Privacy Policy

I. Introduction

Inovo (“we,” “us,” or “our”) takes your privacy seriously. This Privacy Policy explains our data protection practices and describes the types of information we may process when you install and/or use the Inovomobile application (the “App”).

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

This Privacy Policy applies to all users of the App regardless of where they are located. The U.S. Multistate Privacy Notice included as an annex supplementarily applies to residents of U.S. states where corresponding privacy laws have been enacted.

II. Information We Process

Functional Information You Submit

We ask for and collect the following personal information when you use the App. This information is necessary for the adequate performance of the contract between you and us.

• Account Information: email address and other data (such as name or address) required for compliance with applicable local laws. You may create an Account (required to obtain a phone number) by signing in with Apple and providing your email address. You can sign out or delete your Account at any time via App Settings. Deleting your Account erases all associated data and is irreversible. An active credit balance is not automatically refunded upon Account deletion.
• Activity Information: contacts created through the App, call logs and recordings, SMS/MMS logs and records, origination and termination points, history of incoming and outgoing calls, and the list of phone numbers used through the App. With your consent we may also have technical access to the microphone and contact list on your device.
• Content Information:the content of messages sent and received through the App, processed solely to deliver the App's calling and messaging services.
• SMS Messaging. When you use your Inovo number to send or receive SMS, message frequency varies and message and data rates may apply. We do not sell or share your mobile phone number or your messaging consent with any third party for their own marketing or promotional purposes. Message content is processed only to deliver the messaging service and to detect spam, fraud, and abuse, as described in this Policy and in our Acceptable Use Policy for Messaging.

All account, activity, and content information is processed exclusively to operate App services and provide you with App functionality (calls, SMS/MMS, call recording, contact management, and message history). Deleting your Account removes all of the above.

If you use the call recording feature, it is your sole responsibility to notify your dialog partner before recording begins. Please review the call recording requirements in our Terms of Use.

We may engage third-party cloud communications service providers to store this data in order to deliver App services. This data can be deleted either by those third parties per our instructions or by our own means.

Contact Information

When you contact us via a support form, we collect your name, email address, and the content of your message. This is used solely to respond to your inquiry.

Information Processed Automatically

We may process the following non-personal device and session data to operate and improve the App:

• Device Details: device type, operating system version, model, manufacturer, screen size, and memory usage.
• Connection Information: mobile carrier, network type, IP address, and session timestamp and duration.
• Location-related Information: country/region associated with your SIM or device, language setting, and time zone.
• App Information: App version and usage patterns, used to diagnose issues and improve performance.
• Log file information: date/time of sessions and feature interactions.

Analytics

We use Amplitude, a third-party product analytics service, to understand how the App is used and to improve it. Amplitude processes usage and interaction data (such as which features you use and in-App events like sending a message or completing a purchase) associated with a user identifier. This data is processed on our behalf and is notused to track you across other companies' apps or websites. For more information, see Amplitude's privacy policy at amplitude.com/privacy.

Payment Information

All purchases within the App are processed through the Apple App Store or Google Play in-app purchase mechanism, depending on the platform you downloaded the App on. Apple or Google is responsible for billing, processing, and charging for all such purchases and handles your payment information securely. We do not access or store your credit or debit card details. All in-app purchase rules and policies are governed directly by Apple or Google.

III. Purposes of Processing

• (a) To deliver App services. We use the information above to provide calling, messaging, and all other requested App functionality.
• (b) To improve and monitor the App. We use automatically processed information to understand usage patterns, detect technical issues, and optimize the App experience.
• (c) To communicate with you. We use information you submit via support forms to respond to inquiries, deliver support, and fulfill your requests.
• (d) To prevent fraud and enforce the law. We may use your information to detect and investigate fraud, security breaches, and prohibited activities, and to enforce our Terms of Use.

If new processing purposes arise, we will update this Privacy Policy accordingly.

IV. Sharing of Your Information

We will share your information with third parties only as described in this Privacy Policy. We will not rent or sell your personal data.

We engage the following third-party service providers to operate the App:

Refund requests. If you request a refund for a purchase, Apple or Google may ask us for information about that purchase before making their decision. In those cases we share relevant account and usage data with them, including whether the credits or subscription were delivered successfully, how much of the purchase you have used, the age and status of your account, and your purchase and refund history with us. This sharing happens only in response to a refund request you have made.

We may also disclose your information when required by law, to protect our rights or safety, to prevent fraud, or in connection with a merger or acquisition (with prior notice to you).

V. International Data Transfers

We operate globally and may transfer your information across borders. If you are located in the European Union or another region with data protection laws that differ from U.S. law, please be aware that your personal information may be transferred to jurisdictions that do not offer the same level of protection.

We take reasonable measures to ensure that any recipient of personal data provides appropriate protection. We encrypt personal data where possible before transmitting it to storage providers.

VI. Data Retention and Deletion

We retain personal information for as long as necessary to provide App services and comply with legal obligations.

Deleting Your Account

You can permanently delete your Account at any time via App Settings. You may also submit a formal data deletion request through our support form. Both are treated as a final request to close your Account and erase your data.

What Happens When Your Account Is Deleted

• Immediate effect: We immediately stop processing your data for App services. You lose access to your Account and its data with no possibility of restoration.
• Data deleted within 30 days: communications data (call history, SMS/MMS content and history, associated phone numbers, voicemail, and call recordings); account information (email address, physical address if provided); App usage data (contacts, settings, in-App credits, notifications).
• Limited retention for legitimate purposes: User ID and Device ID may be retained for a longer period solely to prevent fraud and enforce our Acceptable Use Policy.

Legal and Law Enforcement Requests

We rigorously review every request from government or law enforcement agencies. We only comply with requests that are lawful, properly served, and supported by the required legal document (warrant, court order, or subpoena). Our responses are strictly limited to data we hold at the time of the request.

VII. Your Privacy Rights

Applicable data protection laws give you the following rights:

• Right to Know and Access: Request confirmation of whether we process your data and obtain a copy.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Correct Inaccuracies: Ask us to correct or update your data where you cannot do so yourself.
• Right to Data Deletion: Request deletion of all or some of your personal data. Legal exceptions may apply.
• Right to Restriction of Processing: Request that we limit how your data is used in certain circumstances.
• Right to Object: Object to processing of your data in certain circumstances.

To exercise any of these rights, contact us through our support form. You also have the right to lodge a complaint with your local data protection authority.

VIII. Managing Your Data

Location Data

Manage location access for the App at Settings → Privacy & Security → Location Services and select Inovo to set your preferred access level.

Microphone and Contacts

You can revoke microphone or contacts access at any time via Settings → Privacy & Security on your iOS device. Revoking access may limit certain App features.

IX. Security

We implement appropriate technical and organizational measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We encrypt personal data where possible. No method of transmission over the Internet is 100% secure; in the event of a security breach affecting your personal information, we will promptly notify you in compliance with applicable law.

X. Children's Privacy

The App is not intended for children. We do not knowingly collect personal information from anyone under the age of 16. If we learn that we have collected personal data from a child without verifiable parental consent, we will delete it as quickly as possible. If you believe we may have information from or about a child, please contact us.

XI. Changes to This Policy

We update this Privacy Policy regularly. When changes are made we will post the updated policy and indicate the revised date. Continued use of the App after changes constitutes acceptance of the updated policy.

XII. Contact Us

If you have any questions about this Privacy Policy, please contact us at support@innovage.io.

Annex: U.S. Multistate Privacy Notice

Scope

This U.S. Multistate Privacy Notice supplements the Privacy Policy above for individual residents of U.S. states that have enacted comprehensive data privacy laws, including but not limited to the California Consumer Privacy Act (CCPA/CPRA), Texas Data Privacy and Security Act (TDPSA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), and Connecticut Data Privacy Act (CTDPA) (collectively, “U.S. State Privacy Laws”). This Notice supplements, and does not replace, the main Privacy Policy.

Categories of Personal Data and Purposes

See Sections II and III of this Privacy Policy above.

Sharing of Personal Data

See Section IV for the full list of service providers. We do not sell your personal information for monetary gain, and we do not share your personal data for advertising or marketing purposes.

Your Rights as a Covered U.S. Resident

In addition to the rights in Section VII, U.S. State Privacy Laws grant you:

• Right to Non-Discrimination: We will not deny services, charge different prices, or provide a lower quality of service because you exercised a privacy right.
• Right to Appeal: If we decline your privacy request, you may appeal that decision. Contact us with additional information and we will respond in writing with our decision.

How to Exercise Your Rights

To exercise any right you cannot manage independently in the App, contact us via our support form. Include the phrase “Exercising my privacy rights in [State name]” in your request. We will respond within 45 days; if we need more time we will notify you in writing. We may ask you to verify your identity before acting on a request.

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