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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:
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.
To learn more about the the EU-U.S. and Swiss-U.S. Privacy Shield programs, please visit http://www.privacyshield.gov. To view the Ribbon Privacy Shield Companies’ certification under Privacy Shield, please visit http://www.privacyshield.gov/list.
Individuals will be offered a clear, conspicuous, and readily available mechanism to choose (opt out) whether their personal information is (1) to be disclosed to a third party (other than a third party acting as an agent to perform tasks on behalf of and under the instruction of Ribbon or (2) to be used for a purpose that is materially different than or incompatible with the purpose for which it was originally utilized or subsequently authorized by the individual.
Additionally, individuals will be offered a similar choice mechanism to give affirmative or explicit (opt in) choice whether their sensitive personal information is to be disclosed to a third party or used for a purpose other than the purposes for which it was originally collected or subsequently authorized by the individual by opt-in choice. However, explicit (opt in) choice is not required when the disclosure of the sensitive personal information is (1) in the vital interests of the individual or another person; (2) necessary for the establishment of legal claims or defenses; (3) required to provide medical care or diagnosis; (4) necessary to carry out the organization’s obligations in the field of employment law, or (5) related to personal information that is manifestly made public by the individual.
Ribbon’s EU and Swiss entities may transfer personal information to a processor in the United States solely for processing purposes. A “processor” is a third party who processes personal information on behalf of and in accordance with the instructions of Ribbon’s EU and/or Swiss entities. When personal information is transferred from the EU and/or Switzerland to the United States solely for processing purposes, Ribbon’s EU and/or Swiss entities will comply with the applicable data protection laws including the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP), respectively and enter into a contract with the processor to ensure that the processor (1) acts only on instructions of Ribbon’s EU and/or Swiss entities; (2) provides appropriate technical and organizational measures to protect the personal information against unlawful destruction or accidental loss, alteration, unauthorized disclosure or access; and understands whether onward transfers are allowed; and (3) assists Ribbon’s EU and/or Swiss entities in responding to individuals exercising their rights under the Privacy Shield principles, taking into account the nature of the processing.
After personal information is transferred from the EU and/or Switzerland to the Ribbon Privacy Shield Companies in the United States, the Ribbon Privacy Shield Companies may thereafter transfer the personal information to third parties acting as controllers. A “controller” is a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal information. Examples of third party controllers may include banks and healthcare providers, or management personnel in other Ribbon Privacy Shield Companies offices outside of the U.S. When the Ribbon Privacy Shield Companies makes such onward transfers to third party controllers, the Ribbon Privacy Shield Companies will comply with the Privacy Shield notice and choice principles and enter into a contract with the third party controller that provides that (1) such personal information may be processed only for limited and specified purposes consistent with the consent provided by the individual; (2) the third party controller will provide the same level of protections as the Privacy Shield principles; (3) the third party controller will notify the Ribbon Privacy Shield Companies if the third party can no longer meet its obligation to provide the same level of protection for the personal information as required by the Privacy Shield principles; and (4) upon such notice by the third party controller, the third party controller will cease processing the personal information and/or take reasonable and appropriate steps to remediate any unauthorized processing.
The Ribbon Privacy Shield Companies have verified and will verify annually through self-assessment that the attestations and assertions made about its Privacy Shield privacy practices are true and that those privacy practices have been implemented as represented and in accordance with the Privacy Shield principles. This verification has been and will be signed by an officer of the Ribbon Privacy Shield Companies or other authorized representative of the Ribbon Privacy Shield Companies at least once a year and is available upon request by individuals or in the context of an investigation or a complaint about non-compliance. The verification includes the following:
Inquiries or complaints regarding transfers of personal data from the EU or Switzerland to the U.S. pursuant to Privacy Shield should be directed to:
Associate General Counsel
5927 South Miami Blvd, Suite 150
Morrisville, NC 27560 USA
Fax: (972) 965-3600
If a complaint remains unresolved, it will be resolved through alternative dispute resolution. Ribbon has selected JAMS Mediation, Arbitration and ADR Services (JAMS) as the administrator of Ribbon’s independent recourse mechanism for Privacy Shield disputes. Ribbon has committed to refer such unresolved Privacy Shield complaints to JAMS in the United States. You may find more information about dispute resolution and how to file a claim with JAMS at https://www.jamsadr.com/eu-us-privacy-shield.
Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Please visit Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
The Ribbon Privacy Shield Companies are also subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
In the context of an onward transfer of personal information, the Ribbon Privacy Shield Companies have responsibility for the processing of personal information they receive under the Privacy Shield and subsequently transfers to a third party agent. The Ribbon Privacy Shield Companies will remain liable under the Privacy Shield principles if their third party agent processes such personal information in a manner inconsistent with the Privacy Shield principles, unless the Ribbon Privacy Shield Companies proves that they are not responsible for the event giving rise to the damage.
All employees who handle personal data transferred from the EU or Switzerland to the U.S. will receive training regarding the data privacy prinicples and procedures under Privacy Shield Principles and this Policy.
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
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.
March 1, 2018
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.