Privacy Policy

This policy covers two separate Android applications published by KiwiCanopy. They differ in exactly one respect that matters for your privacy, and this document does not blur that difference.

KiwiCall, the paid edition:

• Package name: com.kiwicanopy.kiwicall
• Price: paid, one-off purchase
• Advertising: none
• Internet permission: absent from the app
• The section that applies to you: section 4

KiwiCall Lite, the free edition:

• Package name: com.kiwicanopy.kiwicall.lite
• Price: free
• Advertising: yes, Google AdMob
• Internet permission: declared, required by the advertising SDK
• The section that applies to you: section 5

Which edition you have is written on the app itself: the paid edition is named KiwiCall and the free one KiwiCall Lite, on your home screen and in Android under Settings → Apps. The package name is shown on the Google Play listing.

Responsible for data processing within the meaning of Art. 4(7) GDPR:

Maikel Hajiabadi — KiwiCanopy

Moselstraße 43

60329 Frankfurt am Main

Germany

Email: hello.kiwicanopy@gmail.com

Website: https://kiwicall.kiwicanopy.com

A data protection officer has not been appointed, as the conditions of Art. 37 GDPR and § 38 BDSG are not met.

We are established in Germany, so the GDPR and the TDDDG govern our processing for every user of these apps, wherever you are. That is why KiwiCall Lite asks you for consent to advertising, and why the safeguards described below apply to you wherever you are.

Both editions are dialers. To work, they handle:

• telephone numbers you enter, dial or schedule;
• your call history within the app, including attempt counts, durations and outcomes;
• your call schedules, including recurrence rules and archived entries;
• contact names and numbers, read from your device's contact store when you use the contact picker or when an incoming number is matched to a name;
• entries from Android's own call log, read so that the history screen also shows calls made or received outside the app, and — for missed calls only — marked as read once you open the call history;
• SIM and subscription information, used to route a call over the SIM you chose.

All of this is processed exclusively on your device, inside the app's private SQLite database and its protected app sandbox. None of it is transmitted to us, and we have no access to it at any time — not in either edition, not with advertising enabled, not under any circumstances. We cannot read your call history because it never reaches us.

You can erase the call history the app itself stores at any time: open the Call History screen and use “Clear History”. Entries that come from Android's own call log are not the app's to delete and remain where they are; you manage those in Android. The app changes exactly one thing about them: it marks missed entries as read, as described under Android permissions below. The app never deletes anything. Uninstalling the app removes its database with it.

Neither edition puts any of this into Android's cloud backup. The app's data extraction rules exclude everything from cloud backup, so no copy of your database or of your settings is written to a backup server. Android's direct device-to-device transfer does carry the app's database and your settings when you move to a new phone — that transfer runs from the one device to the other and not through a server.

If you move from KiwiCall Lite to the paid edition, the paid app can read KiwiCall Lite's schedules and in-app call history once — when you accept the offer it shows you. That copy is made on the device, between the two apps, and only when both carry our signing key. Nothing is transmitted.

This section applies to com.kiwicanopy.kiwicall.

The paid edition of KiwiCall does not declare the Android permission android.permission.INTERNET. Without that permission the Android operating system refuses the app any network connection at all. The consequence is not a promise we ask you to trust — it is a property of the app that you can check for yourself:

• The app is technically incapable of transmitting any data to any server, ours or anyone else's.
• It contains no advertising SDK, no analytics SDK, no crash reporting and no tracking technology of any kind — no Firebase, no Google Analytics, no Sentry, no AdMob.
• No advertising identifier is read, used or transmitted. The app does not declare the com.google.android.gms.permission.AD_ID permission.
• There is no user account, no registration and no cloud synchronisation.

You can verify the absence of the internet permission yourself in the Google Play listing under App permissions → See more, or with any APK analysis tool. We check it on every commit to the app's source code: an automated gate builds the merged manifest of both editions and rejects the commit if the paid edition declares the permission — or if KiwiCall Lite has lost it.

Accordingly, no personal data is collected, transmitted or shared by us through the paid edition of KiwiCall. One thing does happen on the device, and only at your request: if you upgrade from KiwiCall Lite, the paid edition can read its schedules and call history once, as section 3 describes — that copy never leaves the phone. Sections 5.1 to 5.7 do not apply to it.

This section applies to com.kiwicanopy.kiwicall.lite.

KiwiCall Lite is financed by advertising and therefore declares android.permission.INTERNET. Everything stated in section 3 remains true: your call history, your contacts, your schedules and the numbers you dial stay on your device and are never transmitted, not to us and not to any advertising partner. Sections 5.1 to 5.7 concern advertising data only.

KiwiCall Lite integrates the Google Mobile Ads SDK (AdMob).

Provider for users in the EEA, the United Kingdom and Switzerland: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google's privacy policy: https://policies.google.com/privacy

How Google uses information collected from apps that use its services: https://policies.google.com/technologies/partner-sites

Where you have consented to them, additional advertising partners (vendors under the IAB Transparency and Consent Framework) may also receive data. The complete and current list of those partners is shown to you in the consent dialog and can be reopened at any time under Settings → Advertising and privacy options.

• Advertising identifier (Android Advertising ID) — a resettable identifier assigned by your device, used to deliver, cap and measure advertising, where you have consented to it (section 5.3).
• IP address and the approximate location derived from it — at the level of a region or a city. KiwiCall Lite requests no location permission and does not access GPS or any precise location.
• Device and app information — device model, operating system version, app version, the app's identifier, language and region settings.
• Advertising interaction data — which advertisements were displayed, for how long, and whether they were tapped.

Never processed for advertising, in any form: your telephone numbers, your contacts, your call history, your call schedules, the content of any call, or any message text.

Advertising has to clear two separate requirements, and they are not the same one. Reading anything from your device or storing anything on it needs your consent under § 25(1) TDDDG. Processing the data that results needs a legal basis under Art. 6 GDPR. The first entry below is the first requirement; every entry that depends on your advertising identifier depends on it.

• Storing information on your device and reading it (advertising identifier, ad SDK storage) — your consent, § 25(1) TDDDG. Nothing is read from your device or written to it for advertising without that consent.
• Delivering advertisements, frequency capping and measuring advertising performance, where you have consented — your consent, Art. 6(1)(a) GDPR.
• Delivering advertisements and measuring them where you have declined consent, together with selecting basic advertising, selecting content using limited data, audience statistics, and the development and improvement of the advertising partners' own services — the legitimate interest of the controller in financing the free edition through advertising, and of Google and its advertising partners in operating the advertising system, Art. 6(1)(f) GDPR. On this basis no advertising identifier is read, nothing is stored on or read from your device, and no profile is built about you; what is transmitted is set out in section 5.2. You can object to each of these purposes separately under “Manage options” in the consent form, and to all of them at once by choosing the paid edition (section 5.7), Art. 21 GDPR.
• Personalised advertising, where you have consented to it — your consent, Art. 6(1)(a) GDPR.
• Detecting invalid traffic and advertising fraud, and keeping the advertising system secure — the legitimate interests of the controller and of the advertising partner in the integrity of the advertising system, Art. 6(1)(f) GDPR.

Where advertising partners process this data for their own purposes, they act as independent controllers for that processing. Their own privacy policies then apply in addition to this one, and you can reach them through the consent dialog.

Before the first advertisement is requested, KiwiCall Lite presents you with a consent dialog through a Google-certified consent management platform (Google's User Messaging Platform) under the IAB Transparency and Consent Framework. Loading the consent form itself transmits your IP address, the app's identifier and basic device information; that is our legitimate interest in obtaining a valid consent choice (Art. 6(1)(f) GDPR). No advertising is requested and no advertising identifier is read before you have made a choice.

If you refuse consent, KiwiCall Lite remains fully usable. Every function of the app — dialling, automatic redial, voicemail guard, scheduling, dual-SIM routing — works without restriction. You then see limited ads instead. For these, no advertising identifier is read, nothing is stored on or read from your device, and no profile is built about you. The purposes this limited advertising relies on, and their legal basis, are the third entry in section 5.3. What is still transmitted is your IP address and the approximate region derived from it, basic device and app information, and which ads were shown and whether you tapped them (section 5.2).

You may withdraw your consent at any time with effect for the future, and doing so is as simple as giving it (Art. 7(3) GDPR): open Settings → Advertising and privacy options in the app. You can additionally reset or delete your advertising identifier in Android under Settings → Privacy → Ads.

Advertising data may be processed by Google LLC and other partners in the United States and in other countries outside the EEA. Such transfers are based on the European Commission's adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework where the recipient is certified under that framework, and otherwise on Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. Despite these safeguards, a level of data protection equivalent to that of the EU cannot be guaranteed in every case, in particular with regard to access by public authorities in the recipient country.

We store no advertising data ourselves: no data reaches a server operated by us at any point, and we operate no such server. Retention by the advertising partners is governed by their own retention policies, set out in the privacy policies referred to in section 5.1. Your consent decision is stored locally on your device by the consent management platform until you change or withdraw it, or until you uninstall the app.

If you do not want advertising at all, the paid edition of KiwiCall is available on Google Play. It contains no advertising SDK and no internet permission, as described in section 4. Your choice in the consent dialog has no effect on the availability or the functionality of KiwiCall Lite.

• Default phone app role (ROLE_DIALER) — required so that Android permits the app to place, monitor and end calls through InCallService. Without this role automatic redial cannot work.
• CALL_PHONE — placing calls.
• READ_PHONE_STATE, READ_PHONE_NUMBERS — recognising the state of a call and identifying the available SIM cards for SIM routing.
• READ_CONTACTS — local, read-only matching of numbers to contact names. No contact data is transmitted, in either edition.
• READ_CALL_LOG — reading Android's own call log so that the history screen also shows calls made or received outside the app.
• WRITE_CALL_LOG — marking every unread missed call as read when you open the history screen — all of them, not only the ones the list happens to show — so Android stops announcing the same missed calls after every restart. Nothing else in the call log is changed and no entry is deleted.
• Foreground service (FOREGROUND_SERVICE, FOREGROUND_SERVICE_PHONE_CALL) — keeping an automatic redial session running, with a persistent notification so that a running session is always visible.
• Exact alarms (SCHEDULE_EXACT_ALARM, USE_EXACT_ALARM) — starting scheduled calls at the intended second.
• POST_NOTIFICATIONS — notifications for running redial sessions and scheduled calls.
• USE_FULL_SCREEN_INTENT — showing a scheduled call on the lock screen at the scheduled time, so that no call is placed unannounced.
• RECEIVE_BOOT_COMPLETED — restoring your schedules after the device restarts.
• MANAGE_OWN_CALLS, WAKE_LOCK, VIBRATE, MODIFY_AUDIO_SETTINGS — routing a call through Android's telephony stack, keeping a running redial session from being suspended, vibrating for call notifications, and switching between earpiece and speaker during a call.
• com.kiwicanopy.kiwicall.permission.READ_CARRY_OVER — a permission we define ourselves, not one of Android's. It lets the paid edition read KiwiCall Lite's schedules and call history on the same device, once, when you accept the upgrade offer — and only when both apps carry our signing key. The data moves between the two apps on the device and is never transmitted. Section 3 describes it.
• INTERNET — declared by KiwiCall Lite only, to serve advertising (section 5). The paid edition does not declare it (section 4).
• ACCESS_NETWORK_STATE — KiwiCall Lite only: the ad SDK checks whether the device is online before it requests an ad.
• com.google.android.gms.permission.AD_ID — KiwiCall Lite only: access to the resettable advertising ID. It is transmitted only with your consent (sections 5.2 and 5.4).
• ACCESS_ADSERVICES_AD_ID, ACCESS_ADSERVICES_ATTRIBUTION, ACCESS_ADSERVICES_TOPICS — KiwiCall Lite only: the Android Privacy Sandbox interfaces that the Google Mobile Ads SDK brings with it. They serve advertising and nothing else. The app does not initialise the advertising SDK until Google's consent platform reports that ads may be requested, which is after you have answered the consent form. The measurement the SDK would otherwise start for itself is held back until then too.
• DYNAMIC_RECEIVER_NOT_EXPORTED_PERMISSION — generated by the Android build tools and prefixed with each edition's own package name. It lets androidx register an internal broadcast receiver without exporting it, on Android 13 and newer. It is signature-level, names no data, reaches nothing outside the app's own process, and Play lists it under "Other".

Only two things above move any of your data. In KiwiCall Lite, the six advertising permissions send to Google — what they collect and where it goes is section 5. The carry-over reads KiwiCall Lite's schedules and call history into the paid edition, on the device and only when you accept the offer, and that copy never leaves the phone (section 3). No other permission here moves anything: what they read stays in the app on your device, as section 3 describes. Neither edition sends anything to us: we run no server. While KiwiCall is your default phone app, almost all of the sensitive ones above arrive with that role rather than through a prompt of their own — placing calls, phone state, contacts, notifications and the two call-log permissions. You can deny any of them in Android's permission settings, and KiwiCall stays your phone app if you do; giving the role to another app withdraws them together. The remaining entries are not prompted at all: the app cannot run without them, and Android grants them when it is installed. Before the app asks to become your default phone app, it explains on its start screen why it needs that role.

Under the GDPR you have the right to request access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20), and the right to object to processing based on legitimate interests (Art. 21). Where processing is based on consent, you may withdraw it at any time with effect for the future (Art. 7(3)); see section 5.4.

Please note that data held only on your device is beyond our reach: we cannot provide access to it, correct it or erase it, because we never receive it. You control it directly, in the app and through Android.

To exercise your rights, contact hello.kiwicanopy@gmail.com.

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The authority competent for us is:

Der Hessische Beauftragte für Datenschutz und Informationsfreiheit, Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany

You may also lodge a complaint with the supervisory authority of your habitual residence.

Neither edition is directed at children. We ask that persons under the age of 16 do not use KiwiCall Lite; where the law of a Member State sets a lower age, that age applies (Art. 8(1) GDPR). We have no way to verify a user's age and do not attempt to.

We update this policy when the app changes or the legal position requires it. The current version is always available at https://kiwicall.kiwicanopy.com. The date of the most recent change is given at the top of this page.