Privacy Policy

This Privacy Policy (“Privacy Policy”) explains our privacy and personal data collection practices in connection with any use of Signal Voice and Data Voice Over IP or “VoIP” products, including hardware, software, and related services (“Signal Services” or the “Services”) or any of its websites (each a “Website”).

Please read this Privacy Policy carefully to learn how we collect, use, share, and otherwise process information relating to individuals or consumers (“Personal Data”), and to learn more about your rights and choices regarding your Personal Data that Signal Voice and Data collects.

This Privacy Policy is incorporated into and made part of the Signal Voice and Data Online Terms of Use (“Terms”) and the Signal Voice and Data Cloud Services Terms & Conditions (“Cloud Services Terms”).

By accessing or using any of the Signal Services or the Website, you are acknowledging, accepting, and agreeing to the practices described in this Privacy Policy.

Please note that this Privacy Policy does not apply to any third-party websites, services, products, applications, and the content used within these third-party systems, even if these third-party websites are accessible through our Websites or Signal Services. See Section 13 below for more information.

If you provide us, or our service providers and channel partners, with any Personal Data relating to other individuals, you represent that you have the authority to do so and, where required, have obtained the necessary consent, and acknowledge that this shared Personal Data may be used by this Privacy Policy.

General Principles

Signal Voice and Data has designed this Privacy Policy to be consistent with our core company principles:

• Privacy policies should be human-readable and easy to find and understand.
• We believe that data collection, storage, and processing should be simplified as much as possible to enhance security, ensure consistency, and make our data processing and privacy practices easy for users to understand.
• Data collection practices should always meet the reasonable expectations of users.
• We always endeavor to collect the least amount of Personal Data and information possible.
• We comply with key data protection laws and privacy standards, such as GDPR and CCPA (each as further defined below).
• We do not sell or share your personal data or information, as further described below in our “CCPA Practices” section (see Section 11).

In this Privacy Policy, we use the terms “Personal Data” and “Personal Information” interchangeably. Under the California Consumer Privacy Act (“CCPA”), as modified by the California Privacy Rights Act of 2020 and as further defined by its accompanying Regulations, “Personal Information” means information that can identify, relate to, describe, be associated with, or be reasonably capable of being associated with a particular consumer or household.

Under the European Union’s General Data Protection Regulation ((EU) 2016/679) (“GDPR”), “Personal Data” means any information relating to an identified or identifiable natural person.

In any reference to CCPA requirements and practices in this Privacy Policy, the use of the term “Personal Data” is replaced with the term “Personal Information.”

Responsible Entity

A reference to “Signal Voice and Data,” “we,” “us,” “our,” or the “Company” is a reference to Signal Voice and Data, a legal entity incorporated under the laws of Tennessee, and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Data for or on behalf of Signal Voice and Data.

Except for Personal Data collected by Signal Voice and Data in connection with its employment and candidate recruiting activities where Signal Voice and Data acts as a controller or business concerning that Personal Data or as otherwise specified in this Privacy Policy, Signal Voice and Data is a “service provider” or “processor” of your Personal Data as described in this Privacy Policy and applicable data privacy laws such as CCPA and GDPR.

A large portion of our commercial activity with customers and end users involves Signal Voice and Data’s direct contractual relationship with our channel partners, such as our value-added resellers, sales agents, and other third parties who in turn contract directly with customers and their end users. Our channel partners may also offer additional products and services to these customers. Signal Voice and Data is not responsible for the data collection practices of its reseller and channel partners; each of whom publishes their own privacy policies.

Our Privacy Policy applies only to Personal Data Signal Voice and Data collects and processes from identifiable and authorized users (such as our customers’ users, their guests, and other authorized individuals) who use and access Signal Voice and Data Services. An “authorized user” is an individual who is entitled to log in to Signal Voice and Data Services through a customer account.

This Privacy Policy only applies to the extent we process Personal Data in the role of a processor or service provider on behalf of our customers when we directly collect Personal Data while providing Signal Voice and Data Services to those customers and their end users, including where we offer various software products and services to our customers. Where our customers (or their affiliates) in turn also collect, use, share, or process Personal Data directly from their own customers, employees, guests, or other end users even using Signal Voice and Data products, our customers are solely responsible for their own data collection practices and privacy policies.

For detailed privacy information related to a Signal Voice and Data customer or partner and their affiliates who use the Signal Voice and Data software products and services as a controller or processor, please contact those Signal Voice and Data customers or partners directly.

Processing Activities Covered

This Privacy Policy applies to the processing of Personal Data collected by us when you:

• Visit our Websites that display or link to this Privacy Policy;
• Visit our branded social media pages;
• Request information from us about our products and Signal Voice and Data Services, obtain technical support, complete an online form, or send us any correspondence, including by one of our “Contact Us” options (e.g., email or by US mail);
• Use our products and Signal Voice and Data Services (whether offered by Signal Voice and Data directly or by one of our channel partners); or
• Apply for employment opportunities with us, or are employed by Signal Voice and Data or one of its affiliates.

What Personal Data Do We Collect and Process?

The Personal Data we collect from you includes the following categories:

• Personal and device identifiers;
• Professional or employment-related information;
• Certain limited financial account information related to your account subscriptions or other purchases;
• Commercial information;
• Internet activity information; and
• Inferences drawn from any of these categories.

We also collect and process your Personal Data in the following situations:

• If you express an interest in obtaining additional information about our Services through a Website form, request customer support, use our “Contact Us” option, including by sending us an email, or similar Services or Website-related features;
• When you register to use our Services as a customer-authorized user or as a guest on behalf of our customers, we may require that you provide us with your contact information, such as your name, job title, company name, address, phone number, email address, or username and password;
• If you obtain our products or Services directly from us (as opposed to directly from a reseller), we may require that you provide us your financial and billing information, such as billing name and address, credit card number, or bank account information; we do not retain either credit card or bank account information, as this sensitive financial information is stored and processed only by our third-party payments processing partner and not by Signal Voice and Data;
• If you interact with our Websites or send us emails, we automatically collect information about your device and your usage activities on our Websites (such as Internet Protocol (IP) addresses, MAC ID, or other identifiers), which may include Personal Data;
• If you use and interact with our Services or mobile applications, we automatically collect information about your device and your usage of our Services through log files and other technologies;
• If you communicate with us by way of a phone call, we may record and store that call for the limited purpose of responding to your requests, including technical support needs; and
• If you voluntarily submit certain information to our Services, such as completing online forms, responding to surveys, or interacting with our webchat feature, we collect the information you have provided as part of that request or interaction.
• If you believe that your Personal Data has been provided to us improperly, or want to exercise any of the rights described in this Privacy Policy relating to your Personal Data, please contact us by using the information in the “Contact Us” Section 15 below.

What Device and Usage Data Do We Process?

We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our Websites, use our Services, or interact with emails we have sent to you.

• Device and Usage Data:  As is true of most websites, we gather certain information automatically when individual users visit our Websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider identity, mobile carrier identity, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the Websites. This information, which may include limited Personal Data, is used solely to analyze overall visitor use trends, help us provide and improve our Websites, offer a tailored experience for Website users, and secure and maintain our Websites.

• Cookies, Web Beacons, and Other Tracking Technologies: To make our Websites and Services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. It enables the website to remember your actions and preferences over time so that you don’t have to keep re-entering this information whenever you come back to the website or browse from one page to another.
• Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the Websites. We do not combine the information collected through the use of Google Analytics with Personal Data that we collect. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on. You may wish to restrict the use of cookies. Please be aware that some of the features of our Website may not function correctly if you disable cookies.

Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Microsoft Edge
• Cookie settings in Safari web and iOS
• Do-Not-Track Signals

Do Not Track (“DNT ”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Zultys does not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT and a common approach to responding to DNT. We may recognize and respond to these DNT signals in the future.

Our Business Purposes and Lawful Bases for Processing Personal Data

We use Personal Data that we collect only for permitted “business purposes” (as defined in Section 1798.140(e)(1)-(8) of CCPA), or in a manner described in Article 6 of GDPR (“Lawfulness of Processing”).

We collect and process your Personal Data for the following business or lawful purposes:

• Providing our Websites and Services: We process your Personal Data to perform under our agreements with our customers for the use of our Websites and Services and to fulfill our obligations under these contracts with our customers;
• Promoting the security of our Websites and Services: We process your Personal Data by tracking the use of our Websites and Services, creating aggregated data that anonymizes Personal Data, verifying accounts and user activity, investigating suspicious online activity, and enforcing our terms and policies to the extent it is necessary for promoting the safety and security of our Services, systems, and applications;
• Managing user registrations and your account: If you have registered for an account with us (or our customers have set up an account for you), we process your Personal Data by managing your user account to perform our contractual obligations with our customers according to our agreed-upon terms;
  
• Handling contact and user support requests: If you fill out a web form or request user support, or if you contact us by other means, including via a phone call, we process your Personal Data to fulfill our contractual obligations to our customers and only to the extent it is necessary to respond to our customers’ requests and communicate with you on behalf of our customers;
• Enabling payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments through our payment processing service provider to the extent that doing so is necessary to complete a transaction and perform our contracts with our customers;
  
• Developing and improving our Websites and Services: We process your Personal Data to analyze trends and to track your usage of and interactions with our Websites and Services to the extent it is necessary for developing and improving our Websites and Services and providing our users with more relevant content and Service offerings;
• Assessing and improving user experience: We process device and usage data as described above, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience;
• Identifying customer opportunities: We process your Personal Data to assess new and potential customer opportunities to ensure that we are meeting the demands of our customers and their users’ experiences;
• Recording phone calls: We may record phone calls for training, quality assurance, and administration purposes. If required under applicable law, we will obtain your prior consent or give you the option to object to a call being recorded; and
• Complying with our legal obligations: We process your Personal Data when cooperating with public and government authorities, courts, or regulators in accordance with legal obligations.

Do We Share Personal Data That We Collect?

Signal Voice and Data does not “sell” or “share” your Personal Information, as such terms are defined in CCPA. We do not offer California consumers a “right to opt-out” of the sharing and selling of Personal Data. We also do not share the Personal Information we collect with service providers who undertake cross-context behavioral advertising. If Signal Voice and Data changes its business practices in the future, we will update this Privacy Policy and provide consumers the right to opt out of such Personal Information usage.

SMS Opt-in or Consent Status

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

We may share your Personal Data for business purposes, as described above, with:

• Service Providers: With our contracted service providers, as required, to offer you our products and Services. These providers help us to run, operate, and maintain our Services through third-party platforms and software tools; perform content moderation and crash analytics; run email and mobile messaging campaigns; and provide technical and customer support.
• Professional Advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Third Parties Involved in a Corporate Transaction: If we are involved in a merger, reorganization, dissolution, or other corporate change, or if all or a portion of our business, assets, or stock are acquired by a third party.

We may also share anonymous and de-identified usage data with Signal Voice and Data service providers to help Signal Voice and Data in the analysis and improvement of its products and Services. For more information on those entities with whom we share your Personal Data, please contact us by using the information in the “Contact Us” Section 15 below.

International Transfer of Personal Data

Any Personal Data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States. Signal Voice and Data may transfer your Personal Data across international borders for business purposes. Please be aware that data protection standards may vary by location.

Children and Persons the Age of 16 and Under

Our Websites are not directed at individuals under the age of 16. We do not knowingly or intentionally collect Personal Information from children under 16. If you become aware that a child has provided us with Personal Information, please contact us. We will take steps to delete such information.

How Long Do We Keep Your Personal Data?

Signal Voice and Data retains Personal Data for as long as necessary to provide the products and Signal Voice and Data Services and fulfill transactions, or for other legitimate purposes such as complying with legal obligations, resolving disputes, and enforcing agreements.

Your Rights Relating to Your Personal Data

• CCPA Practices

These additional disclosures for California residents (e.g. “consumers”) apply only to individuals who reside in California. The CCPA provides consumers additional rights to know, delete, correct, and opt-out, and requires businesses collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise.

California Notice of Collection.  See our separate California Notice of Collection (“Notice of Collection”) under CCPA located here: https://www.zultys.com/notice-of-collection/. In this Notice of Collection, we provide you with all the details for privacy policies required under 11 CCR § 7011 (California Code of Regulations).

In general, a California consumer has the following rights under CCPA: Right to Know, Delete, and Correct. If You are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• The categories of Personal Information about you that we disclosed for a business purpose or sold;
• The categories of third parties to whom the Personal Information was disclosed for a business person or sold;
• The business or commercial purpose for collecting or selling the Personal Information; and
• The specific pieces of Personal Information we have collected about you.

In addition, you have the right to delete the Personal Information we have collected from You. However, this is not an absolute right and we may have legal grounds for keeping such data. You also have the right to correct the Personal Information we have collected from you if you can demonstrate that such Personal Information is inaccurate.

To exercise any of these rights, please submit a request to privacy@zultys.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) business days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Sensitive Personal Information.  We only collect Personal Information from consumers that under CCPA is considered to be “sensitive personal information” for the limited purposes described in our Notice of Collection.

Authorized Agent.  You can designate an authorized agent to submit requests on Your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination. You have the right to non-discriminatory treatment by Signal Voice and Data, should you exercise any of Your rights.

• GDPR Practices 

If your Personal Data is subject to the GDPR, Signal Voice and Data or its service providers act as your data processors or sub-processors. To exercise your rights under GDPR, contact us at privacy@signalvoiceanddata.com.

How We Secure Your Personal Data

Signal Voice and Data has implemented reasonable security measures to protect your Personal Data. However, no system is completely secure, and we cannot fully guarantee the security of your data. If a breach occurs, we will notify you promptly and take appropriate action.

Third-Party Sites

Our Websites may link to third-party websites. We are not responsible for the privacy practices of those websites. We encourage you to review their privacy policies before providing any Personal Data.

Changes to This Privacy Policy

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy or by other means. Continued use of our Website after changes have been posted constitutes your agreement to the changes.

Contact Us

If you have questions about this Privacy Policy or your Personal Data, contact us at:

Email:

info@signalvoiceanddata.com

Phone: (423) 756-4066

Mail:
Signal Voice and Data
2100 Broad Street
Chattanooga, TN 37408