Privacy Policy

1. General Terms

This section explains general terms and conditions related to your privacy, responsible entities and persons (a data controller) as well as disclaimers and notices regarding your acceptance of this Policy.

1.1. nomadlabs Limited and its subsidiaries and affiliates (“we”, “our” or “us”) believe that your privacy is important. We encourage our current and prospective users (“Users”, “you”) to read this Privacy Policy (“Policy”) carefully when using our mobile app (Ricochet), our website (, or transacting business with us. By using our app, website, or other services (“Services”), you are accepting the practices described in this Policy.

1.2. Please review this Policy carefully. If you do not agree with any of its terms, please do not use our Services and/or request the deletion of your personal information from our records.

1.3. This Privacy Policy describes the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.

1.4. The entity that is a data controller under this Policy is nomadlabs Limited:

nomadlabs Limited
14/F Manning House
38-48 Queen’s Road Central
Central, Hong Kong
Hong Kong SAR

1.5. A responsible person in nomadlabs Limited for matters relating to the collection, storage, and processing of personally identifiable information is the administrator. In case of any questions, suggestions, or requests regarding Personal Data, please contact the administrator by e-mail

1.6. Ricochet app is an application-based software that allows its users to make international phone calls via a local number.

2. Information we collect from you

This section specifies general categories of Personal Data that we may process and why we process it, including a legal basis for such processing.

2.1. We may collect personally identifiable information, such as:

  • First and Last Name;
  • Email address;

2.2. The information in paragraph 2.1 you actively provide to us during the waitlist registration and registration in Ricochet, we do not collect this personal information about you unless you voluntarily provide it to us.

2.3. We may collect personally identifiable information, such as:

  • Subscriber ID (unique number assigned to each user);
  • Phone numbers (both registered and destination numbers).

2.4. The information in paragraph 2.3 we collect automatically through our systems and systems of service providers, such as Twilio when placing a call.

2.5. Types of information specified in paragraph 2.1 and paragraph 2.3 may be used separately or collectively to identify you, therefore are considered a personal information about you (“Personal Data”). We collect Personal Data to determine the actual identity of a specific living person. We process Personal Data to ensure that our users receive a high-quality Service, to deliver customized Services for each client or region and to prevent abuse of our system. The legal basis for this processing is your consent by means, specified above.

2.6. We may process data about your use of our Services (“Usage Data”) with our systems. The Usage Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your Service use. The sources of the Usage Data are also Google Firebase, Amazon Web Services, Twilio and Bugsnag. You may find out more about how these services use information from sites or apps that use them by checking their privacy notices and privacy policies.. This Usage Data may be processed for the purposes of analyzing the use of our Services. The legal basis for this processing is our legitimate interests in monitoring and improving our Services.

3. External sources

This section specifies ways of providing your Personal Data to others.

3.1. We do not sell, rent, or lease Personal Data and our customer lists to third parties.

3.2. Call connection is handled by Twilio’s API. We receive your phone number and destination numbers you attempt to dial or call to, apart from information in paragraph 2.4. We process only anonymized metadata to understand how users in each country use our service. We do not share any Personal Data with Twilio. Please check Twilio privacy statement for more on their data practices.

3.3. Financial transactions relating to our Services (such as an in-app subscription) are handled by AppStore (Apple Inc.) and Google Play (Google Inc.) payment systems. We do not receive any identifiable information from them, except for transaction identification number which cannot be tracked back to you. However, we may share some Personal Data with Apple Inc. or Google Inc. only to the extent necessary for processing and refunding payments. Please check Apple guidelines and Google policy to find out more about their data practices.

3.4. We may disclose your Personal Data to our subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Policy. As of now, we do not have other entities.

3.5. We will disclose your Personal Data, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on us or Services; (b) protect and defend our rights or property; and, (c) act under exigent circumstances to protect the personal safety of our users, or the public.

4. Protecting your data

This section specifies means we use to secure your Personal Data.

4.1. We secure your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We use SSL Protocol for this purpose. When Personal Data is transmitted, it is protected through the use of such protocol which encrypts all the data transmitted.

4.2. We also ensure that your Personal Data is safe by integrating management solutions (such as training staff), physical solutions (such as using locks and access keys for our employees) and might use other ways to protect your Personal Data.

4.3. Although, we take reasonable measures to do so, please remember that no transmission of data over the internet or any wireless network can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant fully the security of any information that you transmit to us or from us, and you do so at your own risk. Therefore, while we strive to protect your Personal Data, you acknowledge that there are security and privacy limitations inherent to the internet which are beyond our control.

5. Children

This section specifies our approach to processing Personal Data of persons who have not reached a legal age.

5.1. Our Services are intended for general audiences; therefore, we do not knowingly collect or use any personally identifiable information from children under the age of eighteen. In case we learn that you are under 18 and registered with us, we will remove your Personal Data from our records.

5.2. If you are a parent of a child under the age of 18 and you believe some of your child’s personal information was collected by us, please send us an inquiry at and we will delete Personal Data from our systems.

6. E-mail communications from us

This section specifies how we send you e-mail communications and how you can opt-out.

6.1. From time to time, we may contact you via email for general communication about your use of Services. If you opted-in for marketing communications, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication.

6.2. If you would like to stop receiving marketing communications via email from us, you may opt-out of such communications by clicking on the “Unsubscribe” button at the bottom of an email sent from us.

7. Retaining, deleting your Personal Data and your rights

This section specifies for how long your Personal Data is retained, reasons for deletion and your rights regarding your Personal Data.

7.1. Your Personal Data will not be stored for longer than is necessary for purposes, described in this Policy.

7.2. Once you terminate your account in Ricochet, we will remove your Personal Data from our systems.

7.3. If we can specify the period for which your Personal Data will be retained, we will retain it for no longer than 2 years of your inactivity in Ricochet app or on the website or other Services, unless you have instructed us to delete your Personal Data from our systems. We retain your Personal Data for such period in case you want to return back to us and reopen your account as well as to monitor and improve our services.

7.4. If we cannot specify the period for which your Personal Data will be retained (for instance, if such Personal Data is necessary for compliance with certain legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person), we will do our best to retain your Personal Data for as short period of time as possible and will delete it from our systems immediately after such Personal Data is no longer required for the purpose, for which it was required.

7.5. You have the following principal rights under the relevant privacy laws: the right to access, the right to erasure, the right to rectification, the right to restrict and/or object to processing, the right to data portability, the right to complain to a supervisory authority, and the right to withdraw consent. Please review the relevant legislation and regulatory authorities’ instructions to understand what these rights are about.

7.6. Applicable privacy laws may allow you the right to access, delete, and/or request the correction of errors or omissions in your Personal Data that is in our custody or under our control.

7.7. We will respond to requests within the time allowed by all applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to Personal Data will be promptly sent to any organization to which it was disclosed, if any.

7.8. For security purposes, not all personal information is accessible and amendable by us. If access or corrections cannot be provided, we will notify you or the individual making the request on your behalf within 30 (thirty) days, in writing, of the reasons for the refusal.

8. Changes to this Policy

This section specifies procedures regarding changes to this document.

8.1. We reserve the right to change this Policy from time to time. We will notify you about significant changes in the way we treat Personal Data by email and updating any privacy information on this page.

8.2. Your continued use of Services after such modifications will constitute your acknowledgement of the modified Privacy Policy and agreement to abide and be bound by that Policy.

8.3. Please check this page from time to time to ensure that you agree to this Policy and any changes to it.

9. Questions

9.1. We take reasonable measures to store only accurate, up to date, complete, relevant and not misleading information about you. We accept any inquiries from you related to this Policy. We also welcome your questions or comments regarding this Policy.

9.2. Contact us:

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