Privacy Policy

Callbridge has a policy of protecting customer privacy. We believe that you have the right to know what information we collect from you as well as how that information is used, disclosed and protected. We have created this policy statement (the “Privacy Policy” or the “Policy”) to explain our privacy practices and policies. When you use any Callbridge product or service, you should understand when and how personal information is collected, used, disclosed, and protected.

Callbridge is a service of Iotum Inc.; Iotum Inc. and its subsidiaries (collectively the “Company”) are committed to protecting your privacy and providing you with a positive experience on our websites and while using our products and services (the “Solutions”).  Note: “Callbridge”, “We”, “Us” and “Our” means the www.callbridge.com website (including subdomains and extensions thereof) (the “Websites”) and the Company.

This Policy applies to the Websites and Solutions that link to or reference this Privacy Statement and describes how we handle personal information and the choices available to you regarding collection, use, access, and how to update and correct your personal information. Additional information on our personal information practices may also be provided with other notices provided prior to or at the time of data collection.  Certain Company websites and Solutions may have their own privacy documentation describing how we handle personal information for those websites or Solutions specifically. To the extent a specific notice for a website or Solution differs from this Privacy Statement, the specific notice will take precedent. If there is a difference in translated, non-English versions of this Privacy Statement, the US-English version will take precedent.

What is Personal Information?
“Personal information” is any information that can reasonably be used to identify an individual or that can be directly associated with a specific person or entity, such as name, address, email address, phone number, IP address information, or login information (account number, password).

Personal information does not include “aggregate” information. Aggregate information is data we collect about a group or category of services or customers from which individual customer identifiers have been removed. In other words, how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data. Aggregate data helps us understand trends and customer needs so that we can better consider new services or tailor existing services to customer desires. An example of aggregate data is our ability to prepare a report that indicates that a certain number of our customers always use our collaboration services at a certain time of day. The report would not contain any personally identifiable information. We may sell aggregated data to, or share aggregate data with, third parties.

Collection & Use of Your Personal Information
Our Websites collect personal information about You so that we can deliver the products or services you request. We may collect data, including personal information, about you as you use our Websites and Solutions and interact with us. This happens automatically when You interact with us, such as when You register or log into the service. We may also buy commercially available marketing and sales information from third parties so we can better serve you.

The types of personal information that we may process depend on the business context and the purposes for which it was collected. We may use Your personal information for the purposes of operating and helping to ensure the security of our business, delivering, improving, and customizing our Websites and Solutions, sending notices, marketing, and other communications, and for other legitimate purposes permitted by applicable law.

Information Collected About You
As both a data controller and a data processor, We collect a variety of personal information about users of Our products or services.  A summary of the personal information that we may collect and process about You is outlined below:

Description of Service:  Callbridge is a group meeting, conferencing, and collaboration service provided by Iotum Inc. and its affiliates. 
Subject-matter of Processing: Iotum processes certain Customer Personal Information on behalf of its Customers in relation to the provision of conferencing and group collaboration. The content of the Customer Personal Information is determined by the products and services used by its Customers; during the provision of such services, Iotum’s platform and network may capture data from Customers’ systems, phones, and/or third party software platforms.
Duration of Processing: For the duration of the Services to which the Customer uses them or the duration of the subscription for an account to use such Services, whichever is longer.
Nature and purpose of Processing: To enable Iotum to provide the Customer with certain Services in relation to conferencing and group collaboration services in accordance with the Terms and Conditions of its services.
Type of Personal Information: Customer Personal Information relating to Customers and provisioned end users of the Services which is based on data supplied by such Customers or provisioned end-users and/or otherwise collected by or on behalf of the Customer or provisioned end-user as a result of the use of the Services. Iotum also collects information about visitors to its web properties. The collected information may include without limitation, data uploaded or pulled into Iotum, personal contact information, demographic information, location information, profile data, unique IDs, passwords, usage activity, transaction history, and online behaviour and interest data.
Categories of Information Subjects:  Callbridge Customers (and, if corporate or group in nature, their provisioned users of Services), as well as visitors to Websites.

The specific types of personal and other information that we may collect from you are as follows:

  •  Information You Give Us: We collect the information you give us when you sign up with the Websites or use our services. For example, you may provide us with an e-mail address when signing up for services. You might not have thought about it this way, but the e-mail address you may use when browsing to our website is an example of information you give us and that we collect and use.
  • Information from Other Sources: We may obtain information about you from outside sources and add it to or, subject to your express consent, combine it with our account information. We may use commercially available demographic and marketing information from third parties to help us better serve you or inform you about new products or services that we think will be of interest to you.
  • Automatically Collected Information: We automatically receive certain types of information whenever you interact with us. For example, when you visit the Websites, our systems automatically collect your IP address and the type and version of browser you use.

You should refer to the rest of this Policy to see how we use, disclose and protect this information, which generally falls into the following categories:

Source of personal data Types of personal data to be processed Purpose of processing Lawful basis Retention period
Customer (at signup) User name, email,  selected username, account creation date, password  To provide collaboration applications

* Consent

 * Required to provide requested collaboration services to customer

Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Customer (at signup) Source data  Providing efficient collaboration applications and associated marketing and customer support

* Consent

 * Required to provide requested collaboration services to customer

Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Operating systems (driven by customer activity and use of service) Call record (CDR) data, log data, call rating data, customer support tickets and data To provide collaboration applications

* Consent

 * Required to provide requested collaboration services to customer

Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Operating systems (driven by customer activity and use of service) Recordings, whiteboards Application logging

* Consent

 * Required to provide requested collaboration services to customer

Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Operating systems (driven by customer activity and use of service) Transcriptions, intelligent call summaries To provide the associated additional functions and features related to the collaboration application(s)

* Consent

 * Required to provide requested collaboration services to customer

Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Customer (only if billing information entered and applicable) Billing Info details, transaction details  Credit card processing 

* Consent

 * Required to provide requested collaboration services to customer

Longer of duration of customer contract period and any longer period required due to specific regulatory requirements

Callbridge recognizes that parents often sign up for our products and services for family use, including for use by children under the age of 18. Any information collected from such usage will appear to be the personal information of the actual subscriber to the service, and will be treated as such under this Policy.

When our customer is a business or other entity purchasing services for employees or other authorized users, this Policy will generally govern the personal information associated with individual employees or authorized users. However, whether the business customer has access to personal information of employees or other authorized users will be governed by the terms of any service agreement. On that basis, employees or other authorized users should check with the business customer regarding its privacy practices, before using the Services.

Personal information does not include “aggregate” information. Aggregate information is data we collect about a group or category of services or customers from which individual customer identities have been removed. In other words, how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data. Aggregate data helps us understand trends and customer needs so that we can better consider new services or tailor existing services to customer desires. An example of aggregate data is our ability to prepare a report that indicates that a certain number of our customers always use our conferencing services at a certain time of day. The report would not contain any personally identifiable information. We may sell aggregate data to, or share aggregate data with, third parties.

Children’s Online Privacy Protection
Callbridge does not knowingly, directly or passively, collect information from children under the age of 18. If we create offers and products that make it appropriate to collect information from children under the age of 18, we will notify you of the change in this Policy. We also will ask a parent to confirm his/her consent in advance of any collection, use or disclosure of that information. You should be aware, however, that web browsers and conferencing services set up for family use may be used by minors without the knowledge of Callbridge. If that happens, any information collected from the usage will appear to be the personal information of the actual adult subscriber and treated as such under this Policy.

Internal Use of Personal Information
In general, we use personal information to serve our customers, to enhance and extend our customer relationship and to enable our customers can take maximum advantage of our products and services. For example, by understanding how you use our Websites from your computer, we are able to customise and personalise your experience. More specifically, we use personal information to provide services or complete transactions you have requested and to anticipate and resolve problems with your services. Subject to you providing your express consent, Callbridge may also e-mail to inform you about new products or services we think will interest you or that better meet your needs (unless otherwise stated when you complete your registration as a user of our services).

Third Party Use of Personal Information
You should review the following section (‘Disclosure of Personal Information’) to understand when Callbridge discloses personal information to third parties.

Disclosure of Personal Information
Information about our customers is one of our most important business assets, and therefore we strive to protect it and keep it confidential. Save for any permitted disclosures set out in this section, we will not disclose your personal information to any third party without your express consent. Depending on the service, we may obtain your express consent in a number of ways, including:

  • In writing;
  • Verbally;
  • Online by ticking unchecked boxes on our registration pages as to which forms of third party communication you consent to (such as email, telephone, or text message);
  • At the time of service initiation when your consent is part of the required terms and conditions to use the service.

You are not obliged to give your consent to any particular type of communication or at all. In certain circumstances, your consent to disclose personal information can also be implied simply by the nature of your request, such as when you ask us to deliver an e-mail to another person. Your return address is disclosed as part of the service and your consent to do so implied by your use of the Service. To determine how personal information may be disclosed as part of a particular service, you should review the terms and conditions of use for that service.

We may share personal information with third parties as necessary to complete a transaction, perform a service on our behalf or that you have requested or to enhance our ability to serve you better (for example, business partners, suppliers, and subcontractors). If the third party acts solely on our behalf, Callbridge will require them to follow our privacy practices. Iotum Inc. (including its operating subsidiaries) may share your personal information with the operator of a supplier of Callbridge, to the extent necessary to deliver the Services to you, as further detail below.

Subcontracting and Subprocessing
Iotum Inc. may provide the following types of information to the following types of third party processor for the following purpose(s) in order to provide the Services to You: 

 

Type of Subcontracted Subprocessor  Types of personal data to be processed Purpose of Processing and/or Task(s) to be performed International transfer (if applicable)
User management SaaS Platform Customer details, source data details User base management for marketing and promotional campaigns US
Canada
Secure colocation and webhosting facilities providers and/or cloud-hosting providers All Data, excluding credit card numbers Hosting of Iotum collaboration applications May include (depending on Your location and location of participants involved in Your sessions): US, Canada, Ireland, Japan, India, Singapore, Hong Kong, UK, Australia, European Union
Software development environments and platforms All Data, excluding credit card numbers and passwords Application development; application debugging and logging, internal ticketing, communication, and code repository US
Customer Management SaaS Platform Personal information, support tickets, support contact CDR data, customer details, service usage, transaction history Customer support,  managing sales leads, opportunities, and accounts within CRM US
Canada
UK
Telecommunications and communication network providers, including dial-in numbers providers Conference CDR data Data transport and dial in number (“DID”) services; Some DIDs within Iotum’s collaboration applications may be provided by communications and network companies located around the globe (in order to provide access to participants in such locales) US; associated global jurisdiction
Toll Free Number Providers Conference CDR data Toll-free number services; Some Toll-Free numbers within Iotum’s  collaboration applications are provided by communications and network companies located around the globe (in order to provide access to participants in such locales) US; associated global jurisdiction
Data Analytics SaaS Provider All Data, excluding credit card numbers Reporting and data analytics; marketing and trend analysis US/Canada
Credit Card Processing Provider Billing Info details, transaction details Credit card processing; hosted credit card processing services US

Where applicable, Iotum relies upon the associated contractual clauses with such third-party processors in each case to ensure that any necessary data privacy processing requirements are met.  Where applicable this may include the European Commission Standard Contractual Clauses for international transfers described at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en.

International Transfer, Processing and Storage of Personal Information

We may transfer your personal information to any Company subsidiary worldwide, or to third parties and business partners as described above that are located in various countries around the world. By using our Websites and Solutions or providing any personal information to us, where applicable law permits, you acknowledge and accept the transfer, processing, and storage of such information outside of Your country of residence where data protection standards may be different.

Security of Your Personal Information
We take reasonable and appropriate steps to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Statement. The Company implements physical, technical, and organizational safeguards designed to protect Your personal information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.  Where applicable, We also contractually require that Our suppliers protect such information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

 We maintain a variety of physical, electronic, and procedural safeguards to guard your personal information. For example, we use accepted tools and techniques to protect against unauthorized access to our systems. Also, we restrict access to personal information about you to those employees who need to know that information to provide products or services to you. You should be aware that Callbridge has no control over the security of other websites on the Internet you might visit, interact with, or from which you buy products or services.

An important part of protecting the security of personal information is your efforts to protect against unauthorized access to your user name and password and to your computer. Also, be sure to sign off when finished using a shared computer and always log out of any site when viewing personal account information.

Retention and Disposal of Personal Information
We will retain your personal information as needed to fulfill the purposes for which it was collected.  This is further detailed in the earlier section titled “Information Collected About You”.  We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements. 

 We will not retain personal information in identifiable form when the purpose(s) for which the personal information was collected have been achieved and, there is no legal or business need to retain such personally identifiable information. Thereafter, the data will either be destroyed, deleted, anonymized, and/or removed from our systems.

Updating this Policy
Callbridge will revise or update this Policy if our practices change, as we change existing or add new services or as we develop better ways to inform you of products we think will be of interest. You should refer back to this page often for the latest information and the effective date of any changes.

Callbridge Use of “Cookies”
Like many websites and web-based Solutions, Callbridge uses automatic data collection tools, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends to us (e.g., Internet Protocol (IP) address).  Cookies are small text files placed on your hard drive by a website when you visit. These files identify your computer and record your preferences and other data about your visit so that when you return to the website, the website knows who you are and can personalize your visit. For example, cookies enable a website function so that you only have to log in once.

 In general, we use cookies to personalize the Websites and make recommendations based on selections you have made in the past as well as to improve each Website’ experience; to improve your browsing experience online, and to complete transactions you have requested.  These tools help make your visit to our website and Solutions easier, more efficient and personalized. We also use the information to improve our website and Solutions and provide greater service and value.

Advertisers that serve ads on our Websites may also use their own cookies. Such outside cookies are governed by the privacy policies of the entities placing the ads, and are not subject to this Policy. We may also provide links to other third-party websites and services that are outside Company control and not covered by this Privacy Policy. We encourage you to review the privacy statements posted on the websites you visit.

As technology advances and cookies provide more functionality, we expect to use them in different offerings in different ways. As we do so, this Policy will be updated to provide you with more information.

Children’s Online Privacy Protection
Callbridge does not knowingly, directly or passively, collect information from children under the age of 18. If we create offers and products that make it appropriate to collect information from children under the age of 18, we will notify you of the change in this Policy. We also will ask a parent to confirm his/her consent in advance of any collection, use or disclosure of that information. You should be aware, however, that web browsers and conferencing services set up for family use may be used by minors without the knowledge of Callbridge. If that happens, any information collected from the usage will appear to be the personal information of the actual adult subscriber and treated as such under this Policy.Callbridge does not knowingly, directly or passively, collect information from children under the age of 18. If we create offers and products that make it appropriate to collect information from children under the age of 18, we will notify you of the change in this Policy. We also will ask a parent to confirm his/her consent in advance of any collection, use or disclosure of that information. You should be aware, however, that web browsers and conferencing services set up for family use may be used by minors without the knowledge of Callbridge. If that happens, any information collected from the usage will appear to be the personal information of the actual adult subscriber and treated as such under this Policy.

EU-US PRIVACY SHIELD
Callbridge complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Callbridge has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Callbridge is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Callbridge complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Callbridge is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and the U.S. Federal Communication Commission. In certain situations, Callbridge may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Callbridge commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Callbridge at c/o Iotum Inc., attention: Privacy Officer, 1209 N. Orange St, Wilmington DE 19801-1120 and/or privacy@callbridge.com. Callbridge has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the associated dispute resolution provider (free of charge) as set forth at https://www.privacyshield.gov. Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Consistent with Privacy Shield Principles, this privacy policy reflects the right of individuals to access the personal information about them held by us and be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. Refer to the section “Can I Check Account Information for Accuracy Or Ask You to Delete This Information?” above for details.

In compliance with the Privacy Shield Principles, Callbridge commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Callbridge at c/o Iotum Inc., attention: Privacy Officer, 1209 N. Orange St, Wilmington DE 19801-1120. Callbridge has further committed to cooperate with the panel established by the EU data protection authorities.

 Although the Privacy Shield has been invalidated as a transfer mechanism by the European Union (EU), the Company is committed to protecting all personal information received from European Union (EU) member countries, the UK, and Switzerland (see above Information Collected About You for examples of the personal information the Company processes when you use our Websites and Solutions and interact with us), in accordance with applicable Principles and to ensure personal information collected from individuals in the EU is accessible to them as part of their individual rights when the Company is the Controller of the personal information.

Callbridge Placement of Banner Ads on other Web Sites
Callbridge may use third-party advertising companies to place advertisements about our products and services on other websites. These third-party companies may use other technology such as web beacons or tagging, to measure the effectiveness of our ads. To measure advertising effectiveness and offer selective ad content, they may use anonymous information about your visits to our and other websites. But in all cases, they use an anonymous number to identify you, and do NOT use your name, address, phone number, e-mail address, or anything that personally identifies you. The use of such cookies is subject to the third party’s privacy policy, not the policy of Callbridge.

Your California Privacy Rights
This section is only applicable to California residents.

California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)

For business purposes in the last twelve months, the Company may have collected, used, and shared personal information about you as described in this Privacy Policy.  Each category of data that may be used by the Company or shared with third parties is categorically outlined in this Privacy Policy.

 California consumers have the right to (1) request access, correction, or deletion of their personal information (2) opt-out of the sale of their personal information; and (3) nor be discriminated against for exercising one of their California privacy rights.

 All individuals have the right to request access to or deletion of the information the Company holds about them either online via the Company’s Privacy Request Form or by mail to: CallBridge, a service of Iotum Inc., 1209 N. Orange St, Wilmington DE 19801-1120 Attn: Privacy.  In addition, California residents may also submit a request to privacy@callbridge.com.   The Company does not discriminate against individuals who exercise their privacy rights.

Do Not Sell My Personal Information
The Company does not sell (as “sell” is traditionally defined) your personal information.  That is, we don’t provide your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money.  However,  under California law, sharing information for advertising purposes may be considered a “sale” of “personal information.” If you’ve visited our digital properties within the past 12 months and you’ve seen ads, under California law personal information about you may have been “sold” to our advertising partners for their own use. California residents have the right to opt-out of the “sale” of personal information, and we’ve made it easy for anyone to stop the information transfers that might be considered such a “sale” from our website or mobile app.

How to Opt-Out of the Sale of Your Information
For our Websites, click on the “Do Not Sell My Personal Information” link at the bottom of the home page. For our mobile apps, we do not currently offer in-app hird party advertising and hence there is nothing to opt-out of in this regard.   After you click the “Do Not Sell My Personal Information” link on one of our Websites, You will be able to manage your cookie preferences for the Website, which will create an opt-out cookie to be stored on your browser, preventing personal information from being made available from this Website to advertising partners for their own use, independent of the Company (this opt-out cookie will only apply to the browser you were using and only for the device you were using at the time you made the selection. If you access the Websites from other browsers or devices, you will also need to make this selection on each browser and device). It’s also possible that portions of the Website service may not function as intended.  You should be aware that if you delete or clear cookies, that will delete our opt-out cookie and you will need to opt-out again.

 We have taken this approach rather than taking your name and contact information because:

  • We don’t ask for your personally identifiable information because we don’t need it to honor your Do Not Sell request. A general rule of privacy is to not collect personally identifiable information when you don’t need to—so we’ve set up this method instead.
  • We may not know the information we share with advertising partners is related to you. For example, we may capture and share an identifier or IP address of a device you are using to visit our website, but not have tied that information to you. With this method, we are better at ensuring that we honor the intent of your Do Not Sell request, versus just taking your name and address.

California Shine the Light
Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

The Company has a comprehensive Privacy Policy and provides you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes.  Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.

Updates to this Privacy Policy
We may update this Privacy Policy from time to time.  For example, Callbridge will revise or update this Policy if our practices change, as we change existing or add new services or as we develop better ways to inform you of products we think will be of interest. You should refer back to this page often for the latest information and the effective date of any changes. If we modify our Privacy Policy, we will post the revised version here, with an updated revision date. If we make material changes to our Privacy Statement, we may also notify you by other means, such as by posting a notice on our Websites or sending you a notification. By continuing to use our Websites after such revisions are in effect, you accept and agree to the revisions and abide by them. 

 The Callbridge Privacy Policy was revised and effective as of November 3, 2021.

How to Contact Us
Callbridge is committed to the policies set forth in this Policy. If you have any questions, comments or concerns about this Policy, please contact support@callbridge.com. Or you can post to: CallBridge, a service of Iotum Inc., 1209 N. Orange St, Wilmington DE 19801-1120 Attn: Privacy.

Opt-Out: If you wish to opt-out from all future correspondence from us, please contact privacy@callbridge.com or support@callbridge.com.

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