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Vonage Business Phone System Privacy Policy

1. Introduction

Vonage Limited, company number 05199171, and its group companies including Vonage Holdings Corp ("Vonage", "we", "us" and/or "our") is strongly committed to respecting and protecting your privacy. Please read carefully the following Privacy Policy. In order to ensure your privacy, Personal Information (as defined below) Vonage collects from you as a customer or potential customer or, visitor to its website ("Customer(s)" and/or "you") located at vonage.co.uk ("Site"), is used only in the manner and for the purposes described in this Privacy Policy.

"Personal Information" includes any information which can identify an individual, presented in any form, such as: age, name, address (incl. email address), ID numbers, income, credit references and records, ethnic origin, demographic information and evaluations.

This Privacy Policy expresses our approach to complying with the data protection and privacy laws that apply in the UK, and applies to the collection and use of your Personal Information via the Site.

You must not register with Vonage or sign up to any Vonage service available via this Site if you do not accept this Privacy Policy and the Vonage Terms of Service.

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2. Your Personal Information and the purposes for which information is used

As a general principle, Vonage will identify the purposes for which Personal Information is collected at or before the time the Personal Information is collected.

What Personal Information will Vonage collect: When registering with Vonage you must provide Vonage with the following Personal Information:

  1. your full name;
  2. business name
  3. your address;
  4. your email address;
  5. current phone number;
  6. credit/debit card details;
  7. bank details.
  8. if you use our mobile apps and set your mobile device to share this with us, content on your mobile device, such as your contact lists and address book, camera, microphone and photos;
  9. your location information, if you consent to our mobile apps sharing this with us, based on the location of your mobile device at any given time;
  10. if you register or access our services through your account with a third party service, such as Facebook, Google or Twitter, or use a social media feature through our services, certain Personal Information from those third party social media services may be shared with us; such information may include your interests, "likes" and friends list. We may use this information, for example, to personalise your Vonage experiences and marketing communications, to enhance our services and to better serve you. You can control this data sharing via options in your social media accounts.

Vonage may also collect Personal Information from such third parties as credit bureaus, employers or personal references or other third parties that represent that they have the right to disclose the information.

We collect Personal information in several ways, including the following:

  1. when you register for our services, use our services and contact us;
  2. our servers automatically collect technical and usage information when you use our services;
  3. we may deploy cookies and other tracking technologies on our services to collect additional information about your usage of our services and online activities; and
  4. we may obtain information from third parties, such as analytics companies, third party ad networks, and other service providers.

Purposes: The Personal Information and any other information you provide to Vonage via the Site, email or telephone is required in order to provide you with Vonage's services and the relevant equipment required to use Vonage's services. Also to verify your credit status with third party credit agencies and to inform you of any new offers and services which may be of interest to you.

Vonage collects Personal Information only for the purposes set out in this Privacy Policy, including to provide service(s) and/or products to its Customers:

  1. to maintain commercial relations and to communicate with our Customers (which will include, but not be limited to: billing, collection, support, advertising, marketing, promotion, account and credit/debit card verification);
  2. to evaluate Customers' financial status and eligibility for credit;
  3. to market products and services we believe may be of interest to Customers;
  4. to identify Customer needs and/or preferences;
  5. to meet legal and regulatory requirements;
  6. to administer and manage our business operations;
  7. to enable our vendors, contractors and partners to provide and assist us in the provision and marketing of services to Customers and to participate in joint marketing efforts;
  8. to engage in research and development and to evolve and create new service offerings;
  9. to monitor quality control, integrity and security of our services;
  10. to prevent and investigate fraud;
  11. for other purpose disclosed when Personal Information is submitted to us; and
  12. as otherwise required or permitted by law.

By providing your contact information to us, you consent to receive communications by email, SMS, phone and post, including communications of a promotional nature, from Vonage and our affiliates at the contact information you provide.

Vonage does not sell services for purchase by children. Vonage does not knowingly solicit or collect Personal Information from children or teenagers under the age of eighteen. If you believe that a minor has disclosed Personal Information to Vonage, please report this to us at Vonage: c/o Privacy Officer, support@vonagebusiness.co.uk

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3. Mobile Apps

If you use our mobile apps:

1. We may request your permission to access and store the contact list or address book maintained on your mobile device. Your contact list is considered your Personal Information. We may use your contact list information to facilitate certain services such as to enable you to make calls easily and to facilitate free calls, texts and other services. We may also facilitate the delivery of messages to individuals in your contact list that you wish to invite to download our mobile apps so that you can use our services with these selected individuals. We will not use your contact list information for other purposes without first notifying you of the proposed use. If you do not allow us to access your contact list information, certain features of our mobile apps may not be available to you. You may at any time opt out from further allowing us to have access to your mobile device's contact list via the mobile app's privacy settings on your mobile device.

2. We may request your permission to access the camera, microphone and photos on your mobile device. If you approve and/or enable the function in your mobile device settings, our mobile apps may access and use the camera, microphone and photos on your mobile device to make and receive voice and video calls and messages and to send photos to others. You may at any time opt out from further allowing us to have this access via the mobile app's privacy settings on your mobile device.

3. Our mobile apps may collect information about the geographic location of your mobile device. If you have consented, the geographic location of your mobile device will be transmitted to our servers in real time any time that our mobile apps are running (even if you are not actively using our mobile apps, they are minimised, or they are closed on your mobile device). Once you set your mobile device to transmit its location information to us, your mobile device will continue to transmit its location information to us until you set your mobile device to no longer do so. Your geographic location is considered your Personal Information unless it is aggregate data and does not identify you. To the extent our mobile apps collect your geographic location, you may at any time opt out from further allowing us to have access to your mobile device's location information via the mobile app's location settings on your mobile device.

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4. Limiting use, disclosure and retention

Sharing and use of Personal Information: The overriding principles that Vonage apply are these:

1. Vonage, and (where relevant) our credit card processing agents or other third parties we share your information with, will not supply, sell or rent your Personal Information to a third party for commercial exploitation - you can therefore rest assured that we will not sell or rent lists of our Customers' email addresses or telephone numbers to a third party; and

2. The only circumstances in which we will provide any of your personal data to a third party for non-commercial purposes are those contained in this Privacy Policy.

Credit/debit card information: There has been a lot of publicity about credit/debit card security on the internet so Vonage has decided to operate a secure server, to process credit/debit card payments. Vonage encrypts Customers' credit or debit card information and authorises payment directly. Vonage may transfer to, process and hold your credit/debit card information in countries either within or outside the European Economic Area in connection with performing Vonage's duties.

Changes in Vonage's business. Personal Information may also be disclosed in connection with a sale, transfer or reorganisation of one or more of Vonage's businesses, in which case Vonage will require that any Personal Information will continue to be treated in accordance with this Privacy Policy or as otherwise permitted by law.

Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of you, the individual or as otherwise required or permitted by law. Personal Information will be retained only as long as necessary for the fulfilment of those identified purposes or as otherwise required or permitted by law.

Vonage may disclose a Customer's Personal Information to:

  1. another party for the provision of its services to that Customer;
  2. a person involved in the development, promotion, marketing or enhancement of Vonage services;
  3. a credit checking or collections agency;
  4. emergency services in an emergency situation;
  5. third parties for administrative purposes (for example, billing, support, marketing, etc.); and
  6. any other third party, upon receiving the consent of the Customer or as required by law.

Such disclosures may in some cases be to recipients outside of the UK and European Economic Area ("EEA").

Vonage will retain Personal Information that has been used to make a decision about an individual long enough to allow the individual access to the information after the decision has been made, and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law.

When Personal Information that previously has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless otherwise permitted by applicable law, Vonage will obtain the consent of the individual before Personal Information is used for that new purpose.

Occasionally, Vonage will communicate to you special bonus and new product and service offers that we think may be of value to you. Vonage may retain third parties to assist it in marketing such new or additional Vonage products and services to our Customers (and for such purpose may share Personal Information with such third parties).

If you purchase certain products and services offered by Vonage or a partner through a special marketing arrangement (for example, through a co-branded advertisement or offer, or an arrangement where we and a partner market or offer the other's products or services), Personal Information may be received and shared by both Vonage and our partner. Each company's own privacy policy applies.

All Customers have the right to choose not to participate in direct marketing of new products and services from Vonage. If you wish to opt-out of receiving targeted communications from Vonage in electronic, printed or verbal format (other than information in connection with your monthly bills), simply inform us in writing at Vonage: c/o Privacy Officer, support@vonagebusiness.co.uk.

The Site may provide hyperlinks, which are highlighted words or pictures within a hypertext document that may, when clicked, take you to a third party website not controlled by Vonage. Such hyperlinked third party websites may collect and disclose information in a different way to this Site. Vonage is not responsible for the collection, use, or disclosure of information collected through these third party web sites, and Vonage expressly disclaims any and all liability related to such collection, use, or disclosure.

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5. Consent to transfer of Personal Information Overseas

Place of processing: Personal Information held by Vonage is stored on and processed on computers situated in the United Kingdom, the EEA and the United States of America. We may need to transfer your Personal Information outside of the EEA in order to provide you with the services you require. Some countries outside of the EEA do not always offer the same standards of protection of Personal Information as EEA countries. However, Vonage will ensure that your Personal Information is always treated in accordance with this Privacy Policy.

The knowledge and consent of you, the individual is normally required for the transfer of Personal Information to a destination outside the EEA, subject to certain exceptions. However, in certain circumstances, Personal Information can be transferred to a destination outside the EEA without the knowledge and consent of the individual.

Personal Information is transferred abroad for the purpose of performing contractual obligations owed by Vonage to you.

Consent: Where required, Vonage will generally seek consent for the use or transfer of the information overseas at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Vonage wants to use information for a purpose not previously identified).

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Vonage will inform you of the implications of such withdrawal. In order to withdraw consent, you must provide notice to Vonage in writing c/o Privacy Officer, support@vonagebusiness.co.uk.

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6. Cookies Policy

The Site uses a feature of Internet web browsers called a cookie, which is a file that is sent to your browser from the Site's computers and stored on your computer's hard drive or mobile device. A cookie assigns a unique identification code to your computer or mobile device.

Cookies are used to track and maintain continuity of web sessions such as the subscription process or your viewing of your call details. They also help us track Customers, conduct research, allow you to back click to earlier registration pages viewed by you and improve our content and services.

Vonage's cookies do not collect Personal Information other than the IP address from which you are accessing the Site which may be considered Personal Information. Vonage only collects Personal Information if you knowingly and willingly provide such information.

On this Site, the following types of cookie are used:

Session cookies: these cookies are temporary and will be removed from your computer or mobile device when you leave the Site.

Persistent cookies: these cookies remain on your computer or mobile device until you either delete them or they expire.

Third Party cookies: these cookies are set by companies and websites that help us make Vonage offers and promotions that we feel will be of more interest to you. These third party companies and websites are trusted and their cookies only collect anonymous data. These cookies cannot be used to find out your identity.

When you visit third party websites, we strongly recommend that you read their applicable terms and cookie policies before using any third party website.

For a list of the main cookies used on the site, click here.

You may set your Internet web browser to notify you when you receive a cookie or to prevent cookies from being sent or to search for and delete cookies stored on your hard drive or mobile device. If you prevent a cookie from being sent or if you delete a cookie from your hard drive, you may limit the functionality of the Site. For more information on disabling cookies please visit www.allaboutcookies.org/manage-cookies/ or visit your Internet web browser's help menus.

In addition to cookies, we may use other technologies such as clear gifs, web beacons, pixel tags, Java script, device fingerprinting and third party cookies. We may use these technologies for analytics to improve the performance of our services and learn how to improve them, to better understand usage of our services, for tailored advertising, to measure advertising effectiveness, and to anonymously track usage of third party sites.

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7. Accuracy and removing your details

Personal Information will be updated as necessary for the purposes for which it is to be collected and used.

Vonage will not routinely update Personal Information unless such a process is necessary to fulfil the purposes for which the information was collected. Personal Information that is used on an ongoing basis, including information that is disclosed to third parties, will generally be accurate and up-to-date to the best of Vonage's knowledge.

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8. Safeguards and security

Vonage has implemented and deployed a wide variety of technology and security features to ensure the privacy of personal and anonymous information collected by it. In addition, Vonage has implemented strict operations guidelines to safeguard Customer privacy at every level of its organisation. Unfortunately, no system is perfect; therefore, Vonage makes no representations or warranties with regard to the sufficiency of these security measures.

Vonage shall not be responsible for any actual, indirect or consequential damages (or any other damages or liability of any kind whatsoever, whether as a result of negligence or otherwise) that result from a lapse in compliance with this Privacy Policy because of a security breach or technical malfunction. Nothing in this Privacy Policy shall however limit or exclude Vonage's liability in respect of death or personal injury caused by its negligence or for fraud.

Vonage protects all Personal Information regardless of the format in which it is held. The methods of protection include:

  1. physical measures, such as restricted access to offices;
  2. organisational measures, such as security clearances and limiting access on a "need to know" basis;
  3. technological measures, such as the use of passwords and encryption.

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9. Accountability

Vonage is responsible for Personal Information under its control and has designated an individual or individuals who are accountable for the organisation's compliance with this Privacy Policy.

If you have any questions or concerns in relation to this Privacy Policy Vonage's Privacy Officer may be contacted at:

Attention: Vonage Limited c/o Privacy Officer: e-mail: support@vonagebusiness.co.uk

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10. Individual access

Access requests: Upon written request, Vonage will inform you whether or not it holds Personal Information about you, and will provide you with the opportunity to review the Personal Information it holds and request the update or modification of the same or request its deletion in accordance with this Privacy Policy. Vonage may charge a £10.00 fee to cover its costs in providing such data to you.

Disclosure for legal reasons: Vonage reserves the right to communicate such of your Personal Information as it holds to third parties which seek the disclosure of it, and which make a legally compliant request for its disclosure. Vonage also reserves the right to communicate your Personal Information to the relevant authorities if we believe that you are involved in illegal activities or commit any breach of this Privacy Policy, which would justify such disclosure.

Data protection information: You can obtain further information about data protection laws in the UK by visiting the Information Commissioner's website at https://ico.org.uk/. You can search for our publicly available Data Protection Notification there, should you so wish.

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11. Changes to this Privacy Policy

We may, at our discretion, change, modify, add, or remove portions from this Privacy Policy at any time by posting such changes here. You should review this Privacy Policy regularly for changes, and can easily see if changes have been made by checking the "last updated" date below. If at any time in the future we plan to use Personal Information collected under this Privacy Policy in a way that differs materially and adversely from this Privacy Policy, we will post such changes here and we may request your consent or approval before implementing the change with respect to Personal Information that you provided to us before the change in policy.

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This policy was last updated on 27th May 2016.

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