Effective December 20, 2019
- This privacy notice relates to CallTrackingMetrics’s publicly-accessible website (CallTrackingMetrics Site) at www.calltrackingmetrics.com, CallTrackingMetrics account portals, and our products and services.
- The CallTrackingMetrics Site is operated by CallTrackingMetrics LLC. If you are in the EU, we will be the controller for the purposes of relevant data protection law.
- Information for California consumers can be found in section 15 “California Consumer Privacy Act.”
- We can share the data we collect from you with those outside of CallTrackingMetrics if they are a service provider for CallTrackingMetrics (and have to follow our requirements) or if we’re legally required to share it with those outside of CallTrackingMetrics.
- If you want to ask how to delete or access your data, email email@example.com.
Below is a summary of our practices when it comes to information collected when you visit CallTrackingMetrics site and/or use the CallTrackingMetrics account portals and our products and services. If you are interested in learning about our practices relating to information we collect as a processor for our customers, visit our Platform Privacy here.
Please note that some CallTrackingMetrics customers may have special agreements with us that specify the collection, use, and sharing of their information. If those special agreements and this notice conflict, those special agreements will apply.
For purposes of this notice, the words “our,” “us,” “we,” and “CallTrackingMetrics” refer to CallTrackingMetrics LLC and our affiliates (which includes any person or entity that controls us, is controlled by us, or is under common control with us, such as our subsidiary, parent company, or our employees). “You” refers to our customer, who is accessing their CallTrackingMetrics account portal and using our products and services.
2. What information we collect, how we collect it and why
Information you give to us directly on our website
On some pages of the CallTrackingMetrics Site, you can fill in a web form to share your information with us directly, such as on our “Contact Sales” page or on our “Contact Support” page. We collect the information you provide in response to those web forms. Occasionally, we may also offer opportunities for you to share your information with us such as through a survey, to sign up for a newsletter, or to register for or receive details about an event we are hosting. If you participate in those surveys, sign up for a newsletter, or register for an event, we will collect the information you provide to us in doing so.
Information we collect from you automatically
Customer Account Information
Customer Account Information is all the information that relates to the relationship between CallTrackingMetrics and its customers, like our customers’ names, contact information, and billing information, and records.
Customer Usage Information
Customer Usage Information includes operational information like call or messaging logs, origination and termination points (i.e. to/from numbers), traffic routing information, API requests, or usage information.
3. What we use your information for
Information you give us directly on our website
For information that you give to us directly through the “Contact Sales” and “Contact Support” pages, we will use that information to formulate a response to your inquiry and get back to you with our response. Similarly, if you provide us information directly in response to a survey or when signing up for an event, we will use the information you provide for the reason that you provided it to us.
Information we collect automatically
Customer Account Information
When you sign up for an account with CallTrackingMetrics through our account portal, you’ll be asked to give us information like your email, name, and address. You’ll also be asked to create a password. We collect this Customer Account Information so that we know who you are, we can communicate with you about your account, and we can recognize you when you communicate with us through the account portal or otherwise.
We use your email address in connection with your account password to authenticate your account and allow you to access your account information through the account portal. And, we use your Account ID and Auth Token to authenticate that it is your application that is making requests to our APIs.
If two-factor authentication is set up for your account, we’ll ask you to enter a telephone number to which we will communicate verification codes to verify that it is you logging into your account.
We also use contact information you provide to CallTrackingMetrics to communicate information regarding your account and the products and services you are using or to respond to an inquiry you have sent us. If you enable two-factor authentication, we’ll use the telephone number you provide in connection with that feature to send you verification codes.
When you sign up for a paid account or upgrade your account from a trial or account, we’ll ask you to provide our payment processor with your payment method information like your credit card information and/or your billing address. Our payment processor, acting on our behalf, gathers this so that we can bill you for your use of our products and services. Our payment processor will generally share your billing address with CallTrackingMetrics.
For some products, we may have to obtain a physical address from you. For example, to get a phone number in certain countries, local regulations may require us to have a physical address on file for you or your end user. We may also need your physical address or billing address for tax purposes. We may have to share your physical or billing address with the telecommunications carrier from whom CallTrackingMetrics obtained the phone number or local government authorities upon their request. Unless prohibited from doing so by law, we’ll let you know if we have to share your address like this.
We also gather information about you when you interact with our customer support team, sales team, or account management team. For example, when you contact our customer support team, you will be asked to give your account information and tell us the question you have or any problem you’re experiencing. We gather this information so that we can help you with your question or problem. When you communicate with our sales team or account management team, we’ll gather information about you, such as your use case and your business requirements, so that these teams are better equipped to assist you. We may also use this information so that we can improve our products and services and train our team members.
When you sign up for an account with CallTrackingMetrics, we’ll assign you an Account ID (and Agency ID if you are on a plan that has an umbrella Agency ID), which acts as a username, and a password. If using our API, you will also be assigned an authentication key that you will need to use in connection with making requests to our APIs. We keep a record of these credentials, so that when you login to your account or your application makes requests to our API using these credentials, we know that it is you making the requests.
Customer Usage Information
When you use our products and services, we collect Customer Usage Information. This may include information like what commands your application has communicated to CallTrackingMetrics through the API, what configurations you have made in your account portal, your IP addresses, how many times you used a CallTrackingMetrics product or service, when the product or service was used by you or your end users, the number of website visits, calls, messages, or form entries that occurred, the length of calls or messages, where those calls or messages originated or terminated, how those calls or messages were routed, and whether or not the connection was successful or failed.
We collect Customer Usage Information so that you can view it in the account portal and you can manage your use of our products and services. We also collect it so that we can properly bill you for your use of our products and services, appropriately manage and route customer traffic, analyze and improve our products and services, and identify and solve problems that arise. We also use certain usage information to support regulatory requirements, such as calculation and reporting of tax or similar obligations.
4. Who we may share your information with
We share your information in the manner and for the purposes described below:
- Third-party service providers or consultants. We may share information collected from you on the CallTrackingMetrics Site with third-party service providers or consultants who need access to the data to perform their work on CallTrackingMetrics’s behalf, such as a website analytics company or our third-party advertising partners. These third-party service providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances that they will appropriately safeguard the information.
- Compliance with Laws. We may disclose your information to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or government request (including to meet national security or law enforcement requirements), (ii) to obtain legal advice, (iii) to enforce our agreements and policies, (iv) to protect the security or integrity of the CallTrackingMetrics Site or our services and products, (v) to protect ourselves, our other customers, or the public from harm or illegal activities, or (vi) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing a death or serious bodily injury. If CallTrackingMetrics is required by law to disclose any of your information that directly identifies you, then we will use reasonable efforts to provide you with policy of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena, or court or administrative order. Further, we object to requests that we do not believe were issued properly.
- Affiliates. We may share information collected from you from the CallTrackingMetrics Site with our affiliates. Our affiliates will use the information for the same purposes as CallTrackingMetrics, as described in this policy.
- Business transfers. If we go through a corporate sale, merger, reorganization, dissolution, or similar event, information we gather from you through our website may be part of the assets transferred or shared in connection with due diligence for any such transaction. Any acquirer or successor of CallTrackingMetrics may continue to use the information we collect from you through our website as described in this policy.
- Aggregated or de-identified data. We might also share information collected from you from the CallTrackingMetrics Site with a third party if that information has been de-identified or aggregated in a way that does not directly identify you.
We do not share your information (including, but not limited to, the personal data of your end users) with third parties for their direct marketing purposes, unless you give us your consent to do so.
5. Information from Children
6. Links to Other Websites
7. Social Media Widgets
9. How we secure your information
We use appropriate security measures to protect the security of your information both online and offline. These measures vary based on the sensitivity of the information that we collect, process, and store, and the current state of technology. Please note, though, that no website or internet transmission is completely secure, so while we strive to protect your information, we cannot guarantee that unauthorized access, hacking, data loss, or a data breach will never occur.
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal information for longer periods of time; for instance, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements.
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
10. How we tell you about changes to our privacy practices
11. How to make choices about your information
Deletion, access, and changes to your information.
To request deletion of, access to, or to make changes to information we’ve collected from you via the CallTrackingMetrics Site, email us at firstname.lastname@example.org. Please note that even if you request that we delete information we’ve collected from you, we may still retain information collected from you in an aggregated or anonymized form that does not identify you. We also will not delete your information if we are legally required to maintain it.
We may ask you for additional information to confirm your identity and for security purposes, before taking any action in respect of your information. We reserve the right to charge a fee where permitted by law; for instance, if your request is manifestly unfounded or excessive.
If you are receiving promotional emails from us, you can choose to stop receiving those by following the unsubscribe/opt-out instructions in those emails. You can also opt-out by contacting customer support at email@example.com. Please note that even if you opt out of promotional communications, we may still send you non-promotional messages relating to things like updates to our terms of service or privacy notices, security alerts, and other notices relating to your access to or use of our products and services.
We will respond to your request within a reasonable timeframe and notify you of the action we have taken.
Cookies and tracking technologies.
12. How to resolve disputes relating to our privacy practices
If you have a dispute with us relating to our privacy practices, please email us at firstname.lastname@example.org.
13. How you can contact us
You may contact via email at email@example.com.
Or, you may write to us at the address listed below.
877 Baltimore Annapolis Blvd. Suite 207
Severna Park MD 21146.
14. Additional information for EU residents
The following information is provided for the benefit of CallTrackingMetrics Site users resident in the European Union.
Lawful basis for processing. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This will be because:
- you have provided consent to us using the personal information, for example you have opted-in to receiving marketing communications from us;
- our use of your personal information is in our legitimate interest as a commercial organization (for example communicating with you to resolve a complaint or query, or tracking your use of the CallTrackingMetrics Site using cookies in order to improve and tailor your browsing experience) – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to this processing as explained below;
- our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have, for example where we are required to disclose data to a government body, law enforcement agency or regulator.
Your EU rights.
In addition to the erasure, access and correction rights referred to in section 12 above, you also have a right to object to direct marketing, and to any use of your personal information which is based on a ‘legitimate interest’ justification.
You also have a right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction, and to lodge a complaint with your local supervisory authority.
To exercise any EU specific right, please contact firstname.lastname@example.org.
CallTrackingMetrics is based in the United States of America, and you understand that by browsing the CallTrackingMetrics Site your information will be stored on servers in that country, which has different standards of data protection.
In addition, we use service providers located around the world. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law to protect your privacy rights and interests. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information is disclosed.
15. California Consumer Privacy Act – Information for California Consumers
This section provides specific information for residents of California (“consumers”), as required under California privacy laws, and is intended to satisfy the California Consumer Privacy Act (“CCPA”), which requires that we provide certain information to consumers about how we handle certain personal information that we have collected.
You should also refer to sections 2, 3, and 4 of this notice, which provide further detail about what personal information we collect, for what purposes, and where we disclose this information to third parties.
This notice does not address our handling of personal information about consumers that is exempt from the CCPA because it is covered by existing qualifying privacy laws. It also does not address personal information collected in a business-to-business context (defined as personal information reflecting a communication or transaction with a consumer, where that consumer is acting as an employee, owner, director, officer, or contractor of another business, non-profit or government entity, and where the communication or transaction occurs solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from the other business), except in relation to the “Do-Not-Sell” right (see below).
Categories of Personal Information that We Collect, Disclose, and Sell
As required by the CCPA, and dependent on the type of consumer you are, the table below lists the categories of personal information about consumers that we collect, disclose for a business purpose, and/or sell.
* A physical or billing address (to the extent that this constitutes personal information) with a telecommunications carrier, upon their request. See “Customer Account Information” in section 2.
Purposes for which Personal Information is Used
The categories of personal information described above are collected and disclosed for the following purposes:
- NAME, CONTACT INFORMATION, AND IDENTIFIERS: receiving enquiries, complaints and other communications from you (including through “contact us” mechanisms); authenticating you and providing access to account portals; maintaining the security of the website; defending claims and other legal actions.
- USAGE DATA: understanding your use of the website and account portal in order to make improvements to it; tailoring the website to your preferences, location, and other personal attributes; serving advertisements to you, including when you leave this website and navigate to third party sites; maintaining the security of the website; defending claims and other legal actions
California Consumer Rights
California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below.
Verifiable Requests for Copy, Deletion, and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months:
Deletion: the right to request deletion of their personal information that we have collected about you, subject to certain exemptions, and to have such personal information deleted.
Right to Know: the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including the:
- categories of personal information collected
- categories of sources of personal information collected
- business and/or commercial purposes for collecting and selling your personal information
- categories of third parties with whom we have disclosed or shared your personal information
- categories of personal information that we have disclosed or shared with a third party for a business purpose
- categories of third parties to whom the consumer’s personal information has been sold
- categories of personal information that we have sold (if any)
- The specific pieces of personal information we collect from you
Submitting Requests. You can submit a deletion or right-to-know request by contacting us at 1-800-577-1872 (toll free) or by emailing us at email@example.com; we will respond to verifiable requests received from California consumers as required by law. [Account holders may also submit requests in their account by going to the Help menu and using any of our customer support channels. We also ask you for additional information necessary to verify or process your request. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. We will respond substantively to your verifiable requests within 45 days, unless additional time (up to 45 additional days) is needed, in which case we will let you know.
Incentives and Discrimination. The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information. Businesses may offer different prices, rates, or quality of goods or services if the difference is reasonably related to the value of the consumer’s data.
Effective December 17, 2019
Please note that some CallTrackingMetrics customers may have special agreements with us that specify the collection, use, and sharing of their information. If those special agreements and this notice conflict, those special agreements will apply.
For purposes of this notice, the words “our,” “us,” “we,” and “CallTrackingMetrics” refer to CallTrackingMetrics and our affiliates (which includes any person or entity that controls us, is controlled by us, or is under common control with us, such as our subsidiary, parent company, or our employees). “You” refers to our customer, who is accessing their CallTrackingMetrics account portal and using our products and services.
Before you submit any information on or through the CallTrackingMetrics account portal or use CallTrackingMetrics products and services, please carefully review this Notice. You acknowledge and understand that, by using any part of the CallTrackingMetrics account portal, products or services, your information may be collected, used, disclosed, and shared as further outlined below in this Notice.
What is CallTrackingMetrics? CallTrackingMetrics is a contact management company. Our customers are generally marketing agencies or businesses. Our customers generally use CallTrackingMetrics products and services to track the performance of their marketing campaigns, their sales teams and their contact centers. Our customers then often have their own customers or users of the reporting they are compiling and the communication campaigns they are developing using CallTrackingMetrics products and services. To avoid confusion, we’ll call the individuals that use our customers’ applications the “end users.”
If you are resident in the EU, you should know that, in operating our portal and our products and services on behalf of our customers, CTM operates as a processor only, and is not a controller in relation to any personal information processed about you. Therefore, CTM cannot respond to requests to exercise rights under data protection laws – these should be directed to our customers.
What information we collect, how we collect it and why
Customer Content consists of the communications that are sent through the use of CallTrackingMetrics products and services, like the body of a text message or phone call.
We may collect Customer Content in connection with your use of our products or services. For example, if you use our messaging services, we collect the messages being sent and received so that we can convey those messages to and from the carrier networks and surface the content in your account portal and in our API. Similarly, to transmit voice calls to and from the telecommunications carrier networks, we have to collect the voice communications being sent and received to route them appropriately, and then surface that information in our portal and our API. You can also use our products and services to record voice communications or have them transcribed, in which case, we will also collect those voice recordings or transcriptions.
If you are using caller ID services that we offer through a sub processor, we will collect information about your end users such as the caller’s name, phone number, and the city in which the phone number is registered (not available in all countries or for all phone numbers). In addition, Customers can enable our premium caller ID service which uses one of our sub processors to collect address and other demographic information about an end user, such as marital status and occupation.
You should not use CallTrackingMetrics products or services to receive, send, or otherwise process Personal Health Information (PHI) as defined by the Health Insurance Portability and Accountability Act of 1996 as amended (HIPAA), unless you have a Business Associate Agreement (BAA) with CallTrackingMetrics or your use case for CallTrackingMetrics products and services does not require a BAA. CallTrackingMetrics disclaims all liability for PHI sent, received, or processed through CallTrackingMetrics products or services without a Business Associate Agreement.
Please contact our sales team to speak further regarding HIPAA-compliant uses of CallTrackingMetrics products and service.
What we use your information for
Generally, we use all the information that you provide to us or that we collect to provide our products and services to you, to deliver your communications to their intended destination, to provide reporting on your communication programs in your account portal, to analyze our customers’ use of our products and services, to improve our products and services, and to detect fraudulent or unlawful activity in connection with CallTrackingMetrics accounts.
Below are some additional details regarding how we use categories of information we collect.
We use Customer Content for the purposes of including it in your reporting in your account portal or through the API, conveying it to and from telecommunications carrier networks, or recording and transcribing it per your instruction. We may also use Customer Content stored on our systems to troubleshoot issues such as call quality concerns.
We will use your email address to send you information about other CallTrackingMetrics products, services, or events that you might be interested in. If we are required to do so by applicable law, we will obtain your prior consent before marketing to you.
You can choose not to receive marketing emails from CallTrackingMetrics at any time. If you wish to stop receiving CallTrackingMetrics marketing emails you may click on the unsubscribe link that will appear at the bottom of any CallTrackingMetrics marketing emails or you can contact customer support.
We will use publicly-available Customer Account Data about your company, such as your industry, the size of your company, and your company’s website URL, to help us understand our customer base better and to tailor information we send you about other CallTrackingMetrics products, services, or events.
If you provide us with a physical address in order to obtain a number for which CallTrackingMetrics is required to have your physical address on file, we’ll use that address so that we can confirm we can allow you to have that number. We may also check the physical address you provide and/or your billing address, as well as other information you provide or that we obtained from your use of our service about your identity such as your name, email address, and IP address, with our fraud prevention and identity validation providers (to confirm you have provided us with accurate details). We may also use your address information to calculate taxes. We may also have to share these addresses with the telecommunications provider from whom CallTrackingMetrics obtained the phone number or local authorities upon their request. Unless prohibited from doing so by law, we’ll let you know if we have to share your address information like this.
We use your payment information so we can bill you and be paid for your use of our products and services.
Who we may share your information with
Unless you give us your permission, we won’t share your Customer Content, Customer Account Data, or Customer Usage Data with third parties, except as described below:
- Cloud Communication Providers and Telephony operators as necessary for proper routing and connectivity. Customer Content and certain Customer Usage Data is shared with and received from communication providers and telephony operators to the extent necessary to route and connect those communications from the sender to the intended recipient. How those providers and telephony operators handle your Customer Content and Customer Usage Data is generally determined by those operators’ own policies and local regulations.
- Third-party service providers or consultants. We may share your information stored on our systems with third-party service providers or consultants who need access to the information to perform their work on CallTrackingMetrics behalf, like sharing relevant Customer Account Data with our payment processor so it can process payments on our behalf, or our storage provider for storing your information on our behalf. These third-party service providers are limited to only accessing or using this information to provide services to us and must provide reasonable assurances that they will appropriately safeguard the information.
- Compliance with Laws. We may disclose your information stored on our systems to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements), (ii) to obtain legal advice; (iii) to enforce our agreements and policies, (iv) to protect the security or integrity of the CallTrackingMetrics Site or our services and products, (v) to protect ourselves, our other customers, or the public from harm or illegal activities, or (vi) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If CallTrackingMetrics is required by law to disclose any of your information that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Further, we object to requests that we do not believe were issued properly.
- Business transfers. If we go through a corporate sale, merger, reorganization, dissolution or similar event, customer information we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction. Any acquirer or successor of CallTrackingMetrics may continue to use your information as set forth in this notice.
We do not share your information (including, but not limited to, the personal information of your end users) with third parties for their direct marketing purposes, unless you give us your consent to do so.
International Operations and Transfers Out of the EEA and Switzerland
Please note that when you use our account portal, or our other products and services, your Customer Content, Customer Account Data, or Customer Usage Data may be sent to the United States and possibly other countries. Some, but not all of this, may be in connection with routing your communications that are sent via our products and services in the most efficient way. We store customer information on servers located in the United States, and we may also store this information on servers and equipment in other countries.
We take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests, and that transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end, where appropriate to do so (e.g. because our customer is established in the EU), we enter into appropriate data transfer agreements incorporating the EU Commission approved standard contractual clauses, or rely on other mechanisms provided for by data protection law. You have a right to ask our customers for more information about the safeguards they have in place to ensure the adequate protection of transferred information.
How we tell you about changes to our privacy practices
We may change our Platform Privacy Notice from time to time. If we make changes, we’ll revise the “Effective” Date at the top of this notice, and we may provide additional notice such as on the CallTrackingMetrics website homepage, account portal sign-in page, or via the email address we have on file for you. We will comply with applicable law with respect to any changes we make to this notice.
Your Choices About Your Information
You may access and make changes to certain parts of your Customer Account Data through the account portal. You also have access to Customer Content stored on our systems and various types of Customer Usage Data through the account portal.
To request deletion of your CallTrackingMetrics account, email us at firstname.lastname@example.org. You should know that deletion of your CallTrackingMetrics account will result in you permanently losing access to your account and all customer information to which you previously had access through your account. Please note that certain information associated with that account may nonetheless remain on CallTrackingMetrics servers in an aggregated or anonymized form that does not specifically identify you. Similarly, information associated with your account that we are required by law to maintain will also not be deleted.
Cookies and tracking technologies.
How you make choices about cookies and other tracking technologies depends on the type of cookie or tracking technology being used. For details on how to manage your preferences for cookies and tracking technologies, please check out our Cookie Notice.
Information from Children
We do not knowingly collect any personal information directly from children under the age of 16. If we discover we have received any personal information from a child under the age of 16 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 16, please contact us at email@example.com.
How we secure your information
We use appropriate security measures to protect the security of your customer information both online and offline. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Please note though that no service is completely secure. So, while we strive to protect your information, we cannot guarantee that unauthorized access, hacking, information loss or an information breach will never occur.
You may access your account through our account portal by using your email address and a password that you chose when you signed up for CallTrackingMetrics’s products and services. To protect the confidentiality of your customer information and protect from unauthorized use of your account, you must keep your password confidential and not disclose it to any other person. Please let us know right away if you think your password or API Auth Token was compromised or misused.
For additional information regarding CallTrackingMetrics’s security practices, click here.