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At Ribbon, privacy matters. Ribbon respects the privacy of its customers and other individuals with whom Ribbon has business interactions This policy is global, applying to all Ribbon locations. It applies to personal information regardless of format. For example, the policy applies to computerized records and electronic information as well as paper-based files.It is also applicable to all personal information that is collected, maintained or processed by Ribbon. The concepts enumerated in this this policy will guide Ribbon’s selection and expectations of its agents and contractors to whom Ribbon transfers and relies on for processing of personal information. Ribbon processes personal information that is controlled by or originated from other companies, such as our customers or other business partners. Ribbon shall protect the personal information, comply with all laws that regulate the processing of such personal information, and process the information only as authorized by the data controller or the data subject. In some cases, Ribbon may collect and process personal information for our own business purposes and shall comply with the applicable privacy laws concerning Ribbon’s processing.
Ribbon provides the technology platform for hosted cloud information and communications services. These services merely act as a conduit for data transmitted by third parties and subscribers. Ribbon also processes personal information in the course of providing support for Ribbon communications products. In its role as a data processor, the standard of care that Ribbon must comply with is that of the data processor rather than the data controller. Accordingly, Ribbon relies on guidance and direction of the data controller, who determines the purposes of processing such personal information. While Ribbon does process data in its role of providing a technology platform, it does not own, control or direct the use of any of the personal information stored or processed by any subscriber. Ribbon only processes such personal information in order to provide and bill for subscribed services.
Ribbon processes and in certain situations collects personal information as needed to deliver its products and services and manage its business. When collecting personal information, Ribbon does so in a reasonable and lawful manner. The types of information and the purposes for which Ribbon collects or processes personal information may include: For Customers & Resellers
Ribbon uses such personal information only for relevant, appropriate, and customary purposes. Ribbon will not share or disclose personal information for purposes other than as described herein. The following are examples of some of the personal information Ribbon processes.
Business Contact Information: Ribbon may collect and use personal information about individual contacts of customers and others who access Ribbon public websites or provide personal information through other means. Such information may include account information, first/last name, company name, title and responsibilities, work email address, work mailing address, telephone numbers, as well as additional information provided by such individuals in the course of receiving products or services from Ribbon and/or requesting information about Ribbon. We will use such information for the purposes of providing services, product support, conducting data analytics and product assessments and related activities, and providing information regarding Ribbon products and services. Unless expressly requested by Ribbon and consented by the business contact, Ribbon will not share or disclose such business contact information to marketing firms or similar organizations.
Customer Proprietary Network Information (CPNI): Customer Proprietary Network Information (CPNI) may include information regarding quantity, destination, technical configuration, location, amount of use and related billing information of telecommunications, interconnected or non-interconnected Voice over Internet Protocol (VoIP) services. This may include but is not limited to the phone numbers that you call or send messages to (or the phone numbers that you receive these calls and messages from) through our service. The date, time and duration of the calls may also be collected. This data is used for billing and service level assurance. Ribbon provides services that are primarily for the benefit of organizations and subscribers in that it transmits, routes, switches or caches information. These services merely act as a conduit for data transmitted by third parties and subscribers. Ribbon does not determine the purposes and means of processing this personal information. However, for data that is collected by Ribbon that is not subject to the control of others, Ribbon shall obtain consent from the user for the processing of this data. Ribbon collects end user CPNI in the course of providing service and product support. This data may pertain to direct customers of Ribbon or indirect customers (eg: end users of Ribbon’s direct customers). This data may include IP address, telephone number, call detail records and other information sufficient to identify an individual end user. Indirect End User’s CPNI: Ribbon acts as a data processor with regard to indirect end user personal information, and our customers act as the data controller of such data. In the course of Ribbon’s processing and protection of such data, use will be in conformity with the data controller’s instructions. Direct End User’s CPNI: Ribbon typically collects and processes direct end user personal information for the purposes of providing services, product support, conducting data analytics and managing product performance.
Messaging, Voicemail, Video and Media Files: Ribbon’s provides services that facilitate the recording and storage of audio and video by way of services such as voicemail, call and conference recording. Users may elect to store or record personal information including Sensitive Personal Information (SPI) within these resources at their discretion. Ribbon does not own, control or direct the use of any of the information stored or processed by any user.
Credit Card Information: Ribbon only collects credit card information in order to bill for subscribed services. Ribbon utilizes credit card payment processing agents solely for the purpose of processing payment for the services you receive. We require these agents to take reasonable and appropriate measures to protect this information from loss or misuse.
For Vendors, Suppliers and Sub-Contractors
Ribbon may collect personal information about individuals who are employed by our suppliers and vendors. This business contact and payment information is strictly used to administer existing and future business arrangements.
Additional personal information may be collected, processed and disclosed for the purposes for which it was collected and for legal compliance purposes, including regulatory reporting, investigation of allegations of wrongdoing, and the management and defense of legal claims and actions, and compliance with subpoenas, court orders and other legal obligations. For example, we may collect information about individuals that visit our facilities.When we do collect data, such collection shall be relevant, proportionate and limited to the purposes for which they are processed.
Where feasible Ribbon utilizes geographically aligned resources for primary data processing in order to reduce complexity and volume of cross-border personal information transfer. Where cross-border transfer is necessary Ribbon utilizes entities who have demonstrated an ability to comply with applicable personal information privacy regulation. Ribbon shall comply with the applicable laws governing personal information transfer and where required shall ensure that such transfers are made to countries where the data protection regime is compatible with that of the originating jurisdiction.
Ribbon will only transfer or provide direct access to personal information covered by this policy to third parties that have:
EU Personal Information
Additionally, for personal information pertaining to EU data subjects Ribbon will only transfer or provide direct access to personal information covered by this policy to third parties that:
Accordingly, Ribbon requires the following of it’s onwards transfer agents:
The data Ribbon processes is described in further detail in the “Information We Collect and Use” section above. Ribbon recognizes and promotes the right of subscribers to have reasonable opportunities to object to the collection (opt out), use and disclosure of their personal information while still maintaining the minimal data needed to provide the subscribed service. However, except for data provided by the subscriber for which Ribbon is merely providing a conduit for transmission, the subscribed services are of such a nature that, in most instances, Ribbon requires and collects only essential CPNI and billing information, and opting out or declining to provide the requested data may hinder the provision of subscribed services. For further information on opting out please reference the instructions in the Contact section below.
Ribbon recognizes that for some sensitive information, affirmative express consent from individuals is required and must be obtained if such information is to be (i) disclosed to a third party or (ii) processed for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice. In addition, Ribbon shall treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.
If you have created a user profile on any Ribbon service portal (eg: Salesforce, uReach.com, Kandy.io), you may access and revise the personal information in your user profile when you log into your account. In general, these portals will only require minimal personal information that is necessary to provide and administer the service.
If you provide us with your email address or other Business Contact Information to enable us to provide current communications and information to you, we may use the information for providing such communications including delivery of press releases and other Ribbon marketing materials. You may request to no longer receive Ribbon marketing communications by following the "unsubscribe" instructions in emails from Ribbon or by sending a request to the contact identified below.In the rare and unlikely event that Ribbon wishes to use an individual’s personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals, Ribbon will seek consent in advance as required by law.
Ribbon employs reasonable means to keep personal information accurate, complete, and current, as needed for the purposes for which it was collected.
In general, personal information may be shared within Ribbon, where legally permitted for reasonable and appropriate corporate purposes. However, even within Ribbon, we restrict access to personal information to those employees, agents, or contractors who need access to carry out their assigned functions.
Ribbon uses vendors and partners for a variety of business purposes such as to help us provide, and bill for services we provide. We share information with those vendors and partners when it is necessary for them to perform work on our behalf. As described in the Accountability for Onward Transfer section of this policy, Ribbon requires that these vendors and partners protect the customer information we provide to them and limit their use of such information to their respective processing activity.We may disclose information that individually identifies our subscribers or identifies customer devices in certain circumstances, such as:
If Ribbon enters into a merger, acquisition or sale of all or a portion of its assets or business, customer information will also be transferred as part of or in connection with the transaction as per local law and/or non-disclosure agreement.
To help protect the confidentiality of personal information, Ribbon employs security safeguards appropriate to the sensitivity of the information. These safeguards include reasonable administrative, technical and physical measures to safeguard the confidentiality and security of personal information against anticipated threats and unauthorized access to the personal information. We convey safeguard obligations to our agents who receive personal information from or on behalf of Ribbon in the course of their relationship with our organization as described above in the Accountability for Onward Transfer provision.
Personal information collected by Ribbon will be retained for as long as necessary and legally permitted for the purposes for which it was collected, to provide you with services and to conduct our legitimate business interests or where otherwise required by law.
We shall generally provide individuals with an opportunity to examine their own Personal Information, confirm the accuracy and completeness of their Personal Information, and have their personal information updated, if appropriate. The ability of an individual to access his or her personal information is not unlimited, however. An individual’s ability to access personal information may be limited, for example, where (a) the burden or expense of providing access would be unreasonable or disproportionate to the risks to the individual’s privacy, (b) the information should not be disclosed due to legal or security reasons or to protect confidential commercial information; or (c) providing access would compromise the privacy of another person. If you have created a user profile on a portal, you may also access and revise the personal information in your user profile when you log into your account.Individuals who wish to access or update their personal information not accessible via a portal, or who wish to file a complaint or who take issue with Ribbon’s policy should direct such communications to Ribbon at:
Ribbon Legal Department
Attention: Chief Legal Officer
3605 East Plano Parkway Suite-400
Plano, Texas 75074 USA
Ribbon undertakes annual compliance review of our policies, procedures with respect to data privacy to ensure that policy is implemented as presented and, in particular, to address any cases of non-compliance. Ribbon also considers any impact to our policies and procedures as a result of privacy law changes or trends in recurring complaints from individuals.
October 30, 2017
500 Palladium Drive
Ottawa, Ontario, Canada K2V 1C2
Ribbon's team of professionals are ready to answer your questions, guide you to the right solution or help you with your network design.