CTTC respects your right to privacy. This Privacy Supplement describes what personal information CTTC processes for the CTTC Mobile App for Android & iOS service and why.
CTTC Mobile is a unified collaboration service brought to you by CTTC. CTTC Mobile for Android and CTTC Mobile for iOS allows users to securely call from your business number directly on your device as if you were using your desk phone. It allows you to be reachable from anywhere around the world.
CTTC processes and, in certain situations, collects personal information as needed to deliver its Products and Services and manage its business. When collecting personal information, CTTC does so in a reasonable and lawful manner.
The types of information and the purposes for which CTTC collects or processes personal information may include:
CTTC acts as a data processor with regard to indirect end-user personally identifiable information, and our Clients act as the data controller of such data. During CTTC’ processing and protection of such data, all use will be in conformity with the data controller’s instructions.
Specifically, only when enabled via system permission on CTTC Mobile Android and CTTC iOS, CTTC shows personal contacts within the respective application. When the user sends an SMS message to one of their phone contacts or initiates a call to one of their phone contacts, the phone number is transmitted securely through CTTC's API. CTTC does not store this number with any other PII, and it cannot be directly or indirectly attributed to any person or persons; CTTC stores only the phone number and pertinent metadata to be compliant with all applicable state and federal laws, and CTTC does not share this data with any advertisers or third parties under any circumstances. A user can revoke phone contact access on their mobile device at any time, and their app experience is not hindered or interrupted.
CTTC Android and iOS also use Gravatar only when enabled via Settings and UIConfigs, a service that provides avatar images linked to the MD5 hash of the user’s email address. This means that only when Gravatar use is enabled, we hash each contact’s email address and send it to Gravatar to try and retrieve an avatar image. MD5 hashes cannot be directly or indirectly attributed to any person or persons, and we only send the MD5 hash to Gravatar, never the email address in plain text. As with phone contacts, a user can revoke Gravatar access at any time in Settings or via UIConfig, and their app experience is not hindered or interrupted.
CTTC uses such personal information only for relevant, appropriate, and customary purposes. CTTC will not share or disclose personal information for purposes other than as described herein. Capitalized terms used in this Privacy Policy shall have the meaning as given in the Client’s Master Services Agreement (MSA). The following are examples of some of the personal information CTTC may process.
CTTC may collect and use personal information about individual contacts of Clients and others who access CTTC public websites, knowledge bases, forums, ticket systems, or provide personal information through other means. Such information may include but is not limited to account information, first/last name, company name, title, and responsibilities, work email address, work mailing address, telephone numbers, login information, device identifiers, as well as additional information provided by such individuals while receiving Products and Services from CTTC and/or requesting information about CTTC. We will use such information for the purposes of providing Products and Services, support, conducting data analytics and product assessments and related activities, and providing information regarding CTTC Products and Services.
Customer Proprietary Network Information (CPNI) may include information regarding quantity, destination, technical configuration, location, amount of use, and related billing information of telecommunications, interconnected and/or non-interconnected Voice over Internet Protocol (VoIP) services. This may include but is not limited to the phone numbers that you call or send messages to (or the phone numbers that you receive these calls and messages from) through our Products and Services. The date, time, and duration of the calls may also be collected. This data is used for billing and service level assurance.
CTTC provides Products and Services that are primarily for the benefit of Clients and Subscribers in that CTTC transmits routes, switches, or caches information. These Products and Services merely act as a conduit for data transmitted by third parties and Subscribers. CTTC does not determine the purposes and means of processing this personal information. Except for Subscriber data provided by the Client (the Subscribers service provider) for which CTTC is merely providing a conduit for transmission, the subscribed services are of such a nature that, in most instances, CTTC requires and collects only essential CPNI and billing information; and opting out or declining to provide the requested data may hinder the provision or delivery of subscribed services. However, for CPNI data that is collected by CTTC that is not subject to the control of others, CTTC shall obtain consent from the user for the processing of this data.
CTTC collects end-user CPNI while providing Product support. This data may pertain to Clients of CTTC or Subscribers (e.g., end-users of CTTC’ direct Clients). This data may include IP address, telephone number, email address, call detail records, call recordings, and other information sufficient to identify an individual end-user.
CTTC acts as a data processor with regard to indirect end-user personal information, and our Clients act as the data controller of such data. During CTTC’ processing and protection of such data, all use will conform with the data controller’s instructions.
CTTC typically collects and processes direct end-user (e.g., Clients, vendors, and partners) personal information for the purposes of providing Products and Services, support, conducting data analytics, and managing product performance.
CTTC provides Products and Services that facilitate the recording and storage of audio and video by way of features such as but not limited to voicemail, call, and conference recording. Users may elect to store or record personal information within these resources at their discretion.
CTTC may use anonymized, non-identifying data collected from the use of our other CTTC Products and Services. This anonymized, non-identifying data may be used to enhance such items but is not limited to voice activation, improve traffic analysis algorithms and techniques, and recognition algorithms. This processing is executed under applicable terms and supports CTTC’ legitimate interests in tuning, maintaining, and enhancing these Products and Services.
CTTC websites may use cookies to collect certain kinds of personal information about Subscribers or users. Please refer to the following section for more details on how CTTC uses cookies and choices available to Subscribers and users.
We collect information in various ways, including the following:
When you use one of our Products or Services, CTTC collects and stores certain information that you provide directly. We also collect information about your use of the Products and Services.
CTTC also collects technical information about your usage of the Products and Services. We use various technologies to collect information about cookies, IP addresses, device type and device identifiers, application state, the date and time of activity with our Products and Services, and other similar information. CTTC may associate this information with your user identification and/or account number for our internal use.
Websites may also utilize Internet Protocol (IP) addresses and log files to identify network and server concerns and problems. CTTC also uses web beacons and other passive tracking mechanisms to perform standard website traffic analysis, similar to how we utilize cookies.
We use your information primarily and as necessary to provide you with the various CTTC Products and Services, including but not limited to one or more of the following ways: to create your accounts and allow the use of our Products, to provide technical support, and respond to Client inquiries, to prevent fraud or potentially illegal activities, enforce our other agreements with you, to notify Clients of application updates, and to inform Clients about new products or promotional offers.
CTTC recognizes that for some sensitive information, affirmative express consent from individuals is required and must be obtained if such information is to be (i) disclosed to a third party or (ii) processed for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice. In addition, CTTC shall treat any personal information received from a third party where the third party identifies and treats it as sensitive.
We may disclose or report information that individually identifies Clients, Subscribers, or devices in certain circumstances, such as:
(i) if we have a good faith belief that we are required to disclose the information in response to a valid legal process (for example, a court order, search warrant or subpoena, or to defend or respond to legal actions, and as otherwise authorized by law, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements); (ii) to satisfy applicable laws, (iii) if we believe that the Products and Services are being used in an unauthorized, unlawful or abusive manner, such as to commit a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction, (iv) if we have a good faith belief that there is an emergency that poses a threat to the health or safety of a person or the general public, (v) in order to protect the rights or property of CTTC, including enforcement of our Intellectual Property Rights and terms of the Agreement(s), and (vi) for all other purposes with your consent. We may also provide your information to third-party companies to perform services on our behalf, including but not limited to payment processing, data analysis, message delivery, hosting services, customer service, and marketing.
If CTTC enters a merger, acquisition, or sale of all or a portion of its assets or business, Client and Subscriber information, including personal information, will also be transferred as part of or in connection with the transaction per applicable law.
In general, personal information may be shared within CTTC, where legally permitted for reasonable and appropriate corporate purposes. However, even within CTTC, we restrict access to personal information to those employees, agents, or contractors who need access to carry out their assigned functions.
CTTC uses vendors and partners for various business purposes, such as to help us develop, deploy, and invoice for the various Products and Services we provide. We share information with those vendors and partners when necessary for them to perform work on our behalf. CTTC requires that these vendors and partners protect the customer information we provide and limit their use of such information to their respective processing activities. CTTC will only transfer or provide direct access to personal information covered by this policy to third parties that have made a commitment to respect the privacy rights of the data subject; limit processing of personal information to comply with data controller instructions and provide CTTC contractual assurances that they will provide at least the same level of privacy protection as is required by applicable privacy laws.
We implement security measures we believe are reasonable to protect your information. It is essential that you protect and maintain the security of your account, and you need to immediately notify us of any unauthorized use of your account. Remember, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot and do not guarantee its absolute security.
To help protect the confidentiality of personal information, CTTC employs security safeguards appropriate to the sensitivity of the information and in accordance with this Privacy Policy. These safeguards include reasonable administrative, technical, and physical measures to safeguard the confidentiality and security of personal information against anticipated threats and unauthorized access to personal information. No transfer of your personal information will occur to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information. Additionally, as described above in the section titled External Disclosure, we convey safeguard obligations to our agents who receive personal information from or on behalf of CTTC during their relationship with our organization.
Your information, including personal information, may be transferred to and maintained on computers, servers, or other data storage located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. If you reside outside the United States and choose to provide information to CTTC, please note that we transfer the data, including personal information, to the United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Personal information collected by CTTC will be retained for as long as necessary and legally permitted for the purposes for which it was collected, to provide you with Products and Services, enforce our legal agreements and policies, and conduct our legitimate business interests or where otherwise required by law.
CTTC employs reasonable means to keep personal information accurate, complete, and current, as needed for the purposes for which it was collected.
We generally provide individuals with an opportunity to examine their personal information, confirm the accuracy and completeness of their personal information, and have their personal information updated, if appropriate.
The ability of an individual to access their personal information is not unlimited, however. An individual’s ability to access personal information may be limited, for example, where (i) the burden or expense of providing access would be unreasonable or disproportionate to the risks to the individual’s privacy, (ii) the information should not be disclosed due to legal or security reasons or to protect confidential commercial information; or (iii) providing access would compromise the privacy of another person.
CTTC reserves the right to change this Privacy Policy at our discretion subject to business or legal requirements. You are advised to review and check this Privacy Policy from time to time and particularly before you provide personal information to CTTC. Changes to this Privacy Policy are effective when posted on this page. By using our Products and/or Services, you agree to be bound by any changes or revisions made to this privacy policy.
If you have any questions or concerns about our use of your personal information, please contact us here.
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