Last Updated: 2001-12-14 00:00:00 +0000, 2021
1. Contacto Privacy Notice
Welcome to Contacto’s Privacy Notice. This notice explains to you how Contacto manages and protects your personal data when you use our application or visit our website.
We want to make sure that you fully understand what personal data we need from you in order to serve you better, how we use and protect your personal data and why we need your personal data when you are interacting with us. We want to assure you that we have implemented strict information security and privacy practices to ensure that your personal data is safe while in our custody.
We always look for ways to improve our products, services and practices therefore we will update this Privacy Notice whenever there are changes to the ways that we manage and protect your personal data.
2. What is personal data?
It is important to understand what we mean when we discuss personal data. Personal data refers to any information related to someone that can be identified through it either directly or indirectly. This means that, in some cases, a single element of information may not identify you but several pieced together will and, if they do, then they are considered personal data. Examples of personal data include your name, identification numbers, location, factors specific to your physical, mental, economic or social identity, among others.
3. What personal data protection and privacy regulations does Contacto need to comply with?
Because we are a global organization, we need to comply with different data protection and privacy regulations around the world such as the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) and others. And because we understand we live in a fully interconnected world, we want to assure you that Plivo commits to protecting all of our customers and visitors to our website personal data regardless of where they are located. We respect your privacy rights at all times.
4. Is Contacto a data controller or a data processor?
Some data protection regulations differentiate between a data controller and a data processor. A data controller is an organization that determines how to collect and process personal data whereas a data processor is an organization that collects and processes personal data on the data controller’s behalf and under the data controller’s instructions.
Contacto is both a data controller and a data processor.
As a controller, Contacto collects and processes personal data from visitors to the Contacto’s website and from customers that sign up for our services. In this context, Contacto determines how this personal data is collected, processed and shared.
As a data processor, Contacto collects and processes personal data from registered customers’ users and only does so as per customers’ requirements. Even if we are not making decisions about how personal data is being processed, we continue to protect at all times.
5. How does Contacto collect and process your personal data?
In order to provide you with an optimal web experience and also great products and services, we need to collect and process your personal data.
The following table explains what personal data we collect from you, how we process it, how we classify your personal data and, according to personal data protection regulations, what is the legal basis for the processing of your personal data.
We classify your personal data as Account data, Contacto Services data, Usage data, Content data and Visitor data.
Account data is all the personal data we collect from you to manage your account including managing end user accounts, managing routing workflows, renting phone numbers, payment information, accounts configured to establish integrations with third-party business systems (like CRM, Order management and payment systems, helpdesk, and the like) . Your account data is also used for giving you support and charging you for our services.
Contacto Services data refers to all personal data collected, used and shared through the ‘Application’. This data includes calls, chats and messages exchanged with customer, recordings and transcripts of calls, chat and messages, customer information fetched from third-party business systems integrated with the Contacto account.
Usage data is all the personal data we collect from you when you use our services such as when you make a call, the length of your call, if you are using voice or text, among others.
Content data is all the personal data we collect from you within the service including the content of the conversations via chat or calls or messages.
Visitor data is all the personal data we collect from you when you visit our website and when you sign up for our current wait list and, in the future, for communications from Contacto.
|Personal data collected||Personal data processing||Type of personal data||Legal basis for processing|
|Contact data (name, address, email, company, Authorized Users)||This data is used throughout your relationship with Contacto including opening an account, managing your account, inviting new users, giving you support, providing you with discussion boards and communicating with you||Account data||We process your information to fulfil our obligations to you as part of your contract with Contacto|
|Conversation details||We use this data to transcribe calls, for your analysis of conversation details, review of notes taken during conversations and to access the conversations later.||Contacto Services data Content data||We process your information to fulfil our obligations to you as part of your contract with Contacto|
|Customer details and related information from business systems||We transfer this data from/to your business systems as part the integrations that Contacto offers.||Contacto Services data||We process your information to fulfil our obligations to you as part of your contract with Contacto|
|Transcripts and Recordings of customer conversations||As part of our services and coaching functionality, we store and process recordings and transcripts of conversations over all channels including calls, messages and chats.||Usage Data|
|We process your information to fulfil our obligations to you as part of your contract with Contacto|
|Payment management||In order to pay for our services, we need information about your payment method. We also keep history of your usage and payments for you to be able to verify our charges and if necessary, dispute any billing||Usage Data|
|We process your information to fulfil our obligations to you as part of your contract with Contacto|
|Email address, name and communication preferences||If you want to join our waiting list and in the future are interested in hearing from us, you may sign up for our newsletter.||Visitor data||This is a legitimate interest on our part to ensure that we sign you up for the Contacto service in priority and are giving you the right information and to engage with you|
You may opt out of cookies at any time.
|Visitor data||This is a legitimate interest on our part to continuously improve our website content and navigation as well as the relevance of ads you may find on other sites|
6. How does Contacto share your personal data?
As part of the products and services that Contacto offers to you, we need to share your personal data with our employees and some other third-parties that help Contacto deliver our products and services. We always make sure that we share your personal data when it is absolutely necessary to give you the best products and services and we ensure that we do so in a safe and controlled way.
We transmit your personal data to the business system that you integrate Contacto with.
Contacto does not sell or share your personal data for any monetary or business reason that will directly benefit or advance Plivo’s business interests.
The following table explains who the parties are we share your personal data with and the purposes why they need access to your personal data.
|Contacto’s sub-processors||These are companies that provide services to Contacto such as storage and infrastructure, payment services, support processing, data analysis. Refer to our sub-processor section for a list of these service providers.|
7. How does Contacto protect your personal data?
Contacto takes the protection and security of your personal data very seriously. We use physical, organizational, technical, and administrative measures to safeguard your personal data, and regularly re-assess and revise our policies and practices to improve security measures to protect personal data and seek to partner with organizations that do the same.
Please remember that no data transmission over the Internet, whether wired or wireless, is 100% secure, therefore we cannot fully guarantee the security of information transmitted to Plivo and cannot be responsible for the actions of any third-party that may intercept any such information. Once we receive your data, we commit to making all reasonable efforts to protect it to ensure it resides securely in our systems.
If you believe that your personal data may have been compromised by Contacto or by using Contacto’s website, products or services, please contact our Help Centre immediately. We will be happy to assist you.
8. Where does Contacto store your personal data?
Contacto stores your personal data with third-party providers that have locations around the globe. We try, as much as possible, to keep your data in your region of residence. However, sometimes this is not possible, and we need to transfer your data internationally.
We work with data service providers that are able to support our expectations of security, privacy and compliance.
Keeping in line with our commitment to protect your personal data, Contacto ensures that all third-party vendors we work with sign a Data Processing Agreement to ensure that they will protect your personal data according to Contacto’s expectations.
For the purpose of transferring your data to the US, we sign Standard Contractual Clauses (Model Clauses) with all the third-party vendors that will receive your data for the purpose of storing it and we only work with vendors that have the infrastructure required to fulfil their obligations under the Standard Contractual Clauses.
9. Rights over your personal data
Privacy and data protection regulations such as the GDPR and the CCPA grant you with rights that you can exercise over the personal data that organizations like Contacto collect and manage about you. At Contacto we believe in providing these rights to all of our customers regardless of where they are located in the world. Every Contacto customer has the same rights over their personal data.
Unless there are clear exceptions because of legal or regulatory requirements, we will work to ensure that your requests are addressed within 30 days. These are the requests you may contact Contacto about:
- You have the right to access the personal data that Contacto maintains about you, including the categories of data and how Contacto collects, processes and shares your personal data.
- You have the right to request deletion of your personal data, update or correct your data, object to processing of your data, ask us to restrict processing of your data or request portability of your data. In each particular case we will inform you of the consequences of your request and if there are any exemptions to honouring your request based on legal, regulatory or contractual requirements.
- If Contacto has collected and processed your personal data based on your explicit consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing Contacto conducted prior to your withdrawal.
- You have the right to be notified about a data breach that may impact the integrity, availability or confidentiality of your personal data. Refer to our data breach notification section for more details.
- You have the right to complain to a data protection authority about Contacto’s collection and processing of your personal data. However, we will appreciate it if you give us the opportunity to deal with your complaint internally before contacting a data protection authority.
You have the ability to access, update or delete the personal data in your account if you choose to do so. Furthermore, you also have the ability to withdraw your consent to any marketing communications you have signed up for.
In order to exercise any of the rights you have over your personal data or if you are not able to complete your request directly through your account, please send an email to email@example.com. Once we receive your request, we will contact you to provide acknowledgement and request further information if required. We will never discriminate against you for exercising your personal data rights.
10. Personal data breach notification
As part of our security and data protection measures we have implemented processes to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Should we learn of a security breach that affects your personal data, we will notify you in order to explain how this breach may affect you and to provide you with any advice on how to protect yourself. We will contact you through the email address we have on file or by posting a notice on our website.
11. Contacto’s personal data retention period
Due to telecommunications and other regulations, we need to retain all the data that you generate as part of your relationship with Contacto for seven (7) years after you close your account.
12. Contacto’s Data Processing Addendum
In our role as a processor, we are happy to provide you with a Data Processing Addendum (or DPA) where we commit to safeguarding the personal data that we will process on your behalf, will support you on any request you may receive from individuals or Data Protection Authorities and will ensure that we process personal data according to personal data protection regulations such as the General Data Protection Regulation in the EU.
13. Contacto’s contact information
If you have any further questions about how Contacto collects, uses, discloses or protects your personal data or if you have any questions about this privacy notice, including any requests to exercise your personal data rights, you may contact our appointed Data Protection Officer using the details set out below.
Email address: firstname.lastname@example.org