Effective Date: June 25, 2019
- The web site or web pages located at www.CTIconnect.com/ or any other web site or web pages owned or operated by CTIconnect, our events pages located at http://events.CTIconnect.com/, our blog pages located at https://blog.CTIconnect.com/, and our support site located at http://support.CTIconnect.com (each a “Site” and collectively the “Sites”).
- Our CRM system through our NetSuite product; and
- Any other solutions or services provided by us or in connection with access to or through use of our products, network, devices, software or Sites (collectively, the “Services”).
Information We Collect
We may collect information directly from you, as well as automatically through your use of our Sites or Services. For example, when you contact us or when a device connects to one of our products or when you use one of our Services, we automatically collect information, including in connection with use of our Services and, in some cases, information about the devices connected to or by our products.
Registration Information. You can browse many areas of our Sites and use many of our Services without registering with us or providing us your name or contact info. However, to access certain Services or content on the Sites, we may ask you to register or provide certain information to us, including name, address, email address, telephone number, credit card information, promotional preferences, and passphrases and passcodes to facilitate the log-on functionality. We collect this type of personal information, as follows:
- When you register on one of our Sites, including setting up an account for support, training, or software downloads, or access certain Services from us, we collect information including the user’s name, job title, company, email address, telephone number and location.
- When you download software updates, we may collect information including your name, job title, company, email address, telephone number and location.
- When you download or access our white papers or marketing materials, we may collect your name, contact information, location and other information.
- We may also collect your name, contact and other information when you participate in promotions and contests; access product demonstrations; participate in seminars, training courses or product-related events; apply for a job; complete a survey; register products; or seek technical support, or customer or consulting services.
Device and Network Information. When you download a software or a software license key or apply for an unlock code, we will collect information about you and your device, including location information. This information includes personal information about you and your location and the serial number of the device. In addition, if you use any of our network planning and management services, and establish an account with us, we will collect information about your network and the devices attached to it, including the following: (i) MAC address, (ii) device type, (iii) operating system, (iv) geo-location information, and (v) network traffic information (e.g. hostnames, protocols, port numbers and IP addresses). When you use location-enabled Services, we may collect, process, use and share information about your actual real-time geographic location, such as signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may provide information on and to nearby Wi-Fi access points.
Automatically Collected Information on our Site. We may automatically collect the following information about your use of our Sites or Services through cookies, web beacons, log files, java script and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; MAC address, the length of time you visit our Sites and or use our Services; your location information; and the referring URL, or the webpage that led you to our Sites; access time; and a device identifier. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
How We Use the Information We Collect
We use the information we collect through our Sites and Services as follows:
- To help us improve our Sites and Services, including by analyzing site usage.
- To provide you with the products you have requested and to otherwise fulfil your requests.
- To provide our Services to you, to communicate with you about your use of our Sites and Services, to respond to your inquiries, to respond to your requests for support, and for other customer service purposes.
- To help you resolve network issues and provide other technical support.
- To send you marketing and informational communications about products or services that may be of interest to you, and for other marketing and promotional purposes. For example, we may send you emails about products, services or other information that we think may interest you. If you submit your name, phone number and contact information to us in order to receive more information from us, we may call or email you to follow up on your inquiry.
- In order to troubleshoot issues with our products.
- To better understand how users access and use our Sites, Services and products, in order to improve them, respond to user desires and preferences, and for other research and analytical purposes.
- Information security and IT management.
Sharing of Personal Information
We do not sell or rent your personal information to anyone. Unless you have specifically granted us permission to do so, we will not sell or share your personal information to or with third parties for their own marketing purposes. Instead, we will ask for your permission before we use or share your information for any purpose other than the reason you provided it or as otherwise provided by this Policy.
We may share the information we collect as follows:
- Service Providers. We may share the information we collect with service vendors, authorized third-party agents or contractors who provide requested services or process transactions on our behalf.
- In Response to Legal Process. To comply with the applicable laws or legal processes (e.g., lawful subpoenas or court orders), exercise our legal rights, comply with government regulatory requirements, or as otherwise required by law.
- To Protect Us and Others. To investigate, prevent, or take action regarding illegal activities, suspected or potential fraud, brand protection matters (such as gray market sales or unauthorized use of our intellectual property), actual or potential threats to personal safety, violations of this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We may share aggregate and/or de-identified information about users with third parties:
- To assist us in determining appropriate marketing and advertising channels;
- To evaluate the success of our advertising campaigns;
- To assist us with market research;
- For research and development purposes related to our products or the industry.
- Partners. We disclose personal information and other information to our channel partners, including our resellers, integrators, manufacturers and value-added resellers. These third parties may use the personal information and other information that we provide to them for purposes such as marketing, and to provide services to you.
- Business Transfers. Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of company assets or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Any non-personal information that we collect from your use of our Sites or Services, whether through cookies or otherwise, may be used in combination with other information for analytical purposes, to track the number of visitors to our Site or to each page of our Site, the domain names of the internet service provider of visitors to our Sites, and how users interact with and use the Site. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy as well as applicable data protection laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures).
Community Forum and Chatrooms
If you participate in a discussion forum or chatroom on one of our Sites, we will collect registration information from you when you register on our Community Forum; in addition, any information that you post may be available to other users or the general public. As a result, other third parties will potentially be able to read, collect or use your information, including to send you unsolicited messages. We are not responsible for the information that you publish on our discussion forums, including our Community Forum, or chatrooms. Also, if you post any content to our Sites – such as a comment to a blog – we collect information about what you have posted, as well as your name and contact information if you submit it.
Cookies and Other Tracking Mechanisms
Cookies. A cookie is a small piece of computer code that we transfer to your computer’s hard drive through your web browser, which enables our web servers to identify users and collect certain usage Sites information from users. Some cookies allow us to make it easier for you to navigate our Sites and services, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites and Services. Most web browsers automatically accept cookies, but if you prefer, you can delete cookie files from your hard drive, or avoid cookies by configuring your browser to reject them or to notify you when a cookie is being placed on your hard drive. The Help portion of the toolbar on most browsers will tell you how to manage how your computer accepts cookies. Visitors to our Sites who disable cookies will be able to browse certain areas of the Sites, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our Sites to, among other things, track the activities of Sites visitors, help us manage content and compile statistics about Sites usage. We or our service providers may also use clear GIFs in HTML emails to our customers to help us track email response rates, identify when our emails are viewed and track whether our emails are forwarded. We may also collect usage information via java script, log files and other sources.
Third Party Ad Network
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are in the EU, you may opt-out of certain third party cookies that we and other websites may use for targeting through http://www.youronlinechoices.eu or www.aboutads.info.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
User Generated Content
We may invite you to post content on our Sites or Services, including your comments, reviews, pictures, and any other information. If you post such content, all of the information that you post will be available to other users of our Sites and Services. Your posting may become public and we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
Access to Your Personal Information
If you would like to update your registration information you may do so by contacting your CTIconnect representative or emailing us at privacy@CTIconnect.com. In addition, you may have the ability to view or edit your personal information in other areas of the Sites or through registration-required portals for customers, distributors or resellers. We will make good faith efforts to honor reasonable requests to correct inaccurate personal information we are not required by law to retain, and to delete your personal information and account, but some information may remain in archived/backup copies for our records or as otherwise required by law.
If you are a resident of the European Union, please see the Information for EU Individuals section below for additional information on accessing your information and other legal rights available to you under European Union law.
Personal Information Choices and Communication Preferences
We may send you marketing and other information emails when we have an appropriate legal basis. You can manage communication preferences and unsubscribe from emails or other communications using one of the following methods:
- Promotional emails include instructions on unsubscribing or opting out of that mailing; or
- Send an email to privacy@CTIconnect.com; or
- Send a letter to CTIconnect, Inc., Legal Department, 2001Broadway, Suite 600, Riviera Beach, FL 33404.
When doing so, please include your name, email address and details of the change or deletion requested, the email or promotion from which you would like to opt out, or any other action you would like us to take. We may continue to send you service communications, or other communications related to your use of our Services and products, or our regulatory or other legal obligations.
Securing Personal Information
We have implemented safeguards to protect the information we collect from unauthorized access, use, and disclosure. Please be aware that despite our best efforts, no data security measures can guarantee security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Other Websites Linked to the Sites
From time to time we may include links to other parties’ websites and services that you are free to visit. We do not control these third-party Sites or services and you visit them at your own risk. The use of these Sites and the treatment of any personal information you provide to these Sites are not covered by this Policy. If you follow any links you should review the privacy statements of those websites.
California Privacy Rights
California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at: privacy@CTIconnect.com. Please allow up to thirty (30) days for a response.
Collection and Use of Children’s Personal Information
CTIconnect does not knowingly collect personal information from children under the age of 13. If we learn that we have collected personal information of a child under the age of 13, we will delete that data from our systems.
Information for EU Individuals:
If we process your data as a Data Processor: For certain activities where we provide equipment or other services to corporate customers, we act only on the instruction of those corporate customers who would be the Data Controller for that purpose. Where we process your data in our capacity as a data processor on behalf of the Data Controller, the processing of your data will not be governed by this Policy. You may contact the customer directly to learn about their processing of your information and to exercise your rights, or we will forward your request directly to our corporate customers.
If we process your data as a Data Controller: Please see the following description of our processing activities where we are acting as a data controller.
The legal bases for using your personal Information. We collect your information as a data controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:
- Our use of your personal information is in accordance with your consent (for example, when you consent to sharing your personal information with a third party for their own marketing).
- Our use of your personal information is in our legitimate interest as a commercial organization (for example in order to make improvements to our products and services and to provide you with information you request); you have a right to object to processing as explained in the section below titled Your legal rights;
- Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example where we use your personal information to respond to your customer service requests); and/or
- Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).
If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.
Your Legal Rights. Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, European Union individuals have certain rights in relation to your personal information:
- Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you and:(a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
You also have the right to request that we delete your information.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or deference of legal claims.
- Right to restrict the processing of your personal information: You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
- Right to data portability: To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
- Right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction: You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA.
- Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
- How to Exercise Your Rights: If you would like to exercise any of the rights described above, please send us a request to privacy@CTIconnect.com. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
We may not always be able to fully address your request, for example if it would affect the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Cross-border Transfer of Information. CTIconnect generally maintains servers and systems in the United States hosted by third party service providers. We also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States. As a result, where the personal information that we collect through or in connection with the Site or Services is transferred to and processed in the United States, xor anywhere else outside the European Economic Area (EEA) for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the EEA.
CTIconnect values your opinions and suggestions. If you have any privacy-related questions or comments, or concerns related to this Policy, please email us at privacy@CTIconnect.com.
Updates to this Policy
We retain the right to update or amend this policy at any time. Please review it frequently. If the policy is revised or amended in any material way we will post the revised version here and include an updated revision date. We may also notify users by other means prior to the changes taking effect, such as sending an email or posting a notice on our website.