Privacy Policy

DATA SET	PURPOSE AND OPERATIONS	LAWFUL BASIS (per the GDPR)
Contacting Us, Requesting a Quote or Booking Demos If you voluntarily contact us for your interest in our services (for general inquiries or otherwise to receive a quote, “Starting a Free Trial”, booking a demo), for support, or for any other inquiry, including through any digital form  made available by us on the Website (e.g., “Contact Us”, or “Chat With Support”, request for a quote, etc.) you will be required to provide us with certain information such as your name, email address, phone number, company name, country, referral subject and other related data (“Contact Communications”).  If you are contacting us on behalf of another person, we value your assistance and care for others, but please note that it is your responsibility to make sure that any person whose Personal Data you provide is aware of the principles of this Privacy Policy and agrees that you will provide Personal Data to us on this basis.	We will use Contact Communications data to respond to your inquiry, including contacting you to provide you with the quote you have requested, schedule the demo, set up the free trial, or to provide you with information regarding our services. In addition, we may process Contact Communications data to send you additional occasional communications and updates related to our services, promotional and marketing emails (“Direct Marketing”). We may further process the content of our correspondence to improve our customer service, and if we believe it is required to provide you with any further assistance or to handle any dispute you might have with us (if applicable). We will collect the Contact Communications data, store it in our data systems, such as CRM or enterprise email, analyze it, provide access to our relevant staff members, and keep records of our correspondence as part of our business records keeping.	If you are not our Customer (e.g., you are a Visitor of our Website or anyone interested in our services), we will process Contact Communications data subject to our legitimate interest. If you are an actual Customer of our services contacting us for support or any similar inquiry, we will process your Contact Communications data for the purpose of performing the contract between us – providing you with our services. After addressing your inquiry, we may retain your Contact Communications data in our systems as part of our business records-keeping under our legitimate interest. Direct Marketing is based on our legitimate interest per applicable law, you may opt-out at any time through the “unsubscribe” link within the email or by contacting us directly. If you unsubscribe, we will further retain your email address, however solely as part of our internal suppression file to ensure we comply with such preference and choice, based on our legitimate interest.
Accessing our Services The Website contains a “Login” or “Billing Portal” button allowing Customers to access our service’s web-interfaces. In addition, our Customers may upload certain data to their account such as their authorized representatives’ name, job title, email address, phone number, and other similar contact information (including usernames, and other authentication and security credential information) (“User Account Data”).	We will use and process your User Account Data in order to designate your account and verify your identity through the username and password you have provided, monitor your activity through our security measures and tools, and manage your account within the relevant product. We will further use and process your User Account Data in order to provide you with better services, understand your needs and adjust our services to your needs and preferences. Note that, for such purpose, as a Customer, we may connect your data collected on the Website to your User Account Data. We may further process the email addresses provided as part of the User Account Data for Direct Marketing purposes (see above under Communications Data).	We will process your User Account Data for the purpose of performing the contract between us and as per our legitimate interest when it is related to improving our services as well as protecting, and ensuring the security of, our systems.  ** please note that any use of our services and the processing of User Account Data may also be subject to the separate agreement(s) between us and our relevant Customer with whom we engaged to allow the use of our products and services (“Account Owner”).
Subscribing to and Using N2P App If you purchase and register our N2P App through your Google account, we will receive and maintain certain data which may include your name, email, Google ID and other details regarding your use of the N2P App, management of your subscription and accounts, etc. In addition, we may collect certain usage data pertaining to your use of the N2P App, preferences, etc.	We will use such data to allow you access and use the N2P App. We will verify your identity, keep your preferences and usage history, secure the app, monitor it, maintain and support its usage, etc.  *** Please note that we will not use your Personal Data for any of our own purposes, including without limitation any marketing purposes.	We will process such data for the purpose of fulfilling the contract between us and as per our legitimate interest when it is related to improving our services as well as protecting, and ensuring the security of, our systems.  *** Please note that data processed on your behalf in our capacity as a data processor, such as your users (e.g., your organizations’ employees) data, is not controlled by us and is processed by us for the sole purpose of providing you with the services you have purchased.
Subscribing to our Mailing Lists & Events. In the event you sign up to receive our newsletter or marketing materials or any other marketing event ("Marketing Materials"), you will be requested to provide your contact details, such as email address.	We will collect and store your email address and additional data provided through the sign-up process to send you our newsletter and other Marketing Materials you have signed up to receive. We may further collect data related to your interaction with such Marketing Materials, for statistical analysis and to assess the performance of our campaigns, and for example, to understand how many users opened our emails, and to improve our content.	We process such Personal Data subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within any email sent to you or by contacting us directly. If you unsubscribe, we will further retain your email address, however solely as part of our internal suppression file to ensure we comply with such preference and choice, based on our legitimate interest.
Call records When contacting our customer support or when our sales team contacts you, (including when contacting you following submission of a contact us form, requesting a demo, etc.), we record the call (“Call Records”) and, in certain cases, transcript the call.	We use such Call Records and the transcript in order to manage, measure and improve our sales efforts and customer support service. We further use the transcript to summarize the call, to assist us in improving our customer service and to offer you additional support or offers following the call and based on the call content. The transcripts may be analyzed by a team member or by AI tools which we license. We make sure to use the AI tools that do not use the inputs (i.e., transcripts) for learning purposes, and commit to delete the inputs or outputs within 30 days.	Where required under applicable laws, we will process Call Records and use the transcripts subject to your consent which will be obtained at the beginning of our conversation. In all other cases, we will process Call Records and transcripts subject to our legitimate interest.
Recruitment Information In the event you apply for a job, we will collect your details as and to the extent provided by you, including resume as uploaded by you, including your name, email address, phone number, information regarding your education and skills, employment history, and your photo. Also, where allowed or required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability. In addition, we may collect further information from public and online sources, and former employers and combine such data with your other data (all together “Recruitment Data”). Further, we may receive information from third parties, such as recruiting agencies, about candidates interested in working with us. In such cases, we rely on the agreements we have with the third parties for obtaining your information.	We will process such Recruitment Data as part of our recruitment and screening efforts to decide whether you suit a position in the company. Also, sometimes we will process your Recruitment Data to enable us to comply with corporate governance and legal and regulatory requirements. After completing the recruitment process, we will retain the Recruitment Data as part of our internal record-keeping, including for legal defense from any future claim. If we hire you, your Recruitment Data may be used in connection with your employment and our corporate management. We will keep your Recruitment Data, analyze it, store it in our systems, use it to contact you for further recruitment steps (e.g., interview) and keep records of our interaction with you.	We process such Recruitment Data subject to our legitimate interest. In some cases, for example, where we ask you to provide health related data or diversity and inclusion data, in accordance with applicable law, we will process your data based upon your consent.   You may always withdraw consent at any time by contacting us. We will retain your Recruitment Data for record-keeping and future defense from legal claims under our legitimate interest.
Online Identifiers and Usage Data We may use third-party cookies and similar tracking technologies (tags, pixels, etc.) on the Website. As further detailed under the “Cookies Usage” section below, these cookies assist us with improving and protecting our systems and services, as well as being used for our marketing and advertising purposes. The Personal Data processed through our use of such cookies and similar technologies may include online identifiers, a cookie ID, IP address, etc., alongside the relevant data regarding your usage of the Website (e.g., date and time of usage, pages visited and actions such as the content/buttons you click, referrer webpage, user agent, etc.) (collectively “Website Interactions Data”)	We will use Website Interactions Data (collected directly or through the use of third-party cookies and technologies) to improve our Website, content and services, and for analytic, marketing and advertising purposes. We will aggregate and analyze the data to produce insights regarding your usage and your suitability for our services as a potential customer or contact point, as well as to measure the effectiveness of our features, content and marketing campaigns. We will use this data and insights as part of our marketing efforts, including remarketing to individuals who have accessed our Website. In addition, we process such Website Interactions Data for operation, Website functionality, security and fraud prevention purposes, debugging purposes and to resolve technical problems.	Strictly necessary cookies which are required for the proper and basic operation of the Website and security purposes will be processed under our legitimate interest. Other cookies data, including any targeting and marketing cookies, will be subject to a proper disclosure or consent mechanism (subject to applicable Privacy Legislation), provided through the cookie banner on our Website. You can change your preferences at any time through the Cookies Setting tool available on our Website. For more information regarding cookies, see the “Cookies Usage” section below.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. Transfer of Personal Data to third-party countries, as further detailed in the “International Data Transfer” Section below and where the GDPR applies, is based on the same lawful basis as stipulated in the table above.  

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of our service, as well as to protect the security or integrity of our databases and Website, and to take precautions against legal liability. Such processing is based on our legitimate interests. 

4. COOKIES USAGE

We use “cookies” (or similar tracking technologies such as pixels and tags) when you access and use our Website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your browser or device while you are viewing a website. Cookies are used for various purposes, and mainly, as follows: 

Essential/Strictly Necessary Cookies – which are strictly necessary for the Website to work correctly.

Functional Cookies – allows for enhanced functionality such as saving your language preference and enabling you to navigate between pages more efficiently.

Targeting/Marketing Cookies - used to collect information to help us improve marketing campaigns as well as to serve targeted advertisements.  

Social Media Cookies - Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn, etc.) enabling social media features such as log-in, sharing content, etc., as well as marketing and targeting campaigns.

Analytics/Performance Cookies - give us aggregated and statistical information regarding the usage of our Website (for example pages views, etc.) to improve the services and further develop them.

The cookies we use on our website are listed under our Cookies List, where you can further change your preferences, and restrict data collection by certain cookies by using our Cookie Setting tool available on the Website, provided however that strictly necessary cookies cannot be rejected.

In addition – if you wish to manage your preferences or opt-out of cookies –most browsers will allow you to remove cookies, block acceptance of cookies, or receive a warning before a cookie is stored. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. 

For additional information of our use of Google products, click HERE.

Please note that once you choose to opt out of or disable cookies, some features of the services may not operate properly and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.  

5. METHODS FOR COLLECTING YOUR DATA

According to the nature of your interaction with our Website and services available therein, we may collect information as follows:

Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as completing any contact form.

Provided by your admin as a Customer of any of our products and services – if you are a user of our services, some of your data, including data related to your User Account Data, may be provided to us through your admin., i.e., the relevant Account Owner.  

Automatically – we may use cookies and similar tracking technologies (as elaborated in the “Cookies Usage” Section above) to gather some information automatically when you access the Website.

Provided to us by third parties – as part of our digital marketing efforts as described above.   

6. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH

We share your data with third parties, including with trusted partners or service providers that help us operate our Website, provide our services and other business practices (such as marketing, etc.). Below you can find information about the categories of such third-party recipients.  

CATEGORY OF RECIPIENT	DATA THAT WILL BE SHARED	PURPOSE OF SHARING
N2P Group	All types of Personal Data	We may disclose some of our Customer’s Personal Data with our affiliated companies (in the N2P Group, to allow us to manage our business as a global group. Your data will always be managed under strict procedures and processes ensuring it is taken care of as required under law and with respect to your privacy and rights.
Trusted Agents and Service Providers	All types of Personal Data	We may disclose Personal Data to our trusted agents and service providers (including, but not limited to, our cloud service provider, our analytics service provider, our CRM provider, etc.) so that they can perform the requested services on our behalf. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.
Any acquirer of our business	All types of Personal Data	We may share Personal Data in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Legal and law enforcement	Subject to law enforcement authority request	We may disclose certain Personal Data to law enforcement, governmental agencies, regulatory authorities, traceback requestors or other authorized third parties, in response to a request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.

 

Where we share information as set forth above, we ensure they only have access to such information that is strictly necessary. Our service providers, agents, and affiliated companies are further required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

Please note that for the avoidance of any doubt, Personal Data originated from Google as part of the N2P App, is not used for any other purpose than the provision of the N2P App’s services and will not be shared with nor sold to any other third-party, including for any marketing purposes. 

7. INTERNATIONAL DATA TRANSFERS

The Company’s headquarters is based in Newark New Jersey, USA, and we operate from a few separate worldwide sites in which we may access the information stored on servers or other systems such as the Company’s ERP, CRM, and other systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law.

Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") or the UK is transferred outside of these territories to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union or other approved mechanism. Thus, we will obtain contractual commitments and/or assurances from the data importer to protect your Personal Data, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. 

8. RETENTION

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulations, or until you express your preference to opt out, where applicable.

The criteria used by us to determine our retention periods are as follows:

• We retain Personal Data for the periods needed to achieve the purpose for which Personal Data was collected. For example, Contact Communications data will be retained at least as long as necessary to address your inquiry.
• We retain Personal Data for the periods needed to comply with our obligations under applicable laws. For example, transactional data may be kept for up to seven years and sometimes more, in accordance with our bookkeeping obligations.
• If you have a dispute with us, we may retain certain types of Personal Data as necessary and as applicable to your claims, including any legal proceedings between us, until such dispute is resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the relevant correspondence for as long as needed to demonstrate compliance.

At our sole discretion, we may rectify or erase information from our systems without prior notice to you, once we deem it no longer necessary for such purposes.

Note that data regarding Customers’ access to their Account within our services will also be retained in accordance with the relevant Account Owner instructions, as the controller and legal owner of such data.   

9. SECURITY

We work hard to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. We have implemented physical, technical and administrative security measures for the Website and our systems storing Personal Data that comply with applicable laws and industry such as: encryption using SSL, we minimize amount of data that we store on our servers, restrict access to Personal Data to our employees, contractors and agents, etc. Note that we cannot be held responsible held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

We will make a reasonable effort to notify you and the appropriate authorities in relevant cases (if required by applicable law).

10. CHILDREN

Our Website and services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law which with respect to the EEA is under the age of 16 and with respect to the US, under the age of 13) and we do not knowingly process children’s information. We will discard any information that we receive from a user that is considered a "child" immediately upon our discovery that such a user shared information with us. Please contact us promptly if you have any reason to believe a child has shared with us any information. 

11. YOUR RIGHTS

Individuals have certain rights under applicable privacy laws concerning their Personal Data.

In the table below you can see the rights that may apply to you (subject to your jurisdiction and additional conditions), how you can exercise them, and appeal a decision we take in this regard: 

RIGHT TO BE INFORMED	You have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy. If you have any additional questions, please contact us at: Privacy@net2phone.com.
RIGHT TO KNOW, ACCESS RIGHTS	You have the right to confirm whether we collect Personal Data about you and to know which Personal Data we specifically hold about you, and receive a copy of such or access it. If you wish to exercise these rights, please contact us at Privacy@net2phone.com. You do not need to create an account with us to submit such request.
RIGHT TO CORRECTION/ RECTIFICATION	You have the right to request the updating of Personal Data that is not correct, taking into account the nature of the processing and the purposes. At any time, you may correct certain Personal Data included in the Customer Account information by logging in to your account. Otherwise, if you wish to exercise these rights, please contact us at Privacy@net2phone.com
RIGHT TO BE FORGOTTEN, RIGHT TO DELETION	You have the right to request the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. We may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, other legitimate interests such as record keeping with regards to our Customers’ data, completing the transaction for which we collected the Personal Data, providing a good or service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, fulfilling the terms of a written warranty, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality; exercising free speech, ensuring the right of another consumer to exercise their free speech rights, or exercising another right provided for by law; and engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. If you wish to exercise these rights, please contact us at Privacy@net2phone.com. You do not need to create an account with us to submit a deletion request.
RIGHT TO RESTRICTION OF PROCESSING	You may be entitled to limit the purposes for which we process your Personal Data if one of the following conditions are satisfied: where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data; where the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; where we no longer need the Personal Data for the purposes of the processing, but we are required by you to retain it for the establishment, exercise or defense of legal claims; where you objected to processing (as detailed below) pending the verification whether our legitimate grounds override your request. If you wish to exercise these rights, please contact us at Privacy@net2phone.com
RIGHT TO DATA PORTABILITY	You have the right to get a copy of your Personal Data in a portable format and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please contact us at Privacy@net2phone.com
RIGHT TO WITHDRAW CONSENT OR OPT-OUT (OBJECT) UNDER  THE GDPR, AND SPECIFICALLY IN THE US THE RIGHT TO OPT OUT FROM:  (I) SELLING PERSONAL DATA;  (II) TARGETED ADVERTISING; AND  (III) PROFILING AND AUTOMATED DECISION MAKING	When the lawful basis for processing your Personal Data is your consent, you may withdraw such consent at any time. For example, you may unsubscribe at any time from our mailing list. You further have the right to object to the processing of Personal Data, in the event the basis for processing is our legitimate interests. However, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise, or defend a legal claim or right. You have the right to opt-out from Direct Marketing, if applicable, by unsubscribing through the email received. We do not profile you in a manner that has a significant effect on you or other consumers, therefore there isn’t an opt-out option. We do not “sell” or “share” information as most people would commonly understand that term. We do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment; however, we do share Personal Data for analytic and marketing purposes, including targeted advertising, when we promote our Website or products. In most cases we obtain Personal Data collected automatically from our Website and your actions therein through our use of cookies, and do not combine it with your actions on other websites, however, our third-party partners might do so, when providing analytic or advertising services to us. For the avoidance of doubt, data originated from Google processed as part of our N2P App is not used for and will never be shared with any third party for marketing purposes.  You have the right to opt-out of the “selling” or “sharing” of your Personal Data for “cross-contextual behavioral advertising”, or “targeted advertising”, often referred to as “interest-based advertising” as well. You can exercise these rights by clicking the "do not sell or share my personal information" button through the Cookie Settings tool available on our Website. You are able to install privacy-controls in the browser's settings to automatically signal the opt-out preference to all websites you visit (such as the “Global Privacy Control”). We honor the Global Privacy Control as a valid request to opt-out of the sharing of information linked to your browser.  In any event, please keep in mind that opt-out tools are limited to the browser or device you use because they work off your browser ID and device ID and, accordingly, you will need to opt-out on each browser and device you use. Your browser may save some information in its cookies and cache to maintain your privacy preferences. Clearing these may remove opt-out preferences, requiring you to opt-out again.
RIGHT TO APPEAL OR LODGE COMPLAINT	If we decline to take action on your request, we will inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the GDPR you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK.
NON-DISCRIMINATION	Denying a good or service, providing a different level or quality of service, or charging different prices. We do not discriminate against our Visitors or Customers, but we reserve the right to deny a good or service, provide a different level or quality of service, or charge different prices, all subject to applicable laws.

 

Please note that certain rights can be easily executed independently by you without the need to approach us, for example: (i) You can opt-out from receiving our marketing emails by clicking “unsubscribe” link; and (ii) You can use the cookie settings tool on our Website to change your preferences.

In the event you are a user of our services operating under an Account Owner, please note that your Account Owner is responsible for exercising certain rights regarding your personal Data, as the Controller and legal owner of such data, and you should contact your Account Owner with such requests.

Where we are not able to provide you with the information which you have requested, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the relevant supervisory authority. We reserve the right to ask for reasonable evidence to verify your identity before providing you with any such information per applicable law.

Below are US jurisdiction specifications on how and if the rights below apply to you, depending on your residency and how to exercise your rights.

12. US JURISDICTION-SPECIFIC NOTICE

General Applicability and Jurisdictions

This section 12 applies to residents of specific US States under applicable specific state laws (including residents of Virginia, Connecticut, Colorado, Utah, Texas, Oregon, Montana, Nebraska, New Hampshire, New Jersey, Delaware, and Iowa), as amended or superseded from time to time and including any implementing regulations and amendments thereto (collectively, “US Privacy Laws”). Any term not defined herein under this section 12 shall have the meaning ascribed to such term in the Privacy Policy above or applicable US Privacy Laws. 

California residents, please refer to our CCPA Notice, which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sold or shared, the retention period, and how to exercise your rights as a California resident.

The specific disclosures in this Section 12 supplement our general Privacy Policy as detailed above and provide additional details to the extent we are deemed a “Business” or “Controller” under applicable US Privacy Laws -- for example where we process Visitor’s information regarding their use of the Website.

The Personal Information We Process

Section 3 of this Privacy Policy “THE DATA WE COLLECT AND ITS PURPOSES”, describes the categories of Personal Data that are collected and processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collect for a materially different, unrelated, or incompatible purpose without obtaining your consent. As further set forth above, collected Personal Data may include, depending on your interaction with us: 

• Contact Communications Information - including your identifiers and contact information (name, email, phone number, etc.), the content of your inquiry, and additional information as provided voluntarily by you, such as your workplace and position, country of residence, etc. – collected and processed to respond to your inquiry and to keep a record of our interaction with you. 
• User Account Data - to allow our Customers to access and interact with our service’s web-interfaces, including any data provided by the Customer such as their authorized representatives’ name, job title, email address, phone number, and other similar contact information (including usernames, and other authentication and security credential information). 
• Call Records - which may be collected when contacting our customer support or when our sales team contacts you (including when contacting you following submission of a contact us form, requesting a demo, etc.); we record the call and, in certain cases, transcript the call.
• Newsletter and Events Registration Information  -  such as your email, phone number, and your interaction with the messages and content we will send you – collected and processed for sending you news, promotional material and updates regarding our services per your consent and subject to applicable law, and to offer you to participate in certain Events. 
• Recruitment Data - resume, name, email, phone number, professional experience and other related information as further detailed above – to process your job application and candidacy.  
• Online Identifiers and Advertising and Targeting data - your IP address, location and time zone setting, operating system and platform, browser plug-in types, domain name and your choice of browser, approximate location (derived from IP address), etc. – processed as part of our technical website management and operations, analytics and online marketing activity.  

Please note that under US Privacy Laws, Personal Data does not include publicly available information and information that cannot be reasonably linked to you, directly or indirectly, such as de-identified or aggregated data, and information governed by other state or federal laws, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974,National Security Exchange Act of 1934, higher education data and employment data, etc.

“Sensitive Data” under US Privacy Laws is generally defined as data revealing racial or ethnic origin, religious beliefs, mental or physical health history, condition or diagnosis, sex life or sexual orientation, citizenship or immigration status, genetic or biometric data that can be processed/is processed to uniquely identify an individual, precise geolocation or personal data from a known child. We do not collect, process, or use any Sensitive Data from our Website's users and visitors.  

Disclosures of your Personal Data to Third Parties, and Sale or Share of Personal Data 

Under Section 6 of this Privacy Policy, “Data Sharing”, you will find details regarding the categories of third parties we share Personal Data with for business purposes.

We do not sell your personal information for profit. However, we do engage in targeted advertising on the Website. Some of those marketing activities, when conducted through the use of third parties, may be considered a “Sale” or “Share” under certain US Privacy Laws. In this context, as is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third-party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with the Website, for example, for collection of Online Identifiers and Advertising and Targeting data as detailed above. These third parties use this personal information to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our Website, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. To learn more about this please read Section 4 regarding Cookies. Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal information or the processing of personal information for purposes of targeted advertising through the use of the Cookie Toolbar on the Website’s footer or as described above in Section 11.

We do not knowingly sell or share personal information of individuals younger than 16 years of age. Similarly, we do not Sell or Share any Sensitive Data.

Exercising Your Privacy Rights 

Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the rights detailed in Section 11 above, “Your Rights”, by contacting us by email at: Privacy@net2phone.com. We reserve the right to ask for reasonable evidence to verify your identity before providing you with any such information per applicable law, including requesting a photo ID or other similar documentation and records. We will always maintain the privacy and security of such evidence.

Further, and as explained in Section 11, certain rights can be easily executed independently by you without the need to contact  us, for example: (i) You can opt-out from receiving our marketing emails by clicking the “unsubscribe” link; and (ii) You can use the cookie settings tool on our Website to change your preferences.

Furthermore, you can also opt-out from Interest-Based Advertising ("IBA") using certain available tools and features, as further detailed in the links below:
 

• Digital Advertising Alliance (US) https://www.aboutads.info/choices/
• Digital Advertising Alliance (Canada) https://youradchoices.ca/en/tools
• Digital Advertising Alliance (EU) https://www.youronlinechoices.com
• Network Advertising Initiative https://optout.networkadvertising.org/?c=1

Authorized Agents

In certain circumstances, and subject to applicable US Privacy Laws, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf or provide sufficient evidence to show that the agent has been lawfully vested with power of attorney. For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent's authority to act on your behalf. Please note that for privacy and security reasons, we will direct future communications to the individual on whose behalf the request was made.  

Appeal Rights

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request, by contacting us as instructed in our response. Please send your appeal request with a summary of the request and decision you want to appeal to Privacy@net2phone.com.

Not more than 60 days after receipt of an appeal, and always in accordance with the timelines set by applicable US Privacy Laws, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision.

If you are not happy with our response, depending on your jurisdiction, you may have the right to lodge a complaint against us with the relevant State’s Attorney General:

• Colorado Attorney General at: Colorado AG at https://coag.gov/file-complaint
• Connecticut Attorney General at: https://www.dir.ct.gov/ag/complaint/ or by phone (860) 808-5318.
• Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.
• Utah Attorney General at https://www.attorneygeneral.utah.gov/contact/complaint-form/.
• Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.
• Oregon Attorney General at https://www.doj.state.or.us/consumer-protection/contact-us/ .