Last modified: October 22, 2020
We respect your privacy and are committed to protecting your Personal Data when you use our website (www.voicespin.com) including any mobile or a device-specific version of the website (together the “Website”) or any other products or services we provide, including our official representations on social media. We refer to all of these products, together with our other services and Website as “Services” in this Policy.
We will tell you:
- Let’s get oriented
- Our contact details
- What Personal Data do we collect about you?
- What happens if you do not give us your data?
- How we use your personal information
- When and how we share information with others
- International transfers
- Your rights
- Your right to complain
- Data storage and retention
- What happens when you visit other websites?
You can find the vocabulary of the definitions and legal references at the end of this Policy.
Let’s get oriented
While providing Services to our customers and processing Personal Data, we act as either the Controller or the Processor, depending on the situation.
We act as a Processor
In cases where our customers use our communications platform, they are able to interact with and contact end users via different communication channels. We only distribute these communications through communications providers.
In such cases, we act as a Processor, in the meaning of the applicable Data Protection Legislation, since we process Personal Data of end users on behalf of our customers only. This means that our customers remain Controllers for the Personal Data of their end users. We only process Personal Data as strictly necessary for the provision of Services and according to customer’s instructions. We never determine our own purposes and means of the end users’ Personal Data processing.
This Policy does not apply to us when we process the end user’s Personal Data in the role of a Processor on behalf of our customers.
We act as a Controller
In cases, we determine the purposes and means of the processing, i.e. why and how the processing is carried out, and when we do not act not on behalf of someone else, we are considered a Data Controller.
For example, when we process Personal Data of our customers, including their representatives, employees, officers, agents, shareholders we usually act as a Controller of Personal Data.
Any references to “you” and “your” include all individuals whose Personal Data we collect, hold and process as a Data Controller in the course of providing Services.
Our contact details
Voicespin LTD (registration number: 513983676) is a Controller in respect of your Personal Data as it relates to your use of the Website and Services.
Any references in this document to “we”, “us” or “our” are references to Voicespin LTD only.
Address: 3 Tefutsot St., Givataim, Israel
Email address: email@example.com
What Personal Data do we collect about you?
Information you directly provide to us
Below, you can find the information on what Personal Data we collect or you provide to us when interacting with us or when using our services. We have grouped all the Personal Data you usually provide to us in the following groups.
|Account Data||When you create an account, you provide us with the personal information that includes first name, last name and log in details (username, password, API token).When we do business with organizations, we additionally collect professional or employment information such as information about the position of their representatives and other personnel that will be our contact points.|
|Contact Data||When you create an account, request a demo or subscribe to our newsletter, you provide us with an email address and/or telephone number. When we do business with organizations, we may collect such Personal Data about their representatives and other personnel that will be our contact points.|
|Regulatory Data||Records of registration of your organization with any applicable regulatory authority, regulated status and any regulatory references, such as:Name and type of business entity, registration number, country of incorporation, governed jurisdiction, address of registration, phone number, official website;Name, title, phone number and email address of authorized signatory;Name, phone number and email address of main financial contact.|
|Payment Data||Once you register your account and use our Services, we collect your payment details, billing address, balance on the Website, payment history on the Website, receipts or other documents confirming successful payments uploaded by you on the Website, and any other payment data depending on the jurisdiction and payment method used.|
|Traffic Data||When you use our Services, we collect information necessary for the conveyance of communication exchanged by using our Services. For example, routing data, country, type, duration, date and time of the communication, and other communication and traffic metadata, depending on the Services provided.When we process Traffic Data, we act as a Processor in many respects, but we may act as a Controller in others. For example, as a Controller, we may need to use certain Traffic Data for billing purposes, reconciling invoices with telecommunications carriers, etc.|
|Customer Content Data||This includes end user’s names, telephone numbers, email addresses and other data related to end users received from customers directly or generated during the provision of Services.When we process Customer Content Data, we generally act as a Processor on behalf of our customers and according to their instructions.|
|Log in Data||Log in Data includes internet protocol (IP) address, information on your usage, routing information, time zone, logs on your activity generated while using our Services.|
|Usage Data||We collect information about how you use the Website, pages visited, time spent, features used, etc.|
Information we collect through cookies
Information we collect from social media platforms and through messengers
|Social media platforms||We collect information about you when you contact us through your account on a social media platform such as Facebook, for various purposes (such as to contact us for information). We also collect information about you if you chose to interact with our content and pages available on our official representation on a social media platform.|
|Messengers||When you communicate with us via a platform that enables real-time text transmission (“messenger”) such as WhatsApp, Facebook Messenger, we collect information about you, date, time and content of the communication.|
Special Category of Personal Data
We do not collect any Special Category of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) in the general course of business. Nor do we collect any information about criminal convictions and offences. However, from our experience, we may not exclude that you, at your own discretion, send us such data in communication with us, or that such data otherwise becomes available to us in the course of providing Services to our customers.
What happens if you do not give us your data?
You are under no obligation to provide Personal Data to us. However, certain Personal Data are mandatory for the provision of Services. Where we ask you to provide Personal Data to us on a mandatory basis, we will inform you of this at the time of collection and in the event, that particular information is required by the contract or statute, this will be indicated.
Failure to provide any mandatory information will mean that we cannot carry out certain processes. For example, if you do not provide us with your name, we will not be able to enter into a contract with you.
How we use your personal information
In the table below, you can find the purposes of the processing of your Personal Data and the legal bases for such processing. We also provide you with information on our or third parties’ legitimate interests. Please note that we may process your Personal Data for more than one lawful bases depending on the specific purpose. If you need more details, please contact us.
|Purpose||Data category||Legal bases|
|To set up and administer your account on the Website||Account DataRegulatory DataContact DataLog in Data||If our customer is a natural person: entering into and performing a contract, if our customer is a legal person: legitimate interests (providing our Services to your organization)|
|To provide our Services||Account DataRegulatory DataPayment DataTraffic DataCustomer Content Data||If our customer is a natural person: entering into and performing a contract, if our customer is a legal person: legitimate interests (providing our Services to your organization)ContractLegitimate interests (e.g. to manage traffic with the purpose of transmitting communications toward or from communication networks)|
|To process and manage payment transactions||Account DataRegulatory DataPayment Data||If our customer is a natural person: entering into and performing a contract, if our customer is a legal person: legitimate interests (providing our Services to your organization)Contract|
|To manage our relationship with you and exercise our rights and fulfil our obligations arising from the relationship that with you or your organization||Account DataRegulatory DataContact DataCustomer Content Data||If our customer is a natural person: entering into and performing a contract, if our customer is a legal person: legitimate interests (providing our Services to your organization)Legitimate interests (e.g. for the establishment, exercise or defense of legal claims)|
|To establish and investigate any suspicious behavior in order to protect you and our business from fraud and other illegal activities||Traffic DataCustomer Content DataLog in Data||Legitimate interests (e.g., detection of spam, prevention of fraud)|
|To maintain information security, including troubleshooting, hosting data, preventing unauthorized access to electronic communications networks and ensuring the safety, security and integrity of our Website and Services||Account DataTraffic DataLog in DataUsage Data||Legal obligations (for instance, to implement appropriate technical and organizational security measures)Legal obligations (for instance, to implement appropriate technical and organizational security measures)Legitimate interests (e.g. to protect the security of our system)|
|To provide technical and customer support||Contact DataTraffic DataLog in Data||Legitimate interests (for instance, to deal with your service requests and respond to communications)|
|To suggest and provide relevant information about our products and Services||Contact DataTraffic DataUsage Data||Legitimate interests (e.g., to promote our Services, to enhance relationship with you, etc.)|
|To deliver marketing communications to you across various platforms, such as email, text messaging, push notification or otherwise||Contact DataUsage Data||Consent|
|To improve our Website, Services, marketing campaigns and your experience||Traffic DataLog in DataUsage Data||Legitimate interests (for example, to develop our product and Services and to grow our business)|
When and how we share information with others
We may share your information with third parties, who may act as both Controllers and Processors in respect of your Personal Data, and solely for the purposes explained in the Section “How we use your personal information”.
Sharing Personal Data with third-party service providers and partners
|Telecom operators and other communications providers||To set up the proper routing and connectivity and to distribute communications that our customers send to their end users, we engage telecom operators and other communications providers.|
|Anti-spam and anti-fraud service provides||In order to comply with legal requirements, we use service providers to detect and prevent spam and fraud while using our Services.|
|Data storage services||Personal information we collect from you is stored in one or more databases hosted by third parties located in the European Union.|
|Third-party service and technology providers||Depending on the Services delivered, we engage third-party service and technology providers to perform specific actions on our behalf (for example, for automatic speech recognition).|
|Analytics||We use analytic services to collect details of the Website use, including, but not limited to location data, IP address, device information, etc.|
Sharing your Personal Data with statutory authorities
We will share personal information when we believe it is required, such as:
- To comply with legal obligations and respond to requests from government agencies;
- To protect our rights, users, systems, and Services.
Sharing your Personal Data in other circumstances
In addition to the disclosures for the purposes identified before, we may disclose information:
- In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
As a multinational business, we engage service providers and advisers from different countries, including countries outside the European Economic Area (“EEA”). Countries outside the EEA do not always have strong data protection laws. Where we transfer personal information from the EEA to other countries in which applicable laws do not offer the same level of data privacy protection as in the EEA, we take measures to provide an appropriate level of data privacy protection:
- We may transfer Personal Data to a third country when the European Commission has decided that such a third country ensures an adequate level of protection. See more details on the European Commission official website;
- We enter into standard model clauses with our vendors whenever feasible and appropriate. For further details on this safeguard, see European Commission: Standard contractual clauses for data transfers between EU and non-EU countries.
Under data protection law, you have rights including:
|Right of access||You have the right to ask us for copies of your personal information.|
|Right to rectification||You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete the information you think is incomplete.|
|Right to erasure||You have the right to ask us to erase your personal information in certain circumstances.|
|Right to restriction of processing||You have the right to ask us to restrict the processing of your personal information in certain circumstances.|
|Right to object to processing||You have the right to object to the processing of your personal information in certain circumstances.|
|Right to data portability||You have the right to ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances.|
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you since the day your request is received.
If you wish to make a request, please contact us:
- By email: [firstname.lastname@example.org];
- By letter: 3 Tefutsot St., Givataim, Israel.
Your right to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at [email@example.com].
If you are not satisfied with how we manage your Personal Data, you have a right to make a complaint to your local Data Protection Authority.
Data storage and retention
Your Personal Data is stored on the servers of the database management services we engage, located in the EU. We retain data for the duration of the customer’s relationship with us and for a period of time thereafter to fulfil our legal and regulatory obligations or where there are any laws and/or contractual provisions that may be invoked against us by you and/or third parties and if so, what the prescriptive periods for such actions are (for example, when we need to keep Personal Data to defend ourselves against any claims, challenges or other such actions initiated by you and/or third parties).
For more information on where and how long your Personal Data is stored, please contact us at [firstname.lastname@example.org].
What happens when you visit other websites?
Definitions and legal references
|Controller or Data Controller||A company or other legal entity, or an individual (such as a sole trader) which are the main decision-makers – they exercise overall control over the purposes and means of the processing of Personal Data.|
|Processor||A company or other legal entity, or an individual (such as a sole trader) which process Personal Data on behalf of the Controller.|
|Personal Data||Any information that relates to an identified or identifiable natural person. Different pieces of information, which are collected together can lead to the identification of a particular person, also constitute Personal Data.|
|Special Category of Personal Data||Personal Data revealing details about natural person’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.|
|Data Protection Legislation||Any and all data protection and privacy legislation in force in those parts of the world in which the Company operates and/or processes the Personal Data, including but not limited to the Data protection legislation of Estonia and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR).|