Effective Date: 22nd May 2018
Blueface Limited (hereinafter referred to as “Blueface” “us” “we” or “our”) is dedicated to bringing a superior IP telephony experience to its customers. In providing that experience, Blueface is committed to respecting your privacy and to complying with all applicable data protection and privacy laws.
Data We Collect
We may collect the following type of information from you:
- All information you choose to provide Blueface (e.g., name, address, telephone number, email address, payment details, and images);
- Your employee names, extension numbers, direct inwards dials, and email addresses which are used to configure and maintain the Blueface system;
- Information about how you use our services such as information generated when you or your employees use our services to make a phone call;
- Information needed to transfer your existing telephone numbers to us, including your existing account number from your existing carrier as well as copies of your telephone bills; and,
- All information that may be collected using cookies or other technology when you use, access or interact with us via our website or other online services that we provide.
Acquisition of Data
- All data will be obtained in a lawful, transparent and fair manner. We will make you aware of all purposes for which we intend to use your data at the time of collection.
- Data will be acquired, processed and stored in a manner that respects your legal rights and the legal rights of all data subjects.
- Data will be obtained with your express consent and may be provided to us by a third party or your employer.
- In some cases, we collect data to fulfill legal or contractual obligations, including information provided about a data subject from the data subject’s employer.
- Data will be adequate, relevant, and not excessive in relation to the purposes for which it was obtained.
- All acquisition methods (e.g., written forms or online forms) will have a clear information piece explaining any intended purposes.
- We may collect about you in different ways, including:
- From your direct communication with Blueface, e.g., via fax, email or instant message;
- Directly from you, such as where you are receiving services from us, directly or through the use of our third party service providers;
- From forms you complete and submit to us (online and on paper);
- From calls that may be recorded with your consent;
- From voicemail messages that you leave with us;
- From your employer, if they provide us certain details to assist in the configuration of the services or to create a user account for you;
- From third parties, such as authorised resellers, wholesalers, partners, service providers, or your appointed representatives.
Use and Processing of the Data We Collect
- Purposes for which we hold your data:
- To communicate with you;
- To administer, manage and support the products and services we are providing to you;
- To promote the safety and security of our products and services by investigating any suspicious activities or violations of our policies;
- To personalise your visit to our website;
- To track your movement through our website to better understand and improve our site;
- To notify you of competitions, ezines, or other promotions;
- To provide you with marketing or product information;
- To notify you of any changes to our products and services;
- To provide information to our advertisers and business partners;
- For the performance of any request by or contract with you;
- For training of our employees and to help ensure the quality of your experience when contacting us; and
- As permitted or required by any law applicable to us or arising from your interaction with us.
- All data will be processed fairly and in keeping with the purposes for which it was obtained. All such processing will take place in full compliance with all applicable laws.
Disclosure of Data
- Data will not be used, disclosed or processed in any manner incompatible with the purposes for which it was obtained or in violation of your legal rights as a data subject.
- Disclosure of data will only be made to third parties who are our agents or servants acting on our directions.
- No disclosure of your data will be made to third parties for those third parties’ purposes or use, except as required by law (e.g., criminal investigations).
- Under no circumstances will lists of customer data/information (i.e., mailing lists or database information) be disclosed to a third party for that third party’s exploitation or use without your express permission. Data may be legitimately given to our affiliates, servants or agents for legitimate purposes as described above. This may include the transfer of data to other jurisdictions for processing. In these circumstances, we will ensure that adequate contractual and technical safeguards are in place to protect your data.
- If data has been obtained for a purpose without advising you of other compatible secondary purposes for which it is subsequently to be used, the data will not be so used without advising you.
- For our Irish-based customers, where you have agreed to be in included in our directory enquiry list your information will automatically be included in the National Directory Database (NDD) currently hosted by Eir (as nominated by the Commission for Communications Regulation (ComReg). We will automatically list you as preferring to receive direct telemarketing from third parties. Contact us at firstname.lastname@example.org if you would like to amend this preference.
Retention Of Data
- Data will be kept only for clearly stated and lawful purposes.
- Data will be kept, and in a manner that respects your legal rights as a data subject.
- Data will be kept for no longer than is necessary for the primary purpose for which it was obtained.
- Data will be retained for the period required or permitted by law.
- Some data that is not otherwise subject to retention for normal reasons may need to be retained in exceptional circumstances, such as litigation or government investigation.
- Depending on the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of the web browser for specific details about cookie security.
Access to your Information
- You are entitled to copies of your data kept by us. Requests should be in writing and should be addressed to Blueface Privacy Team, Blueface Limited, 10/11 Exchange Place, IFSC, Dublin 1. Please quote your name, address and your Blueface Account Number. We will take all reasonable steps to confirm your identity before releasing the requested data. Upon your request, we will undertake to supply copies of your data in user-friendly form.
- You can withdraw your consent to our processing of your data at any time. To “opt-out” of (a) any consents previously given to us by you, (b) receiving communications from us, or c) having personal information disclosed to third parties, please send an email to email@example.com.
- Notwithstanding the above, Blueface retains the right to collect, maintain, and process information provided by you and collected about you on and through our website, and disclose this information to the extent required to comply with our reasonable business and legal obligations, including to provide our products and services.
- If you chose not to provide certain information to us, we might not be able to provide you with the products or services you require or it may impact our ability to respond to your needs.
- Any complaints may be directed to the Data Protection Commissioner. Further information on your data privacy rights is located at www.gov.uk/data-protection.
- We are constantly reviewing and enhancing our technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction. We use industry standard secure sockets layer (SSL) technology, for example, to encrypt information we deem sensitive, such as your credit card and other financial information.
- Please be aware that communications over the Internet, such as emails or instant messages, are not secure unless they have been encrypted. For example, your emails or instant messages may route through a number of countries before being delivered – this is the nature of the Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
- We care about the safety and privacy of children online. Accordingly we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA, and its accompanying regulations, protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. Our website is not intended to solicit information of any kind from persons under the age of 18.
- It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to firstname.lastname@example.org.
- This policy should be read in conjunction with terms and conditions that apply to your use of Blueface’s telephony services where more details of the use we make of your data are outlined. This can be found at www.blueface.com/uk/terms-of-service.