August 31, 2021
- “Customer Data” consists of information made available to us through your use of our Services under our Terms of Service, which includes information such as your name, contact information, billing records, call or messaging logs, and traffic routing information, as well as the content of communications sent through or integrated with our services, such as audio recordings, message bodies, and call recording transcriptions, and for the avoidance of doubt includes all Customer Personal Data.
- “Customer Personal Data”: means any personal data contained in the Customer Data (where “personal data” has the meaning given to it by the Data Protection Laws).
- “Data Protection Laws”: means applicable legislation protecting the personal data of natural persons and the privacy of electronic communications, including in particular Regulation (EU) 2016/679 (“GDPR”) and any national legislation with supplements the GDPR, together with national legislation implementing Directive 2002/58/EC (and any legislation which replaces Directive 2002/58/EC), but excluding the CCPA.
- CallTrackingMetrics process two categories of Customer Data when you use our products and services
- Your personal information as a customer (or potential customer) of CallTrackingMetrics services — information that we refer to as Customer Account Information, and
- The personal information of your end users who use or interact with your account or application that uses CallTrackingMetrics services, like the people you communicate with — this category contains both your Customer Usage Information (e.g., communications metadata) and your Customer Content (e.g., the contents of communications).
- CallTrackingMetrics processes these categories of Customer Data differently because the direct relationship we have with you, our customer, is different from the indirect relationship we have with your end users.
- Data protection laws and privacy laws in certain jurisdictions, like the European Economic Area (EEA), differentiate between “controllers” and “processors” of personal information. A controller decides why and how to process personal information.
- A processor processes personal information on behalf of a controller based on the controller’s instructions. When CallTrackingMetrics processes your Customer Account Information, we are acting as a controller.
- There are two sections to this Notice:
- 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.
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 from your end users, see 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.
2. What information we collect, how we collect it and why
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.
Broadly speaking, we use Customer Account Information to further our legitimate interests to:
- understand who our customers and potential customers are and their interests in CallTrackingMetrics product and services,
- manage our relationship with you and other customers,
- carry out core business operations such as accounting, filing taxes, and fulfilling regulatory obligations and
- help detect, prevent, or investigate security incidents, fraud and other abuse and/or misuse of our products and services.
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
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. 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 keys and an authentication token 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 log in to your account, or your application makes requests to our API using these credentials, we know that it is you making the requests.
And, we use your Account ID and API authentication 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.
When you sign up for an 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. For some products, we may also obtain a physical address from you that includes a proof of address, name, or other identification information. For example, to get a phone number in certain countries, local law may require us to have a physical service address on file for the individual who will be using that CallTrackingMetrics number, whether that’s you or your end user, and/or proof of identity and physical service address. We call this “Customer Data”.
We may have to share Customer Data subscriber records with the local telecommunications carrier that provides local connectivity services or with local government authorities. We may also use this physical service address for tax purposes.
Similarly, for some of our products, you or your end user, whoever is going to be making use of the product, may have to complete an application form providing details about your company and your intended use of the product. We’ll use this information for the purpose for which it was gathered from you. We may also use it in connection with improving our own internal processes and services or training our team members.
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.
All information we collect when you sign up for a CallTrackingMetrics account and interact with the CallTrackingMetrics account portal or our products or services may be used to detect, prevent, or investigate security incidents, fraud, or abuse and misuse of our platform and services. We will also use it, and share it with our service providers, as needed for our operational purposes — such as to do things to function as a business and provide our services to you.
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 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.
- 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 email@example.com. 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 firstname.lastname@example.org. 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 email@example.com.
13. How you can contact us
You may contact via email at firstname.lastname@example.org.
Or, you may write to us at the address listed below.
231 Najoles Road Suite #500
Millersville, MD 21108.
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 email@example.com.
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.
Categories of Personal Information that We Collect and Disclose
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 or disclose for a business purpose.
Categories of personal information Last Updated: July 30th, 2021