|
ANNEX I
INFOE PRIVACY POLICY
according to the General Data Protection Regulation of the European Union
(GDPR) as applied in the jurisdiction of this contract
Infoe processes two broad categories of
personal information when you use our products and services:
●
Your personal information as
a customer, as a potential customer or as an authorized representative of your
company. We refer to this information as “Customer Account Data”, and
●
The personal information of
your end users who use or interact with the services that you’ve configured on
Infoe’s platform - this category contains both your Customer Usage Data (e.g.,
communications metadata) and your Customer Content (e.g., the contents of
communications).
Infoe processes these categories of
personal information differently because the direct relationship we have with
you, our customer, is different than the indirect relationship we have with
your end users.
How Infoe Processes Your Personal
Information
We, Infoe, collect and process your
personal information:
●
When you visit a Infoe public-facing
website like infoe.es, infocaller.com, Infofax.es or infosms.es, sign up for a
Infoe event, or make a request to receive information about Infoe or our
products, like a Infoe whitepaper or a newsletter;
●
When you contact Infoe’s
Sales Team or Customer Support Team; and
●
When you sign up for an
Infoe account and use our products and services.
We call this personal information Customer
Account Data.
Data protection laws in certain
jurisdictions, like the European Economic Area (EEA), differentiate between
“controllers” and “processors” of personal information. A controller decides
why and how to process personal information.
A processor processes personal information
on behalf of a controller based on the controller’s instructions. When Infoe
processes your Customer Account Data, the Infoe entity with whom you are
contracting is acting as a controller.
Broadly speaking, we use Customer Account
Data to further our legitimate interests to:
●
understand who our customers
and potential customers are and their interests in Infoe’s product and
services,
●
manage our relationship with
you and other customers,
●
carry out core business
operations such as accounting and filing taxes, and
●
help detect, prevent, or
investigate security incidents, fraud and other abuse and/or misuse of our
products and services.
What Customer Account Data Infoe
Processes When You Visit Our Website, Sign Up for a Infoe Event, or Make a
Request for Information About Infoe and Why
When you visit our website, sign up for an
Infoe event or request more information about Infoe, we collect information
automatically using tracking technologies, like cookies, and through web forms
where you type in your information. We collect this information to provide you
with what you request through the web form, to learn more about who is
interested in our products and services, and to improve navigation experience
on our pages.
Information You Share Directly: In some places on Infoe’s public-facing websites, you can fill out
web forms to ask to be contacted by our Sales Team, sign up for a newsletter,
register for a Infoe event, or take a survey. The specific personal information
requested on these forms will vary based on the purpose of the form. We will
ask you for information necessary for us to provide you with what you request
through the form (for example, we will ask you for your email address if you
want to sign up for an email newsletter and for your phone number if you want a
member of our Sales Team to call you). We may also ask you for additional
information to help us understand you better as a customer like your Infoe use
case, your company name, or your role at your company. If you sign up to
receive ongoing marketing communications from Infoe, like a newsletter, you can
always choose to opt-out of further communications through a preferences page
which will be linked from any marketing email you receive from Infoe. Or, you
can contact our Customer Support Team to communicate your choice to opt-out.
Information We Collect Automatically: When you visit Infoe websites, including our web forms, we and our
service providers acting on our behalf automatically collect certain
information using tracking technologies like cookies, web beacons, and similar
technologies. We use this information to understand how visitors to our
websites are using them and which pages and features of the websites are most
popular. This helps us understand how we can improve our websites and track
performance of our advertisements. In addition, we using tracking technologies
to help improve the navigation experience on Infoe websites. For more details
on our use of cookies and tracking technologies, please see our Cookie
Notice.
What Customer Account Data Infoe
Processes When You Communicate with Our Sales or Customer Support Teams and Why
You may share personal information, like
your contact information, with a member of our Sales or Customer Support Team
when you communicate with them. We keep a record of this interaction.
If you contact our Sales or Customer
Support Teams, those teams keep a record of that communication, including your
contact details and other information you share during the course of the
communication. We store this information to help us keep track of the inquiries
we receive from you and from customers generally so we can improve our products
and services and provide training to team members. This information also helps
our teams manage our ongoing relationships with our customers. Because we store
a record of these communications, please be thoughtful about what information
you share with our Sales and Customer Support Teams. While we will take
appropriate measures to protect any information you share with us, it is best
to avoid sharing any personal or other sensitive information in these
communications not necessary for these teams to assist you.
We may use third party
products and services to process and store the information you share with our
Sales and Customer Support teams and in such a case we will have subscribed the
agreements required by law and privacy regulations.
What Customer Account Data Infoe
Processes When You Sign Up for and Log Into a Infoe Account and Why
When you sign up for an Infoe account, we
ask for certain information like your contact details and billing information
so we can communicate with you and so you can pay for our products and
services. We also collect some information automatically, like your IP address,
when you log in to your account or when your software application built on
Infoe makes requests to our APIs. We use this to understand who is using our
services and how, and to detect, prevent and investigate fraud, abuse, or
security incidents.
Information You Share Directly: When you sign up for a Infoe account, you’ll be asked to give us
your name, email address, and optionally, your company name, tax id information
and to create a password. You can also name your account (or accounts, if you
manage more than one). We collect this information so we know who you are, we
can communicate with you about your account(s), and we can recognize you when
you communicate with us through the account portal or otherwise.
We also use your email address to send you
information about other Infoe products, services or events in which we think
you may be interested. You can opt out of further marketing communications
through your marketing preferences page linked from any marketing email you
receive from Infoe. Or, you can contact our Customer Support Team to
communicate your choice to opt-out.
When you first sign up for an account, we
may also ask you for a telephone number so we can communicate a verification
code to that telephone number and have you enter the code into our website. This helps us ensure the uniqueness of our customer and
that there is an actual person and not a robot behind the process. An
Infoe team member may also contact you at this number to help you with
onboarding unless you tell us you don’t want us to contact you.
If you set up, or we ask you to set up,
two-factor authentication for your account, we’ll ask you to enter a telephone
number to set up the process. You have the option to use that telephone number
as the method for us to communicate verification codes to you to verify that it
is you logging into your account.
When you upgrade a trial account or sign up
to a new account, we’ll ask you to provide us with
your payment method information like a credit card, bank account or your Paypal
account, and/or your billing address. Our payment processor, acting on our
behalf, gathers this so we can bill you for your use of our products and
services. Your billing address may also be used by Infoe for tax calculation
and audit purposes.
For some products, we may also have to
obtain a physical address from you, including proof of address or other
identification information. For example, to get a phone number in certain
countries, local law may require us to have a physical service address on file
for you or your end user and/or proof of identity and physical service address.
We may also use this physical service address for tax purposes. We may have to
share your service or billing address with the telecommunications carrier from
whom Infoe obtained the phone number or with local government authorities upon
their request.
Similarly, for some of our products, you
may have to complete an application form providing details about your company
and your intended use of the product, like when you are interested in getting a
short code. We’ll use this information for the purpose for which it was gathered
from you. We may also use it in connection with improving our own internal
processes and services or training our team members.
Information We Generate or Collect
Automatically. When you sign up for an account with
Infoe, we’ll automatically assign you and your account(s) unique customer ID.
We may generate an API token for each of your accounts. These are used like a
username and password to make API requests. Instead of using these API tokens,
you can provision passwords and API Keys, and use your passwords and API key
for authentication when making requests to our APIs. We keep a record of these
credentials so we know it is you making the requests when your application
makes requests to our API using these credentials.
In addition, when you use our account
portal, we collect your IP address and other data through tracking technologies
like cookies, web beacons, and similar technologies. We use this information to
understand how customers are using our platform, who those customers are (if
they are a company and the IP address is associated with that company), what
country they are logging in from (for analytics and export control purposes),
and to help improve the navigation experience. We also used the IP address to
audit any account data changes. For more details on our use of cookies and
tracking technologies, please see our Cookie Notice.
Note that we also collect the IP address of
your devices or servers when you make requests to our APIs. When you use our
APIs, we also collect and process the information contained in those
interactions.
All information we collect when you sign up
for a Infoe account and interact with the Infoe account portal or our products
or services may be used to detect, prevent, or investigate security incidents,
fraud, or abuse and misuse of our platform and services.
Other Customer Account Data We Collect
and Why
We may collect information about you, as
our customer, from publicly-available sources so we can understand our customer
base better.
We may use publicly-available information
about you through services like LinkedIn, or we may obtain information about
your company from third party providers to help us understand our customer base
better, such as your industry, the size of your company, and your company’s
website URL.
How Long We Store Your Customer Account
Data
Infoe will store your Customer Account Data
as long as needed to provide you with our services and to operate our business.
If you ask Infoe to delete specific personal information from your Customer
Account Data, we will honor this request unless deleting that information
prevents us from carrying out necessary business functions, like billing for
our services, calculating taxes, or conducting required audits.
Here is an overview of how long we hold on
to Customer Account Data in a form that can be used to identify you, unless
there is a specific need or obligation to retain your information longer (like
in the case of an open investigation, audit or other legal matter):
Customer Account Data stored in our
customer relationship management system(s) is generally stored up to 7 years
following closure of your account. Invoice records, including their digital
equivalent, may be retained in identifying form by Infoe for longer periods for
accounting, tax, and audit purposes depending on and in accordance with
applicable tax law.
Your communications with Infoe’s Customer
Support Teams may be retained for up to 7 years after your account is closed.
How To Make Choices About Your Customer
Account Data
You can make various choices about your
Customer Account Data through the account portal, such as accessing it,
correcting it, deleting it, or updating your choices about how it is used, when
you log into your Infoe account or through the marketing preferences center.
Any other requests about your data you cannot make through these self-service
tools, you can request by emailing dpo@infoe.es or contacting Customer Support.
Closing Your Account and Deletion. Cancelling specific products or services does not imply closing
the account. You can request closure and deletion of the account sending an
email to dpo@infoe.es
or contact Customer Support, after adequate authentication of your identity.
You should know that closure and/or deletion of your Infoe account will result
in you permanently losing access to your account and data in the account.
Please note that certain information associated with your account may nonetheless
remain on Infoe’s servers in an aggregated form that does not identify you or
your end users. Similarly, data, including personal information, associated
with your account we are required to maintain for legal purposes or for
necessary business operations (see “How Long We Store Your Customer Account
Data” section above) will be retained after account closure until no longer
needed.
Promotional Communications. You can choose not to receive promotional emails from Infoe by
following the unsubscribe/opt-out instructions in those emails. You can also
opt-out in the account portal, by contacting Customer Support. Please note that
even if you opt out of promotional communications, we may still send you
non-promotional messages relating to things like updates to our terms of
service or privacy notices, security alerts, and other notices relating to your
access to or use of our products and services.
Cookies and Tracking Technologies. How you make choices about cookies and other tracking technologies
depends on the type of cookie or tracking technology being used. For details on
how to manage your preferences for cookies and tracking technologies, please
check out our Cookie Notice.
Other Choices About Your Customer
Account Data. In addition, you can express other
choices about your Customer Account Data (i.e., accessing it, deleting it,
restricting its use, porting it, or withdrawing consent for its use) by
contacting dpo@infoe.es
.
If you are an end user of an application on
Infoe’s platform and not a direct customer of Infoe, you should direct requests
relating to your personal information to the Infoe customer who gave you access
to the application and according to their own privacy policy.
How Infoe Processes Your End Users’
Personal Information
Your end users’ personal information
typically shows up on Infoe’s platform in a few different ways:
●
Communications-related
personal information about your end users, like your end users’ names, email
addresses, phone numbers for number-based communications, IP addresses for
IP-based communications, or device tokens, show up in our systems when you
configure, use or intend to use this information to contact your end user
through use of our products and services.
●
Your end users’ personal
information may show up in “friendly names,” which are strings you provide, if
you choose to include your end users’ personal information in communications.
●
Your end users’ personal
information, or third parties which are not end users or customers, may also be
contained in the content of communications you (or your end users) send or
receive using Infoe’s products and services.
We call the information in the first two
bullets above Customer Usage Data. The information in the third bullet is what
we refer to as Customer Content.
As noted above, data protection law in
certain jurisdictions, like the European Economic Area (EEA), differentiate
between “controllers” and “processors” of personal information. When Infoe
processes Customer Content, we generally act as a processor. When we process
Customer Usage Data, we act as a processor in many respects, but we may act as
a controller in others. For example, we may need to use certain Customer Usage
Data for the legitimate interests of billing, reconciling invoices with
telecommunications carriers, and in the context of troubleshooting and
detecting problems with the network.
What Customer Usage Data and Customer
Content Infoe Processes and Why
We use Customer Usage Data and Customer
Content to provide services to you and to carry out necessary functions of our
business as a communications service provider. We do not sell your end users’
personal information and we do not share your end users’ information with third
parties for those third parties’ own business interests.
The particular end user personal
information Infoe processes when you, our customer, use our products and
services and the reason Infoe processes it depends on how you use our products
and services and which Infoe products and services you use. For that reason,
our API docs for each of our products and services are the best place to find
information about our processing of personal information when you use that
Infoe product and service.
In many cases, you can opt to store records
of your communications, or other activities, on Infoe services, which may
include your end users’ personal information. You may also have the option to
use additional features or tools within Infoe’s products or services that allow
you to do things such as analyze the records, including end user personal
information, in your Infoe account. In those cases, Infoe will process this
information to provide you with the service you request.
In addition, records containing end user
personal information may, from time to time, also be used in debugging or
troubleshooting or in connection with investigations of security incidents, as
well as for the purposes of detecting and preventing spam or fraudulent
activity, and detecting and preventing network exploits and abuse.
How Long Do We Store Customer Usage Data
and Customer Content and Exercising Choices About End User Personal Information
Details regarding how long your end user
personal information may be stored on Infoe systems and how to delete, access,
or exercise other choices about end user data will depend on which Infoe
products and services you are using and how you are using them. For that
reason, our API docs for each of our products and services are the best place
to find more detailed information about managing end user data collected and
stored in connection with your use of our products and services.
As a Infoe customer, if the Infoe product
or service you use enables you to store records of your usage on Infoe,
including personal information contained within those records, and you choose
to do so, then Infoe will retain these records for as long you instruct. In
some cases, use of extended storage may cost more. If you later instruct us to
delete those records, we will do so. Please note it may take up to 30 days for
the data to be completely removed from all systems. In some cases, a copy of
those records, including the personal information contained in them, may
nonetheless be retained to carry out necessary functions like billing, invoice
reconciliation, troubleshooting, and detecting, preventing, and investigating
spam, fraudulent activity, and network exploits and abuse. Sometimes legal
matters arise that also require us to preserve records, including those
containing personal information. These matters include litigation, law
enforcement requests, or government investigations. If we have to do this, we
will delete the impacted records when no longer legally obligated to retain
them. We may, however, retain Customer Usage Data transformed such that your
end user cannot be identified.
When and Why We Share Your Personal
Information Or Your End Users’ Personal Information
We do not sell or allow your Customer
Account Data to be used by third parties for their own marketing purposes,
unless you ask us to do this or give us your consent to do this. Further, we do
not sell your end users’ personal information (whether contained in Customer
Usage Data or Customer Content). And, we do not share it with third parties for
their own marketing or other purposes, unless you instruct us to do so.
Below are the different scenarios under which we may share your data with third parties.
●
Telephony operators as
necessary for proper routing and connectivity. Infoe provides an easier way for use of the publicly
switched telephone network (PSTN) to send communications. Therefore,
communications-related data is shared with and received from telephony
operators as necessary to route and connect those communications from the
sender to the intended recipient. How those telephony operators handle this
data is generally determined by those operators’ own policies and local
regulations.
●
Other communications
service providers for proper routing and connectivity. Infoe also enables sending or receiving communications
through communications service providers that do not use the PSTN, such as
online Over-the-Top (OTT) communications service providers (SMS, Skype and
other similar services). Infoe will share communications data with these
providers as necessary to route and connect those communications from the
sender to the intended recipient. How those OTT communications service
providers handle this data is determined by their own policies.
●
Third-party service
providers or consultants. Infoe
engages certain third-party service providers to carry out certain data
processing functions on our behalf. These providers are limited to only
accessing or using this data to provide services to us and must provide
reasonable assurances they will appropriately safeguard the data.
●
Sub-processors. We may share Customer Content with
sub-processors who assist in providing the Infoe services, like our
infrastructure provider, or as necessary to provide optional functionality like
transcriptions. An up-to-date list of our sub-processors is located here
●
Add-on Partners. Add-ons are additional features, functionality
or services offered by Infoe’s Add-on Partners (third parties not affiliated
with Infoe). Infoe may make Add-ons available through the Infoe portal (like
Google Drive or Dropbox). Some Add-ons may need to access or collect some of
your information, including personal information. If you choose to use an
Add-on, Infoe will share your information with the Add-on Partner so you can
use the Add-on. Infoe does not control Add-on Partners’ use of your information
and their use of your information will be in accordance with their own
policies. If you do not want your information to be shared with an Add-on
Partner, then you should not use the Add-on.
●
Compliance with Legal
Obligations. We may disclose
your or your end users’ personal information to a third party if (i) we
reasonably believe that disclosure is compelled by applicable law, regulation,
legal process or a government request (including to meet national security or
law enforcement requirements), (ii) to enforce our agreements and policies,
(iii) to protect the security or integrity of our services and products, (iv)
to protect ourselves, our other customers, or the public from harm or illegal
activities, or (v) to respond to an emergency which we believe in good faith
requires us to disclose data to assist in preventing a death or serious bodily
injury.
●
Affiliates. We may share your personal information or your
end users’ personal information with an affiliate company, like a subsidiary or
parent company of Infoe. We and our subsidiaries or parent company will only
use the information as described in this notice.
●
Business transfers. If we go through a corporate sale, merger,
reorganization, dissolution or similar event, data we gather from you may be
part of the assets transferred or shared in connection with the due diligence
for any such transaction. Any acquirer or successor of Infoe may continue to
process data consistent with this notice.
●
Aggregated or
de-identified data. We might
also share data with third parties if the data has been de-identified or
aggregated in a way so it cannot be used to identify you or your end users.
Transfers of Personal Information Out of
the EEA and Switzerland
When you use our account portal or Infoe
websites, or our products and services, personal information of you and your
end users processed by Infoe may be transferred to other countries where we or
our service providers operate.
Infoe employs appropriate safeguards for
cross-border transfers of personal data, as required by applicable local law.
European Union Model Clauses. Infoe establishes EU Model clauses with its suppliers to provide
appropriate safeguards for Customers Account Data that is transferred outside of the EEA and Switzerland. Infoe has verified that its sub-processors in the United
States, and other countries which allow it, have a valid Private Shield certification.
Automated Decision Making
Infoe may use automated decision making
using a variety of signals derived from account activity to help identify and
suspend accounts sending spam or engaged in other abusive or fraudulent
activity. Holders of accounts suspended under these circumstances are notified
of the suspension and given an opportunity to request human review of the
suspension decision.
Handling Disputes Relating To Our Data
Protection Practices
We hope we can resolve any disputes
relating to our data protection practices between us. You can raise your
concern or dispute by emailing our Privacy Team at dpo@infoe.es or by writing to us at:
Infoestructura S.A.
Francisco Gervás, 8
28108 - Alcobendas - Madrid
Spain
For individuals in the EEA, you have
additional rights to make a complaint to a competent data protection authority
or commence proceedings in a court of competent jurisdiction in accordance with
applicable data protection laws. You also have the right to lodge a complaint
with your local data protection authority.
How We Secure Personal Information
We use appropriate security measures to
protect the security of your personal information both online and offline.
These measures vary based on the sensitivity of the personal information we
collect, process and store and the current state of technology. We also take
measures to ensure service providers that process personal data on our behalf
also have appropriate security controls in place.
Please note that no service is completely
secure. While we strive to protect your data, we cannot guarantee that
unauthorized access, hacking, data loss or a data breach will never occur.
To protect the confidentiality of your
account and protect from unauthorized use of your account, we recommend you use strong
passwords. Additionally, you must keep your account password an any API
tokens or credentials confidential and not disclose them publicly or to
unauthorized individuals - this includes accidentally distributing them in a
binary or checking them into source control. Please let us know right away if
you think your password or Token was compromised or misused. You can change password
or Tokens in the account portal.
Other Information You May Find Useful
Information from Children
We do not knowingly permit children (under
the age of 13 in the US or 16, if you live in the EEA) to sign up for a Infoe
account. If we discover someone who is underage has signed up for a Infoe
account, we will take reasonable steps to promptly remove that person’s
personal information from our records. If you believe a person who is underage
has signed up for a Infoe account, please contact us at dpo@infoe.es
Do-Not-Track Signals
Infoe does not currently respond to web
browser’s Do-Not-Track signals. You can learn more about Do Not Track here.
Changes to Our Privacy Statement
We may change our Privacy Statement from
time to time. If we make changes we’ll revise the “Effective” date at the top
of this statement, and we may provide additional notice such as on the Infoe
website homepage, account portal sign-in page, or via the email address we have
on file for you. We will comply with applicable law with respect to any changes
we make to this notice and seek your consent to any material changes if this is
required by applicable law.
Legal Basis for Processing Personal
Information (EEA only)
If you are from the EEA, our legal basis
for collecting and using the personal information described above will depend
on the personal information concerned and the specific context in which we
collect it.
However, we will normally collect personal
information from you only where we need the personal information to perform a
contract with you, or where the processing is in our legitimate interests and
not overridden by your data protection interests or fundamental rights and
freedoms, or where we have your consent to do so. In some cases, we may also
have a legal obligation to collect personal information from you or may
otherwise need the personal information to protect your vital interests or
those of another person such as in the case where we request personal
information from you in the context of a government audit or in response to a
request from law enforcement.
If you have questions about or need further
information concerning the legal basis on which we collect and use your
personal information, please contact our Customer Support Team
|