttons or the Thrutu Website.

Your rights

You have the right to ask us not to process, sell, rent or trade your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

You can exercise this right at any time by contacting us at privacy@metaswitch.com.

Thrutu Buttons and other third-party websites and services

The Thrutu application enables you to download Thrutu Buttons. We do not have any control over how the Thrutu Button provider may use any personal information that it collects in connection with the download or use of the Thrutu Button. Thrutu Button providers and their websites will have their own privacy policies. The Thrutu application and the Thrutu Website may also contain links that will let you access third party websites and services. Linked websites are not under our control and will have a different privacy policy. We do not accept any responsibility or liability for these privacy policies. Please check these privacy policies before you submit any personal information to a Thrutu Button provider or a third party website.

Access to and updating personal information

You will be able to correct any of your personal information associated with the Thrutu application if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical (such as requests concerning information residing on backup tapes), or for which access is not otherwise required by local law. You can exercise this right at any time by contacting us at privacy@metaswitch.com.

Retention of information

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Thrutu Privacy Policy unless a longer retention period is required or permitted by law.

You may have the right to apply for a copy of the personal information we hold about you and to have any inaccurate personal information about you corrected. We may charge a small administrative fee for this.

Changes to the Thrutu Privacy Policy

We reserve the right to change the Thrutu Privacy Policy from time to time. We will inform you of these changes by publishing the revised Thrutu Privacy Policy and prominently posting a notice of the change at http://thrutu.com/thrutu-privacy-policy/.