OUR COMMITMENT TO PRIVACY

Introduction

Your privacy is of the utmost importance to us and we want to be transparent about the personal data we collect, why we collect it, how we collect it, and how we share it. We also want you to understand your rights and choices regarding processing, access, correction, and deletion of personal data about you.

Who we are

We, the Televerde Group, provide sales and marketing solutions to help our clients’ businesses accelerate sales and generate revenue and to help third parties learn about and decide to purchase our clients’ products and services.

The Televerde Group consists of:

How to contact us

The Televerde Group has appointed a data protection officer who is responsible for our compliance with relevant data protection legislation.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data protection officer using the details set out below.

By post: The Data Protection Officer, Televerde, LLC, Arizona, USA at 4636 E University Drive, Suite 150, Phoenix, AZ 85034

By email: dataprotection.officer@televerde.com or privacy@televerde.com

By phone:+1 888-925-7526

Privacy information

This privacy notice applies to all members of the Televerde Group, subject to any variations due to local laws (please see below for further details).

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This version of our privacy notice was last updated on September 8, 2021.

Data controller / Data processor

For most purposes, the Televerde Group is a data controller of any personal data that it obtains and processes. In certain circumstances, we may act as a data processor on behalf of our Client, in which case the privacy statements of the relevant Client will apply to any personal data that we process in the course of providing such services.

Televerde EU is a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and is registered as a data controller with the Information Commissioner’s Office (ICO) (the supervisory authority for data protection issues in the United Kingdom). Our registration number is ZA286468.

Clients / Prospects

In this privacy notice, we refer to our clients (whether they are incorporated organizations, partnerships, sole traders or any other organization) as Clients, and we refer to third party businesses (whether they are incorporated organizations, partnerships, sole traders or any other organization) who are interested in learning more about our Clients or who our Clients are interested in targeting as Prospects.

To whom does this Privacy Notice apply?

This privacy notice applies to:

This privacy notice also does not apply to existing, former or prospective employees or workers of the Televerde Group. We have a separate privacy notices for such purposes.

Information about our Website

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

Please see our Cookie Notice for further details.

Protecting children’s privacy

For the purposes of our data protection policies, we consider anyone under the age of 13 to be a child.

Our Website is not intended for children and we do not knowingly collect any personal data relating to children. We do not intend for our products and services to be used, accessed or stored by children and we do not target children for marketing purposes.

If you are a parent or guardian and believe we may have collected information about a child, please contact our data protection officer at dataprotection.officer@televerde.com or via any of the other methods set out in paragraph 3 (How to contact us).

About the personal data we collect and hold

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been permanently removed (anonymous data).

The table set out in SCHEDULE 1 summarizes the personal data we collect and process, how we use it (our processing purposes) and why we use it (the lawful bases of processing).

We do not collect any “special categories of personal data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

How is your personal data obtained?

We use different methods to collect personal data from and about you including through:

Direct interactions generally. You may give us your identity, contact, financial, transactional or similar personal data when you correspond with us by post, phone, e-mail, social media, live chat, via our Website or otherwise, including when:

Direct interactions with business contacts. You may give us your identity, contact and other business related personal data when you correspond with us, including when:

Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Recording telephone calls and live chat sessions. We record incoming and outgoing telephone calls and live chat sessions, although we will always inform you of this during the call/chat session.

Failure to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Marketing

With regard to marketing-related communications (whether by e-mail, telephone, post, social media or otherwise) and direct marketing activities, we differentiate between individual consumers and individuals who are representatives of a business or organization.

If you are an individual consumer (e.g. an individual Client, individual Prospect or individual business contact):

If you represent another business (e.g. a Client contact, Prospect contact or corporate business contact):

Where you opt out of receiving these marketing-related communications, this opt-out will not apply to personal data provided to us for any other purpose.

With whom do we share your personal data?

For the purposes of providing our products and services to our Clients where we are acting as controllers, we may share information about our Client (and the relevant Client contacts) with Prospects and we may share information about Prospects (and the relevant Prospect contacts) with our Clients.

Where we are acting as a data processor on behalf of a Client, we may transfer personal data of Client contacts, Prospects and Prospect contacts to such Client or to a third party in accordance with instructions received from the relevant Client. In those circumstances, the privacy statement of the relevant Client will be applicable.

There may be other circumstances in which we may need to share your personal data with certain third parties (strictly on a confidential, business need-to-know basis), acting in our capacity as controllers. The third parties to which we may transfer your personal data include:

Any sharing of your personal data (where we are acting as controllers) will only take place either where you have provided your consent to such sharing, where we are legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in our legitimate interests to do so, including as follows:

International transfers

The Televerde Group is a global group of companies which provides products and services and engages third party service providers within as well as outside of the European Economic Area (EEA). As a consequence, whenever the Televerde Group is processing personal data originating in the EEA in accordance with this privacy notice, Televerde may transfer such personal data to countries and territories outside of the EEA.

Whenever we are required to transfer your personal data originating within the EEA outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:

Automated-decision making or profiling

We do not use automated decision-making (including profiling) to make any decisions which would produce a legal or similarly significant effect on a data subject.

How long do we retain your personal data?

We use different methods to collect personal data from and about you including through:

We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your data will only be retained for as long as it is still required to provide you with services or is necessary for legal reasons.

Generally speaking, we will usually retain your personal data for six (6) years following expiry of any contracts or arrangements between us, unless we are obliged to retain your personal data for a longer period as a result of an overriding legal obligation or in order to establish, defend or exercise legal rights.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

When we determine that personal data can no longer be retained (including where you exercise a right of erasure (see below for further details)), we ensure that this data is securely deleted or destroyed.

For more details about our retention periods, please contact us using the details above.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the relevant data protection supervisory authority of a breach where we are legally required to do so.

Data security – Registered Website Users

PROTECTING YOUR USERNAME AND PASSWORD FROM UNAUTHORIZED ACCESS IS YOUR RESPONSIBILITY. While we use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with the Website, we cannot guarantee that these efforts will always be successful.

WE DO NOT REPRESENT, WARRANT, OR GUARANTEE THAT OUR SAFEGUARDS WILL PROTECT THE PERSONAL DATA ABOUT YOU. PERSONAL DATA ABOUT YOU MAY BE ACCESSED AND VIEWED BY OTHER INTERNET USERS, WITHOUT YOUR KNOWLEDGE AND PERMISSION, WHILE IN TRANSIT TO OR FROM US. WE CANNOT AND DO NOT ENSURE, REPRESENT, WARRANT, OR GUARANTEE THE SECURITY OF ANY INFORMATION YOU TRANSMIT THROUGH THE WEBSITE.

Your rights

With regard to any personal data that is processed by the Televerde Group, you may:

If you wish to exercise any of these rights, please contact us using the details above at paragraph 3 (How to contact us) or by completing the form here.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Your California privacy rights

California law permits users who are residents of California to request the following information regarding our disclosure of their personal information to third parties for those third parties’ direct marketing purposes:

If you are a California resident and would like to make such a request, please email us at privacy@televerde.com.

EU/US Privacy Shield and Swiss/US Privacy Shield

Televerde US participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland to the United States.  Although Televerde US does not rely on the EU-U.S. Privacy Shield Framework or the Swiss-U.S. Privacy Shield Framework as its lawful basis for transfers of personal information in light of the judgment of the Court of Justice of the EU in Case C-311/18 and the concurring Swiss Federal Data and Information Protection Commissioner’s Privacy Shield policy paper dated August 9, 2020, Televerde US has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between any terms in this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]

Televerde US is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Televerde US complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Televerde US is subject to the regulatory enforcement powers of the US Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including for purposes of meeting national security or law enforcement requirements.

Complaints

You have the right to make a complaint at any time to an appropriate data protection supervisory authority, as set out below. We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance on privacy@televerde.com or dataprotection.officer@televerde.com.

Changes to this privacy notice

We may update this privacy notice to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

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