The Calling Bear Company - Privacy Notice
Introduction
Last modified 25th June 2026
This privacy notice describes how we will collect, use, share and otherwise process your personal data in connection with your use of:
- The Calling Bear mobile application software (App).
- Any of our services that are accessible through the App (Services).
The App provides a Service where a primary user can be prompted to respond to an alert issued by the App (an Alert) at a pre-selected time and frequency. Each failure to respond to an Alert will then be notified to selected contacts. The primary user controls who will be their respective contacts.
This App is not intended for those under 13 and we do not knowingly collect data relating to children.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
The Calling Bear B.V. of Tulpstraat 39, 4101 GJ, Culemborg, Gelderland, Netherlands is the controller and is responsible for your personal data (TCBBV, we, us or our in this notice).
If you have any questions about this privacy notice, please contact us using the details set out below.
Contact details
Our contact details are:
- Email address: contact@callingbear.com
- Postal address: Tulpstraat 39, 4101 GJ, Culemborg, Gelderland, Netherlands
You have the right to make a complaint at any time to us or to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review.
This version was last updated on 25th June 2026. It may change and, if it does, those changes will be posted on this page and notified to you when you next start the App or otherwise log onto your account. You may be required to read and acknowledge the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. Please visit the relevant section of your Profile to update your details.
Third party links and sites
Our App and Services may, from time to time, contain links to and from the websites of third parties. Please note that these websites and any services accessible through them are controlled by those third parties and are not covered by this privacy notice. You should review their own privacy notices to understand how they use your personal data before you submit any personal data to these websites or use these services.
The data we collect about you
We collect, use, store and transfer different kinds of personal data about you, as follows:
- Identity Data - first name, last name.
- Contact Data - your email address, mobile phone number and home address.
- Profile Data - other information contained in your Profile.
- Transaction Data - the records of your purchases of subscriptions; billing and (where relevant) delivery addresses, payment card details, history of your payments, purchases, deliveries, returns and refunds and the applicable terms and conditions of your purchases.
- Device Data - information (such as the type of device, operating system, IMEI number, mobile network information, mobile browser,IP address and time zone setting) of the devices which you use to access the App and the Services.
- Usage Data - information about how you use the App and the Services, such as logs and detail of your use of our Apps and Services, being the dates and times on which you download, access and update the App and our Services, any error or debugging information, and the resources that you access and the actions we and you take in relation to them.
- Cookies Data – please see our Cookie Notice for details.
- Feedback Data - any information which you provide to us as feedback about the App or our Services.
We do not intentionally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
We do not ask why the primary user needs to use our Services, and we do not ask why any Alerts do not receive a Response.
How is your personal data collected?
We collect your personal data in the following way:
- Registration. We collect your Identity Data and Contact Data when you register your account with us.
- Communications. When you communicate with us via email, telephone or one of our online forms we collect your Contact Data. If the communication relates to an error or problem you are having with the App or one of our Services, we will also collect Usage Data for diagnosis and improvement.
- Information you generate when using our App and Services. Each time you access and use our App and Services we may collectDevice, Cookies and Usage Data. We may collect Content Data where you upload it to the App (where such feature is available)or interact with the content available on the App. Please see our cookie notice for further details.
- Information we collect through monitoring the use of our App, Sites and Services. Each time you access and use our App and Services we collect information about that access and use, being Device, Cookies and Usage Data.
- Additional information we otherwise collect through our App, Sites and Services where we have your consent to do so. Where you provide your consent, we collect your Location Data on an ongoing basis while you have the App installed on your device.
- Information we receive from third parties. If you are the primary user, wemay receive personal data about you from your contacts. If you are a contact, we may receive information about you from the primary user. .
How we use your personal data
We will only use your personal data when we have a lawful basis to do so. Our lawful basis for each purpose for which we use your personal data is specified below. Most commonly we will use your personal data in the following circumstances:
- Consent. Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us (see Your legal rights below). We will rely on each primary user's consent to provide information about their non-responses to Alerts to their respective contacts.
- Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract. We rely on this ground in order to perform our contract with you as set out in our Terms of Use.
- Legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Recognised legitimate interests. We may sometimes use your personal data because we (or a third party) have a recognised legitimate interest (RLI). These are different to legitimate interests. RLIs apply where there are public interest reasons for processing (such as preventing or detecting crime, safeguarding individuals, responding to emergencies, supporting national or public security or defence, or sharing information with public bodies when they confirm it is necessary for their official functions). RLIs are legally recognised within data protection law. Where we rely on an RLI, we will ensure the use is strictly necessary and only use or share the minimum data required.
- Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.
Delivery and improvement of our App and purchases
| Purpose or activity | Type of personal data | Lawful basis for processing |
|---|---|---|
| To permit you to install the App and register you as a new App user | Identity Contact Financial Device | Performance of a contract Legitimate interests (delivering our App to you) |
| To take steps towards providing you with services at your request and deliver services to you, including managing payments and sending you service communications | Identity Contact Transaction Device | Performance of a contract |
| Enforce our terms and conditions, including to collect money owed to us | Identity | Legitimate interests (to recover debts due to us) |
Direct marketing
| Purpose or activity | Type of personal data | Lawful basis for processing |
|---|---|---|
| To send you direct marketing communications via email, text and/or push notification | Contact Device Direct Marketing | Consent Unless we can rely on the soft opt-in and you have not opted out, in which case we rely on Legitimate Interest (to publicise and grow our business) |
| To send you direct marketing communications by telephone or post | Contact Device Direct Marketing | Legitimate interests (to publicise and grow our business) Unless you have opted out, in which case we rely on Consent |
Troubleshooting, improvement and security
| Purpose or activity | Type of personal data | Lawful basis for processing |
|---|---|---|
| To administer, monitor and improve our business, Services and this App including troubleshooting, data analysis and system testing | Identity Contact Device | Legitimate interests (for running our business, provision of administration and IT services, network security, maintaining the security of our App and Services, providing a secure service to users and preventing fraudulent and other misuse of our App) |
| Applying security measures to our processing of your personal data, including processing in connection with the App | All personal data under this privacy notice | Legal obligation (applying appropriate technical and organisational measures under applicable law ) |
| Otherwise monitoring use of the App and deploying appropriate security measures | Contact Security Transaction | Legitimate interests (running our business, provision of administration and IT services, network security, maintaining the security of our App and services, providing a secure service to users and preventing fraudulent and other misuse of our App) |
Rights and obligations
| Purpose or activity | Type of personal data | Lawful basis for processing |
|---|---|---|
| To comply with our other legal obligations, including compliance with tax legislation, judicial, law enforcement and government authorities' requests | All personal data under this privacy notice | Legal obligation Recognised legitimate interests to ensure that we are legally compliant |
Cookies and personalisation
| Purpose or activity | Type of personal data | Lawful basis for processing |
|---|---|---|
| To deploy and process personal data collected via Cookies as set out in our Cookies Notice | Cookies | Legitimate interests (delivering and securing the App and our Services) |
Other communications
| Purpose or activity | Type of personal data | Lawful basis for processing |
|---|---|---|
| To notify you of changes to the App, Services, your purchases and our terms and conditions for ongoing contracts | Contact | For ongoing or prospective contracts, Performance of a contract Otherwise, Legitimate interests (in servicing our users and prospective users) |
| To notify you of updates to this privacy notice | Contact Transaction | Legal obligation (to inform you of our processing as required by applicable law ) |
| To respond to your requests to exercise your rights under this notice | As relevant to your request | Legal obligation (complying with data subject requests as required by applicable law ) |
| To otherwise respond to your enquiries, fulfil your requests and to contact you where necessary | As relevant to your enquiry or request | Legitimate interests (service our users and prospective users) |
Automated decision making and profiling
We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).
Disclosures of your personal data
We may share your personal data with the following third parties:
- Your Appstore Provider and mobile network operator to allow you to install the App.
- Service providers who provide IT and system administration services, hosting services for our App, delivery and logistics services, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.
- Our professional advisors including lawyers, auditors, insurers and consultants who provide legal, accounting, insurance and other services.
- Your service providers that you have appointed and we need to contact to fulfil your requests, such as your banking or payment card provider to process your transactions.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- HM Revenue and Customs, regulators, law enforcement, public authorities or other third parties [acting as controllers] based in the UK where necessary to exercise our rights or comply with a legal obligation.
International transfers
Data relating to UK and European users is stored in the EEA. We do not transfer your personal data outside the EEA.
Data security
All information you provide to us is stored on our secure servers located in the EEA. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer (SSL) technology or alternative encryption technology.
Where we have given you, or where you have chosen, a password that enables you to access certain parts of our App or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to protect your personal data from loss, unauthorised use or access.
We have put in place procedures to detect and respond to personal data breaches and notify you and any applicable regulator when we are legally required to do so.
Data retention
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
In some circumstances you can ask us to delete your data: see below for further information.
Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, anonymise your personal data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
You have the following rights under data protection laws in relation to your personal data.
- Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
- Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us.).
- Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it.
- Objection. Object to us processing your personal data where we are relying on legitimate interests as the lawful basis or where the processing is for direct marketing purposes.
- Restriction. Request that we restrict or suspend our processing of your personal data in certain circumstances.
- Data portability. Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format.
- Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data.
- Complain to us. If you are unhappy with how we process your personal data, please contact us first using the details below so that we have the chance to put it right.
- Complain to the UK data protection regulator. If you are unhappy with how we process your personal data, you also have the right to make a complaint to the ICO at any time.
You can exercise any of these rights at any time by contacting us at contact@callingbear.com.