IntelePeer takes its responsibility seriously to protect any personally-identifiable information to which we have access in conjunction with the provision of our products and services (“Protected Data”). IntelePeer commits to using any Protected Data collected only for the purposes of provisioning and enhancing our offerings to our customers, and to not using or sharing your information with anyone except as described in this Policy. For any questions about this Policy, please contact IntelePeer at email@example.com.
In this Policy, IntelePeer outlines our privacy practices, including how and why we collect, use and share any personal or sensitive data through our interaction with our customers and their users using our products, services, applications, customer portal, platforms and application programming interfaces (“Services”), as well as visitors to our website at www.intelepeer.com (“Website”). We can process your Protected Data in different circumstances and in different capacities, namely as a data controller in certain circumstances and as a processor in others. The Policy also describes your choices regarding use, access, deletion and correction of any Protected Data. As such, this Policy applies to our customers and their users or customers (“Customers”), along with all other individuals who are not our Customers but use the IntelePeer Website or Services for some legitimate purpose (“Users”).
IntelePeer obtains certain Protected Data, from you or automatically from your device(s), when using our Website or Services:
When we obtain your Protected Data, we will only use this Protected Data for the specific reason(s) for which it is collected and no other reason. Please note that the Protected Data collected by IntelePeer for the provision of our Services includes Protected Data about your customers, end users, employees, business associates, agents, any person you communicate with in the course of your business or any other User, to the extent those persons utilize our Services or systems, or their Protected Data is contained in the content of your communications to us as our Customer. Some applicable data privacy laws, like the EU, differentiate between “controllers” and “processors” of Protected Data. When IntelePeer processes Protected Data from our Customers about their customers or end users, IntelePeer generally acts as a processor, though we may act as a controller in some respects. For example, IntelePeer will need to use certain Protected Data for the legitimate interests of billing, reconciling invoices with underlying third-party providers, in the context of troubleshooting and detecting problems with the network or in connection with investigating or preventing network exploits, fraudulent activity or other security incidents. When acting as processor for our Customers, IntelePeer will adhere to the terms of this Policy, unless otherwise instructed by the Customer pursuant to our service contracts. Special Categories of Protected Data IntelePeer does not intentionally collect or process any special categories of data in the provision of its Services or Website. However, special categories of data may from time to time be inadvertently processed by IntelePeer where the Customer or User choose to include this type of data within the communications transmitted using the Services or Website. As such, the Customer or User respectively has sole responsibility for ensuring the legality of any special categories of data it or its Users choose to process using the Services or Website including without limitation any Protected Data which is likely to result in high risk to the data protection rights and freedoms of the Data Subject as defined by the EU Regulation 2016/679 (“GDPR”), and to promptly inform and provide IntelePeer with reasonable and timely assistance as IntelePeer may require in order to conduct any requisite data protection impact assessment and consultation with any relevant data protection authority. Our Services are for business enterprise customers and should not address or involve anyone under the age of 13 using our Website or Services, and we do not knowingly permit such usage. In the case we become aware that a child under 13 has provided us with Protected Data, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with Protected Data, please contact us so that we will be able to undertake necessary actions to address the situation.
Subject to the terms of this Policy, IntelePeer may use the Protected Data collected from our Customers or Users for a range of purposes, including to:
For any marketing materials sent, IntelePeer will only contact you pursuant to your marketing preference, and provide you an opportunity to unsubscribe from any further communications. IntelePeer will collect and process Protected Data from our Customers and Users when: (i) we need the Protected Data to perform our obligations under a contract for the provision of cloud communications services with connections primarily offered in the form of APIs, secured SIP trunking or dedicated circuits to or from other communications networks or storage facilities; (ii) we have obtained your consent to do so; (iii) required by law; (iv) our legitimate interests (as listed above or otherwise provided in writing) in doing so does not overridden by the data protection interests or fundamental rights and freedoms you have in the Protected Data. If Protected Data is required to comply with a legal requirement or enter into a contract, IntelePeer will advise you whether the provision of your Protected Data is mandatory and what the possible consequences are if the Protected Data is not made available. Access by Third Parties IntelePeer does not sell the Protected Data of our Users, Customers or our Customers’ customers or end users to any third party, or otherwise share Protected Data for those third parties’ own business interests unrelated to the provision of our Services or support. IntelePeer may employ third-party entities and individuals, including business partners, contractors, vendors, and authorized third party agents to perform certain functions or features of our Website or Services. Specifically, we rely on third-parties to:
IntelePeer strives to use commercially acceptable measures for securing your Protected Data, through employing current industry standards and state-of-the-art technologies, based on the sensitivity of the Protected Data being protected and the likelihood of any risk associated with such Protected Data. Such measures may include, as appropriate: (a) the pseudonymization or encryption of Protected Data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to Protected Data in a timely manner in the event of a physical or technical incident; or (d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing. However, we cannot guarantee that unauthorized access, hacking, data loss or data breach will never occur, so Customers and Users must inform IntelePeer without undue delay upon becoming aware of a security issue, and provide timely details and cooperation as IntelePeer may require in order for IntelePeer to address the issue and comply with all applicable data protection laws. Such details should include the possible cause and consequences, the categories of Protected Data involved, a summary of unauthorized recipients of the Protected Data and the anticipated mitigation measures. To protect Protected Data, IntelePeer utilizes technical and organizational safeguards, internally and with third-party vendors, both during transmission and in storage from accidental or unlawful destruction, as well as loss, alteration, unauthorized disclosure of, or access to the Protected Data. Such safeguards will take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, the risk of varying likelihood and severity for the rights and freedoms of natural persons, and any technical progress or further developments of such. A detailed description of the technical and organizational security measures implemented by IntelePeer can be found at www.intelepeer.com/privacy/TOMs (“Security Measures”), which IntelePeer reserves the right to modify the description and measures as needed, provided that such changes will not degrade the functionality and security of the Services. Customers and Users will be solely responsible for determining whether our Security Measures are suitable for its use, and implementing any additional safeguards necessary for its own adherence to applicable data protection laws. IntelePeer also will work diligently to remedy or mitigate the effects of any security incident, to keep impacted Customers and Users apprised of all developments in connection with the incident, and to treat information shared by Customers or Users in relation to the incident as confidential. IntelePeer also retains Protected Data for no longer than is necessary to fulfill the purposes for which the information was originally collected, unless a longer retention period is required pursuant to IntelePeer’s Record Retention Policy, or permitted for legal, tax or regulatory reasons, or other legitimate and lawful business purposes. The majority of the Protected Data associated with a Customer account will be stored for 7 years following the closure of the account, unless longer periods are required for accounting, tax, audit or other legal purposes. Any communications or interactions with our Support teams will be retained for 3 years. Where we have no ongoing legitimate business reasons or legal obligations to have your Protected Data, we will either delete or anonymize it for analytic purposes. If you ask IntelePeer to delete specific Protected Data, we will honor your request unless deleting that information prevents IntelePeer from complying with applicable law or its Record Retention Policy for carrying out necessary business functions, like billing for our services, calculating taxes, or conducting required audits.
Any users, including EU Data Subjects, may also at any time ask us to remove you from our marketing lists for promotional communications by sending us an email at firstname.lastname@example.org, and we will remove you from our lists in accordance with applicable laws. Please note that even if you opt out of, or withdraw consent for, promotional communications, IntelePeer may still send you non-promotional messages relating to updates to our services, security alerts, and other notices relating to your access to or use of our Services, or may continue processing your personal data based on other legal grounds, except for direct marketing. EU Data Subjects may also exercise additional rights to make a complaint to a competent data protection supervisory authority or commence proceedings in a court of competent jurisdiction in accordance with applicable data protection laws, or to engage an independent dispute resolution provider, at no cost to you, as part of our Privacy Shield. In compliance with the Privacy Shield Principles, IntelePeer commits to resolve complaints about our collection or use of your personal data for EU Data Subjects. If you are an EU Data Subject and IntelePeer has not addressed your Privacy Shield complaint to your satisfaction, please consult ec.europa.eu/justice/data-protection/files/annexes_eu-us_privacy_shield_en.pdf for more information on to file a complaint; provided that you have: (1) contacted IntelePeer and afforded us the opportunity to resolve the issue; and (2) contacted the U.S. Federal Trade Commission at www.privacyshield.gov/assistance and afforded the Federal Trade Commission time to attempt to resolve the issue. Filing such a complaint will be at no cost to you, except that each party will be responsible for its own attorneys’ fees. For EU Data Subjects, if neither IntelePeer, the Spanish Data Protection Agency nor the Federal Trade Commission resolves your complaint, you may have the possibility, under certain conditions, to engage in binding arbitration through the Privacy Shield Panel. Please note that making any changes pursuant to this Section may take up to thirty (30) days from the date of request. For any questions about this Policy, please contact IntelePeer at email@example.com.
For any questions, concerns or complaints related to this Policy or any requests pursuant to Section 4.5, please contact IntelePeer at firstname.lastname@example.org. VeraSafe has been appointed as IntelePeer’s representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR of the European Union. VeraSafe can be contacted in addition to email@example.com, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative or via telephone at: +420 228 881 031. Alternatively, VeraSafe can be contacted at: VeraSafe Ireland Ltd. Unit 3D North Point House North Point Business Park New Mallow Road Cork T23AT2P Ireland
In case you are unsure what certain terms mean within this Policy, we outline some definitions for you to reference. The following definitions apply for this Policy: