Privacy Policy
[Last Updated January 2023]
This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage by Net2Phone Global Services, LLC, together with its subsidiaries and affiliated companies (“Company”, “we” or “us” and “N2P Group”) with respect to the data we collect from individuals who access and use our website and any of our domains or subdomains (respectively, “Website” and “Visitors” or “you”).
This Privacy Policy constitutes an integral part of any other agreement between you and us, including but not limited to the Website’s Terms of Service (together “Terms”), and provides you with information regarding what Personal Data (as defined below) we collect and for what purposes, our data processing operations, the lawful basis pursuant to which we process your Personal Data, third parties to whom Personal Data will be transferred, how long we retain Personal Data, etc.
This Privacy Policy also describes how you may exercise your rights, where and to the extent applicable under relevant privacy legislation, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) (together “Privacy Legislation”).
Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms or the relevant Privacy Legislation.
You are not required by law to provide us with any Personal Data. Sharing your Personal Data with us is entirely voluntary. However, without your data, we will not always be able to provide you with all or some of our services.
Further, please note that this Privacy Policy governs the use of our promotional website and landing pages. It does not cover the use of any of our products and services. As detailed below, this Privacy Policy only covers the link between the Website and those separate web-interfaces.
1. AMENDMENTS
We reserve the right to periodically revise this Privacy Policy, which will have immediate effect upon posting of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Updated” heading at the top of the Privacy Policy. We will make a reasonable effort to notify you by email if we implement any changes that substantially change our privacy practices. We recommend you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.
2. ADDITIONAL POLICIES
If you are a California resident, please review our CCPA Notice.
3. OUR DETAILS AND THE DATA CONTROLLER FOR GDPR PURPOSES
We are: Net2Phone Global Services, LLC
Our address is: 520 Broad Street, Newark, NJ 07102 United States
Phone (toll free number): 866-978-8260
Email: Privacy@net2phone.com
Under the GDPR, we are the data controller of EU residents’ Personal Data collected on our website.
If you have any questions or comments about this Privacy Policy, or any concerns with respect to how your privacy any information is handled, please contact our privacy team through the contact details above. Please include your name, mailing address and email address in the message.
4. THE DATA WE COLLECT AND ITS PURPOSES
“Non-Personal Data”: means non-identifiable data, including statistical, aggregated and “de-identified” data, which can no longer be associated with any individual (even if it was derived from Personal Data). This includes technical data transmitted to us by your device when you access and interact with our services, such as the type of browser, operating system, type of device used, the time and date you access our services, navigation, and language preference, etc. Non-Personal Data is primarily used for technical analysis, research, and development of our services to provide, maintain, develop and enhance it, and is not used to identify individuals. Under this Privacy Policy, we can use any aggregated, statistical and de-identified data with no limitation. Such data may be included in our proprietary information and is not deemed personal data under the law.
“Personal Data”: means information that identifies or may identify, with reasonable effort, an individual. Such data includes, inter alia, your name, address, phone number, email, and online identifiers (such as IP address or Cookie ID).
Please see below the table which specifies the Personal Data we collect and how we use it:
DATA SET |
PURPOSE AND OPERATIONS |
LAWFUL BASIS |
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Contact Us If you voluntarily contact us for your interest in our services, for support, “Starting a Free Trial” or for any other inquiry, including through any form on the Website (e.g., “Contact Us”, or “Chat With Support”) you may be required to provide us with certain information such as your name, email address, company, referral subject and other related data (“Contact Information”). 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 statement and agrees that you will provide Personal Data to us on this basis. |
We will use this data to respond to your inquiry or to provide you with information regarding our services as part of our marketing efforts. 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 (if applicable). We will collect the 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 just a potential customer or anyone interested in our services, we will process such Contact Information 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 data for the fulfillment of the contract between us – providing you with our services. After addressing your inquiry, we may retain your data in our systems as part of our business records-keeping under our legitimate interest. |
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Accessing our Services The Website contains a “Login” or “Billing Portal” button allowing you to access our service’s web-interfaces. As a user of any of our services, we may connect your data collected on the Website to your account data as a user of our services (“User Account Data”). |
We will 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. Also, we may use such data to 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 process your User Account Data to fulfill our agreement(s) with you and as per our legitimate interest when it is related to protecting, and ensuring the security of, our systems. ** please note that any use of our services is also 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”). |
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Subscribing to our Mailing lists 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 use your email to send you our newsletter and other Marketing Materials as part of our marketing efforts to facilitate our business. We will collect your email and other details and add it to our marketing lists. We may manage it through a dedicated system. We will send you Marketing Materials. |
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. |
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Recruitment Information In the event you apply for a job, we will collect your resume as uploaded by you, including your name, email address, phone number, information regarding your education and skills, employment history, and your photo (to the extent provided by you). 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 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, we will process your data based upon your consent. You may always withdraw consent at any time by contacting us. We will retain your data for record-keeping and future defense from legal claims under our legitimate interest. |
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Online Identifiers We use third-party cookies on the Website. As further detailed below, these cookies assist us with improving our systems and services. The Personal Data processed is an online identifier, either a cookie ID, the IP address, etc., alongside the relevant data regarding your usage of the Website (e.g., date and time of usage, pages visited, referrer webpage, device unique identifier, etc.) |
We will use your Online Identifiers to improve our systems and services. We will collect your information and analyze it, whether directly or through the use of third-party systems and services. We will aggregate and analyze the data to produce insights regarding your usage and your suitability to our services as a potential customer or contact point. We will use this data and insights as part of our marketing efforts. |
Strictly necessary cookies which are required for the proper and basic operation of the Website will be processed in our legitimate interest. Other cookies data, including any targeting and marketing cookies, will be subject to a proper disclosure or consent mechanism, provided through the Cookie banner on our website. For more information regarding cookies, see below “Cookies Usage”. |
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 Data Transfer section, 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.
5. COOKIES USAGE
As explained above, we use cookies to improve your experience while using the Website. Cookies are small text files implemented on the user’s computer or web browser that allow some tracking and identification of the user to collect data regarding the user’s data usage. We may use various types of Cookies:
- Essential Cookies – which are strictly necessary for the Website to work correctly (usually appear under our name/cookie tag).
- Functional Cookies – designated to save your settings on the Website - your language preference or other view preferences (also, under our name/cookie tag).
- Session Cookies – used to support the Website's functionality – such Cookies are usually stored only temporarily during a browsing session and are deleted from your device when you close the browser.
- Targeting and Marketing Cookies - These cookies are used to collect information from you to help us improve our services and to serve you with targeted advertisements that we believe will be relevant to you (e.g., Google, HubSpot).
- Social networks Cookies - Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.
- Analytics Cookies - give us aggregated and statistical information to improve the services and further develop them (e.g., Google Analytics, Google Firebase Catalytic, 6Sense, etc.)
- Third-party services used by us – for example, an external service supporting our recruiting options through the Website (e.g., Comeet or Workday), or an external service that allows us to screen short videos on the Website (e.g., YouTube or Vimeo).
Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.
In addition, Cookies data is usually collected through the use of third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is “owned” and processed separately by those third parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. For example, if you have a Facebook account, the Personal Data collected through Facebook’s Cookies on the Website might be linked to other data that Facebook collects from you as a Facebook user, and might be used by Facebook per the independent agreements between you and Facebook.
The specific cookies we currently use, and your choices with regard to such use are detailed HERE.
6. METHODS FOR COLLECTING YOUR DATA
- According to the nature of your interaction with our services, 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 user 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 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.
7. 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 provide our services. Below you can find information about the categories of such third-party recipients.
CATEGORY OF RECIPIENT |
DATA THAT WILL BE SHARED |
PURPOSE OF SHARING |
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N2P Group |
analytics, marketing and usage data |
We may disclose some of our customer’s data with our sister companies and subsidiaries in the N2P Group, to allow us to mange our business as a global group. Your data will be always managed under strict procedures and processes ensuring it is being taken care as required under law and with great respect to your privacy and rights. |
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Trusted Agents and Service Providers |
All 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 information for any purposes other than providing us with requested services. |
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Any acquirer of our business |
All 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 Policy. |
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Legal and law enforcement |
Subject to law enforcement authority request |
We may disclose certain data to law enforcement, governmental agencies, or 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 with services providers and partners, we ensure they only have access to such information that is strictly necessary. These parties are 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).
8. INTERNATIONAL DATA TRANSFERS
The Company’s headquarters is based in Newark New Jersey, USA, and we operate from 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") is transferred outside of the EEA 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. Thus, we will obtain contractual commitments and or assurances from the data importer to protect your Personal Information, 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. Some of these assurances are well recognized certification schemes.
9. YOUR RIGHTS
- Individuals have certain rights under applicable privacy laws concerning their Personal Data. Subject to your jurisdiction (and additional conditions), these rights may include:
- The right to be informed – you have the right to be provided with information regarding our data collection and privacy practices, as detailed in this Policy. If you have any additional questions, please contact us.
- The right to access your Personal Data – you have the right to request a confirmation from us that we process your Personal Data, and in some cases, be provided with a copy of the Personal Data we process.
- The right of rectification - you have the right to require to update Personal Data that is not correct;
- The right to the erasure of your Personal Data
(the right to be forgotten) – you have the right to require 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, etc.; - The right to restrict the processing of your Personal Data – you may be entitled to limit the purposes for which we process your Personal Data if specific conditions are satisfied;
- The right to object to the processing of your Personal Data – you 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, etc.;
- Data portability – you have the right to get a copy of your data in a format that may allow you to "port" it to a third party;
- The right to file a complaint to a supervisory authority – specifically, with regards to Personal Data collected about you in the EEA or UK, please contact the applicable EU Data Protection Authority.
- The right to withdraw your consent – when the lawful basis for processing your Personal Data is your consent. For example, you may unsubscribe at any time from our mailing list.
- The California Consumer Rights as further detailed in our CCPA Notice available below.
You may exercise any or all of your above rights in relation to your Personal Data by emailing us at Privacy@net2phone.com and requesting a Data Subject Request form.
Where we are not able to provide you with the information for which you have asked, 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.
10. 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 will 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 in order to achieve the purpose for which Personal Data was collected. For example, contact us data will be retained, at least as necessary for addressing your inquiry.
- We retain Personal Data for the periods needed in order to comply with our obligations under applicable laws. For example, transactional data may be kept up to seven years and sometimes even 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 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.
11. 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 Services 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 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.
Further, in the event of a data breach, in which we discover your Personal Data is at risk, we will notify you, if technically possible, by sending you an email, subject to applicable law requirements.
Please contact us if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
12. 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 reason to believe that a child has shared any information.
13. CALIFORNIA CONSUMERS
If you are a resident of California, then the following section also applies to you and any of your Personal Information (Personal Data) collected and processed by us. The Company collects and uses the following categories of personal information regarding California residents:
Categories of Personal Information Collected |
Specific Personal Information Collected within Category |
Categories of Sources of Personal Information |
Is this info Sold, Shared(1) and/or Disclosed for a Business Purpose and Categories of to Whom |
Business or Commercial Purposes for Collection and Use of Personal Information |
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Personal Identifiers and Information, including items listed in subdivision (e) of Section 1798.80 of California Civil Code |
name, address, email address, phone number, birthdate, device and marketing identifiers, IP address, payment and financial information, credit/debit card number and details, bank account number and information, personal information necessary to verify you or your account, security code and login credentials, and other personal information you provide |
consumer, consumer’s device, automatic collection by the Company, credit reporting companies, financial companies, 3rd party vendors that provide the Company with transactional services, data resellers |
Sold – no Shared – no Disclosed for a Business Purpose – yes Categories of third parties to whom the Company discloses personal information for a business purpose: the Company family of companies, including our affiliates both in and outside the United States; our service providers, agents and vendors to the extent reasonably necessary for them to perform work on our and your behalf (e.g., credit card processors); ad networks; data analytics providers; social networks; law enforcement; prospective purchasers of our business; outside auditors and lawyers; and government entities, agencies and regulators |
To manage our products and services, including to help us operate, provide, evaluate, improve, monitor, customize, bill and support our products and services To maintain the quality of our products and services, including to improve, upgrade, and enhance our products and services To maintain and service your account, including to process orders and payments To communicate with you about our terms and policies To verify you, your account activity and your information To detect, investigate and report fraud, abuse or illegal use of our products and services or customer accounts To provide customer service To perform due diligence, credit and fraud prevention checks To maintain accurate record keeping |
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Commercial information |
records of products or services purchased and used, diagnostic and service performance information, call records and other traffic data, credit information from reporting agencies, transactional information, and other purchasing or consuming histories or tendencies |
consumer, consumer’s device, automatic collection by the Company, credit reporting companies, financial companies, 3rd party vendors that provide the Company with transactional services, data resellers |
Sold – no Shared – no Disclosed for a Business Purpose – yes Categories of third parties to whom the Company discloses personal information for a business purpose: see list under Personal Identifiers and Information |
To ensure security and integrity of our customers’ personal information To perform product, marketing and organizational analysis To provide advertising and marketing to our customers To measure our marketing campaigns and to audit consumer interactions To comply with regulations and legal requirements To comply with contractual requirements For risk management and compliance For legal advice and defense of claims For general, operational and administrative purposes |
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Internet or other electronic network activity information |
browsing history, search history, messages, personal, phone or social network contact information, device information, device contacts, and information regarding a consumer’s interaction and usage with our websites, apps and advertisements |
consumer, consumer’s device, automatic collection by the Company, credit reporting companies, financial companies, 3rd party vendors that provide the Company with transactional services, data resellers |
Sold – no Shared – no Disclosed for a Business Purpose – yes Categories of third parties to whom the Company discloses personal information for a business purpose: see list under Personal Identifiers and Information |
To ensure security and integrity of our customers’ personal information To perform product, marketing and organizational analysis To provide advertising and marketing to our customers To measure our marketing campaigns and to audit consumer interactions To comply with regulations and legal requirements To comply with contractual requirements For risk management and compliance For legal advice and defense of claims For general, operational and administrative purposes |
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Geolocation data (if use location features) |
location of device |
consumer, consumer’s device, automatic collection by the Company |
Sold – no Shared – no Disclosed for a Business Purpose – yes Categories of third parties to whom the Company discloses personal information for a business purpose: see list under Personal Identifiers and Information |
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Inferences drawn from any of the information above |
profile reflecting the consumer’s marketing preferences; aggregate information from third parties |
consumer, consumer’s device, automatic collection by the Company, credit reporting companies, financial companies, 3rd party vendors that provide the Company with transactional services, data resellers |
Sold – no Shared – no Disclosed for a Business Purpose – yes Categories of third parties to whom the Company discloses personal information for a business purpose: the Company family of companies, including our affiliates both in and outside the United States; our vendors and partners to the extent reasonably necessary for them to perform work on our and your behalf (e.g., credit card processors); ad networks; data analytics providers; social networks; and prospective purchasers of our business |
*** Share and Shared mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
California Residents Rights. As a California resident you have certain additional rights regarding your personal information under the California Consumer Privacy Act of 2018 and (starting on January 1, 2023) the California Privacy Rights Act of 2020 (collectively, the “CCPA”).
(i) Right to Know and Access Personal Information Collected – you have the right to request the following from the Company: categories of personal information collected; categories of sources of personal information; business or commercial purpose for collecting, selling or sharing your personal information; categories of third parties with whom we disclose your personal information; and the specific pieces of personal information that we have collected about you.
(ii) Right to Know Personal Information Sold, Shared or Disclosed – you have the right to request the following from the Company: categories of personal information collected; categories of personal information sold or shared by the Company; categories of third parties to whom the Company has sold or shared your personal information; categories of personal information the Company has disclosed for a business purpose; and categories of persons to whom the Company has disclosed your personal information for a business purpose.
(iii) Right of No Retaliation - the Company does not discriminate against any California consumer who exercises any of the consumer’s rights under the CCPA. Pursuant to the CCPA the Company is permitted to (a) charge a consumer a different price or rate and/or provide a different level of service to the consumer if that difference is reasonably related to the value provided to the consumer by the consumer’s data, (b) offer loyalty, rewards, premium features, discounts, or club card programs to its customers, and (c) offer financial incentives, including payments, as compensation for the collection, sale, sharing or retention of personal information.
(iv) Right to Delete – you have the right to request that the Company delete any personal information that it has collected about you. There are exceptions to this right and the Company does not have to delete your personal information if it is reasonably necessary to complete a transaction with you, to provide you with goods or services you requested, to comply with our legal obligations, and as otherwise provided in the CCPA. In addition, if your personal information is deleted you may not be able to purchase or use our products and services.
(v) Right to Correct Inaccurate Personal Information – you have the right to request that the Company correct any inaccurate personal information that it maintains about you.
(vi) Right to Opt Out of Sale or Sharing of Personal Information – the Company does not sell (as defined in the CCPA) or share (as defined in the CCPA) your personal information. Nonetheless, you have the right to request that the Company not sell or share your personal information should the Company decide in the future to sell or share personal information to third parties. To exercise this right please go to https://www.idt.net/ccpa-do-not-sell and complete the form. We will also process any opt-out of sale/sharing preference signal that meets the requirements set forth in the CCPA and its regulations. the Company does not intentionally collect the personal information of a consumer under the age of 16. the Company does not intentionally sell or share the personal information of a consumer under the age of 16 unless the consumer (if age 13-16) or the consumer’s parent (for consumers under 13) affirmatively authorizes the sale or sharing.
(vii) Right to Limit Use and Disclosure of Sensitive Personal Information – the Company does not use your sensitive personal information (as defined in the CCPA) for purposes other than as set forth in the CCPA. Nonetheless, you have the right to direct the Company to limit its use of your sensitive personal information to that use which is necessary for the Company to perform the services and provide the goods you requested from the Company, to ensure the security and integrity of your personal information, to perform services on our behalf, including to maintain or service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide analytic services, to maintain the quality of our products and services, and as otherwise provided in the CCPA. Please note that sensitive personal information that is collected or processed by the Company without the purpose of inferring characteristics about a consumer, is not subject to this section, and shall be treated as personal information. To exercise this right please go to https://www.idt.net/ccpa-do-not-sell and complete the form.
D. How to Exercise Your Rights. To exercise your rights to know and access your personal information collected, sold, shared or disclosed by the Company, or to exercise your right to delete your personal information or to correct inaccurate personal information, please go to https://www.idt.net/ccpa-request and complete the form. To exercise your right to opt out of the sale or sharing of your personal information, or to exercise your right to limit the use and disclosure of your sensitive personal information please go to https://www.idt.net/ccpa-do-not-sell and complete the form. We will also process any opt-out of sale/sharing preference signal that meets the requirements set forth in the CCPA and its regulations. In addition, you can exercise your rights by calling the following toll-free number: 866-978-8260. Your authorized agent can make these requests on your behalf using the same links and methods.
E. Verification of Consumer Requests. In order to comply with a consumer request, the Company must reasonably verify the requestor. A record of each request is made as soon as it is received by our data protection team. the Company will use all reasonable measures to verify the identity of the individual making the request. We will utilize the requested data to ensure that we can verify the requestor’s identity and where we are unable to do so, we may contact you for further information, or ask you to provide evidence of your identity prior to responding to your request. This is to protect your data and rights. If a third party, relative or representative is requesting the data on your behalf, we will verify their authority to act for you and may contact you and them to confirm you and their identity and gain your authorization prior to responding to the request.
F. Responding to Consumer Requests. the Company will attempt to confirm receipt of each request by contacting the requestor either at the email or telephone number submitted, through the consumer’s account or by other electronic means. the Company will attempt to verify each request and if it is able to verify a request will provide a response (if necessary and applicable) within 45 days of the receipt of the request, which time period may be extended by the Company for an additional 45 days. If a delay is necessary, the Company will contact the requestor within the original 45 day period and provide the reasons for the delay. the Company may charge a fee or refuse to act on any request that is manifestly unfounded or excessive. All the Company responses shall be in writing and cover the previous 12 month period unless the consumer requests information beyond the 12 month period (only applies to personal information collected on or after January 1, 2022). Where possible the response shall be sent through the consumer’s account. Otherwise, the response shall be sent by mail or electronically. the Company is not obligated to provide a response to a consumer more than two times in any 12 month period. The CCPA contains certain exemptions and exceptions to the exercise of some of these rights. If one or more of those exemptions or exceptions applies to your request, then we may not be able to act upon your request. Where possible we will inform you of the reasons for not acting upon your request.
G. How Long will the Company Retain Your Personal Information. the Company retains your personal information for only as long as is necessary to carry out the purposes described above in this privacy policy, and we have strict review and retention policies in place to meet these obligations. This time period may vary depending on the type of information and the services used, as detailed below, and applicable law, which may require us to maintain information for a set amount of time. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from anonymized information retained or used for these purposes.
(i) Customer account information. We store your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate your service. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services. We are required under certain applicable tax laws to keep your basic personal information (name, address, contact details) for a minimum of six years after which time it will be destroyed unless required to be kept for other purposes.
(ii) Communications usage information. While you are an active customer, we retain the communications usage information generated by your use of our services until the information is no longer necessary to provide our services, and for a reasonable time thereafter as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services.
(iii) Marketing information, cookies and web beacons. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
(iv) Device information. We collect device-specific information from you. If you do not revoke our access to this information via the privacy settings on your device, we will retain this information for as long as your account is active.
H. For More Info. For more information on your rights and our obligations under the CCPA please send an email to Privacy@net2phone.com. For California residents with a disability please send an email to Privacy@net2phone for information on how to access this policy in another format.