Privacy Policy

1. Data Controller

Ringo Market (Maxisoft Ltd)

Registration number: 486073

Kalymnou 1, "Q Merito", Floor 4, Agios Nikolaos, Kamares, 6037, Larnaca, Cyprus

Data protection contact: hello@ringomarket.com

2. What Personal Data We Collect

Callers (Independent Contractors)

• Name, email address, and phone number
• Identity verification data (via Veriff)
• Call history and call recordings
• Earnings data and commission calculations
• Training completion records
• Bank account / IBAN for payouts

Advertisers (Companies)

• Company name, registration number, and contact details
• Contact person's name, email, and phone number
• Campaign data and call lists
• Billing information

Consumers / Leads

• Phone number and name (if provided)
• Call recordings
• Written confirmation data (confirmation status, timestamp)
• Do-not-call registry check status

3. How We Use Personal Data

We process personal data for the following purposes:

• Service Delivery: Managing user accounts, matching Callers with campaigns, enabling calling functionality, and managing campaigns.
• Commission Calculation & Payments: Calculating Caller earnings, processing payouts, and invoicing Advertisers.
• Legal Compliance: Sending written confirmations as required by applicable telemarketing law, checking do-not-call registries, retaining call recordings, and fulfilling accounting obligations.
• Quality Assurance: Reviewing call recordings to ensure service quality and compliance.
• Communications: Sending service-related notifications, confirmations, and updates to users.

4. Legal Basis for Processing (GDPR)

We process personal data on the following legal bases:

• Performance of a contract (GDPR Art. 6(1)(b)) — service delivery and commission processing.
• Legal obligation (GDPR Art. 6(1)(c)) — written confirmation, do-not-call checks, and accounting obligations.
• Legitimate interest (GDPR Art. 6(1)(f)) — quality assurance, fraud prevention, and platform improvement.

5. Data Sharing with Third Parties

We do not sell or disclose personal data to third parties for marketing purposes. We use the following service providers as data processors:

• Twilio — call routing, call recordings, and SMS messaging
• Neon — database hosting (PostgreSQL)
• Resend — transactional email delivery
• Veriff — identity verification for Callers
• Vercel — application hosting

Data Processing Agreements (DPAs) are in place with all processors in accordance with the GDPR. Data may be disclosed to authorities where required by law.

6. Data Retention

7. Call Recordings

All calls made through the Ringo Market platform are recorded for quality assurance and dispute resolution. Consumers are informed of the recording at the start of each call. Recordings are stored securely for 12 months, after which they are automatically deleted. Advertisers have the right to listen to recordings related to their campaigns for quality assurance purposes.

8. International Data Transfers

Personal data is primarily stored within the European Union:

• Database: Neon PostgreSQL, Frankfurt, Germany (EU)
• Telephony: Twilio, EU-region servers
• Application: Vercel, EU-region edge servers

Data is not transferred outside the EU/EEA as a general rule. Where such a transfer is necessary, we ensure an adequate level of protection in accordance with the GDPR (e.g., Standard Contractual Clauses).

9. Cookies

Ringo Market uses only cookies that are strictly necessary for the operation of the service. A session cookie is used to maintain your login state and is not used for tracking or marketing purposes. We do not use third-party tracking or analytics cookies.

10. Your Rights

Under the EU General Data Protection Regulation (GDPR), you have the following rights:

• Right of Access: You may request information about what personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate personal data.
• Right to Erasure: You may request deletion of your personal data when there is no longer a legal basis for processing.
• Right to Data Portability: You may request your data in a machine-readable format and transfer it to another controller.
• Right to Object: You may object to the processing of your personal data in certain circumstances.
• Right to Restriction: You may request restriction of processing in certain circumstances.

To exercise your rights, send a request to hello@ringomarket.com. We will respond within 30 days.

11. Complaints to Supervisory Authority

If you believe that the processing of your personal data is not lawful, you have the right to lodge a complaint with the relevant data protection supervisory authority. For Ringo Market, the lead supervisory authority is:

Commissioner for Personal Data Protection

1 Iasonos Street, 1082 Nicosia, Cyprus

Website: dataprotection.gov.cy

12. Data Security

We protect personal data with appropriate technical and organisational measures. All data transmission is encrypted (TLS/HTTPS). The database is protected with access controls and backed up regularly. Access to personal data is restricted to personnel who require it for their duties. Data breaches are reported to the supervisory authority within 72 hours in accordance with the GDPR.

13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy. Material changes will be communicated through the Platform or via email. We recommend checking this page periodically. This policy was last updated on 1 January 2026.