Last updated on 25 May 2018.
At THE REAL PBX LIMITED (“The Real PBX”), we respect your privacy and acknowledge that you have certain rights and we have certain obligations related to the information we collect from you. The Real PBX has put different procedures in place to meet the requirements of both the local and various international laws related to your privacy.
2.1 What personal data means?
The personal data means any information that helps directly or indirectly in the identification of any natural person. It may use or do not contain an identifier such as name, identification number, location details, an online identifier (such as email address, profile URL, and others), or any factor relevant to the social, cultural, economic, mental, genetic, physiological, or physical identity.
2.2 What is the sensitive personal data?
Sensitive personal data contains the above information but includes the following information specifically.
- Medical conditions
- Philosophical or religious beliefs
- Political opinions
- Ethnic or racial origin
- Any membership
2.3 What is Data Controller?
As per Article 4 of General Data Protection Regulation, the “data controller” determines the purposes and the manners to process the data.
2.4 What is Data Processor?
The “data processor” is either an organisation or a person who processes the personal data for the Data Controller.
2.5 What is the Data Processing?
It is an operation or set of operations performed upon personal data, or its sets, either manually or by automated systems. Article 4 in General Data Protection Regulation (GDPR) lists the Data Processing examples that include collection, storing, recording, structuring, organising, adapting, consulting, altering, retrieving, disclosing by transmission, using, disseminating or making available, combining or aligning, restricting, destruction, or erasure.
3. Information We Collect
3.1 Personal Data you provide
We collect the following information that you provide us directly when you use our Website, Apps, or Services.
- Name (including First Name and Last Name)
- Job Title
- Company Name
- Email Addresses
- Phone Numbers
- Information related to our services
- Marketing Preferences
- Credit Card, Banking, or other Payment Information
- Transactional Information
- Any communication, inquiry, or contact with us
- Other information you provide during the usage of our services
We use the above-mentioned personal data for that specific reason only for which you have provided it to us. If you want us to remove any personal information from our database, please contact us at firstname.lastname@example.org.
3.2 Account Information
We collect the following information when you create an account with us, modify the account, set preferences, or make purchases.
- Contact Information
- Billing Information
- Self-picture or Profile Photograph
- Job Title
- Or other required information
3.3 Information we collect automatically
When you visit our Website, submit a query on the Website, use our Chat, or use other services, we automatically collect information from your device (such as computer or smartphone).
NOTE: In some countries, including EEA (European Economic Area), this information is termed as personal data as per their data protection laws.
3.3.1 Usage Information
We track your activities when you visit our Website, use our Apps, or avail our Services. We collect following information during these activities and use them to make the proposed facility or service much better.
- Billing and payment details while making purchases on the Website
- Emails and other communications
- Device information such as hardware model, operating system, device identifier, phone number, and other configuration information
- Log information such as date/time stamp, operating system, browser details, content viewed on the Website, clickstream data (that helps in analysing the visited Web Pages and the order to visit them followed by a visitor), Internet Service Provider details, and other
- The Internet Protocol (IP) Address of device used to access our Website, Apps, or Services
- Communication logs such as SMS (text messages), voice broadcast, calls, and conferences taking place using our platform
- Metadata that contains information about other data, such as title, author, abstract, keywords, size, and others
3.3.2 Cookies and Other Similar Technologies
3.4 Information Obtained from Third-Parties
3.4.1 Information Received from Third-Parties for Marketing
We may collect the following information about the individuals from the public domain (such public databases or social platforms) and receive (purchase) it from third-parties to market our products.
- Name (including First Name and Last Name)
- Email Addresses
- Postal Addresses
- City and Country of office or residence
The collection, usage, storage, and processing of the above-listed information, and the marketing is performed in accordance with the applicable laws.
3.5 Information Received from Your-opted Third-Party Services
When you or your administrator link or integrate a third-party service with our Services, we may receive information that is controlled by your account or settings with the selected third-party service provider. It can be done for any purpose, such as accessing, storing, sharing, and editing content, connecting to calendaring services to allow you to manage the meetings, connecting to an address book service to allow you manage and use the contacts, and others.
4. Usage of the Information
We may use your information to deliver our services, personalise your experience, run marketing campaigns with third-parties, and for other purposes listed hereinbelow. These include our services you have opted, the way you are using them, and your preferences either set in your account with us or communicated to us through any channel.
4.1 Delivering Services
We may use the information to deliver you our services or their parts, for which you have subscribed with us. We use the information to identify you as our customer, authenticate you as a registered user, process transactions, deliver your opted services, provide customer care support, and maintain our deliverables. For example, the name and picture provided in your account are used to identify you and the provided login credentials are used to authenticate your login at our Website.
4.2 Personalizing User Experience
Your information is used to personalise the user-experience and improve your productivity and collaboration when you visit our Website, use our Apps, or avail our services. We automatically analyse the activities of you and your added team members to deliver the most relevant notifications and other feeds, activity logs, recommendations, connections, and search results. If you are using our multiple services, we combine your information and activities to offer you a unique user experience overall.
We may use the title of your name or domain name given in the email address to identify you or your affiliation with a specific organisation to personalise your experience and serve you relevant content when you visit our Website or use our services.
We may combine your pre-selected user role (such as an administrator or regular user) and your activities to show the information (like feeds or search results) that are very important for you. Similarly, we may hide administrative details from a normal user.
4.3 Marketing with Third-Parties
We have partnered with third-party marketing service providers to run our marketing campaigns through different channels including email. Third-party marketing providers or we may use your information for marketing of our products, services, offers, and discounts only as per your pre-selected marketing preferences and applicable laws. You can opt-out from our email marketing campaigns by clicking “Unsubscribe” link given at the bottom of any promotional email.
4.4 Other Specific Purposes
In addition to service delivery, personalisation of your experience, and marketing, your information is used for the following purposes specifically.
- Delivering our Website, Apps, or Services to you and your users or customers
- Administration, operating, protection, and maintenance of our Website, Apps, or Services
- Analysing your usage of our Website, Apps, or Services for user analysis, traffic analysis, monitoring trends, marketing, and advertising
- Improving our Website, Apps, or Services to enhance the user experience
- Processing and completing the transactions related to your purchases
- Delivering the support to you when you contact us in case of any help related to our Website, Apps, or Services
- Responding to your requests and inquiries to provide you with the requisite information and services
- Sending you communications through email or text messages such as transaction confirmations, invoices, administrative communication, security notifications, technical updates, and alerts
- Detecting and preventing unauthorised access, fraudulent practices, and illegal activities related to our Website, Apps, or Services
- Target Advertising and Marketing Practices as per your preferences and law
- For other purposes for which we have received your consent either through preferences or other mediums
4.5 Legal Basis to process Personal Information of Users of European Economic Area
The legal basis to collect and process the personal information of users of the European Economic Area depends upon the type of concerned information and the purpose to collect it. The Real PBX usually collects your information, including personal data, with your consent only. We may need this information to deliver you the requisite information or service as per a contract with you, or where the processing of your information is in our legitimate interests and is not overridden by your freedom, fundamental rights, or data protection laws. The Real PBX also has the legal obligation as per law to collect and process your personal information.
We may state the purpose to collect information at every instance, whenever we ask you to provide any personal information required either to offer you with your requisite service, or to enter in a contract with you, or to comply with a legal requirement. We may also advise you about the essentially required components of your information, including personal data, and consequences if you do not deliver the required information.
The use of your information, including personal data, by our third-party partners or by us are already listed in the “Usage of the Information Section”. If your information is used for other purposes by our third-party partners or by us, we will notify you about the purpose and interests at that instance.
If you need more information or have any query related to our legal basis to collect and use your information, contact us at email@example.com.
5. Sharing and Disclosing the information with Third-Parties
The Real PBX is not in the business of selling the personal information of anyone to third-parties including advertisers. Instead, we share your information with the third-parties only in the following situations.
5.1 Sharing Information with Our Other Users
When you start using our Services, we share some specific information related to you with our other Service users.
5.2 Sharing Information with Managed Accounts and Administrators
You register with our Services through an email address containing a domain name, which is owned by your organisation or employer. If such organisation may wish to create a site or an account, your information such as name, contact details, content, profile picture, and past usage of your account may be accessible to the administrator of that organisation and our other Service Users who are using the same domain name. If you are a group member, group owner, or administrator of a site or user group (created within our Services), your contact information may be shared to facilitate the Service-related requests with the group members who are present or past users of our Services.
5.3 Sharing Information with Third-Parties
We may share your information with the third-parties, who help us in operating, providing, improving, integrating, customising, delivering support, and marketing our Services.
5.3.1 Sharing Information with Our Service Providers
We may take services from third-party service providers for Website development, Application development, Website and Data Hosting, on-premises or virtual infrastructure, backup, storage, payments, analysis, and others. These services are necessary to run our operations. Our third-party service providers may need to access or use your information to deliver us our required services. Any access to our service providers to your information is made as per our close instructions, which are guarded by our policies and procedures to protect your personal information.
5.3.2 Sharing Information with Our Partners
We work with our third-party partners, who provide us technical services, sales, and consultation that enable us to deliver and implement the solutions related to our services. With your consent, we may share your information with our third-party partners as per their services.
5.3.3 Sharing Information with Third Party Applications
5.3.4 Sharing Information with Third Party Review or Social Media Sites
5.4 Sharing Information with Your Consent
We take your consent to share your information with the third parties for marketing purposes.
Example: After taking your consent, we may share your name, picture, and feedback on our Website for marketing purposes.
5.5 Sharing Information with Our Affiliates
5.6 Sharing Information with Business Partners, Vendors, and Authorized Third Party Agents
We may share and disclose your information to our business partners, vendors, or authorised third-party agents for the following purposes.
- Enforcement of our acceptable use policy
- Marketing, operating, delivering, improving, and customising our Services
- Providing technical and other support
- Sending marketing and other communications
- In connection with acquisition, sale, merger, reorganisation, or financing with prospective or actual selected companies
5.7 Sharing Information to Comply with Laws, Compliances, and Enforcement Requests
We have to share your information, including your personal data, with Government bodies, regulatory authorities, law enforcement agencies, Courts, or other third parties only if we have a good-faith belief that use or sharing of your information is really necessary due to any of the following reasons.
- Comply with a legal obligation or process, law, regulation, compliance, Court order, or a Government request for any reason or to meet requirements of National Security
- Enforce our terms of services, policies, and agreements
- Protect the integrity and security of our Website, Apps, or Services
- Protect our property, rights, and interests or those of third-parties
- Protect the public or our customers from fraud, harm, or other illegal activities
- Detect, prevent, or investigate the technical issues, frauds, or any wrongdoing related to our Website, Apps, or Services
6. Your Privacy Rights
6.1 Access and Update Your Information
- Wherever needed or where demanded by law, we provide you opportunities to access, view, modify and delete their own information that we are processing.
- You may also have wider rights to access, modify, and delete the personal information. You can also object and restrict the processing of your information or make a request for its portability. You can contact us at firstname.lastname@example.org to make such requests. We will treat all such requests as per the applicable laws.
- If you have earlier given your consent to us to collect, use, process, and share your information, you can withdraw your consent. Withdrawal of consent, neither affect the lawfulness of processing conducted before your consent withdrawal request nor affect the processing your information, including personal data, performed as per law requirements irrespective of your consent.
- You can complain to the Local Data Protection Authority at any time.
6.2 Your Privacy Rights as an EEA Person
We take the consent of our customers of the European Economic Area (EEA) before processing their information, and we do on their behalf only. As per any applicable EEA law, if you want to access, review, modify or delete your information that we are processing on another customer’s behalf, you have to contact that Customer to request the same. We can only help you and that customer to fulfil your request as per your instructions.
Also, as per any applicable EEA law, if you want to access, review, modify, or delete your information that we are processing on your behalf, please contact us at email@example.com.
7. Third-Party Sites
8. Security of Your Information
It is very important for us to secure your information, including your personal data, that we collect through our Website, Apps, or Services. We have put different standard administrative, technical, and other organisational security procedures in place to safeguard your information during transmission, processing, usage, and storage.
The Real PBX neither controls nor have responsibility for the security, privacy policies, and practices of other Websites that you may visit and use for different purposes, even if you visit them using the links given on the Website, Apps, or Services.
Please note that no online service, App, or Website is completely secure, still, we are committed to protecting your information through the above-listed measures. However, we cannot guarantee the occurrence of data breach, data loss, hacking, and unauthorised access.
9. Data Retention
The Real PBX will retain your information, including your personal data until the purpose for its collection is fulfilled unless a longer data retention period is really required or as such asked by the law (for regulatory, legal, tax, or different reasons), and other legitimate business requirements.
Where we have no continuously going on legitimate business purpose to retain or process or your information, we either anonymise or delete it.
9.1 Retention of Account Information
Your account information is retained for as long as your account is active with us. After the deactivation of your account, it is retained for a reasonable period in which you can decide to reactivate the account. If this period also expires, we delete most of the information, but we will retain some necessary parts of your information to maintain records, to meet the law requirements, to meet legal obligations, to enforce our agreements, to support business operations, to solve disputes, and to continue or improve our Services. Where we retain the account information to improve or develop our Services, we take steps to eliminate that part of the information that identifies you directly. We use and process information to know the collective insights of the usage of our services, instead of analysing specifically about your personal characteristics.
9.2 Retention of Information You Shared on Our Services
If your account on our Services is disabled or deleted, still some of your content and information that you have provided will remain so that the other members of your group and other users continue to make full use of our Services. For example, we have to display the content that you have shared and messages that you have sent to the users even after disabling or deletion of your account.
9.3 Retention of Marketing Information
If you have opted to receive the marketing communications, including email or text messages, we retain your marketing preferences and other information for a specific period starting from the date when you last displayed interest in our Website, Apps, or Services, or stopped using your account.
9.4 Retention of Information received from Cookies and Other Similar Technologies
We retain information received from the cookies and other similar technologies for a fixed specific period starting from the date when such information was collected at first.
10. Access and Control Your Information
You have the following choices to access and control your information, including personal data, which we collect, store, use, and process.
10.1 Your Choices
You can make the following requests related to your information, including personal data.
- Request a copy of your information
- Request for the restriction or deletion of your information
- Request to receive your information in an electronic and structured format
- Raise objection to our use of your information (such as information for marketing)
We have mentioned hereinbelow the processes and tools to make these requests.
If you are a member of a user group created in our Services, your information and opted Services are being administered by a Group Administrator, so at first place, you have to contact your Group Administrator for such requests. We would in such a situation where you face any issue in getting your such request processed by a Group Administrator.
For all other requests, you have to contact us at firstname.lastname@example.org.
Please note that your choices and requests may be limited in some specific cases, such as if meeting your request can disclose information about other persons, or if you request to delete the information that your Administrator or we have compelling legitimate reasons or permissions as per law to keep that information. If you have asked us to share your information (and personal data) with third-parties (for example by installing third-party apps in our Services or integrating our services with third-party), you have to contact those third-parties directly to make requests to access, review, modify, restrict, or delete your information.
If you have a concern or issue related to your information, including personal data, please contact us at email@example.com. If your concern remains unresolved even after contacting our dedicated Privacy Team, you can raise a complaint to a Data Protection Authority in the country where you live, work, or where your right was infringed.
10.2 Access and Update Your Information
In our Services, we give you the options to access, review, and modify your certain information. Such as you can access and modify your profile information in your Account Settings and search for the content that may contain your information using the text-based search in our Services. The content containing information about you can also be edited using the provided tools in our Services. If you need any help to access or update your information, please contact us using the details given at “Contact Us Page” of this Website.
10.3 Deactivate Your Account
If you do not want to use our Services, you or your administrator on your behalf can contact us using the details given at “Contact Us Page” of this Website to deactivate your account. Please refer to the “Retention of Account Information Section” to know about the retention of your account information.
10.4 Request to Stop Us from Using Your Account
In some cases where you believe we do not have rights, you can request us to stop storing, accessing, using, and processing your information, including your personal data. For example, if you believe that your account has been created on our Services without your permission or if you are no more using our services actively, you may request us to delete your account. If you had earlier given consent to use the information towards a limited purpose, you might contact us to withdraw your consent, but it could not affect any processing or usage of your information that has been taking place already. You can click “Unsubscribe” link given at the bottom of promotional emails, being sent as a part of our Marketing Campaigns.
We need time to investigate, process, and facilitate such opt-out requests. If there is any delay or dispute (as to our rights to use your information) related to your such opt-out requests, we restrict any further processing or usage of your information until your request is honoured or the dispute is resolved unless your administrator has any objection.
If you want to object to the information being shared with a third-party service or app, you or your administrator can either disable such third-party app or service or contact us to get it disabled.
10.5 Opt-out of Communications
To opt-out from our promotional marketing campaigns, you can click “Unsubscribe” link given in each promotional email sent to you. You can update the email preferences in your account settings, or by contacting us at firstname.lastname@example.org. You can also opt-out from some notifications in your account settings itself. Even if you opt-out from receiving promotional emails and messages, you will continue to receive the transactional communications related to our Services.
11. International Data Transfers
Your information, including your personal data, may be collected in, stored in, transferred to, or processed in the countries different from the country where you live, work, or where your right was infringed. Your information collected outside European Economic Area (EEA) specifically can be transferred to or stored on our servers located in countries where The Real PBX, our group companies, our partners, or other third-parties operate. The Data Protection Laws of these countries can be different to Data Protection Laws of your country, and these may not be as much protective as your country’s laws in some cases.
12. Children’s Privacy
The Real PBX does not create or offer products or services, which are designed to be used by or take information whatsoever from the children below the age of 16 years. If you believe that information or personal data of a child below 16 years of age has been shared or disclosed to The Real PBX, please contact us at email@example.com.
14. Contact Us