Effective October 23, 2017
West Unified Communications Privacy Statement
West Unified Communications Services, West Cloud Contact Solutions, and West IP Communications (for customers invoiced by West UC Limited or West Cloud Contact Solutions Ltd, respectively, for the purposes of European Union data protection legislation, the Data Controller is the customer, user or any individual who accesses or uses the services and the Data Processor is West UC Limited or West Cloud Contact Solutions Ltd respectively of Unit 1 & 2, Sawmills End, Barnwood, Gloucester, GL4 3DL, UK) (hereafter referred to as “West UC” or “We”) are leading providers of conferencing services and unified communications services, respectively. We value the privacy of our customers, users, and any individual who accesses or uses the West UC websites, products, and services (collectively, the “Services”). This Statement discloses West UC’s practices with respect to the collection, processing, use and disclosure of user information. This Privacy Statement applies to all Personal Information and Sensitive Personal Information collected and processed by West UC whether in electronic, paper or verbal format. As West UC is a global provider, the provision of the Services to users may also require Personal Information to be shared with other West UC group companies around the world. All such West UC group companies are bound by privacy statements, confidentiality and data transfer agreements as appropriate. Where required, such intercompany data transfer agreements include the necessary contractual clauses which provide for the technical and organisational security measures to be applied by West UC group companies whether established within the European Economic Area or in a third country not providing adequate protection, in order to ensure a level of security appropriate to the risks represented by the processing and the nature of the data to be protected.
Collection and Use of Personal Information and Customer Proprietary Network Information
In this Privacy Statement, “Personal Information” is any information or data that can be reasonably linked to a data subject, or to a specific computer or other device. “Sensitive Personal Information” is a subset of Personal Information and is data about children, financial information, health information (including PHI as defined by the Health Insurance Portability and Accountability Act), Social Security or other national identification number, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life, criminal convictions, and precise geolocation data.
We also want you to be aware certain information related to your account (for example, accounts provided by West IP Communications) may be Customer Proprietary Network Information (“CPNI”). CPNI is information we obtain solely by providing telecommunications services or interconnected Voice over Internet Protocol (VoIP) services to you. It includes the type, technical arrangement, quantity, destination, location, and amount of services you purchased and related billing information. CPNI does not include your telephone number, name and address, or aggregate customer information or data not specific to you. The protection of your information is important to us, and you have a right, and we have a duty, under U.S federal law, to protect the confidentiality of your CPNI. We may use or disclose CPNI without your consent to (a) initiate, render, repair, maintain, bill, troubleshoot, and collect for our services; (b) protect our rights and property or to protect our subscribers or other carriers from the unlawful or fraudulent use of our services; (c) provide call location information required in connection with emergency services; (d) market services formerly known as adjunct-to-basic services; (e) market our services within the categories of services to which you already subscribe; and, (f) respond to a valid request from law enforcement, a court order, or other appropriate authority. Absent your consent, we will not access, use or disclose your CPNI to market categories of telecommunications or VoIP products and services that you do not already subscribe to or share your CPNI with unrelated third parties for their own use.
We are aware that you have several rights in respect to how we process your Personal Information, which include but are not limited to, a right to access your Personal Information, be forgotten, restrict and/or object to processing in some circumstances and request your Personal Information be transferred to you or your nominated third party. Personal Information is not kept for longer than is necessary to accomplish the purpose for which it was collected. We undertake to do the following:
- Review the length of time we retain Personal Information;
- Securely delete, anonymize or pseudonymize Personal Information no longer needed for a specific purpose; and
- Update, archive, or securely delete Personal Information if it becomes out of date.
By providing your Personal Information, you opt-in and consent to its collection, use, disclosure, sharing, and transfer as described in this Privacy Statement.
In connection with the access and use of the Services, you may choose to provide us with your Personal Information when, among other things, you register on the West UC website, use one of our Services, fill out a survey, register to attend a seminar; make a request for information, ask to be included in an email or other mailing list; or more generally when you submit your Personal Information to West UC for any other reason. We may also capture your telephone number when you use our Services. In addition, we may collect and process information about your location when you use our Services.
Please be aware any information you choose to share on any publicly available portion of the Services or with third parties, including without limitation your personal page, chat messages, forum posts, blogs, resumes, job applications, business cards, or any other information you provide may be collected and used by third parties or other attendees without restriction.
If you wish to limit West UC’s use and disclosure of your Personal Information, please contact our privacy team. Upon such a request, West UC will take steps to limit the use and disclosure of your Personal Information unless necessary to provide services, or the use or disclosure is required to comply with applicable law or to meet national security requirements. West UC will seek your consent prior to sharing Sensitive Personal Information with a third party, or if the information will be used for a purpose other than that for which it was collected. Further, you acknowledge and agree the Services are not intended to transmit Sensitive Personal Information and West UC makes no warranties, representations or covenants with respect to, any laws related to the collection, storage or transmission of such data.
West UC Primary and Secondary Use
West UC will use the Personal Information you provide us in these circumstances to the extent required for the delivery of the Services (such as account set up, billing, debt-collection, customer services, reporting), to satisfy West UC’s legitimate business interests (such as customer analysis, fraud-prevention and internal marketing study and analysis) and to provide information you request from us (“Primary Use”).
West UC may provide your Personal Information to business partners or third party suppliers that assist West UC in processing such Personal Information for Primary Use (such as partners or agents who are involved in delivering the Services you have ordered or used, credit-reference agencies, fraud-prevention agencies, business-scoring agencies or other credit-scoring agencies, debt-collection agencies or other debt-recovery organizations). Unless you instruct us not to do so, and unless prohibited by law, West UC (either directly or using an affiliate or using business partners or third parties used by West UC) may also use the Personal Information you provide us to contact you regarding additional or new services and features offered by West UC or its affiliates, special offers by West UC or its affiliates, or important information regarding West UC or its affiliates (“West UC Secondary Use”).
West UC requires any such affiliate companies, business partners or third parties used to assist West UC for Primary Use or West UC Secondary Use to enter into agreements with West UC including contract terms substantially the same as those contained in this Privacy Statement, prohibiting disclosure of the Personal Information to others and restricting its use in providing the contracted Services of West UC.
Third Party Services
West UC may also provide your Personal Information to business partners in case you purchase services of third parties from West UC (“Third Party Services”). Third Party Services are not directly controlled operated or maintained by West UC and West UC’s Privacy Statement does not apply to such Third Party Services. Any use of Third Party Services is subject to the privacy statement of the Third Party Services providers. For any Third Party Services you purchase from West UC, we recommend you consult the respective privacy policies of the Third Party Services providers to determine how they will handle your Personal Information.
Other Legitimate Use
West UC may also use your Personal Information to create anonymous data records or aggregations of data, to perform statistical analyses and for other purposes, by omitting or removing information that makes the data personally identifiable to you.
West UC will keep your Personal Information for as long as we have to by law. If there is no legal requirement, West UC will keep your Personal Information no longer than strictly required for the legitimate purpose(s) for which it was collected.
Any Sensitive Personal Information you provide us will only be used to implement the specific activity or event it was submitted for and will then be destroyed.
You may stop delivery of informational or promotional mail from us by following the instructions included in the informational or promotional mail itself.
When you register to use any of the Services offered by West UC, West UC will send you a confirmation of your registration showing the Personal Information we obtained from your registration. Also, we will take reasonable steps to give you the opportunity to correct inaccuracies in the Personal Information we retain concerning you and delete Personal Information concerning you upon your request, unless the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than you would be violated. To correct inaccuracies in your Personal Information or delete your Personal Information, or for any other questions, please contact our privacy team through the directions at this link, or by mail, as directed in the “Contact Us” section, below.
You are informed and hereby consent the whole or any part of your Personal Information in connection to the Services, may be processed by West UC, its affiliates and subcontractors in the United States, in the European Union and the rest of the world, and may be transferred outside the country in which you provided the Personal Information. International transfers of Personal Information are made in compliance with relevant international data protection laws and regulations.
West UC’s accountability for personal data it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, West UC remains responsible and liable under the Privacy Shield Principles if third-party agents it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless West UC proves it is not responsible for the event giving rise to the damage.
European Union Transfers - EU-US Privacy Shield and Swiss-US Privacy Shield
West UC has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Under certain limited circumstances set forth in the EU-U.S. Privacy Shield Framework, individuals may invoke binding arbitration before the Privacy Shield Panel.
For questions or concerns on privacy in the European Union, you may contact West UC’s legal team at email@example.com.
West UC shall take reasonable steps to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We are also responsible for ensuring our affiliates and subcontractors take reasonable steps to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Personal Information we collect from you is stored in operating environments that employ reasonable security measures and that are not available to the general public. West UC is not responsible for unauthorized access to such Personal Information by hackers or others who obtain access through illegal measures, in the absence of negligence on the part of West UC. Further, some other websites you may access through the West UC website may have different security practices and you should familiarize yourself with those practices. West UC cannot guarantee the security of Information transmitted via the Internet. You are responsible for the confidentiality and security of passwords West UC issues to you. If you believe a third party has obtained your password in an unauthorized manner, please notify West UC promptly.
West UC shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, West UC shall take reasonable steps to ensure the Personal Information is accurate, complete, current and reliable for its intended use.
Compliance with Legislation
In connection with the Services, and if applicable, you and West UC shall at all times ensure compliance with any privacy and data protection laws including those in the United States (including but not limited to the Gramm-Leach-Bliley Financial Services Modernization Act, the Health Insurance Portability and Accountability Act and the Fair Credit Reporting Act), in the European Union (including but not limited to relevant EU member state legislation and the General Data Protection Regulation once it comes into force), in the Asia-Pacific Economic Cooperation (including but not limited to the Privacy Act along with the Australian Privacy Principles, Singapore’s Personal Data Protection Act and Hong Kong’s Personal Data (Privacy) Ordinance) and anywhere around the world.
West UC uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies the statement is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with its principles. If at any time you believe we have acted contrary to this Privacy Statement, please contact our privacy team at firstname.lastname@example.org, or by mail, as directed in the “Contact Us” section below, and we will take steps to investigate and will use reasonable measures to solve the problem.
Disclosure for Legal Purposes
We may disclose Personal Information if required to do so by law or in the good-faith belief such action is necessary: (a) to conform to the edicts of the law or comply with legal process served on us or our affiliates; (b) to protect and defend our rights or property or those of our customers and their users; (c) to protect the personal safety of our customers and their users or the public; or (d) in connection with a merger, consolidation or sale of substantial assets of West UC. As we continue to develop our business, we might buy or sell assets related to our business. In such transactions Personal Information generally is one of the transferred business assets. Also, in the event West UC or substantially all of its assets are acquired, Personal Information will be one of the transferred assets.
Please understand, in addition to collecting Personal Information, West UC may also gather information that does not personally identify you regarding your use of the West UC website (“Anonymous Information”). The Anonymous Information we collect regarding your use of this website may be used by us to measure the effectiveness of our marketing efforts, for improving the Services we offer to you, or to improve the West UC website. Generally, you will not be aware when such Anonymous Information is being collected about you. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access the West UC website.
Cookies are typically classified as either session Cookies or persistent Cookies depending on whether they expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.
Session and Persistent Cookies
Session Cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session Cookies expire after a browser session, so would not be stored longer term. For this reason, session Cookies may sometimes be considered less privacy intrusive than persistent Cookies. Persistent Cookies – are stored on a users’ device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent Cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising.
Accepting Cookies from West UC
Please note you may browse some West UC websites without accepting Cookies from West UC; however, you may not be able to take full advantage of the functionality of the West UC website or the Services if you do so. Other Services, particularly those which require a login and password, require Cookies and cannot be used when you have disabled Cookies in your browser. For more general information you can visit www.allaboutcookies.org.
How do you handle my “Do Not Track” browser settings?
West UC does not track the non-West UC website activity of any internet user with Do Not Track browser settings engaged.
Important Notice regarding certain Services
Some Services of West UC, including in particular virtual event Services allow certain third party organizers and contributors to host virtual events (each, a “Sponsor”). West UC collects the information described below on behalf of such Sponsors. You should consult the privacy policies of each relevant Sponsor to determine how they may handle your Personal Information.
For virtual event Services, depending on the type of event, some of the following fields may be displayed throughout the event: first and last name, company, user ID, and user avatar/image. The Sponsor may enable attendees to search for and find other attendees based on a user’s registration information. If you associate your actual name or other personally identifiable information with your user ID, the people to whom you have revealed such information will be able to personally identify your activities on the event. In addition, any Personal Information you choose to share on any publicly available portion of a virtual event may be collected and used by others without restriction. Resumes or curriculum vitae that you have posted to or within a virtual event may be available to all Sponsors of any booth, even if you have not filed a job application with such Sponsor. You should consult the respective privacy policies of these Sponsors to determine how they will handle your Personal Information. This Privacy Statement does not apply to such Sponsors or their use of your Personal Information. West UC does not control Sponsors’ use of your Personal Information. If you would prefer that West UC not disclose your Personal Information to any such Sponsor, please contact our privacy team through the directions at this link, or by mail, as directed in the “Contact Us” section, below. Please be reminded, however, that any Personal Information you publicly display or share or that is accessible through the event may already be in such Sponsor’s possession, despite such opt-out choice.
Venturing off the website
The West UC website may contain hyperlinks that can take you to websites run by third parties (“Third-Party Websites”). Any hypertext or other links to Third-Party Websites from the West UC website are provided solely as a convenience to you. If you use these links, you will leave the West UC website. West UC has not reviewed all of these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, West UC does not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Websites linked to the West UC website, you do this entirely at your own risk.
Remember, this Privacy Statement only applies to West UC. When you are no longer on a West UC website, you may encounter different privacy and security practices and you should familiarize yourself with those practices each time you visit a new website.
West UC reserves the right to modify this Privacy Statement at any time. Please therefore read through this Privacy Statement. Your continued use of the website and the Services signifies your assent to such modifications.
If at any time you believe West UC has not followed this Privacy Statement, or if you have questions, comments, or complaints regarding this Privacy Statement, please contact us at email@example.com. By mail, we can be contacted at:
Janette Nelson, Vice President & Deputy General Counsel.
11808 Miracle Hills Drive
Omaha, NE 68154
EMEA and APAC
Steven Taylor, Regional Privacy & Security Manager and Counsel
5 Arlington Square, Downshire Way
Bracknell, Berkshire RG12 1WA