As an interconnected VoIP Provider Digium Cloud Services L.L.C. has access to a highly regulated form of customer personal information known as Customer Proprietary Network Information (CPNI) and shares this access with Digium, Inc. Please see www.digium.com/cpni for information on the CPNI Policy.
We engage certain trusted third parties to perform functions and provide services to us. These include, without limitation, hosting and maintenance, billing, customer relationship services, database storage and management, and direct marketing campaign services. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.
Preferences and Opt-Out
The personal information we collect as part of any entry/registration process also provides us a means to inform you of product updates or revisions, additional special offers, or to notify you of products and services that relate directly to your specific interests and needs. After you have authorized the initiation of transmission of commercial electronic e-mail from us, you may elect to cease further transmissions of commercial electronic e-mail sent to you from us by clicking on the "unsubscribe link" provided within the e-mail or by completing the opt out form available at https://www.digium.com/unsubscribe. Some non-marketing communications are not subject to general opt-out, such as communications relating to product download, sales transactions, software updates and other support related information, patches and fixes, conferences or events for which you have registered, disclosures to comply with legal requirements, and (where permitted by law) quality assurance surveys. Some additional communications with partners are also not subject to general opt-out, including product alerts, updates, contractual marketing and sales materials, and other notices related to partner status. If at any time you change your mind after opting out you may opt in by https://www.digium.com/emailsubscribe .
We may use IP addresses and web server log files to analyze trends, administer a Website, track a user's movement, and gather broad demographic information for aggregate use. Additionally, in areas of a Website requiring registration, we may use this information from time to time to police a Website for unregistered users (but we undertake no obligation to do so). Information of this type may be combined with cookies or other sources of information for these purposes. Specifically, through the use of web server log files, any or all of the following information may be accessed, collected, analyzed, and stored during or after your visits to the Website: the name of the domain name from which you access the Internet; the country from which you access the Website; the date and time you access the Website; the pages you visit on the Website and the sequence in which you visit them; the amount of time you spent on a particular Website page; the Internet address of a website that you visit immediately before or after visiting our Website; the Internet address from which you linked directly to our Website, if any; the type of operating system on your computer; the type of browser that you are using to view a Website. These and similar types of information may also be collected by "web-bugs" or single-pixel gifs and by other means. We use social buttons (such as Facebook and Twitter) to enable sharing of material originating from our Websites. The third party social sites used to share information use scripts and these scripts may be gathering your information.
Use of Google Analytics to support Display Advertising
In order to market to anonymous visitors, we use Google Analytics to support Display Advertising using data collected from Website visitors as they anonymously browse the Websites. The Google Analytics Features implemented based on Display Advertising are Remarketing and Google Analytics Demographics and Interest Reporting. We use the data from Google Analytics Features to ensure that our marketing is targeting the appropriate Website visitors. Website visitors may use the Ads Settings to opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by going to https://www.google.com/settings/ads. Google Analytics’ currently available opt outs are available at https://tools.google.com/dlpage/gaoptout/. We use Remarketing with Google Analytics to advertise online. Third party vendors, including Google, may show our ads on sites across the Internet. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics Cookie) and third party cookies (such as the Double Click cookie) together to inform, optimize, and serve ads based on your past visits to the Websites.
Information Use and Disclosure
We may use the information obtainable from a Website for editorial and feedback and legal purposes and for other purposes.
For example, we reserve the right to provide IP addresses, information provided during registration, and all of the above data obtained through the use of web server log files to third parties for legal purposes such as preventing or investigating any possible criminal activity or in response to any lawful request.
Additionally, we may provide aggregate information to its in-house and independent sales representatives, use the information for marketing and promotional purposes, for a statistical analysis of user behavior, for product development, to inform advertisers as to how many visitors have seen or clicked on their advertisements, to third parties to assist with the protection and registration of our trademarks, to target markets and to formulate our own proprietary and business strategies and plans. Any information that you actively provide to us, such as names, postal and email addresses, and phone numbers may be added to our databases and if you elect to allow such use, may be used by us to contact you regarding Website updates, new products and services and for other purposes specifically allowed by you when you supply such information.
We may retain the content of any customer service web form or email that we receive, the email from which it is sent, and our response, if any. Content and other information related to emails sent by user to us may be used as testimonials or for any other marketing purpose, except that no marketing communications unrelated to the subject matter of the submission will be sent to the email address from which such email or form is sent unless the user specifically elects to receive additional marketing materials or we obtain the email address through another avenue that permits such use. In all cases, email addresses may be compared to subscription or customer lists of ours and our business partners.
Where completion of a sale or shipment requires the use of information, such as credit card information, shipping addresses, or contact persons, we may use the information to the extent necessary.
We may use the information collected to analyze trends, administer Websites, track user movement, and gather broad demographic information for aggregate use, to monitor or to improve the use and satisfaction of a Website, and to customize, upgrade, or configure the layout or content of a Website.
We may share and disclose aggregated user statistics and demographic information in order to describe our services to prospective and existing partners, advertisers, or other third parties, and for other lawful purposes. This information is not linked to any personal information that can identify any individual person. Under confidentiality agreements, we may match user information with third-party data. We may disclose your personal information to business partners unless you directly inform us that you prefer we not do so.
Links to Third Party Sites
Our Websites take precautions to protect our users' information. We use standard industry mechanisms to protect customer data from unauthorized access, for example, by using password protection and standard encryption methods. Transactions, access to transactional records, or access to account information occurs over a server that has safeguards such as secure server software (SSL) which encrypts information before transmission. You can confirm that pages are encrypted, and we urge you to do so before submitting or transmitting sensitive information, by viewing the lock icon on the bottom of most browsers. We also take measures off-line to protect your information that is known to us to be financial and business sensitive information to the same extent that we take measures to protect our own such information.
You may edit your account information and account profile at any time using your email address and password. Do not divulge your password to anyone. We will never ask you for your password in an unsolicited telephone call or in an unsolicited e-mail. Remember to sign out of your account and close your browser window when you have finished your work. This may help to protect against access by others to your personal and business information if you share a computer or are using a computer in a public place.
- Legal Basis for the Processing of your Information
If you are located in the European Economic Area (“EEA”), our processing of your personal information will be based on the following: To the extent that we obtain your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). If the processing of your personal information is necessary for the performance of a contract between you and us or for taking pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for us to comply with a legal obligation, we will process your personal information on basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).
Please note that where you have given your consent to the processing of your personal information you may withdraw your consent at any time, for example by contacting us as detailed below which withdrawal will not affect the lawfulness of any processing previously made on basis of your consent.
We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. You have the right to access, correct, or delete the personal information that we collect. You are also entitled to restrict or object, at any time, to the further processing of your personal information. You have the right to receive your personal information in a structured and standard format and, where technically feasible, the right to have your personal information transmitted directly to a third party. You may lodge a complaint with the competent data protection authority regarding the processing of your personal information.
You may contact us as detailed below to exercise your rights. We will respond to your request in a reasonable timeframe. To protect the privacy and the security of your personal information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the personal information we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.
In addition to the security measures detailed above, Digium takes the following steps to protect personal data: (i) takes measures to ensure the ongoing confidentiality, integrity, availability, and resilience of Digium processing systems and services; (ii) takes measures to ensure Digium’s ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident; and (iii) has a process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures.
Additionally, you may contact Digium’s GDPR Representative pursuant to Article 27 of the GDPR via email or post to Attorney at Law, Ms. Dr. Anjte Johst, Kurfurstendamm 67, 10707 Berlin, Germany, [email protected]