IntelePeer, Inc. Website Privacy Policy

Effective October 23, 2009

I. Our Commitment to Privacy

IntelePeer, Inc. (“IntelePeer”, “we”, “us” or “our”), is committed to respecting and protecting your privacy. IntelePeer has developed this Privacy Policy (“Privacy Policy”) to ensure your personal information is protected. The Privacy Policy discloses the information we gather on www.intelepeer.com (the “Site”), as well as ways in which we process and, share such information and how you can correct or change such information. Except where otherwise expressly indicated herein or on the Site, this Privacy Policy applies only to information collected on the Site and does not apply to information collected outside of the Site.

This Privacy Policy addresses our privacy practices relating to the general use of our Site by anyone who visits, browses or otherwise uses the Site (“Browsers”) as well as our customers (collectively, “Users”). Before submitting information to the Site, please read this Privacy Policy. By visiting the Site, submitting information or using any of our products or services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and processed in the United States. If you do not agree to this Privacy Policy, please do not use the Site. In the case of any direct conflict between the terms of this Privacy Policy and any other agreement between you and Us, the terms of such other agreement shall control but only to extend applicable to the conflicting provisions.

II. The Information We Collect

The Site is intended to provide a unique, educational, and informational experience for Users without requiring them to submit any more Personally Identifiable Information (“PII”) than is necessary to use the Site effectively. We do not require Users to register or submit PII in order to visit the Site. Some activities on the Site can be performed without providing PII. When we ask for PII to participate in an activity, we will not require anyone to disclose more PII than we believe is reasonably necessary to participate in the activity. We collect the following categories of information from our Users:

  • A.    Personally Identifiable Information (“PII”)We may receive and store any information you enter on the Site or provide to us in any other way through or via the Site that would allow us to identify you personally or contact you. The PII you provide to us only will be used by IntelePeer in accordance with this Privacy Policy. Examples of PII we may collect from you:
    • your name, address, phone number(s), company name e-mail address, and/or country
    • PII you provide about yourself when you send us an e-mail.

    You can choose not to provide us with certain PII, but then you may not be able to take advantage of all of the services and products offered on the Site.

  • B.    Passive Gathering of Information Electronically
    1. CookiesDuring the course of any visit to the Site, the pages you see, along with something called a “cookie,” are downloaded to your computer. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. These cookies do not contain or collect any PII, but they do enable us to provide features such as personalization. Most web browsers automatically accept cookies, but you can usually change your browser to limit or prevent cookies. Cookies in themselves do not personally identify the individual user, but rather the computer used by the individual user. Users may have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or to not receive cookies at any time. Different browsers may address cookies differently. If you set your browser to not accept cookies, it may result in certain personalized services not being provided to users of that computer.
    2. Web BeaconsA web beacon is a transparent image file. Web beacons enable IntelePeer to track website usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer. They may be used in association with cookies to understand how visitors interact with the pages and content on the pages of the Site.Web beacons also may be used to track whether you have opened an HTML email. When the email is opened, a part of the code that makes up the HTML page calls a web server to load the web beacon which then generates a record showing that the email has been viewed. Web Beacons may also recognize when the email was opened, how many times it was forwarded and which URL’s (links within the email) were clicked.We do NOT use web beacons to collect or otherwise record any type of PII provided by or about any User.
  • C.    E-mail CommunicationsWhen you send an e-mail to IntelePeer, we may retain your e-mail address and the contents of the e-mail you send.
  • D.    Non Personally Identifiable InformationFrom time to time, we may also ask you to provide us with non-PII which is data that does not allow us to identify you personally, such as your first name or zip code. Your non-PII may be aggregated and used for our internal purposes or for creating reports for third-party advertisers and partners, or otherwise shared with third parties for any lawful purpose, without your permission. No third party will know who you are as a result of the use of your non-PII.We also may automatically collect Site usage information, such as the numbers and frequency of Users to the Site, pages visited and similar data. This data is used in the aggregate, that is, as a statistical measure, and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and web beacons as discussed above. This aggregate information helps IntelePeer determine general usage patterns and modify the Site in order to improve your experience. This type of aggregate information may be shared with third parties at any time.

III. How We Use Information

When you provide us with your PII, we may use such information for a number of purposes, including:

  • To facilitate communication between IntelePeer and Users including, without limitation, responding to Users questions or comments, sending e-mails concerning our products and services, including the IntelePeer Newsletter, or to contact you for feedback regarding us, advertisers or business partners.
  • To provide Users with important functionality changes to the Site, new IntelePeer services and special offers from IntelePeer and reputable third parties that we think you will find valuable
  • To customize, analyze, adjust and improve the Site to meet our Users’, advertisers’ or business partners’ needs and expectations;
  • To enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws;

IV. Disclosure of Information To Third Parties

IntelePeer may give, share, sell or trade your PII to or with any third parties under the following circumstances:

  • A.    Fulfillment of ServicesWe may retain other companies and individuals to perform certain functions on our behalf. Examples include, but are not limited to, companies that help to administer the IntelePeer accounts, surveys, email newsletter or promotional activities, shipping companies that deliver products, third party advertisers or promotional partners who provide a product or service to you, customer support specialists, web hosting and internet service companies, and data analysis firms. Such third parties may be provided with access to PII needed to perform their functions but may not use such information for any other purpose.
  • B.    Compliance with Law and Fraud ProtectionWe may disclose any information, including, without limitation, PII, that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We may also exchange information, including, without limitation, PII, with other companies and organizations for credit fraud protection, risk reduction and related activities or to protect the rights, property of safety of IntelePeer, its agents, employees or affiliates or others. IntelePeer reserves the right to disclose PII for a User who we believe is in violation of our Privacy Policy or other terms of service as posted on the Site, even without a subpoena, warrant, court order or other governmental request.
  • C.    Sale or Transfer of InformationIn the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets of IntelePeer or the Site, PII and/or other information collected about you from the Site may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of IntelePeer or the Site in order to permit the party to continue the operation of IntelePeer and/or the Site or any successor version of the Site. You consent to the sale and transfer of your information as described in this paragraph.

V. IntelePeer Newsletter

If you choose to subscribe to our Newsletter, we will collect your email address and share it with our email vendor for delivery of the Newsletter. In each email you receive, there will be a link to unsubscribe if you no longer wish to receive the Newsletter.

VI. Important Disclosures, Practices and Contact Information

  • A.    Third Party Links and Third Party AdvertisementsThe Site may contain links to third-party websites. Please be aware that we cannot control and are not responsible for the information collection practices of such websites, which may differ from those of IntelePeer. We encourage you to review and understand the privacy policies of these web sites before providing any information to them.
  • B.    Data SecurityWe maintain a variety of commercially reasonable physical, electronic and procedural safeguards designed to protect your PII from unauthorized access and disclosure. For example, we use industry accepted tools and techniques to protect against unauthorized access to our systems.You should be aware, however, that IntelePeer has no control over the security of other websites on the Internet that you might visit even when a link may appear to those websites from our Site. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII.We want you to feel confident using the Site. However, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your information, we do not promise, and you should not expect, that your PII, searches or other communications always will remain secure. In the event of a breach of the confidentiality or security of your PII, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you. Users should also take care with how they handle and disclose their PII. Please refer to the Federal Trade Commission’s Web site at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.
  • C.    ChildrenThe Site is restricted to Users and not intended for persons under the age of 18. IntelePeer does not knowingly market to, or solicit information, accept service or collect information from any person under the age of 18. If we become aware that any person submitting information to a Site is under the age of 18, we will attempt to delete the account and any related information as soon as possible. We require that only persons 18 years of age or older use the Site. By using the Site, you hereby represent that you are at least 18 years old.
  • D.    Changes to this Privacy PolicyWe may occasionally update this Privacy Policy to reflect changes in our practices. When we post changes to this Privacy Policy, we will revise the updated date at the top of this Privacy Policy. If we make any material changes to our Privacy Policy, we will notify Users by sending an e-mail to the e-mail address(s) provided to us by the User, and by prominently posting notice of the changes on the Site. We will give you an opportunity to opt-out of any materially changed Privacy Policy or alternatively, delete the information you have provided to us. We recommend that you check the Site from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.
  • E.    Users From Outside the United StatesThe Site is hosted in the United States and is governed by United States law. If you are visiting the Site from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Site, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.
  • F.    No Rights of Third PartiesThis Privacy Policy does not create rights enforceable by third parties.
  • G.    Contacting UsIf you have any questions about IntelePeer generally, this Privacy Policy or the Site, please feel free to contact us either by sending an email to info@intelepeer.com or by regular mail by sending a letter to us at:IntelePeer, Inc.2855 Campus Drive, Suite 200San Mateo, CA  94403