Privacy Policy

Last Updated: September 17, 2026

Give a Ring is a mobile application offering free in-app calling and chat between users, discounted international calling to standard phone numbers, and dedicated inbound phone numbers ("DID Numbers"), available through the Apple App Store and Google Play. The Service is operated by Aleksei Tuzhilkin, an individual doing business as a sole proprietor under the trade name GIVARING (FBN: GIVARING) ("Provider," "we," "us," or "our"). This Privacy Policy explains what information the Service collects, how it is used, and what choices you have. By downloading, registering for, or using the Give a Ring application, or by visiting givaring.com (the "Website"), you agree to the practices described below.

Your use of the Service is also subject to our Terms of Service, which incorporate this Privacy Policy by reference. Undefined capitalized terms used here have the meaning given to them in the Terms of Service.

1 Scope of This Policy

1.1. This Policy applies to Personal Information gathered through your use of the Give a Ring application and the Website. It does not apply to any third-party application, carrier network, payment processor, or website that the Provider does not own or operate, even where you reach it through a link inside the Service.

1.2. "Personal Information" means information that identifies or could reasonably be linked to you, such as your phone number, any email address you choose to provide, in-app messages and files you send, call metadata needed to connect your calls, and contact details you add to the application's address book.

1.3. This Policy explains our data practices only and does not itself create or modify any warranty, disclaimer, liability limitation, or dispute-resolution term. Those are governed exclusively by the Terms of Service. If this Policy and the Terms of Service conflict regarding a disclaimer, a limitation of liability, indemnification, or dispute resolution, the Terms of Service control; if they conflict regarding the collection, use, or disclosure of Personal Information, this Policy controls.

Note: The Service's emergency-calling (911) limitations and the related disclaimer are set out in the Terms of Service, Section 10, which governs that topic.

2 Age Restrictions and Children's Privacy

2.1. As set out in the Terms of Service, the Service is available only to individuals who are at least 18 years old. We do not knowingly collect Personal Information from anyone under 18, and if you are under 18 you are not eligible to register for or use the Service.

2.2. In the United States, the Children's Online Privacy Protection Act ("COPPA") requires parental consent before collecting information from children under 13. If we discover that a child under 13 has provided us Personal Information, we will delete it as quickly as reasonably possible. If you believe a child under 13 has provided information through the Service, please contact us at privacy@givaring.com.

3 Personal Information We Collect

3.1 Information You Give Us Directly

When you register for the Service, you provide the phone number you will use to sign in, which we verify using a one-time passcode ("OTP") we send to it by SMS, WhatsApp, or Telegram; the Service does not use an email-and-password login. We also collect a display name you choose, and any additional phone number you provide for DID Number activation. If you top up your prepaid balance, our payment processor collects the payment details needed to complete the transaction; the Provider does not store your full card number. You may choose not to provide certain information, but doing so may prevent you from using some features.

3.2 Content and Communications

To provide in-app chat, we process the messages, images, and files you send. To provide calling and DID Number functionality, we process call metadata (such as call time, duration, and the numbers involved) needed to connect and bill your calls. If you add contacts to the application's address book, we store that contact information to enable that feature for you.

3.3 Information Collected Automatically

Our servers automatically log certain technical information when you use the application or visit the Website, including your IP address, approximate location, device identifier, operating system, app version, and diagnostic or crash data. We also record aggregate usage statistics — such as how frequently features are used across all Users — in a form that does not identify you individually, so that we can maintain and improve the Service.

3.4 Cookies and Similar Technologies

The Website may use cookies or similar local-storage technologies to remember basic preferences and to understand, in aggregate, how visitors use the Website. The application itself does not rely on browser cookies. Where your browser supports the Global Privacy Control or a comparable opt-out signal, we will honor it for the Website to the extent required by applicable law.

3.5 Device Identifiers

Mobile devices carry identifiers such as IDFA, UDID, or advertising identifiers. We may read a device identifier solely to keep your account secure, prevent abuse of free calling and messaging features, and diagnose service problems — never to build an advertising profile of you or to enable third parties to target ads at you.

3.6 Sensitive Personal Information

The Service is not designed to request "sensitive personal information" as that term is defined under the California Privacy Rights Act (CPRA) and comparable state laws (for example, precise geolocation beyond approximate location, government identification numbers, or financial account credentials), except as described in Section 3.7 below. If our payment processor's checkout flow separately collects such information, it does so on the Provider's behalf under its own privacy terms, and the Provider does not itself view, use, or store your full financial account information. We do not use or disclose sensitive personal information for any purpose other than providing the Service.

3.7 Identity Verification (Government ID and Selfie)

In some cases — for example, to comply with carrier or regulatory requirements intended to prevent fraud and unlawful robocalling before issuing, renewing, or continuing to provide a DID Number — we may ask you to complete an identity-verification step within the application, which involves taking a photo of a government-issued identification document and a selfie. This is sensitive personal information under the CPRA. We use it only to verify your identity for this purpose; we do not use it to build a profile of you, for advertising, or for any other purpose, and we share it only with our identity-verification service provider(s) acting on our behalf, under contracts limiting their use of it to that purpose. We retain these images only for as long as necessary to complete the verification and to satisfy applicable telecommunications recordkeeping requirements, after which we delete or securely dispose of them, unless a longer period is required by law.

Providing this information is your choice, but it is required if you want to obtain or keep a DID Number. If you decline a verification request, the Provider may refuse to issue you a DID Number, or may reclaim a DID Number already assigned to you, as described in the Terms of Service.

4 Legal Basis for Processing (EEA, UK, and Switzerland Users)

4.1. If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your Personal Information on one of the following bases: your consent; because processing is necessary to perform our contract with you (providing the Service you signed up for); because processing serves a legitimate interest of ours that is not overridden by your rights; or because we have a legal obligation to do so. If you have questions about the legal basis that applies to a particular use of your data, contact us at privacy@givaring.com.

5 How We Use Your Personal Information

5.1. We use the Personal Information described above to: create and maintain your account; verify your phone number using one-time passcodes sent by SMS, WhatsApp, or Telegram; connect and route your calls and messages; issue and maintain DID Numbers; verify your identity and prevent fraud where required before issuing, renewing, or continuing to provide a DID Number; process top-ups and bill for paid usage; respond to your support requests; secure your account against unauthorized access and abuse; comply with applicable law; and understand, in aggregate, how the Service is used so that we can maintain and improve it.

5.2. We will only send you marketing communications about Give a Ring in accordance with the preferences you have expressed to us, and you may opt out at any time by emailing privacy@givaring.com.

6 Data Security

6.1. As described in the Terms of Service, your account is authenticated through a one-time passcode sent to your registered phone number by SMS, WhatsApp, or Telegram, rather than a traditional password. You are responsible for keeping control of that phone number and of the SMS, WhatsApp, or Telegram account used to receive passcodes, for keeping any passcode confidential, and for signing out of shared or public devices after use.

6.2. The Provider applies reasonable technical and organizational safeguards designed to protect your Personal Information from unauthorized access, alteration, or loss. No method of transmission or storage is completely secure, however, and the Provider cannot and does not guarantee absolute security. You use the Service and provide Personal Information at your own risk.

6.3. If the Provider becomes aware of a breach of security affecting unencrypted Personal Information that requires notification under California Civil Code § 1798.82 or another applicable data breach notification law, the Provider will notify affected Users in the time and manner required by that law, using the email address or other contact information associated with the affected account.

7 International Data Transfers

7.1. Because the Service operates over the internet and relies on infrastructure located in the United States, using the Service necessarily involves transmitting your Personal Information internationally, including to the United States. By using the Service, you acknowledge this transfer. Where required by applicable law, the Provider takes reasonable steps intended to ensure that Personal Information transferred internationally continues to receive a level of protection consistent with this Policy.

8 Your Choices and Rights

8.1. Through your in-app account settings, you can view your registered phone number, and correct or delete certain information you have provided, including your display name and address-book contacts.

8.2. You may request deletion of your account and associated Personal Information at any time by emailing privacy@givaring.com. Some information may remain in our records for a limited period after deletion where retention is necessary for billing records, fraud prevention, or compliance with legal obligations, as described in Section 10.

8.3. If you have general questions about what information we hold about you, contact us using the details in Section 13.

9 Regional Privacy Notices

9.1. California — Notice at Collection and Your CCPA/CPRA Rights. This section is provided for California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA").

9.1.1. Categories collected, sources, and purposes. In the preceding 12 months, we have collected the categories of Personal Information described in Section 3 of this Policy (identifiers such as your phone number and, if you provide one, an email address; internet or electronic network activity such as IP address and device identifiers; audio, electronic, and visual information such as call metadata and chat content; geolocation data limited to approximate location; and, only where you complete identity verification for a DID Number, government identification and selfie images as described in Section 3.7). We collect this information directly from you, automatically from your device as you use the Service, and, for payment details, from our payment processor. We use it for the business and commercial purposes described in Section 5: providing and securing the Service, billing, customer support, identity verification and fraud prevention, and legal compliance.

9.1.2. Disclosures to service providers. We disclose the categories of Personal Information above to the categories of service providers described in Section 3 — cloud hosting and infrastructure providers, telecommunications carriers and routing partners needed to connect your calls and DID Numbers, identity-verification providers where verification is required, payment processors, and analytics or crash-diagnostic providers — solely so they can perform services on our behalf, under contracts that restrict their use of your Personal Information to those services.

9.1.3. No sale or sharing. As stated in Section 5, the Provider does not sell Personal Information for money, and does not "share" Personal Information for cross-context behavioral advertising, as those terms are defined by the CCPA. Because we do not sell or share Personal Information, no "Do Not Sell or Share My Personal Information" opt-out is required.

9.1.4. Sensitive personal information. We use the sensitive personal information described in Section 3.7 (government identification and selfie images) only to verify your identity, prevent fraud, and comply with telecommunications recordkeeping requirements — purposes for which the CCPA does not require us to offer a "Limit the Use of My Sensitive Personal Information" link, and we do not offer one because we do not use sensitive personal information beyond those purposes.

9.1.5. Your rights. Subject to certain exceptions, you have the right to: know the categories and specific pieces of Personal Information we hold about you; request deletion of your Personal Information; request correction of inaccurate Personal Information; and not be discriminated against for exercising any of these rights, including through denial of service, a different price, or a different level of service. You, or an authorized agent acting on your behalf, may submit a request by emailing privacy@givaring.com. To protect your information, we will take reasonable steps to verify your identity before fulfilling a request, which may include confirming details tied to your account. If we deny a request, you may ask us to reconsider by replying to our response.

9.1.6. Shine the Light. California Civil Code § 1798.83 permits California residents to request certain information about disclosures of Personal Information to third parties for their own direct marketing purposes. The Provider does not disclose Personal Information to third parties for their own direct marketing purposes.

9.2. Colorado and other U.S. states. Residents of states with comparable consumer privacy laws may have similar rights to access, correct, or delete their Personal Information. Requests can be submitted using the same contact details.

9.3. Canada. If you are located in Canada, you have the right to be informed about, and to request access to, the Personal Information we hold about you, subject to certain exceptions, and to have inaccurate information corrected. Requests can be directed to Aleksei Tuzhilkin at privacy@givaring.com.

10 How Long We Keep Your Information

10.1. We retain Personal Information for as long as reasonably necessary to provide the Service to you, maintain accurate billing records, resolve disputes, and comply with legal or regulatory retention requirements. Retention periods vary depending on the type of information and the purpose for which it was collected.

11 Disclaimer of Warranties; Limitation of Liability

11.1. Your use of the Service, and any claim relating to how your Personal Information is collected, used, stored, or disclosed, is subject to the disclaimer of warranties, limitation of liability, and indemnification provisions of the Terms of Service (currently Sections 14 and 15), which are incorporated into this Policy by reference. Those provisions — including the applicable liability cap and the carve-outs for liability that cannot be limited by law, such as liability for death or personal injury caused by the Provider's negligence, or for fraud — apply equally to claims arising under this Policy.

11.2. This Policy does not create any separate or additional liability cap, warranty, or remedy beyond what the Terms of Service provide.

12 Changes to This Privacy Policy

12.1. We may update this Privacy Policy from time to time to reflect changes in the Service or applicable law. The revised version will be posted on this page with an updated "Last Updated" date, and material changes will be flagged through an in-app notice. Your continued use of the Service after a change takes effect constitutes acceptance of the revised Policy.

13 Contact Information

The Service and this Privacy Policy are administered directly by Aleksei Tuzhilkin, d/b/a Give a Ring (FBN: GIVARING), who is personally responsible for the Personal Information described in this Policy. Questions, requests, or concerns about your privacy can be sent to:

We will make reasonable, good-faith efforts to resolve your concerns.