Ring2 Privacy Policy

Version 2.9, last updated 11 August 2008.

IMPORTANT: If we only process your personal data pursuant to an agreement with you or your employer, parts of this policy may not apply and the agreement in question will contain provisions on data protection and privacy. In that instance, you or your employer will be the ‘data controller’ and we will be a ‘data processor’.

Introduction

References in this policy to ‘us’, ‘we’ and ‘our’ are references to Ring2 Communications Limited (‘Ring2 Ltd’) and/or Ring2 Communications LLC (‘Ring2 LLC’), according to the context.

Ring2 Ltd (of 12 Tokenhouse Yard, London EC2R 7AS, UK) is registered in England, company number 4677393. Ring2 Ltd is notified with the UK Information Commissioner, number Z855314X. Ring2 LLC (of 400 2nd Street, Suite 450, San Francisco, CA 94107, USA) is Ring2 Ltd’s subsidiary in the United States of America and is a company registered in Nevada.

We take privacy and data protection seriously and comply with the relevant US, EU and UK data protection laws. This policy applies to any of your personal data we may collect or receive about you, through your use of www.ring2.com or www.calleffect.com, as amended or replaced from time to time (‘our website’), your use of our services (including the Ring2 Conferencing™ and CallEffect™ services) or otherwise. This privacy policy informs you of our practices and policies regarding how your personal data is collected and used, your related rights and how you can exercise them.

By visiting our website or using our products or services, you agree to our processing your personal data and sensitive personal data in accordance with this policy. By continued visits to our website or continued use of our products or services, you agree to our processing your personal data and sensitive personal data in accordance with the most recent policy then posted on our website.

We may change this policy at any time by posting a new policy on our website. Any change will take effect from the date it is posted on our website. It is your responsibility to return to this policy online from time to time and check for changes.

Who is the data controller?

If you are based in the USA or Canada, Ring2 LLC will be the data controller. Otherwise, Ring2 Ltd will be the data controller.

How do we collect personal data?

We may collect or receive personal data about you from a number of sources, for example:

You may contact us with an enquiry and provide us with your name, contact details and other information.
In the course of further communication with us, you may provide us with a range of personal data, for example: your name; contact details for work and/or home; employment details; financial details for credit checks and payment processing; and other information for security issues, such as your date of birth, usernames, passwords and password reminders.
We may receive personal data about you from third parties such as credit reference agencies or from your friends for example under our “Tell a Friend” service.
When you visit our website, we may collect information about your visit such as your IP address and the pages you visited. (This may not be personal data as you may not be identifiable from such information.) We may analyse such information, for example for technical purposes and to improve the customer experience.
You may provide us with information such as your name or phone number, when using our service, whether as a customer or a participant on a customer’s conference call or by making a call using our CallEffect service.

Cookies

Our site uses ‘cookies’, which are bits of information stored on your computer. The main function of cookies is to allow websites to recognise one visitor from another so they can tailor the visitor’s experience. We use cookies to help provide you with our services, for example by storing certain account or call information on your computer, and we may analyse the cookies, for example to improve the customer experience.

You can set your internet browser to reject cookies, although that will usually affect your experience when you visit websites and use our services. You hereby consent to our use of cookies as required to provide you with our services.

How we use your personal data

We will use your personal data in the course of our business, including without limitation to:

communicate with you directly and to respond to your communications to us;
provide our website, our products or services to you (and to your employer if the relevant agreement is with them) and bill you or your employer accordingly;
analyse our business looking at technology, performance, customer service, marketing, finance, billing, the prevention or detection of fraud, etc;
share it with our offices worldwide and third parties as described in this policy; and
we may communicate with you about the same or similar services that we offer, or services of third parties that we carefully select and believe will be of interest to you. If we do so, we will provide you with an easy and free way to opt-out of receiving such communications in the future.

At all times we will keep your email address and other personal data confidential.

The Conferencing Service “Live Call Status”

When you use our conferencing service, you may provide us with your name or phone number, for example when requesting a toll-free call-back to join a conference call from our website. Unless you inform us otherwise using the method provided, we will display your name or phone number to the customer hosting the conference call (the “call leader”) and to the participants on that conference call. In addition, Live Call Status shows you if colleagues within your Ring2 account are on your call; and we do this by a look-up against numbers registered with us by you and others within your account. We may also carry out a look-up against a third party database and, if so, we will do so according to all applicable laws, we will disclose the minimum information necessary, and we will ensure that the third party maintains the confidentiality of that information. We include available name and number information in our call history report to the call leader after the call and as set out in this Privacy Policy to bill our customers and for our record purposes as described in this policy.

The CallEffect™ Service

The CallEffect service operates within a third-party application or “TPA”, such as your online CRM service, and allows you to initiate calls by clicking within the TPA, but taking the call on your normal landline or mobile phone. CallEffect then logs the call within the TPA, together with any notes you may make, for productive call history analysis and activity reporting. As such, you will be transferring certain user data from the TPA, normally the names and phone numbers displayed within the relevant webpage of the TPA, to our system for us to present you with the calling option and to connect the calls. Once the user data leaves the TPA, it is no longer governed by the third party’s privacy policy; instead it is governed by our contract with you, and protected as part of our continuing data security practices.

The “Tell a Friend” service

If we receive your personal data from a subscriber using our “Tell a Friend” service, we will only send you one email with your friend’s message and details on how to sign up to our service. We will only retain your personal data for the purpose of checking that we do not send you another email under the “Tell a Friend” service and no further use will be made of your personal data received as part of the “Tell a Friend” service. Any personal data that we receive other than through the “Tell a Friend” service (for example if you become a subscriber or provide us with personal data yourself) will be handled according to this privacy policy.

What we do not do with your personal data

We will not sell or rent your personal data to third parties for marketing their services to you or for any other statistical purpose.

We do not have a service on our website similar to a chat room, nor do we accept advertising from third parties. Therefore, other than as described in the Live Call Status section above, when you visit our website your personal data will not be shared with other visitors to the website, and at no time will it be shared with any third party advertisers.

How we may disclose your personal data

As an international company, we will share information, including your personal data, between our offices around the world (for example, between Ring2 LLC in the USA and Ring2 Ltd in the UK). All our offices worldwide comply with this privacy policy.

We may also share your personal data with a limited set of third parties such as our partners, contractors and agents in the course of our business (for example in providing services to you or analysing our performance) or during commercial negotiations with third parties for the sale or purchase of all or part of our business. If we sell a business to a third party, we will disclose the personal data to that third party as part of the business assets under conditions of confidentiality and they will be bound by our privacy policy that applies to that data.

We may carry out a credit check on you either before agreeing to provide products or services to you or your employer, or during the term of any resulting agreement, if we determine it is reasonable to do so. That would entail disclosing your personal data to third parties such as credit agencies and financial institutions.

We may use any communication you send to us as part of our marketing activities, for example as a testimonial. If we do so, we may refer to your style, initials and your country or state (for example: Mr JK, FL); we will not disclose your full name or address or other personal data unless you have given us your prior consent.

We may be obliged to disclose your personal data to comply with any law, order or request of a court, government authority, other competent legal or regulatory authority or any applicable code of practice or guideline.

International transfers (including outside the EEA)

In order to provide our services to you, and to provide for disaster recovery and business continuity, we may share your personal data between our offices and group companies, including Ring2 Ltd in the UK and Ring2 LLC in the USA. Ring2 Ltd and Ring2 LLC have signed the European Model Clauses on transfer of personal data outside the EEA. We may also share certain of your personal data with the third parties described in the section above, who may be outside the USA, the European Economic Area and in countries whose laws do not provide adequate protection to personal data (as determined under EU or UK law). In such cases we will take steps to ensure that appropriate security measures are in place to protect your personal data. You hereby confirm your consent to international transfers as described in this privacy policy.

Sensitive Personal Data

As the nature of our business is to provide you with communications services, we are unlikely to ask for or receive ‘sensitive personal data’, such as information about your health, political opinions, racial origins or sexual life. However, if you do provide sensitive personal data to us, or we receive it from another party, we will only deal with it, share it or transfer it in accordance with this policy, including transferring it to our offices or the third parties described above, inside or outside the EEA in the situations described above. You hereby confirm your consent to such use and transfers of your sensitive personal data.

Other use or disclosure

We will give you the opportunity to choose (opt-in) if we wish to use or disclose your personal data or sensitive personal data in a manner not in accordance with this policy.

Retention of personal data

We will only retain personal data for a reasonable period based on need, for example to use that particular data as described in this policy or to comply with any law, order of a court, government authority, other competent legal or regulatory authority or any applicable code of practice or guideline.

Security

The security of data is central to our business and we have taken appropriate technical and organisational measures to safeguard your personal data.

For example, when you provide communicate with us through our website, or transmit information to us using our products and services, we encrypt that communication or transmission using industry-standard 128-bit Secure Socket Layer encryption. In addition, our data-centres are protected by industry-standard firewalls and their physical locations have appropriate security procedures in place. We keep these security measures under review so that we appropriately protect your personal data.

We can only be responsible for systems that we control and we would remind you that the internet itself is not a secure environment. So when you send us an email, that communication may only be encrypted if you use the necessary software.

Your rights - access, correction, copies

You are entitled to know if we are processing any personal data about you and, if we are, with certain limitations, to a copy of that personal data. We will ask you to prove your identity and to pay an administration fee of ₤10 if Ring2 Ltd is your data controller or $10 if Ring2 LLC is your data controller. You can also ask us to remove or correct inaccurate personal data that we hold about you and ask that we do not use your details to contact you for marketing purposes.
You can exercise these rights by contacting us by email at submitting our web form or by post to the Privacy Officer at Ring2 Ltd or Ring2 LLC, depending on which is your data controller.

Information you give to us

If you provide us with personal data for another person, you warrant to us that you are authorised by that other person to provide us with that information. We have an obligation to ensure that the personal data we hold is accurate. You therefore must ensure that any personal data you give us is accurate and up-to-date.

Monitoring communications/recording calls

As part of our service, we allow you to record calls. If you use our service to record calls, you warrant that you have the consent of all parties on each call in question to record that call and that you will only use such recording in accordance with all applicable laws, including data protection laws.

We reserve the right, in accordance with applicable law, to monitor or record any telephone call or other communication with us or over our systems, website, products or services, for example for training purposes, monitoring the quality of customer services or where a recording has been requested by you or a party to your communication. We will notify you when a recording is taking place as required by law.

How to exercise your right to opt-out

Presently, we do not send marketing communications to you. If we do send you any marketing communications in future, we will provide you at that time with an easy and free way to opt-out of receiving such communications.

Contact and complaints

You can contact us with questions or complaints by submitting our web form or by post to the Privacy Officer at Ring2 Ltd or Ring2 LLC, depending on which is your data controller. You are recommended to raise complaints with us first, but this policy does not affect your right to notify a complaint to any third party such as the UK Information Commissioner (www.informationcommissioner.gov.uk) at any time.