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Terms of service

Public Offer

for Access to a Cloud Platform for Creating and Managing Automated Voice Calls

August 17, 2026

Telecoma, a sole proprietorship limited liability company, hereby establishes the terms and conditions for access to a cloud platform for creating and managing automated voice calls (hereinafter referred to as the "Platform") via the Internet.

This public offer (hereinafter referred to as the "Offer" or "Agreement") is the Copyright Holder's formal offer to the User, i.e., any individual who is not a citizen or resident of the European Union (EU) or who is not located within the territory of an EU member state (hereinafter referred to as the "User"), to enter into an agreement (hereinafter referred to as the "Agreement") on the terms and conditions set forth below.

Acceptance of the Offer is accomplished by registering on the Website, creating a Personal Account, making a payment, or performing other implied actions that clearly indicate the intent to use the Platform. Acceptance of the Offer constitutes the User's full and unconditional acceptance of all terms and conditions of this Agreement, as well as its appendices, without any reservations or exceptions.

1. The Basic Concepts Used for the Purposes of This Agreement

1.1. For the purposes of this Agreement, the following terms shall be used with the following meaning:

1.1.1. Internet site (Site) — a set of programs for electronic computers and other information contained in the information system, access to which is provided through the information and telecommunication network Internet at https://callo.com.

1.1.2. Personal Account — a section of the Copyright Holder's Site, which is used by the Copyright Holder and the User for exchange of legally significant information within the framework of this Agreement. Personal Account is located at: https://app.callo.com/manager.

1.1.3. Platform Features — a list of features provided by the Copyright Holder through the Platform, defined on the Copyright Holder's Internet site in the "Official Documents" section.

1.1.4. Official Documents — a special section on the Site, containing a comprehensive list of legally significant documents, including information on the cost of Platform Features. The information in this section is recognized as an integral part of this Agreement.

1.1.5. Personal Account Balance — a record used to track the receipt and expenditure of the User's funds deposited for Platform Features. The Personal Account Balance is accessed by the User through the Personal Account. The Personal Account Balance is not a bank account and is for information purposes only.

1.1.6. Guides — reference materials explaining how to use the Platform to the User, located in the "User Guide" section of the Site. The Copyright Holder makes every effort to keep the User Guide up-to-date (fully consistent with all Platform Features), but does not guarantee this.

1.1.7. Primary Number — the telephone number specified by the User upon registration on the Site, which allows the Copyright Holder to uniquely identify the User.

1.1.8. Secondary Number — the telephone number specified by the User in the Personal Account using the "Alias Users" feature. Actions performed using the Secondary Number are equivalent to actions performed using the Primary Number.

1.1.9. The Cloud Platform for Creating and Managing Automated Voice Calls (the Platform) — a hardware and software system hosted on the Internet that allows the User to create and configure a personalized voice robot for use on public switched telephone network (PSTN) endpoints, including, but not limited to, generating behavioral scenarios, integrating third-party services, and performing other actions specified by algorithms and software code. The Platform is provided to the User without downloading or distributing a distribution package. The location of access to the Cloud Platform under this Agreement is outside the customs and tax territory of the European Union.

1.1.10. Copyright Holder — Telecoma Sole Proprietorship Limited Liability Company (Telecoma SPLLC), which has the right to grant (transfer) the right to use the Platform.

1.1.11. CDR (Call Detail Records) — a record automatically generated for the purpose of ensuring continuous recording of calls by the telecommunications equipment of the Copyright Holder, containing comprehensive data on each specific telephone call and an indication of the User who made this call.

1.1.12. Right of Access — a non-exclusive right to use the SaaS version of the Platform under the name designated by the Copyright Holder, without the right to alter or otherwise adapt it, or distribute it without the written consent of the Copyright Holder, granted in territories outside the customs and tax territory of the European Union.

2. Subject Matter

2.1. The Copyright Holder grants the right of access to the Platform under the terms of this Agreement, and the User undertakes to pay for this right in the manner and under the terms established by the Agreement.

2.2. A full list of Platform Features, their prices, terms of provision, and terms of use are provided in the "Official Documents" section of the Site, all information on which constitutes an integral part of this Agreement.

2.3. The User has the right, at their own discretion, to use communication services from third-party communication providers. In this case, the User independently enters into an agreement with third-party communication providers, independently pays for the services of third-party communication providers, and activates them in the appropriate section of the Personal Account (subject to technical limitations). The legal relationship between the User and the third-party communication providers is governed by an agreement and/or other contract concluded between them, to which the Copyright Holder is not a party.

2.4. The Platform's algorithms are designed to perform tasks solely for the User's benefit, not the Copyright Holder's. When using the Platform, the User defines the tasks and purposes for which it is used at their own discretion, while agreeing to comply with the terms of this Agreement and the current legislation of the country in which the Right of Access is granted. Tasks are set by the User without the intervention of the Copyright Holder.

2.5. The scope of the Platform Features and the list of options available to the User are determined by the User independently in their Personal Account. Information on the scope and cost of the actual right of access to the Platform is available in the "Details" and "Charges" sections of the Personal Account.

2.6. The Copyright Holder grants the User the right to access the Platform via the Internet through the Internet site and the Personal Account. The Copyright Holder reserves the right to use and grant the right to use the Platform in any territory.

2.7. By accepting the terms of this Offer (accepting the Offer), the User confirms and warrants to the Copyright Holder that:

  • They are not a citizen, tax resident, or currency resident of any Member State of the European Union (EU);

  • They are not actually located or reside within the territory of any EU Member State at the time of acceptance and execution of this Agreement;

  • If any of these circumstances change, the User undertakes to immediately cease using the service(s) and notify the Copyright Holder thereof.

3. User Registration on the Copyright Holder's Internet Site

3.1. The User undertakes to register in their Personal Account and provide accurate information about themselves.

3.2. After registration, the User may access their Personal Account using their Primary or Secondary Number by authorizing a call to the verification number.

3.3. The Copyright Holder undertakes not to disclose the User's registration data, or any other information concerning the User's personal data, to persons not involved in the execution of this Agreement, except in cases of official requests from government agencies and organizations authorized to receive relevant information in accordance with the laws of the country in which the Right of Access is granted.

3.4. The User undertakes not to disclose to third parties the data required for authorization.number The User is fully responsible for the disclosure of this information in accordance with the current legislation.

3.5. The Copyright Holder shall not be liable for any losses incurred by the User resulting from loss of access to the Personal Account or transfer of such access to third parties due to the User's fault.

3.6. The User is responsible for the content and accuracy of the data provided upon registration in the Personal Account.

3.7. The User expresses full and unconditional consent to the collection, processing, distribution, provision, and storage of the User's personal data provided by the latter upon registration by the Copyright Holder.

3.8. All information materials presented on the Site, with the exception of this Agreement, the "Official Documents" section, and related agreements, are for informational purposes only, unless otherwise expressly stated in the Agreement.

3.9. For individuals, User identification is carried out using electronic services that have the necessary functionality to confirm the identity of individuals.

3.10. The Copyright Holder reserves the right to restrict access to the full Platform Features for Users who have not been identified.

4. Platform Use Procedures

4.1. The User may use the Platform in the following ways:

4.1.1. Access the Platform 24/7, except during maintenance via the Site.

4.1.2. Use the Platform Features to the extent of funds available on the Personal Account Balance in accordance with the tariffs, rules of use set forth in this Agreement, section "Official Documents" and User's Guide.

4.2. When using the Platform, the User may not:

4.2.1. Commit actions and/or disseminate information that in any way violate the current legislation of the country in which the Right of Access is granted or the requirements of international treaties.

4.2.2. Transfer rights under this Agreement to third parties without the written consent of the Copyright Holder.

4.2.3. Send advertisements without complying with the requirements established by the legislation of the country in which the Right of Access to the advertising content and the terms of its distribution are granted.

4.2.4. In any way violate the rights of third persons, including minors, and/or harm them in any form.

4.2.5. Impersonate another person or use any other forms and methods of illegal representation of other persons, as well as misleading other addressees or the Copyright Holder with the use of the Platform.

4.2.6. Use the Platform to make telephone calls without prior consent of the addressee(s) of the calls, if obtaining such prior consent is mandatory in accordance with the current legislation of the country in which the Right of Access is granted.

4.2.7. Disseminate information that: is illegal, harmful, defamatory, offensive to morality, or demonstrates (or promotes) violence and cruelty; is aimed at the violent change of the constitutional order, contains calls for violation of the territorial integrity of the country on the territory of which the Right of Access is provided, propaganda of war, terrorism, separatism and religious extremism; violates intellectual property rights; promotes hatred and/or discrimination against people on racial, ethnic, sexual, religious or social grounds, contains insults against any persons or organizations; contains elements of (or is propaganda of) pornography, child erotica, is an advertisement (or is propaganda) of services of a sexual nature (including under the guise of other services); explains the procedure for the manufacture or use of narcotic substances or their analogues, explosives or other weapons; is an advertisement (or is propaganda) of alcoholic beverages, beer and drinks made on its basis, tobacco, tobacco products and smoking accessories; items withdrawn from circulation or of restricted circulation; constitutes advertising (or promotion) of risk-based games, betting, and bookmaking activities organized by persons without the appropriate license from the authorized government agency; violates securities market laws, financial services advertising, and consumer protection requirements.

4.2.8. Use obscene language and offensive expressions against any person or group of persons.

4.2.9. Use the Platform for any purposes related to political activities.

4.2.10. Use the results of intellectual activity, means of individualization of third parties in the absence of legitimate grounds.

4.2.11. Distribute information containing viruses or other computer codes, files, or programs designed to disrupt, destroy, or limit the functionality of any computer or telecommunications equipment or programs for unauthorized access, as well as serial numbers to commercial software products and programs for their generation, logins, passwords, and other means for obtaining unauthorized access to paid resources on the Internet, as well as posting links to the above information;

4.2.12. Disrupt the normal operation of the Platform, including distributing spam, viruses, or malicious code.

4.2.13. Facilitate actions aimed at violating the restrictions and prohibitions imposed by this Agreement;

4.2.14. Initiate short calls that do not contain a semantic load, the purpose of which is to encourage the person who received the call to make a callback to a certain number.

4.2.15. Initiate a large number of calls (with or without semantic load) to one number in order to make it difficult for the owner to use this number (flood).

4.2.16. Register social media, instant messaging, and other accounts to the phone numbers allocated under this Agreement.

4.2.17. Copy, reproduce, process, distribute, or otherwise use the Platform (including its functionality, interface, algorithms, and database), in whole or in part, without the written permission of the Copyright Holder.

4.2.18. Otherwise violate the norms of legislation, including the norms of international law.

4.3. the Platform can be used only if the User has access to the Internet.

4.4. The Copyright Holder shall not be liable for improper operation of the Platform due to the User's claims to the quality of connection to the Internet related to the quality of functioning of Internet providers' networks, traffic exchange policy between providers, and other circumstances beyond the Copyright Holder's competence, influence and control.

4.5. The Copyright Holder does not guarantee the availability of the Platform at all times. The Platform is provided "as is." The Copyright Holder does not provide any guarantees regarding the error-free or uninterrupted operation of the Platform or any of its individual components and/or functions, the Platform's compliance with the User's specific purposes and expectations, the integrity of the User's files and/or other information entered in the Personal Account, or any other guarantees not expressly stated in this Agreement.

4.6. At its sole discretion, to fulfill this Agreement, the Copyright Holder may require the User to undergo extended (including repeated) identification and may deny access to the Platform until the User has completed the required identification.

4.7. The presence of a CDR in the Copyright Holder's telecommunications equipment log indicating the fact of each specific telephone call made by the User is recognized by the User as legally valid evidence thereof and is not contested. The User is solely responsible for all calls initiated from the User's Personal Account.

5. Rights and Obligations of the Parties

5.1. The Copyright Holder undertakes to:

5.1.1. Grant the User access to the Platform under the terms of this Agreement.

5.1.2. Generate and store CDRs of calls made by the User via the Platform for one year from the date of their execution.

5.2. The Copyright Holder has the right to:

5.2.1. Unilaterally change the terms of this Agreement. The User will be notified of changes to the Agreement by posting new information on the Copyright Holder's Site. If the User does not agree to the new terms of the Agreement, they must immediately cease using the Platform. If the User continues to use the Platform after changes in the terms of the Agreement — the new terms of the Agreement shall be deemed accepted by the User.

5.2.2. Engage third parties to perform this Agreement without the written consent and/or agreement of the User.

5.2.3. Deny the User access to the Platform unilaterally and extrajudicially if the User violates the terms of this Agreement, including the prohibitions set forth in paragraph 4.2 of the Agreement.

5.2.4. Update, modify the Platform, add, change, or disable features at any time, with prior notice via the Site or Personal Account.

5.3. The User undertakes to:

5.3.1. Use the Platform only for actions permitted by the laws of the country in which the Right of Access is granted and by international treaties, and in compliance with the terms of this Agreement, including those set forth in paragraph 4.2 of the Agreement. Any use of the Platform for purposes or in actions that violate the laws of the country in which the Right of Access is granted is contrary to this Agreement and is not covered by the Parties' agreement.

5.3.2. Ensure that all consents and permissions required by the law of the country in which the Right of Access is granted are obtained before performing any actions for which the relevant consents/permits are necessary. Upon request, the User shall provide the Copyright Holder with the consents/permits specified above, as required by the law of the country in which the Right of Access is granted.

5.3.3. Create backup copies of information uploaded to the Personal Account on their own storage media as frequently as necessary to fully prevent the negative consequences of any failures or accidents (including in the event of complete inaccessibility or destruction of data). Given the above, the Copyright Holder shall not be liable for the security of information entered on the Site.

5.3.4. Provide the Copyright Holder with all information and documents necessary for the Copyright Holder to fulfill its obligations under this Agreement and to third parties. In case of changes in the information specified during registration, conclusion of this Agreement and related agreements, the User shall notify the Copyright Holder in writing (including through the Personal Account) no later than 3 (three) working days from the date of such change. The User bears all possible risks and losses associated with failure to fulfill the obligation to notify the Copyright Holder in due time.

6. Payment for the Platform

6.1. The User shall pay for the use of the Platform in accordance with the information in the "Prices" section. Other payment terms may be offered for individual Users. Such terms are set forth in the "Prices" section of the User's Personal Account and take precedence over the terms set forth in the "Prices" section.

6.2. The opportunity to use the Platform is provided on prepayment terms, unless otherwise provided by the appendix or additional agreement between the Parties.

6.3. Valid payment methods are listed in the Personal Account. When paying by bank transfer, invoices under this Agreement are issued upon the User’s request automatically in the Personal Account. Payment by card is made through the payment system.

6.4. Payment under this Agreement is processed in the national currency of the country indicated by the User when registering their Personal Account.

6.5. In the event the User's Personal Account Balance is replenished by a third party by transferring funds in favor of the Copyright Holder, such third party must agree to the terms of this Agreement. The User and the third party who has replenished the User's Personal Account Balance agree that the services are provided to the User whose Personal Account Balance is being replenished, and not to the third party who has replenished the Personal Account Balance of such User, even if the User creates an invoice in the Personal Account for payment using the details of the third party.

6.6. The Copyright Holder shall not be liable for the fulfillment of obligations by the User in the interests of a third party who has replenished the User's Personal Account Balance. All claims regarding the use of the Platform by the User in the interests of a third party are made by such a third party to the User, and not to the Copyright Holder, who is not a party to the agreement and/or other transaction between the User and the third party. The User undertakes to acquaint the third party depositing funds to the User's Personal Account Balance with the provisions of of this Agreement.

6.7. If the User has a debt (the Personal Account Balance has become negative), the User undertakes to repay the debt within 5 (five) calendar days from the date of the debt occurrence.

6.8. The right to access the Platform Features is deemed granted to the User upon receipt of payment to the Copyright Holder's account.

The Copyright Holder is deemed to have fully fulfilled its obligations under the Agreement upon providing the User with technical access to the Platform, regardless of whether the User has actually begun using the Platform.

If the User fails to report a technical impossibility of accessing the Platform within 3 days of payment, access to the Platform Features is deemed to have been granted in full without issue.

6.9. In the event of early termination of this Agreement or in the event of erroneous or double payment, the User's unused funds may be returned to the User in accordance with paragraph 6.11 of this Agreement, less any actual expenses incurred by the Copyright Holder. Actual expenses incurred by the Copyright Holder include, but are not limited to: provision of paid Platform Features; payment system and bank fees for payment acceptance and refund; communication costs (based on itemization); infrastructure allocation and maintenance costs; and other expenses directly or indirectly related to the performance of this Agreement.

6.9.1. Such a refund is made within 30 (thirty) calendar days from the date of receipt of the User's request.

6.9.2. The funds to be refunded may, upon the User's request, be used for payment under other agreements between the User and the Copyright Holder.

6.10. The refund of unused funds to the User is carried out on the basis of a written application from the User containing the following information:

For individuals – last name, first name, patronymic (if any), User ID, identity document details (passport or ID card: series, number, issuer and date), bank card or current account details (IBAN), amount to be refunded, reason for refund, and signature.

6.11.1. An application for a refund can be submitted by the User through Personal Account, by e-mail or in any other way provided for by law.

6.11.2. The funds are refunded to the same User details that were used to replenish the Personal Account Balance.

6.11.3. If the User changes the details for a refund, the application for a refund is sent to the Copyright Holder only in paper form by mail to the Copyright Holder's postal address specified in section 11 of this Agreement. The new bank account details must be specified in the application.

6.11.4. Refunds to third-party accounts are not permitted.

7. Responsibilities of the Parties and Dispute Resolution Procedures

7.1. The Parties to this Agreement shall be liable in accordance with the laws of the country in which the Right of Access is granted, taking into account the provisions of this Agreement.

7.2. The Copyright Holder shall not be liable, including to third parties, for any direct or indirect damages, including lost profits, arising from the User's use of the Platform.

7.3. The Copyright Holder shall not be liable for the User's inability to use the Platform Features due to reasons beyond the control of the Copyright Holder.

7.4. The Copyright Holder will not be liable in case of blocking by the communication provider of the package of calls and messages composed by the User and intended for further sending to the User's clients.

7.5. Under any circumstances, the Copyright Holder's liability is limited to 500 euros and is imposed on the Copyright Holder if there is fault in the Copyright Holder's actions and the amount of damage incurred by the User is proven.

7.6. The User is solely and fully responsible to third parties for their actions while using the Platform, including if such actions result in a violation of the rights and legitimate interests of third parties, as well as for any information posted in the Personal Account.

7.7. The Copyright Holder does not control the content of the User's scripts for execution by the algorithms of the Platform, carried out using the User's Personal Account. The User independently determines the content, orientation, and addressees of the calls. The User fully and unconditionally accepts any responsibility (including financial) for all scripts created with the help of the User's Personal Account to any third parties and/or state authorities.

7.8. The User is solely and fully responsible for obtaining consent to the processing of personal data of their counterparties, and consent to make mailings and calls for which they use the Platform. The User is the personal data processor with respect to the data entered in the Personal Account and is solely responsible for its processing.

7.9. The User is solely and fully responsible for compliance of the actions performed by them using the Platform with the applicable legislation, including the legislation in the field of advertising.

7.10. In case of bringing the Copyright Holder to responsibility (including, but not limited to — in the form of imposing a fine (administrative, etc.), including both the Copyright Holder and the Copyright Holder's official, the obligation to compensate for damages / losses, etc.) in connection with the User's actions, the Copyright Holder shall promptly notify the User of the claims and bringing to responsibility.

In the event that the Copyright Holder is held liable (including, but not limited to, in the form of a fine (administrative, etc.), liability for damages / losses, etc.) in connection with the User's actions, the User undertakes, within 5 (five) working days from the date of the Copyright Holder's submission of the relevant claim, to reimburse all the amount of money required for collection (as well as money paid/collected) from the Copyright Holder.

Within 5 (five) working days from the date of submission of the relevant claim, the User reimburses the Copyright Holder for losses caused to the Copyright Holder or third parties by actions of a third party committed using the User's credentials.

7.11. Neither Party is liable to the other Party for non-fulfillment of obligations caused by circumstances that arose beyond the will and desire of the Parties, which could not have been foreseen or avoided, including, but not limited to, declared or actual war, civil unrest, epidemics, blockades, embargoes, fires, natural disasters, as well as illegal actions of third parties (force majeure).

A Party that does not fulfill its obligations must notify the other Party about the obstacle and its impact on the fulfillment of obligations.

7.12. All disputes and disagreements that may arise between the Parties will, if possible, be resolved through negotiations.

Compliance with the claims procedure when resolving disputes under this Agreement is mandatory. The deadline for responding to a claim is 15 (fifteen) working days from the date of receipt of the claim.

If the claims are not satisfied (in whole or in part) within the time period specified in the claim, the Party whose right has been violated has the right to file a claim with the court. Disputes that are not settled in a claim-based manner are resolved in court at the place of registration of the Copyright Holder.

8. Term and Termination of the Agreement. Amendment of the Agreement

8.1. This Agreement is concluded for an indefinite period and comes into force from the moment of acceptance of the public offer by the User (registration on the Site).

8.2. If this Agreement is concluded through the Site in electronic form (public offer), the date indicated in the preamble of the Agreement is the date of publication of the Agreement and is not the date of its conclusion with a specific User.

8.3. The Copyright Holder has the right to unilaterally amend the terms of this Agreement and its appendices by publishing them on the Site.

In case of amendments and additions to this Agreement and its appendices, these amendments and additions shall enter into force from the moment the new version of the Agreement / appendix to the Agreement is posted on the Internet site, unless another term is specified in the new version of the Agreement. Continued use of the Platform Features after amendments or additions to this Agreement and its appendices means that the User agrees to such changes or revisions.

If the User does not agree with the new version of the Agreement / appendix to the Agreement or wishes to stop using the Platform for any other reason, they have the right to stop using the Platform. In this case, the User undertakes to immediately delete the information entered by them in the Personal Account. Termination of the Platform use does not release the User from the obligation to compensate the Copyright Holder for the losses caused by their actions.

8.4. Either Party has the right to unilaterally terminate this Agreement out of court by notifying the other Party by sending a notification 30 (thirty) days in advance through the Personal Account or by e-mail.

8.5. In the event of a violation by the User of the Platform use terms, as well as in the event of the User carrying out suspicious actions containing signs of a possible violation of current legislation and/or the terms of this Agreement, the Copyright Holder has the right, at its own discretion, in an extrajudicial procedure and without observing the deadlines set out in paragraph 8.4 of the Agreement:

  • immediately suspend the User's access to the Platform Features;

  • refuse to perform the Agreement and terminate the Agreement early.

9. Electronic Document Management

9.1. The Parties have agreed that messages sent by them through the Personal Account (via the "Technical Support" section), as well as this Agreement and its appendices, requests, notifications, invoices, and other electronic documents transmitted by the Parties through the Personal Account or to the Parties' email addresses, generated in electronic form (in the form of an electronic document or a scanned copy of a paper document) and transmitted to the User through the Personal Account, are equivalent in legal force to paper documents signed by the Parties, unless this is prohibited by law.

10. Miscellaneous

10.1. Current information on the Copyright Holder's operating mode, the licenses / permits the Copyright Holder has is located on the Site and is part of this Agreement.

10.2. By using the Platform, the User agrees to receive advertising and informational messages from the Copyright Holder through the Personal Account, by email and by phone, specified during registration and in the User profile. The User has the right to refuse to receive advertising messages by sending a corresponding request through Personal Account.

10.3. The Copyright Holder has the right to use the commercial designation and/or trademark (service mark, trade name) of the User, as well as a link leading to the User’s site, on the Site in all sections containing information about the Copyright Holder’s clients. The User's consent to use their commercial designation and/or trademark on the Site is presumed, which means the User's consent to use their commercial designation and/or trademark on the Site simultaneously with the acceptance of this Agreement. If the User does not agree with the use of their commercial designation and/or trademark on the Site, the User has the right to send the Copyright Holder a notification of their disagreement, after which the information about the User's commercial designation and/or trademark will be immediately deleted by the Copyright Holder.

10.4. By accepting the terms of this Agreement, the User confirms that they have legitimate grounds for concluding this Agreement and working with the Platform, as well as for processing information belonging to them using the Platform.

10.5. All requests, questions and applications to the Copyright Holder related to the use/inability to use the Platform, with the exception of claims under the Agreement and other documents expressly stipulated in the Agreement, must be sent using the "Technical Support" section posted in the Personal Account or to the Copyright Holder's email address. The period for consideration of these requests and the response to them is 15 (fifteen) calendar days from the date of their receipt by the Copyright Holder.

10.6. This Agreement is an agreement between the User and the Copyright Holder regarding the use of the Platform and supersedes all previous agreements between the User and the Copyright Holder.

10.7. If for one reason or another, one or more provisions of this Agreement are declared invalid or unenforceable, this does not affect the validity and applicability of the remaining provisions of the Agreement.

10.8. This Agreement has been drawn up in Russian, Ukrainian and English.

10.9. The Copyright Holder, as an authorized person, undertakes to comply with the principles and rules for processing personal data stipulated by the legislation of the country in which the Right of Access is granted, to maintain the confidentiality of personal data, and to take the necessary measures to ensure the fulfillment of obligations.

10.9.1. The User transfers the following personal data of Addressees to the Copyright Holder as an authorized person by manually uploading information through the Personal Account:

  • Telephone numbers;

  • Other information that may be contained in audio and text messages sent by the User to Addressees via the Site.

10.9.2. The purpose of processing the personal data of Addressees by the Copyright Holder is the performance of the Agreement with the User (processing of the User's calls and messages through the Platform).

10.9.3. List of actions performed by the Copyright Holder with the personal data of Addressees:

  • Recording;

  • Accumulation;

  • Storage;

  • Use;

  • Blocking;

  • Deletion.

10.9.4. The User guarantees to the Copyright Holder that they have all necessary consents (including consent from personal data subjects to transfer Personal Data to the Copyright Holder) from personal data subjects to the processing of personal data.

10.9.5. When processing personal data on behalf of the User, the Copyright Holder undertakes to:

  • Maintain the confidentiality of personal data;

  • Comply with the requirements stipulated by the personal data legislation of the country in which the Right of Access is granted;

  • Ensure the security of personal data during its processing.

10.9.6. If required by law, the User is obliged to obtain the consent of the Addressee to the processing of personal data, as well as consent to the transfer of personal data to a third party. As an authorized person, the Copyright Holder is not obliged to obtain the consent of the Addressees.

10.9.7. The User is solely responsible to the personal data subjects (Subscribers) for the actions of the authorized person (Copyright Holder) entrusted with data processing.

10.9.8. If the Copyright Holder receives a request from the Addressee to block their telephone number and prohibit the processing of their personal data, the Copyright Holder will not provide services to the User in relation to this Addressee and will bear no liability for such refusal.

10.10. In all cases not regulated by this Agreement and its appendices, the Parties shall be guided by the current legislation of the country in which the Right of Access is granted.

11. Copyright Holder's Details

Telecoma Sole Proprietorship Limited Liability Company (Telecoma SPLLC)

Legal address: Bulgaria, Burgas Region, Burgas Municipality, Burgas City, 8000, Aleksandrovska Street, No. 16, Bldg. 14

UIC 205906695

Contractor's email: bg@telecoma.com