Regardless of whether you are a visitor on our website, a telecom professional with whom we create or maintain a relationship or our customer, the privacy of your personal data is very important for us!
Should you have any further question in relation to the processing of your personal data, we invite you to contact Vox Carrier at email email@example.com
1 What information do we have about you?
This information is mainly provided by our business partners (i.e. the legal entity for whom you work), it is either directly provided by you or sometimes by third parties (e.g. telecommunication publications, events organizers, other agencies) or it is obtained through trusted publicly available sources (such as LinkedIn, I3 Forum, TM Forum, GSMA or ITU websites). We collect various types of personal data about you, including:
- your general and identification information (e.g. name, first name, last name, email and/or postal address, fixed and/or mobile phone number);
- your function (e.g. title, position, name of company);
- your electronic identification data where required for the purpose of delivering products or services to our company (e.g. IP address, online identifiers/cookies, logs, access and connection times, image recording or sound, CCTV or voice recordings, if the case);
- information regarding your preferences including in terms of channels of communication and frequency;
- data you provide to us for example when you fill in forms or during events you attend, or when you answer questions in a survey;
- data which relate to our products and services;
2 For which purposes do we use your personal data and why is this justified?
2.1 Legal basis for the processing
We will not process your personal data if we do not have a proper justification foreseen in the law for that purpose. Therefore, we will only process your personal data if:
- we have obtained your prior consent;
- the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
- the processing is necessary to comply with our legal or regulatory obligations; or
- the processing is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms.
- Please note that, when processing your personal data on this last basis, we always seek to maintain a balance between our legitimate interests and your privacy. Examples of such ‘legitimate interests’ are data processing activities performed:
- to benefit from cost-effective services (e.g. we may opt to use certain platforms offered by suppliers to process data);
- to offer our products and services to our customers;
- to prevent fraud or criminal activity, misuses of our products or services as well as the security of our IT systems, architecture and networks;
- to sell any part of our business or its assets or to enable the acquisition of all or part of our business or assets by a third party; and
- to meet our corporate and social responsibility objectives.
2.2 Purposes of the processing
We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process your personal data for the following purposes:
- implement tasks in preparation of or to perform existing contracts;
- implement tasks in preparation of or to perform future business contracts;
- manage our relationship with you (e.g. through our databases);
- answer your requests and provide you with efficient support;
- evidence transactions;
- provide you with adequate and updated information about our products and services;
- send you communications regarding products or services that we promote;
- improve the quality of our services by adapting our offering to your specific needs;
- send you surveys (e.g. to help us improve your future interactions with us);
- manage communications and interactions with you (e.g. through the operation of a database keeping records of interactions);
- track our activities (e.g. measuring interactions or sales, number of appointments/calls);
- invite you to events or promotional meetings sponsored by us (e.g. telecommunication events, speaker events, conferences);
- manage our IT resources, including infrastructure management and business continuity;
- preserve the company’s economic interests and ensure compliance and reporting (such as complying with our policies and local legal requirements, tax and deductions, managing alleged cases of misconduct or fraud; conducting audits and defending litigation);
- manage mergers and acquisitions involving our company;
- archiving and record keeping;
- billing and invoicing; and
- any other purposes imposed by law and authorities.
3 Who has access to your personal data and to whom are they transferred?
- our personnel (including personnel, departments or other companies of the group);
- our independent agents or brokers (if any);
- our suppliers and services providers that provide services and products to us;
- our IT systems providers, cloud service providers, database providers and consultants;
- our business partners who offer products or services jointly with us or with our subsidiaries or affiliates;
- any third party to whom we assign or novate any of our rights or obligations; and
- our advisors and external lawyers in the context of the sale or transfer of any part of our business or its assets.
- The above third parties are contractually obliged to protect the confidentiality and security of your personal data, in compliance with applicable law.
Your personal data can also be accessed by or transferred to any national and/or international regulatory, enforcement, public body or court, where we are required to do so by applicable law or regulation or at their request.
The personal data we collect from you may also be processed, accessed or stored in a country outside the country where Vox Carrier is located, which may not offer the same level of protection of personal data.
If we transfer your personal data to external companies in other jurisdictions, we will make sure to protect your personal data by (i) applying the level of protection required under the local data protection/privacy laws applicable to Vox Carrier, (ii) acting in accordance with our policies and standards and, (iii) for Vox Carrier located in the European Economic Area (i.e. the EU Member States plus Iceland, Liechtenstein and Norway, the “EEA“), unless otherwise specified, only transferring your personal data on the basis of standard contractual clauses approved by the European Commission . You may request additional information in relation to international transfers of personal data and obtain a copy of the adequate safeguard put in place by exercising your rights as set out in Section 7 below.
We have implemented appropriate technical and organisational measures to provide an adequate level of security and confidentiality to your personal data.
These measures take into account:
- the state of the art of the technology;
- the costs of its implementation;
- the nature of the data; and
- the risk of the processing.
- The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
Moreover, when handling your personal data, we:
- only collect and process personal data which is adequate, relevant and not excessive, as required to meet the above purposes; and
- ensure that your personal data remains up to date and accurate.
- For the latter, we may request you to confirm the personal data we hold about you. You are also invited to spontaneously inform us whenever there is a change in your personal circumstances so we can ensure your personal data is kept up-to-date.
4 How long do we store your personal data?
We will only retain your personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements.
Personal data we hold in our database about you which is not related to a specific contract or legal obligation will be stored for 24 months after your last interaction with us.
For contracts, the retention period is the term of your (or your company’s) contract with us, plus the period of time until the legal claims under this contract become time-barred, unless overriding legal or regulatory schedules require a longer or shorter retention period. When this period expires, your personal data is removed from our active systems.
Personal data collected and processed in the context of a dispute are deleted or archived (i) as soon as an amicable settlement has been reached, (ii) once a decision in last resort has been rendered or (iii) when the claim becomes time barred.
5 Job applicants
If you apply for a job with Vox Carrier or submit your resume, we use and disclose the information you submit for employment purposes only unless we otherwise obtain consent from you.
6 Marketing and commercial communication
We may use the information you provide us to be in touch with you and to provide updates and send marketing or informational emails to you. You can opt-out at any time by clicking the unsubscribe link or by contacting us at firstname.lastname@example.org. We will treat your information with respect.
7 What are your rights and how can you exercise them?
You may exercise the following rights under the conditions and within the limits set forth in the law:
- the right to access your personal data as processed by us and, if you believe that any information relating to you is incorrect, obsolete or incomplete, to request its correction or updating;
- the right to request the erasure of your personal data or the restriction thereof to specific categories of processing;
- the right to withdraw your consent at any time, without affecting the lawfulness of the processing before such withdrawal;
- the right to object, in whole or in part, to the processing of your personal data;
- the right to object to a channel of communication used for direct marketing purposes; and
- the right to request its portability, i.e. that the personal data you have provided to us be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format without hindrance from us and subject to your confidentiality obligations.
- If you have a question or want to exercise the above rights, you may send an email to email@example.com or a letter to our office, with a scan of your identity card for identification purpose, it being understood that we shall only use such data to verify your identity and shall not retain the scan after completion of the verification. When sending us such a scan, please make sure to redact your picture and national registry number or equivalent on the scan.
If you are not satisfied with how we process your personal data, please address your request at firstname.lastname@example.org who will investigate your concern.
In any case, you also have the right to file a complaint with the competent data protection authorities, in addition to your rights above.