Effective: February 1, 2019
GenVox is dedicated to the use of Voice over Internet Protocol (VoIP) and related technologies to improve the telecommunications industry and the lives of individuals throughout the world.
At GenVox, privacy matters. GenVox respects the privacy of its Clients and other individuals with whom GenVox has business interactions
This policy is global, applying to all GenVox locations. It applies to personal information regardless of format. For example, the policy applies to computerized records and electronic information as well as paper-based files.
It is also applicable to all personal information that is collected, maintained, or processed by GenVox. The concepts enumerated in this policy will guide GenVox’s selection and expectations of its Clients, partners, agents, and/or contractors to whom GenVox transfers and relies on for the processing of personal information.
GenVox provides the technology platform for hosted or “cloud” unified communications as a service offering (UCaaS). These Products merely act as a conduit for data transmitted by third parties and Subscribers. GenVox processes personal information that is controlled by or originated from other companies, such as our Clients or other business partners. GenVox also processes personal information in the course of providing support for GenVox communications products. GenVox shall protect the personal information, comply with all laws that regulate the processing of such personal information, and process the information only as authorized by the data controller or the data subject. Accordingly, GenVox relies on the guidance and direction of the Client (as the data controller), who determines the purposes of processing such personal information. In some cases, GenVox may collect and process personal information for our own business purposes and shall comply with the applicable privacy laws concerning GenVox processing.
While GenVox does process data in its role of providing a technology platform, it does not own, control, or direct the use of any of the personal information stored or processed by any Client or Subscriber. GenVox only processes such personal information in order to provide an invoice for purchased and/or subscribed Products and Services.
What Information We Collect or Process
GenVox processes and in certain situations collects personal information as needed to deliver its Products and Services and manage its business. When collecting personal information, GenVox does so in a reasonable and lawful manner.
The types of information and the purposes for which GenVox collects or processes personal information may include:
Business Contact Information:
GenVox may collect and use personal information about individual contacts of Clients and others who access GenVox public websites, knowledge bases, forums, ticket systems, or provide personal information through other means. Such information may include but is not limited to account information, first/last name, company name, title, and responsibilities, work email address, work mailing address, telephone numbers, login information, device identifiers, as well as additional information provided by such individuals in the course of receiving Products and Services from GenVox and/or requesting information about GenVox. We will use such information for the purposes of providing Products and Services, support, conducting data analytics and product assessments and related activities, and providing information regarding GenVox Products and Services.
Customer Proprietary Network Information (CPNI):
Customer Proprietary Network Information (CPNI) may include information regarding quantity, destination, technical configuration, location, amount of use, and related billing information of telecommunications, interconnected and/or non-interconnected Voice over Internet Protocol (VoIP) services. This may include but is not limited to the phone numbers that you call or send messages to (or the phone numbers that you receive these calls and messages from) through our Products and Services. The date, time, and duration of the calls may also be collected. This data is used for billing and service level assurance.
GenVox provides Products and Services that are primarily for the benefit of Clients and Subscribers in that GenVox transmits, routes, switches, or caches information. These Products and Services merely act as a conduit for data transmitted by third parties and Subscribers. GenVox does not determine the purposes and means of processing this personal information. Except for Subscriber data provided by the Client (the Subscribers service provider) for which GenVox is merely providing a conduit for transmission, the subscribed services are of such a nature that, in most instances, GenVox requires and collects only essential CPNI and billing information; and opting out or declining to provide the requested data may hinder the provision or delivery of subscribed services. However, for CPNI data that is collected by GenVox that is not subject to the control of others, GenVox shall obtain consent from the user for the processing of this data.
GenVox collects end-user CPNI in the course of providing Product support. This data may pertain to Clients of GenVox or Subscribers (eg: end-users of GenVox’ direct Clients). This data may include IP address, telephone number, email address, call detail records, call recordings, and other information sufficient to identify an individual end-user.
Indirect End User’s CPNI:
GenVox acts as a data processor with regard to indirect end-user personal information, and our Clients act as the data controller of such data. In the course of GenVox’s processing and protection of such data, users will be in conformity with the data controller’s instructions.
Direct End User’s CPNI:
GenVox typically collects and processes direct end-user (eg: Clients, vendors, and partners) personal information for the purposes of providing Products and Services, support, conducting data analytics, and managing product performance.
Messaging, Voicemail, Video, and Media Files:
GenVox provides Products and Services that facilitate the recording and storage of audio and video by way of features such as but not limited to voicemail, call, and conference recording. Users may elect to store or record personal information within these resources at their discretion.
Anonymized, Non-Identifying Voice and Traffic Data
GenVox may use anonymized, non-identifying data collected from the use of our SNAPsolution, SNAPvantage, and other GenVox Products and Services. This anonymized, non-identifying data may be used to enhance such items, but is not limited to, voice activation, improve traffic analysis algorithms and techniques, and recognition algorithms. This processing is executed under applicable terms and supports GenVox’s legitimate interests in tuning, maintaining, and enhancing these Products and Services.
How We Collect Information
We collect information in various ways, including the following:
When you use one of our Products or Services, GenVox collects and stores certain information that you provide directly. We also collect information about your use of the Products and Services.
Cookies and Similar Collection Methods
GenVox also collects technical information about your usage of the Products and Services, and we use various technologies to collect information about cookies, IP addresses, device type and device identifiers, application state, and the date and time of activity with our Products and Services, and other similar information. GenVox may associate this information with your user identification and/or account number for our internal use.
Other Passive Site Tracking
Websites may also utilize Internet Protocol (IP) addresses and log files to identify network and server concerns and problems. GenVox also utilizes web beacons and other passive tracking mechanisms to perform standard website traffic analysis in a similar manner to how we utilize cookies.
Credit Card Information
GenVox only collects credit card information in order to bill for purchased or subscribed to Products and Services. GenVox utilizes third-party credit card payment processing agents (where these agents are required to implement reasonable and appropriate measures to protect and secure this information from loss or misuse) solely for the purpose of processing payments for those Products and Services purchased or subscribed to. These payment processors’ use of your personal information is governed by their privacy policies, as well as adhering to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like American Express, Visa, Mastercard, and Discover.
HOW DOES GenVox UTILIZE COOKIES
General Information about Cookies
A cookie (also known as an HTTP cookie, web cookie, or browser cookie) is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. Cookies were designed to be a reliable mechanism for websites to remember useful information (such as items in a shopping cart) or to record the user’s browsing activity (including clicking particular or specific buttons, logging in, or recording which pages were visited by the user as far back as months or years ago).
Utilization of Cookies
A visit to a page on www.GenVox.com (or another GenVox website) may generate the following types of cookie(s):
Anonymous Analytics Cookies
Every time a user visits a GenVox website, software provided by another organization (such as Google Analytics) generates an ‘anonymous analytics cookie’. These cookies can tell us whether you have visited the site before. Your browser will inform us if you have these cookies and, if you don’t, our website generates new ones. This allows GenVox to track how many individual users we have and how often they visit the site. Unless you are signed in to GenVox.com (or any other GenVox website), we cannot use these cookies to identify individuals. We use these cookies to gather statistics: for example, the number of visits to a page. If you are logged in to the GenVox website, we will also be provided the details you gave to us for this, such as but not limited to your username and email address.
When you register with a GenVox website, such as GenVox.com, GenVox generates cookies that inform us whether you are signed in or not. Our servers use these cookies to determine which account you are signed in with and whether you are allowed access to a particular Product or Service.
Advertising (Ad) Cookies
These cookies allow GenVox to know whether you’ve seen a specific ad or the type of ad, and for how long you have viewed it. We also utilize cookies to help us direct targeted advertising.
Other Third-Party Cookies
On some pages of our websites, other organizations may also set their own anonymous cookies. They do this to track the success of their products and/or services, or to customize the experience for you. Because of how cookies function, our websites cannot access these Third-Party cookies, nor can the other organization access the data in cookies GenVox uses on our websites. For example, when you share an article or post using a social media sharing button (Facebook, LinkedIn, or other social media outlets) on GenVox.com, the social network that has created the button will record that you have done this.
How Do I Turn Cookies Off
It is usually possible to stop your browser from accepting cookies or to stop it from accepting cookies from a specific website. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘options’ or ‘preferences’ menu of your browser. To understand these settings, you can use the ‘Help’ option in your browser for more details. It is solely your responsibility to stop cookies in your browser.
VENDORS, SUPPLIERS, AND SUBCONTRACTORS
GenVox may collect personal information about individuals who are employed by our suppliers and vendors. This business contact and payment information is strictly used to administer existing and future business arrangements.
Additional personal information may be collected, processed, and disclosed for the purposes for which it was collected and for legal compliance purposes, including regulatory reporting, investigation of allegations of wrongdoing, and the management and defense of legal claims and actions, and compliance with subpoenas, court orders, and other legal obligations. For example, we may collect information about individuals that visit our office or other facilities. When we do collect data, such collection shall be relevant, proportionate, and limited to the purposes for which they are processed.
How We Use the Information We Collect
We use your information primarily and as necessary to provide you with the various GenVox Products and Services, including but not limited to one or more of the following ways: to create your accounts and allow the use of our Products, to provide technical support and respond to Client inquiries, to prevent fraud or potentially illegal activities, enforce our other agreements with you, to notify Clients of application updates, and to inform Clients about new products or promotional offers.
GenVox recognizes that for some sensitive information, affirmative express consent from individuals is required and must be obtained if such information is to be (i) disclosed to a third party or (ii) processed for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice. In addition, GenVox shall treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.
If you have created a user profile on any GenVox service portal (eg: Knowledge Base help.GenVox.com), you may access and revise the personal information in your user profile when you log into your account. In general, these portals will only require minimal personal information that is necessary to provide and administer the service.
If you provide us with your email address or other business contact information to enable us to provide communications and information to you, we may use the information for providing such communications including the delivery of press releases and other GenVox marketing materials. You may request to no longer receive GenVox marketing communications by following the “unsubscribe” instructions in emails from GenVox or by sending a request to the contact identified below.
In the rare and unlikely event that GenVox wishes to use an individual’s personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals, GenVox will seek consent in advance as required by applicable law.
Sharing Your Information
We may disclose or report information that individually identifies Clients, Subscribers, or devices in certain circumstances, such as:
(i) if we have a good faith belief that we are required to disclose the information in response to a valid legal process (for example, a court order, search warrant or subpoena, or to defend or respond to legal actions, and as otherwise authorized by law, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements); (ii) to satisfy applicable laws, (iii) if we believe that the Products and Services are being used in an unauthorized, unlawful or abusive manner, such as to commit a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction, (iv) if we have a good faith belief that there is an emergency that poses a threat to the health or safety of a person or the general public, (v) in order to protect the rights or property of GenVox, including enforcement of our Intellectual Property Rights and terms of the Agreement(s), and (vi) for all other purposes with your consent. We may also provide your information to third party companies to perform services on our behalf, including but not limited to payment processing, data analysis, message delivery, hosting services, customer service, and marketing.
If GenVox enters into a merger, acquisition, or sale of all or a portion of its assets or business, Client and Subscriber information, including personal information, will also be transferred as part of or in connection with the transaction as per applicable law.
In general, personal information may be shared within GenVox, where legally permitted for reasonable and appropriate corporate purposes. However, even within GenVox, we restrict access to personal information to those employees, agents, or contractors who need access to carry out their assigned functions.
GenVox uses vendors and partners for a variety of business purposes, such as to help us develop, deploy, and invoice for the various Products and Services we provide. We share information with those vendors and partners when it is necessary for them to perform work on our behalf. GenVox requires that these vendors and partners protect the customer information we provide to them and limit their use of such information to their respective processing activity. GenVox will only transfer or provide direct access to personal information covered by this policy to third parties that have made a commitment to respect the privacy rights of the data subject; limit the processing of personal information to comply with data controller instructions, and provided GenVox contractual assurances that they will provide at least the same level of privacy protection as is required by applicable privacy laws.
Security of Your Information
We implement security measures we believe are reasonable to protect your information. It is important that you protect and maintain the security of your account and you need to immediately notify us of any unauthorized use of your account. Remember, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot and do not guarantee its absolute security.
Protecting Personal Information
Transfer of Data
Your information, including personal information, may be transferred to, and maintained on, computers, servers or other data storage located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. If you reside outside the United States and choose to provide information to GenVox, please note that we transfer the data, including personal information, to the United States and process it there.
Retention of Data
Personal information collected by GenVox will be retained for as long as necessary and legally permitted for the purposes for which it was collected, to provide you with Products and Services, enforce our legal agreements and policies, and to conduct our legitimate business interests or where otherwise required by law.
GenVox employs reasonable means to keep personal information accurate, complete, and current, as needed for the purposes for which it was collected.
How to Access and Update Your Information
We generally provide individuals with an opportunity to examine their own personal information, confirm the accuracy and completeness of their personal information, and have their personal information updated, if appropriate.
The ability of an individual to access his or her personal information is not unlimited, however. An individual’s ability to access personal information may be limited, for example, where (i) the burden or expense of providing access would be unreasonable or disproportionate to the risks to the individual’s privacy, (ii) the information should not be disclosed due to legal or security reasons or to protect confidential commercial information; or (iii) providing access would compromise the privacy of another person.
If you have created a user profile on a portal, you may also access and revise the personal information in your user profile when you log into your account.
Individuals who wish to access or update their personal information not accessible via a portal should direct such communications to GenVox Legal Department at legal@GenVox.com
Third-Party Websites, Plugins, or Widgets
California Privacy Rights
The California Data Protection Act (Cal. Civ. Code §§ 1798.83), also known as S.B. 27 “Shine the Light Law”, applies to a business that owns or retains California residents’ personal information and, requires such business to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes.
A business subject to California Business and Professions Code Section 22581 and the Privacy Rights for California Minors in the Digital World Act (Cal. Bus. & Prof. Code §§ 22580-22582) must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal or other forms of anonymization of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be so removed.
Our Products and Services do not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.
If you are a California resident and would like to make such a request, email or contact us at help@GenVox.com
1201 West Peachtree Street
Atlanta, Georgia 30309
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