Purpose and scope

We are Internet Protocol Telecom Limited (trading as IP Telecom)(“we”, “us” and “our”), a company incorporated under the laws of Ireland with company registration number 482356, whose registered office is at Unit 1k, Block 71C, Park West , The Plaza Park, Dublin 12, Ireland. We provide cloud based hosted PBX & SIP trunking and voice over internet protocol (“VOIP”) products (“Product”) to customers as well as the website www.iptelecom.ie and affiliated pages (the “Website”; the Website and Product together referred to as “Services”).In this Privacy Policy (“Policy”), references to “you” means the individual whose personal information (as defined below) we collect, use and process, whether this information is collected on the Services, in person, by telephone or otherwise and will apply whether you provide us with the personal information yourself or it is provided by a third party.

We appreciate that your privacy is important to you. Please read the Policy carefully to understand how we will use and process the personal information that you, or third parties, provide to us or we collect from you.

For the purposes of the Data Protection Acts 1988 and 2003 and any successor legislation including the General Data Protection Regulation (EU 2016/679) (“Data Protection Legislation”) we are the data controller in respect of the personal information that we collect and process in accordance with this Policy.

What information do we collect about you?

The “personal information” we collect and hold about you includes:

  • contact information such as your name, address, telephone number (including mobile number), and email address;

  • the information included in any documents you send to us (such a copy of your driving licence for know-your-client (KYC) purposes;

  • financial details including your bank and the sort code and account number, to the extent that you supply these to us for the purpose of making payments;

  • employee names, extension numbers, DDIs and email addresses to facilitate the configuration of the Services and system;

  • information about how you use our Services, for exampl,e information generated when you use our network to make a phone call, or use our website;

  • information needed to port your existing number, including your existing numbers and your account number from your previous carrier, and copies of previous telephone bills;

  • information you complete in relation to customer satisfaction surveys;

  • all information collected using cookies or similar technologies (please see our Cookie Policy for further details https://www.iptelecom.ie/cookies-policy  and

  • information which we collect about you when you use our Services or visit our Website such as technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

The provision of certain personal information is mandatory (and may be required accordance with a contractual requirement or to enter into a contract). The collection of any such information will be made clear at the time of collection of the information.  If you choose not to submit this information, you may not be able to receive our Services.

How do we collect your information?

We may collect information about you in a number of ways, including:

  • Information you provide

    • either directly from you or others, such as where you set up Services with us or contact us or our service providers with a request or query;

    • from forms you complete, whether paper-based or online;

    • from calls made to us or from us, which may be recorded for training and quality purposes;

    • if you are an individual user, from your employer or company, for example, when they provide us with your details to facilitate configuration of our system or to create a user account for you;

  • Automatically Collected Information

    • When you visit our Website. Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, any phone number used to call our customer service number and other communication data and resources you may access; and

    • Log information. We collect this from our records of how you use our Services.

  • Information from third parties

    • We may receive information about you from our third-party partners. For example we work with resellers, white labelers, wholesalers, IT companies and technology partners for the purposes described in this Policy. As an example, we would receive billing information from a company organisation who installs and supports telephony solutions who works with IP Telecom on billing for their end customers.

Legal Bases

We rely on a number of legal bases to collect, use, share, and otherwise process the personal information we have about you for the purposes described in this Policy. These legal bases are:    

  • as is necessary to enable your use of our Services;

  • where you have consented to the processing, which you may revoke at any time;

  • for us to comply with a legal obligation, a court order, or to exercise legal rights or defend legal claims;

  • when necessary to protect your vital interests or those of others;

  • when necessary to ensure performance of a contract;

  • where you have made the information manifestly public;

  • where necessary in the public interest; and/or

  • where necessary for the purposes of our or a third party’s legitimate interests,

Our legitimate interests

We process your information in furtherance of some or all of the following legitimate interests:

  • Providing, improving and developing the products and services: We use your personal information to provide and further develop the products and services. We do so as it is necessary to pursue our legitimate interests of providing a secure offering to all our customers on a continuing basis.

  • Providing information about new products and services: We may also process your information to provide marketing communications to you and it is in our legitimate interest to promote our Services and issue our direct marketing.  

Keeping the Services secure and safe: We use your personal information as it is necessary to pursue our and our customers’ legitimate interests in ensuring our products and services are secure, such as by implementing and enhancing security measures and protections, protecting against security breaches, fraud, and spam.

What do we use your information for?

We use your personal information as necessary to provide our Services and to fulfil our contract with you. We also process your personal information in order to fulfil our contracts with business partners, vendors and suppliers. We may use your personal information as necessary to manage our business for our legitimate interests. We also use your information for the following range of different purposes, including:

  • operating our website;

  • determining your suitability for our Services;

  • administering and managing the Services we provide to you, to charge you for them, to process payment and collect any amounts you may owe us and to deliver them, and for internal operations, including troubleshooting, data analysis, testing and research;

  • promoting the safety and security of our Services and investigating suspicious activity or violations of our policies;

  • for quality of service monitoring, assisting you with enquiries and to provide you with better customer service;

  • providing you with information that you request from us about our Services and Services that we feel may interest you, to which you have already consented or that are similar to a product or service you purchased from us within the past year;

  • conducting market research and analysis to further enhance and improve the quality of the Services we offer;

  • verifying your identity, or conducting appropriate checks;

  • to send you information relevant to our Services, such as informing you about changes to this Privacy Policy or the Services, or maintenance to our Site;

  • to send you a password reset link if you tell us that you have forgotten your password;

  • if we have any queries concerning any aspect of your use of our Services;

  • to ensure that content from our Services is presented in the most effective manner for your device;

  • to allow you to participate in interactive features of our Services when you choose to do so; and

  • as permitted or required by any law applicable to us or arising from your interaction with us.

How do we share your information?

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may pass personal information to people who process data for us. We have contracts with these people and we ensure they are contractually bound to do only what we say they can do with your information. We may pass details about you to our agents and subcontractors to help us with any of our uses of your data set out in this Policy; for example, we may use third parties to assist us with providing the administration for running our Services, to analyse data and to provide us with marketing or customer service assistance.

By providing us with your personal information, you agree to this transfer, storing or processing of your personal information by us. In addition we may disclose your information to the following third parties:

  • our professional advisers in order for them to provide us with advice;

  • debt collection agencies to assist with the recovery of amounts owed to us by you or the organisation you represent under any agreement between you and us;

  • service providers, such as our payment processors and delivery service providers where necessary for them to provide us with services or to provide services that you have requested;

  • our technology providers, including those which host your data on our behalf and provide certain IT support services to us;

  • business partners and/or possible acquirers or investors (and our and/or their advisors) in the context of a facilitating or implementing a business re-organisation or a transfer/sale of all or part of our assets or business; and

  • law enforcement agencies, regulatory bodies and other third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (including but not limited to in connection with a court order); in order to enforce our Website terms of use or our terms and conditions of service, or any other agreement we have with you; or to protect the rights, property or safety or us, our staff, our customers or others.

Where permitted by law, we reserve the right to release personal information without your consent and/or without consulting you, when we believe that this is appropriate to comply with our legal obligations, to protect the security of our Services and related technologies, to prevent and minimise the effects of fraud, and otherwise to protect our legitimate interests and/or the legitimate interests of our customers.

Where is your information processed?

The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and in accordance with the appropriate safeguards as required by relevant data protection law. To obtain further details and a copy of the appropriate safeguards please contact: dataprotection@iptelecom.ie.

For how long do we retain your personal information?

We retain your personal information for so long as we continue to need it, which will vary depending on the nature of the information and the purposes for which we are processing it.  Any information we hold will be protected by the terms of this Policy and, once no longer required and we have no further legitimate reason to retain it, it will be securely destroyed.

The following specific retention periods will be followed:

Type of Record or Information

Retention Period

Call Data Records (“CDRs”)

We will retain CDRs for up to 3 years for the purposes described above and to comply with legal requirements.

[We will endeavour to make CDRs available to you through the Hosted PBX for up to 12 months after your contract with us ends]. If at any time you store what we consider to be an excessive amount of CDRs we may delete CDRs without notification.

Call recordings

Up to 12 months.

Voicemail retention

Up to 12 months.

If your mailbox allocated limits are reached in order to free space in your mailbox we may delete existing voicemails without notification.

Cookies

See our Cookie Policy for more details.

What about cookies?

One way we collect information is through the use of a technology called “cookies”, as well as other related technologies, such as pixels, tags, beacons and local storage. We use these technologies for many things on IP Telecom’s Services. See our Cookie Policy for more details.

How do we keep your information safe and accurate?

We will take all steps we deem to be reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy. We seek to ensure that we keep your personal information accurate and up to date. However, you are responsible for informing us of any changes to your information (such as a change in contact details). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. You are responsible for protecting against unauthorised access to your password and to your computer and you must not share a password with anyone.

While we take these steps to maintain the security of your information, you should be aware of the many information security risks that exist and take appropriate care to help safeguard your information. The transmission of information via the internet is not completely secure and the nature of the internet is such that we cannot guarantee the security of the information you transmit to us electronically. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted through our Services and any transmission is at your own risk. We store information you provide to us on secure servers and deploy appropriate technical and organisational security measures in the storage and disclosure of your personal information to try to prevent unauthorised or unlawful access to or accidental loss of or destruction or damage to your information.

What are your rights?

You have rights to access and port information you provide to us, along with rights to rectify, and erase your personal information that we hold. You have the right to ask us to restrict processing of your personal data and a right to object to our processing of your personal information. Where we have collected information from you based upon your consent, you can withdraw such consent to our processing of your data at any time.

You also have the right to opt-out of certain direct marketing communications you receive from us.

Please use dataprotection@iptelecom.ie to contact us should you wish to exercise any of these rights. If you exercise these rights you may not be able to make full use of our Services and/or we may not be able to provide you with information that you have requested us to provide to you.

Without prejudice to any other rights you may have, you also have the right to file a complaint against IP Telecom with the Irish Data Protection Commission by contacting them here:

Office of the Data Protection Commissioner

Canal House

Station Road

Portarlington

Co. Laois, R32 AP23,

Ireland

+353 (0761)104 800 (Phone)

info@dataprotection.ie

Your rights may be restricted in certain circumstances for instance where your information may be needed to comply with our legal obligations or for the defence or exercise of legal claims.

Changes to our Privacy Policy

We may modify this Policy from time to time to reflect changes in our privacy practices. If we make any material changes to this Policy, we may notify you by contacting you through our services or by posting a notice on our website – or by some combination of these methods. In circumstances where you have not provided us with your contact information, we encourage you to periodically review the Website for the latest information on our privacy practices.

Contacting us

If you have any questions, comments and requests regarding this Privacy Policy or our management of your information and you should address all correspondence to dataprotection@iptelecom.ie or Unit 1k, Block 71C, Park West, The Plaza Park, Dublin 12.

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