"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.
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 information is collected.
What information will Vonage collect: When registering with Vonage you must provide Vonage with the following Personal Information:
- your full name;
- your address;
- your email address;
- current phone number;
- credit/debit card details;
- bank details;
- 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;
- 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;
- 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:
- when you register for our services, use our services and contact us;
- our servers automatically collect technical and usage information when you use our services;
- 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
- we may obtain information from third parties, such as analytics companies, third party ad networks, and other service providers.
Purposes: This 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.
- 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);
- to evaluate Customers' financial status and eligibility for credit;
- to market products and services we believe may be of interest to Customers;
- to identify Customer needs and/or preferences;
- to meet legal and regulatory requirements;
- to administer and manage our business operations;
- 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;
- to engage in research and development and to evolve and create new service offerings;
- to monitor quality control, integrity and security of our services;
- to prevent and investigate fraud;
- for other purpose disclosed when Personal Information is submitted to us; and
- 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, email@example.com
3. Mobile Apps
If you use our mobile apps:
- 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.
- 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.
- 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.
4. Limiting use, disclosure and retention
Sharing and use of Personal Information: The overriding principles that Vonage apply are these:
- Vonage, and (where relevant) our credit/debit 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 the lists of our Customers' email addresses or telephone numbers to a third party; and
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 authorise 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.
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:
- another party for the provision of its services to that Customer;
- a person involved in the development, promotion, marketing or enhancement of Vonage services;
- a credit checking or collections agency;
- emergency services in an emergency situation;
- third parties for administrative purposes (for example, billing, support, marketing, etc.); and
- 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).
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, firstname.lastname@example.org
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.
5. Consent to transfer of Personal Information Overseas
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, email@example.com.
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. Cookies enable us communicate with our Customers to advertise and promote our products and services. 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.
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.
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 protects all Personal Information regardless of the format in which it is held. The methods of protection include:
- physical measures, such as restricted access to offices;
- organisational measures, such as security clearances and limiting access on a "need to know" basis;
- technological measures, such as the use of passwords and encryption.
Attention: Vonage Limited c/o Privacy Officer: e-mail: firstname.lastname@example.org
10. Individual access
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.
This policy was last updated on 3rd June 2016.