INFORMATION WE COLLECT FROM YOU
In the course of your use of the Services, we obtain the following information about you as described below. We collect this data for the purposes described under “How We Use Your Information”.
SIGNING UP FOR SERVICES; USER INFORMATION
- Information you provide prior to any registration process, such as your email when you provide it to us;
- Information that you provide during any registration process, including in connection with a co-branded offer (such as your name, Grupo Flexicel, email address, phone number, billing address or credit card information, geographic location and industry), when you call or email us (for support or otherwise) or when you use our products or services; and
- Payment information that you provide to us (by way of our Services or otherwise) when you purchase some of our products and services, including credit card data.
USE OF SERVICES, WEBSITE VISITS AND SUPPORT
- Data relating to your online activity on our websites with respect to our Services, including the following:
- IP address
- browser type and version
- geographic location
- pages you view
- how you got to our Services and any links you click on to leave our Services
- when you update your information, communicate with us, or order new Services
- metadata about your use and your contacts’ use of our Services and your emails you send (including clicks and opens)
- your interactions with any videos we offer
- issues you encounter requiring our support or assistance
- any device or other method of communication you use to interact with the Services
- We store this data we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.
- Information from third party social networking sites, including information that social networking sites provide to us if you use your credentials at such social networking sites to log into some of our Services (such as your name and email address to pre-populate our sign-up form).
- The information you allow us to access varies by social networking site, and depends on the level of privacy settings you have in place at the social networking site. You can control and find out more about these privacy settings at the applicable social networking site.
- Information you provide to us at seminars or to our partners;
- Information you provide to us in surveys;
- Information that is publicly available; and
- Information you consent to us receiving from third parties.
HOW WE USE YOUR INFORMATION
We use the information we collect, both on its own and combined with any other information we collect about you, for the following purposes:
- To provide the requested Services to you;
- To provide you with useful content;
- To ensure the proper functioning of our Services
- To offer and improve our Services;
- To provide you with requested information or technical support
- To facilitate your movement through our websites or your use of our Services;
- To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law);
- To advertise and market third party products and services (such advertisement is only performed with your permission where your consent is required by applicable law)
- To diagnose problems with our servers or our Services;
- In connection with our security and compliance programs;
- To administer our websites;
- To communicate with you;
- To target prospective customers with our products or services (such targeting is only performed with your permission where your consent is required by applicable law);
- To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
We also use the information we receive in aggregated and anonymized formats to produce reports on trends and statistics.
Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services.
SHARING OF INFORMATION
As further described below, we will only share certain personal information with:
- Other members of the IPCOM group
- Our partners
- Third party service providers and vendors
- In connection with a sale, merger, acquisition or corporate reorganization
- Authorized users within your organization; and
- For legal reasons
SHARING WITHIN THE IPCOM GROUP
SHARING WITH PARTNERS
When we share personal information with certain third-party partners, including marketing and advertising partners, that information includes your name, email address and other information enabling partners to:
- assist you in using our products and services,
- contact you with offers, services or products that may be of interest to you, and
- provide you with their products or services.
If you are located in a jurisdiction where such sharing requires your permission, we will only do so with your consent. Please note that if you access our services through a tool that hides your location, such as through a virtual private network, you may not receive our request for permission because we were not able to identify you as being located in a jurisdiction where your permission is required.
Further, our partners are prohibited from using your contact information for any purpose beyond those set forth above without your consent.
SHARING WITH THIRD PARTY SERVICE PROVIDERS AND VENDORS
Occasionally, we enter into contracts with carefully selected third parties so that they can assist us in servicing you (for example, a payroll provider responsible for payroll calculation and official social and fiscal declarations) or to assist us in our own marketing and advertising activities (marketing and advertising, IT services, …). Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.
If you purchase a product or service from a third party through one of our brands, we will pass your personal information to such third party in order for them to fulfill your order.
If we are involved in a merger, acquisition, a sale of all or a substantial portion of our assets, or other similar sale transaction, your information will be transferred as part of that transaction. We will notify you by email and/or a prominent notice on our website of any such transfer and any choices you may have regarding your information.
Lastly, if legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to courts of law, law enforcement authorities and other relevant third parties to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action or prevent harm to others.
This disclosure can include transferring your information to other countries outside the European Economic Area. To the extent we are legally permitted to do so, it is our policy to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena.
The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.
When we collect financial account information, such as credit card numbers, we protect its transmission through the use of encryption such as the Transport Layer Security (TLS) protocol.
TRACKING TECHNOLOGIES AND ONLINE ADVERTISING
MARKETING COMMUNICATIONS FROM US
You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at email@example.com.
We may contact you by telephone, with your consent where applicable, for marketing purposes. If you do not want to receive marketing calls, please contact us at firstname.lastname@example.org You do not need to agree to receive marketing phone calls or texts from us to use the Services.
INFORMATION FROM THIRD PARTIES
RETENTION OF PERSONAL INFORMATION
We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information in line with applicable law(s) or regulation(s).
LEGAL BASIS FOR PROCESSING YOUR INFORMATION
Depending on what information we collect from you and how we collect it, we rely on various grounds for doing processing your information under the GDPR, including the following reasons:
- In order to administer our contractual relationship, including setting up your requested Services, payments, renewals and processes;
- Because it is in our legitimate interest to run a successful and efficient business and provide you with the Services and other useful content;
- In order to fulfill any legal obligations we may have to collect this information from you; and/or
- Because you have provided your consent for us to do so.
Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. To exercise any of your rights, please contact us at email@example.com. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.
You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of personal information or its processing once received by the third party.
You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
You may request that we erase the personal information we hold about you in the following circumstances:
- where you believe it is no longer necessary for us to hold the personal information;
- we are processing it on the basis of your consent and you wish to withdraw your consent;
- we are processing your data on the basis of our legitimate interest and you object to such processing;
- you no longer wish us to use your data to send you marketing; or
- you believe we are unlawfully processing your data.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.
RESTRICTION OF PROCESSING TO STORAGE ONLY
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:
- You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
- We wish to erase the personal information as the processing we are doing is unlawful but you want us to simply restrict the use of that data;
- We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
- You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.
You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
THIRD PARTY LINKS AND INFORMATION COLLECTION AND USE BY OUR USERS
Some of our Services provide links to other websites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information.
You may also log in to some of our Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you with the option to share certain personal information with us, such as your name and email address to pre-populate our sign up form. For example, if you take advantage of certain of our social media features, such as the Facebook Like button, and widgets, such as the “Share This” button or interactive mini-programs that run on our site, the applicable social networking sites may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable it to function properly.
Our Services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us. If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files.
For transfers of personal information outside the EER but within the IPCOM Group, such transfer will be under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU.
For transfers of data to third parties outside the EER, such transfers will also be under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU.
You can contact us at firstname.lastname@example.org to obtain a copy of the data transfer agreement or more information regarding the relevant safeguard we put in place.
In the event that you wish to make a complaint about how we process your personal information, please contact us at email@example.com and we will try to deal with your request. This is without prejudice to your right to raise a complaint with the Belgian Supervisory Authority (www.dataprotectionauthority.be)
NOTIFICATION OF CHANGES
Last modified September 30, 2018.