1. Scope and responsibilities
This policy covers the ICS Communicator mobile application and the application services Apeiron
operates for it. Apeiron develops, operates and maintains the app and delivers incoming calls from
the ICS communications network to the app on your phone. Apeiron handles app registration,
authentication, incoming-call delivery, app call history, diagnostics and application support.
The underlying ICS communications service, its service account, facility services, billing and
any service-side call monitoring or recording are separate from your supplemental app account.
ICSolutions explains its handling of that service information in the
ICSolutions / TKC privacy policy.
Facility-specific rules may also apply to calls.
For the app information Apeiron handles, this application policy supplements the
general Apeiron privacy policy. The general policy's service-provider
sharing provisions include the app-related exchanges described here. ICS's separate policy does
not replace this explanation of Apeiron's application practices.
Account, registration and support information
We handle your account username, mobile telephone number, name and email address when provided,
authentication credentials and tokens, phone-verification results, and information you submit for
support or a privacy request. We use this information to create and verify app access, connect
your app account to your authorized calling number, sign you in, recover access, prevent abuse
and respond to you. Your password is used for authentication or confirmation; never send it in
a support email.
Device and incoming-call delivery information
We handle device and installation identifiers, app version, operating-system information, IP
addresses, calling-registration information and push-notification tokens. These allow us to
register your phone, deliver incoming-call notifications, establish calls and troubleshoot delivery.
Notification delivery uses Google Firebase Cloud Messaging and, on Apple devices, Apple's push services.
Call audio and call history
The app uses the microphone to transmit your voice during a call. App call history includes
calling numbers or identifiers, call dates and times, duration, and answered, missed, declined or
failed status. History is stored on your device and synchronized with Apeiron's application
services so you can see recent calls and obtain support. Call history is distinct from call audio.
Apeiron does not store call recordings.
Calls through the underlying ICS service may be monitored or recorded under ICS and correctional
facility policies. ICSolutions' call-recording guidance
describes recording and confidential-call exceptions. Ask ICS or the relevant facility about
recording, access, retention and privileged-call arrangements; the app's diagnostic-sharing
preference does not disable service-side monitoring or recording.
Diagnostics and reliability information
When call-diagnostics sharing and server-side collection are enabled, we collect call-event
timings, connection outcomes, audio-quality measurements such as packet loss and delay, and
network context such as connection type. Optional Android cellular measurements can include
signal strength, carrier and cell identifiers that may reveal approximate location. The cellular
measurement feature does not collect GPS coordinates. Call-quality telemetry excludes call audio.
Crash and error reporting may include app and device information, error messages and technical
traces. The app uses Sentry for crash reporting when configured. We use diagnostics to identify
failures, improve reliability and investigate support issues.
Device contacts and biometric sign-in
If you allow contact access for caller identification, the app can read contact names and telephone
numbers on your device. The ICS app does not enable contacts synchronization. Deleting app data
does not delete your phone's address book. If you enable Face ID, fingerprint or other supported
device authentication, your device performs the biometric check; Apeiron does not receive your
face or fingerprint template through that sign-in feature.
3. Data exchange and service providers
Apeiron exchanges account or calling identifiers, authorized telephone-number mappings,
call-routing and call-status information with the ICS service as needed to connect and deliver
calls and resolve service issues. This does not give ICS unrestricted access to your device.
Providers that support hosting, communications delivery, notifications, crash reporting and
customer support may process the information needed for those functions. In particular,
Google/Firebase and Apple process push-delivery information, and Sentry may process crash
diagnostics. We require providers processing app information on our behalf to use it for the
agreed service and protect it consistently with this policy and applicable requirements.
We do not sell or rent your app personal information or use it for cross-context advertising.
We may disclose information when required by law or valid legal process, or as permitted by law
to address fraud, security incidents or threats to safety. Underlying ICS or facility disclosures
are described in their own policies.
4. Your settings and privacy choices
You can manage microphone, notification, contact and other permissions in your device settings.
Disabling a permission can prevent the related feature from working; for example, microphone
access is needed to speak during a call.
In app versions that offer it, use Profile → Call diagnostics → Share call diagnostics
to control optional diagnostic sharing. Sharing is initially enabled, subject to server-side
collection settings. Turning it off stops new optional captures and discards unsent diagnostics
for the active account; an upload already in progress may complete. It does not erase previously
received server records, app call history or ICS service records. Android cellular measurements
require the separate optional permission choice.
Depending on the laws that apply to you, you may request access to, correction of, deletion of,
or a copy of your app personal information, and exercise applicable objection or restriction rights.
We may verify your identity and authority before acting on a request. Contact us below for help,
including if you cannot sign in. You will not be treated differently for exercising applicable
privacy rights.
5. Retention and exceptions
The following retention periods apply to information Apeiron handles for the app, including
information processed by providers on our behalf. They do not set ICS's or a facility's
retention periods.
ICS Communicator application retention schedule
| Category | Retention period | Scope |
|---|
| App profile, app-associated contacts, call history and telemetry | Delete within 30 calendar days of request receipt | Revoke app login and push access immediately after verified confirmation. Device address-book contacts are unaffected. |
| Required billed or regulated call detail | 18 months from the call, where applicable | Retain only billing fields subject to applicable toll-call record requirements. |
| Invoices, payments and tax evidence | 7 years under a finance-approved policy | Necessary financial records only. This does not retain all call detail for seven years. |
| Routine security and access logs | 90 days from the event | Minimized security and fraud records, excluding passwords, tokens, contacts and raw call telemetry. |
| Documented security incidents | 12 months after closure | Longer retention requires a documented investigation or legal reason. |
| Minimal deletion-request audit | 24 months after the final response | Request reference, dates, verification outcome, processing results and exception reasons; not a copy of the deleted account. |
| Backup copies | 35 days after active-system deletion | Backup copies rotate out within this period. Completed deletions are reapplied before restored data becomes available. |
| Specific legal holds | Until the hold ends | Limit access and use to the hold's purpose; review outstanding holds every 90 days. |
A required exception applies only to the information and purpose that justify
it. When responding to a deletion request, we explain any information retained and the reason.
App deletion does not require removal of separate ICS billing, facility or legally retained records.
6. Account and data deletion
Request deletion through the app's Privacy and account deletion option where
available, or visit the ICS Communicator account-deletion page.
You can reach the website without installing the app. If online submission is unavailable or
you cannot sign in, use the support contact on that page to request deletion and verify your identity.
The request covers your supplemental ICS Communicator app account and associated app data.
It does not delete your separate ICSolutions service account or cancel incoming calls to your mobile
telephone through the public telephone network (PSTN). Request separate service-account deletion or
cancellation directly from ICS.
After verification and confirmation, application access is revoked and eligible
app profile data, app-associated contacts, call history and telemetry are processed for deletion,
subject to the retention exceptions described above. Deletion-aware app versions clear local
account data after receiving confirmation that app access has been revoked. A request receipt
or support ticket acknowledges a request; it does not mean every system has finished deleting data.
We provide processing updates and explain completion or any exception. Uninstalling
the app alone does not delete your server-side app account. The request does not remove another
person's account or your phone's own address book.
7. Security and policy changes
We use safeguards appropriate to the application, including authenticated service access,
device secure storage for app credentials, and account-specific storage for app history and
diagnostics. Access to app information is limited to people and providers who need it to perform
the functions described in this policy. No network or storage system can guarantee absolute security.
When the app's practices change, we update this policy and its last-updated date.
Material changes will be communicated as required by applicable law, and we obtain any required
consent before applying a new use of information.