Funambol Privacy Statement

LAST UPDATED: June 04, 2021

This Privacy Statement is prepared and entered into in the English language only, whose language shall be controlling in all respects. Any translation of this Privacy Statement into any other language are for reference only and shall have no legal or other effect.

This Privacy Statement describes the data protection policies of Funambol, Inc., located at 1065 E. Hillsdale Blvd. #250, Foster City, CA 94404 USA, ("Funambol" or "we") for data collected through (1) and (collectively, the "Site", including any successor web sites), and (2) any services (including without limitation to the Funambol portal service) provided through the Site or hosted for Funambol customers on Amazon Web Services data centers ("Service" or "Services"). The words “you” or “your” refer to a user of the Funambol services. “Funambol customers” refers to third party providers of the Funambol solutions.

Our Services may allow you access to your Contacts data, Rich Media data, text, software, legally acquired music, sound, photographs, graphics, video, messages, call log, applications list or other materials ("Content") from third party sites and applications. Any Content that you provide on or to a third-party site or applications is provided directly to the owner of the site or application and is subject to that party's data protection policy. Our Privacy Statement does not apply to such third party sites or services and we are not responsible for the content, data protection or security practices and policies of those sites or applications. To protect your information we recommend that you carefully review the Privacy policies of other sites and applications that you access. Any capitalized terms not defined in this Privacy Statement shall have the meanings given in Funambol Terms of Use.

With this Statement, we hereby make you aware that your personal data (e.g. Contacts Data and Rich Media Data) provided through the Site or hosted for Funambol customers is stored in EU located Amazon Web Services data centers.

We might transfer outside European Union information useful to provide end users support, to handle payment related to customer purchases and for analytics purpose. This information might include minimized and pseudonymized personal information, properly protected by adequate technical measures and agreed under approved Standard Contractual Clauses.

Funambol complies with the European Union (EU)-US Privacy Shield Framework and Swiss-US Privacy Shield Framework regarding the collection, use, and retention of personal information from EU member countries and Switzerland to the United States. Funambol has certified that it adheres to Privacy Shield Principles and it is subject to investigatory and enforcement powers of the Federal Trade Commission. To learn more about the Privacy Shield program and to view our certification, please visit In compliance with GDPR requirements and with Privacy Shield Principles, Funambol commits to answer to questions or doubts and to resolve complaints about our collection or use of your Personal Data. Individuals with inquiries or complaints regarding our data protection policy should first contact Funambol by emailing

Funambol Inc. designated Funambol srl its Representative in the EU. Funambol srl acts on behalf of Funambol Inc with regard to all obligations under the relevant EU Data Protection Regulation and acts as a point of contact for requests by data subjects and in particular for the assurance of user rights. Funambol srl, located in Italy (Via F.lli Cuzio, 42 - 27100 Pavia (PV), VAT number 01982880187), can be reached by email at

Funambol adheres to an independent recourse for investigating unresolved complaints regarding Privacy Shield commitments as prescribed by JAMS at If you do not receive timely acknowledgment of your complaint from us or if we have not addressed your complaint to your satisfaction, please visit JAMS for more information or to file a complaint. If your complaint has not been resolved by JAMS, under certain conditions, it is possible to seek recourse through binding arbitration. To learn more about Privacy Shield and to view Funambol's certification, visit

By submitting any information or registering for any Funambol Services, you agree (1) to comply with the terms and conditions of this Privacy Statement, and (2) that Funambol may process (i.e., collect, use, etc.) your Personal Data as described in this Privacy Statement and the Funambol Terms of Use.


1.1 Generally

As used in this Privacy Statement, Contacts Data are your personal information manager files (which include your electronic "rolodex" and calendar). Rich Media data are your picture(s), video(s), file(s), music, SMSs, call log and applications list. Funambol allows you to submit Personal Data through the Site and the Services. The Funambol Service enables you to upload your Contacts Data and Rich Media Data to the Service and to synchronize your Contacts Data and Rich Media Data to and from other data stores such as a cellphone, PC, email server, social network site, etc. "Personal Data" is information about you that is personally identifiable to you as well as other non-public information to the extent that it is associated with the foregoing.

1.2 Registration

When you register with Funambol, you submit the following types of Personal Data to Funambol (your "Account Data"): your mobile phone number, your email address, and your chosen password. This information will be kept in our archives for all the duration of the Services provision.

Please note that according to the United State Department of State regulations, resident or citizens of countries that are subject to the US State Department embargo are not eligible to use the service.

Funambol reserves the right to delete without notification any account/s that are discovered in violation of this stipulation.

1.3 Funambol Service, Contacts Data and Rich Media Data

When you use the Funambol Service, you upload or synchronize your Contacts Data and/or Rich Media Data to Funambol's (or our service provider's) servers. We do not use your Contacts Data and/or your Rich Media Data for any purpose other than to provide you the Funambol Service. The legal basis for processing is the performance of the Services as described in the Terms Of Use. This information will be kept in our archives for all the duration of the Services provision. If at any time you no longer wish to use the service for any reason, including you do not want Funambol or third parties to use your Personal Data, you can terminate your account per Section 5 below.

1.4 Use of Account Data

We may use your Account Data for:

  • license reporting and assessment of service levels; to better understand how our Site and Services are used; to gauge traffic patterns and determine what types of content and services are most popular with users (as per the legitimate interest of the Data Controller)

  • to contact you with information about Funambol products, services, news and events (as per the legitimate interest of the Data Controller. However, all users are always presented with the option to not receive these types of communications)

1.5 Cookies and Log Files

We use information that we collect through cookies and log files to understand our users ' preferences and to improve the Site and the Services.
A cookie is a piece of data stored on the user's computer tied to information about the user. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user's hard drive for an extended period of time. We use cookies to save the user's session and to carry out other activities that are strictly necessary for the operation of the same. No consent is required for the usage of these cookies, as per they are intended only for technical purposes. Anyway, persistent cookies can be removed by following Internet browser help file directions. If you choose to disable cookies, some areas of the Site and the Services may not work properly.

In addition we use Google Analytics cookies with IP address anonymization to have an overall view of performance statistics, visitor habits and to improve the overall experience.

In our log files, for security and troubleshooting reasons (legitimate interest of the Data Controller), we collect information such as internet protocol ("IP") addresses, browser type, internet service provider ("ISP"), referring/exit pages, platform type, date/time stamp, and number of clicks. Log file information may be linked to your Personal Data and are kept in our archives for 1 year.

1.6 Feedback

If you send Funambol an email or mail (to provide feedback or to ask a question regarding the Site or Services), Funambol will collect any information contained in such communication. Funambol may retain those communications in order to process your inquiries, respond to your requests, and improve the Services. Funambol will treat the Personal Data in such communication in accordance with this Privacy Statement. Funambol will keep this information for the duration of the Services provision.

1.7 Anonymous Information

Funambol may use any non-personally identifiable information that it collects or stores (including your feedback, but excluding your Account Data and your Contacts Data and Rich Media Data) for any purpose it deems appropriate.

1.8 Children

Individuals under the age of 18 are not permitted to use the Services without the supervision of a parent or legal guardian; (iii) we do not knowingly collect or solicit Personal Data from children under the age of 18 or knowingly allow such persons to register for an online account or to post personal information through the Services; and (iv) should we learn that someone under the age of 18 has provided any Personal Data to the Services, we will remove that information as soon as possible.

1.9 Data subject's rights

We remind you (the user) that you always have the right to access, rectify and erase your personal data, that you can manage your personal data on your own with your account and according to Section 5 below. You have also the right to restrict the processing and data portability of your data, and you can always opt-out of any consent you gave (with no prejudice for previous processing) and you have the right to lodge a complaint to the EU supervisory authority In compliance with GDPR requirements and Privacy Shield Principles, you can raise inquiries, rights execution requests or complaints by emailing .


2.1 Special Offers and Updates

We may send new members a welcoming email or SMS to verify password and username. Established members will occasionally receive information on products, services, special deals, and a newsletter, under Funambol’s legitimate interest of informing its customers about relevant changes or opportunities applied to the Services. We always present the option to not receive these types of communications.

2.2 Service Announcements

We may send you service related announcements, including, for instance, when a Service is temporarily suspended for maintenance. Generally, users may not opt-out of these communications, though they can deactivate their account.

2.3 Tell-a-Friend

If you decide to send a "tell-a-friend" email to another person (when Funambol provides such a feature), we will collect that person's email address in order to send the email. We will also collect your name, email address, and any personal message you decide to include in the email, for the purpose of sending the email with our systems. Unless we note that we may send reminder messages to that person, we will not send additional emails to that person. In addition, we provide the option to opt-out of such messages as provided in section 2.1 above.


3.1 Limited Data Sharing with Third Parties

We may share your Personal Data with third parties in accordance with this Privacy Statement, only for the purpose of Services provision.

We may need to provide your Personal Data to third parties to deliver specific services to you (such as hosting services or support services). These third parties are designated as Data Processors and are required not to disclose your Personal Data and not to use your Personal Data other than to provide the services requested by Funambol. If a third party providing services on our behalf processes your Personal Data in a manner that violates GDPR or Privacy Shield Principles, the third party is liable for damages unless it is proven that Funambol is responsible for the event giving rise to the violation.

You have control over synchronization of your Contacts Data and/or Rich Media Data through your account. Our servers will synchronize your Contacts Data and/or Rich Media Data with other devices, and may synchronize such data with third party applications, as instructed by you through your account. As noted in the Funambol Terms of Use, it is your responsibility to maintain the secrecy of your password; if another person obtains your password, that person may access and misuse your Contacts and/or Rich Media Data.

Funambol may share some or all of your Personal Data with its affiliates, in which case we will require our affiliates to honor this Privacy Statement. If our company or our assets are acquired by another company, that company will possess the Personal Data collected by Funambol and it will assume the rights and obligations regarding your Personal Data as described in this Privacy Statement.

We may share aggregated or non-personally identifiable information with our business partners but such information is not linked to your Personal Data and is not included in your Contacts Data.

3.2 Legal Requirements

Funambol may disclose Personal Data, including, without limitation to, Contacts Data and Rich Media Data - if required by a subpoena or other judicial or administrative order, if required by law, or, at its sole discretion, if Funambol deems it necessary to prevent violation of the Terms of Use Agreement or the rights of Funambol or any third party.

3.3 Security

Funambol uses industry standard security measures to protect against the loss, misuse and alteration of the information under our control. Although we make good faith efforts to protect the storage and transmission of your Personal Data, we cannot guarantee complete security.

Please be aware that, whenever you voluntarily post information to message boards or any other public forums, such information can be accessed by anyone and, if such information includes your contact information, third parties may use it to send you unsolicited communications.


The Site may contain links to third party sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of other sites.


We realize that your Personal Data is subject to change. You may edit your Account Data at any time (provided that it remains accurate) and the Contacts Data and Rich Media Data that we store will change whenever you change it (either directly or via synchronization with another data source). If you wish to have Funambol delete your Account Data, you may terminate your account at any time. If you wish to delete your Contacts Data and Rich Media Data, you may do so at any time. In the event you terminate the account, all your Personal Data will be completely destroyed within 40 (forty) days and won't be recoverable in any way.


If we change the Privacy Statement, we will post the new Privacy Statement on the Site with a link from the Site's homepage, so that you are always aware of our data privacy practices. Any substantive changes to the Funambol Privacy Statement will be posted 30 days prior to taking effect (for any existing users).


If you have questions about anything related to this Privacy Statement please contact Funambol at