Privacy Policy.

Last modified: Nov 7, 2022

 

Privacy Policy and Notice

This policy describes how CallTower, Inc. collects, uses, and shares your information.  When you use our sites, products, or services or otherwise form a relationship with us, we may obtain data from you and the devices you use to interact with us.

This policy is designed to provide transparency into our privacy practices and principles in a format you can navigate, read, and understand.

We commit to treat your personal information with care and respect and give you methods to contact us should you have any questions or concerns about the use of your information.

Finally, you may have received additional privacy documentation from us when you used a specific site, product, or service from us.  In that case, the documentation you received should be read in conjunction with this Notice.

This policy explains:

The Scope of this Policy

This policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.calltower.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Statement). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Your Privacy Rights

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at privacy@calltower.comcreate new email to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your Privacy Rights

If you are a resident of certain states or countries, you may have the right to know, access, correct, transfer, restrict the processing of, opt-out from processing, and delete your personal information. If you choose to exercise any of these options, we will not discriminate against you for making that decision.

You can exercise your privacy rights by contacting us at privacy@calltower.comcreate new email.

There may be situations where we cannot grant your request. In such a situation, we will explain our reasoning to you.

California’s “shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to: privacy@calltower.comcreate new email

Information Collected by This Website

We collect several types of information from and about users of our Website, the following list is of information we may collect:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses) if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
  • Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Cookies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically includes personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
How This Website Uses Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

As a global organization with affiliated entities located inside and outside of the UK, EU/EEA and business processes in operation across borders, we may transfer your personal information to our headquarters in the United States of America, to any of our affiliate entities worldwide or to third-party business partners, providers, vendors, or contractors, that are located inside or outside of the UK, EU/EEA, for purposes described in the section including for the purpose of data processing or storage.  We implement cross-border transfers in compliance with applicable privacy and data protection regulations, including Regulation (EU) 2016/679 of 27 April 2016 on the protection of Personal Information (“GDPR”).

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@calltower.comcreate new email. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Securing Your Information

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Our Commitment to Protecting Information Belonging to Children

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at:

The Privacy Office

10701 River Front Parkway

South Jordan, UT 84095

privacy@calltower.comcreate new email

 

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Customer Proprietary Network Information (CPNI)

Protections

We have a duty, under federal law, to protect the confidentiality of certain types of services, including (1) information about the quantity, technical configuration, type, destination, location, and amount of your use of services, and (2) information contained on your telephone bill concerning the services you receive when matched to your name, address, and telephone number (“Customer Proprietary Network Information,” or “CPNI”). Examples of CPNI include information typically available from telephone-related details on your monthly bill, technical information, type of service, current telephone charges, long-distance, and local service billing records, directory assistance charges, usage data and calling patterns.

CPNI does not include things like customer name, address, or telephone number; aggregate information or data that is not specific to a single customer; customer premises equipment; and Internet access services.

We may not use this CPNI to market products and services to you other than for services you currently purchase if you don’t approve.

Opt-out

We have the ability to use the CPNI on file to provide you with information about our or our business partners’ communications-related products and services or special promotions unless you opt-out. YOU MAY DENY OR WITHDRAW OUR RIGHT TO USE YOUR CPNI FOR MARKETING PURPOSES AT ANY TIME BY EMAILING TO marketing@calltower.comcreate new email. Denying or restricting approval for us to use your CPNI for marketing purposes (also known as “opting-out”) will not affect any of our services to which you subscribe. Any denial or restriction of approval remains valid until you affirmatively revoke or limit such denial or restricted approval.

Customer Authentication

Federal privacy rules require us to authenticate the identity of its customers prior to disclosing or discussing CPNI. Customers calling our customer service center can discuss their services and billings with our representative once that representative has verified the caller’s identity. There are four methods by which we will conduct customer authentication:

  1. by having the Customer provide a pre-established password and/or PIN;
  2. by calling the Customer back at the telephone number associated with the services purchased;
  3. by emailing the Customer the requested information to the Customer’s email address of record; or
  4. by mailing the requested documents to the Customer’s address of record.

In the event the customer fails to remember their password and/or PIN, we will send the password and/or PIN to the Customer’s email address of record in order to authenticate the customer.

Notifications of Certain Account Changes

We notify customers whenever certain account changes occur. For example, whenever an online account is created or changed, or a password or other form of authentication (such as a “secret question and answer”) is created or changed, we will notify the account holder. Additionally, after an account has been established, when a customer’s address (whether postal or email) changes or is added to an account, we will send a notification. These notifications may be sent to a postal or email address, or by telephone, voicemail or text message.

Disclosure of CPNI

  • We may disclose CPNI in the following circumstances:
  • When the customer has approved use of their CPNI for us or our business partners’ sales or marketing purposes.
  • When disclosure is required by law or court order.
  • To protect our rights and property or to protect customers and other carriers from fraudulent, abusive, or unlawful use of services.
  • When a carrier requests to know whether a customer has a preferred interexchange carrier (PIC) freeze on their account.
  • For directory listing services.
  • To provide the services to the customer, including assisting the customer with troubles associated with their services.
  • To bill the customer for services.

Protecting CPNI

We use numerous methods to protect your CPNI. This includes software enhancements that identify whether a customer has approved use of its CPNI. Further, all our employees are trained on how CPNI is to be protected and when it may or may not be disclosed. All marketing campaigns are reviewed by our Chief Revenue Officer to ensure that all such campaigns comply with applicable CPNI rules. We maintain records of our own and our business partners’ sales and marketing campaigns that utilize Customer CPNI.

Breach of CPNI Privacy

In the event, we experience a privacy breach and CPNI is disclosed to unauthorized persons, in certain circumstances federal rules require us to report such breaches to law enforcement and/or regulatory authorities. We will inform our customers of a CPNI breach as and when required under applicable rules. Additionally, we maintain records of any discovered breaches in accordance with federal rules and will retain these records for not less than two (2) years.

Our Global Data Transfer Practices

We store and process your personal information on our servers located within the United States but may transfer your personal information to other countries outside of the United States for the purposes describe in this Privacy Policy. By using our websites, products, or services, you agree to the global transfer, process, and storage of your personal information.

Contacting Supervisory Authorities

If you would like to lodge a complaint against us, you may contact your local supervisory authority. If you have trouble locating a supervisory authority, please contact our privacy office above and they will help you contact a supervisory authority.

Changes to Our Privacy Statement

We keep this privacy statement under regular review and will place any updates on our website. Paper copies of the privacy statement may also be obtained by contacting the privacy office at the information above and requesting a paper copy.

This privacy statement was last updated September 2022.

How to Contact Us

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

 

The Privacy Office

10701 S. River Front Parkway

South Jordan, UT 84095

privacy@calltower.comcreate new email

Relationship-Specific Details

Customers/End Users

Description Data gathered throughout the customer/end user relationship with CallTower.
Categories of Information

Personal Identifiers such as:

–       First and last name

–       Business phone number

–       Mobile phone number

–       Business email address

–       Business mailing address

–       Purchase and service history

Internet Data such as:

–       IP address

MAC address for devices where CallTower provides services for those devices

Category of Data Subjects This information is provided by the customer’s/end user’s business/organization.
Purpose of Processing

CallTower uses this information for activities such as:

–       Creating an account with CallTower

–       Providing services to the customers/end users device

–       Account management

–       Billing

–       Customer support

–       Authentication

–       Device/account configuration

Legal Basis for Processing CallTower processes this information pursuant to the agreements between CallTower and organizations seeking to provide CallTower’s services to such organizations’ employees.
Automated Processing or Profiling

Does this product/service/process use automated processing:
Yes☒

Automated processing may exist to create customer/end user accounts.  Automated processing does not occur to profile individuals or to sell personal information to third parties.

No☐

If yes, the general methods and logic used are: Automated routines take information from CallTower’s customers and create accounts and user profiles.

Does the automated processing create affect the rights of data subjects? No.

Data Sharing Categories of Recipients Description of Business Purpose Shared or Sold
Limited third parties to provide specific services that have been selected by the customer/end user. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. Shared
Whether Personal Information is Transferred Internationally For our international clients.  Information is shared internationally pursuant to global transfer mechanisms under appropriate privacy law.
Retention Period CallTower retains this information throughout the life of the agreement between CallTower and its customers.
Web Visitors
Description Data gathered from visitors to CallTower’s website.
Categories of Information

CallTower only gathers information from web visitor when they input information into CallTower’s online forms.  When visitors fill out those forms, they may provide the following:

Personal Identifiers such as:

–       First and last name

–       Email address

–       Contact details

–       Physical address

Professional Employment information (for individuals who are applying for positions online)

Category of Data Subjects This information is provided directly by website visitors.
Purpose of Processing CallTower uses this information to provide marketing information to individuals who have expressed an interest in CallTower’s products.  CallTower may also use this information when an individual expresses an interest in a job at CallTower.
Legal Basis for Processing CallTower gathers this information so it can prepare either a recruitment relationship or marketing relationship a web visitor.
Automated Processing or Profiling

Does this product/service/process use automated processing:
Yes☒

Automated processing may exist.  Automated processing does not occur to profile individuals or to sell personal information to third parties.

No☐

If yes, the general methods and logic used are:

Information typed into a webform is routed to related departments within CallTower so that CallTower can respond to the information and potential requests placed in the webform.

Does the automated processing create affect the rights of data subjects? No.

Data Sharing Categories of Recipients Description of Business Purpose Shared or Sold
Limited third parties to provide specific services that have been selected by the customer/end user. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. Shared
Whether Personal Information is Transferred Internationally N/A
Retention Period

For marketing, CallTower retains this information until an individual opts out of future marketing messages.

For employment, CallTower retains this information throughout the candidate’s employment until the employment relationship has ended.  Alternatively, CallTower deletes this information if an employment relationship does not form between a candidate and CallTower.

 

Sales Representatives
Description Data gathered from Sales Representatives and their contacts.
Categories of Information

Personal Identifiers such as:

–       First and last name

–       Company name

–       Email address

–       Contact details

–       Physical address

Geolocation Data

Professional Employment Information

Category of Data Subjects This information is provided by the sales representatives of directly from a representative’s contacts.
Purpose of Processing CallTower uses this information to provide marketing information to individuals who have expressed an interest in CallTower’s products.
Legal Basis for Processing CallTower gathers this information so it can pursue a commercial relationship with representatives’ contacts.
Automated Processing or Profiling

Does this product/service/process use automated processing:
Yes☒

Automated processing may exist.  Automated processing does not occur to profile individuals or to sell personal information to third parties.

 

No☐

If yes, the general methods and logic used are: Information typed into a webform is routed to related departments within CallTower so that CallTower can respond to the information and potential requests placed in the webform.

Does the automated processing create affect the rights of data subjects? No.

Data Sharing Categories of Recipients Description of Business Purpose Shared or Sold
Limited third parties who provide CRM and operational support services to CallTower. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. Shared
Whether Personal Information is Transferred Internationally N/A
Retention Period For marketing, CallTower retains this information until an individual opts out of future marketing messages.

 

Vendors and Distributors
Description Data gathered from CallTower’s vendors and distributors.
Categories of Information

Personal Identifiers such as:

–       First and last name

–       Business phone number

–       Business email address

Geolocation Data

Professional Employment Information

Category of Data Subjects This information is provided directly from vendors and distributors.
Purpose of Processing CallTower uses this information to contact vendors and distributors with an interest in selling CallTower’s products.
Legal Basis for Processing CallTower gathers this information so it can pursue a commercial relationship with vendors and distributors.
Automated Processing or Profiling

Does this product/service/process use automated processing:
Yes☒

Automated processing may exist.  Automated processing does not occur to profile individuals or to sell personal information to third parties.

No☐

If yes, the general methods and logic used are:

Information typed into a webform is routed to related departments within CallTower so that CallTower can respond to the information and potential requests placed in the webform.

Does the automated processing create affect the rights of data subjects? No.

Data Sharing Categories of Recipients Description of Business Purpose Shared or Sold
Limited third parties who provide operational support services or provide specific features to vendors and distributors. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. Shared
Whether Personal Information is Transferred Internationally N/A
Retention Period Throughout the commercial relationship with the vendor or distributor.

 

Trade Shows
Description Data gathered from individuals at trade shows.
Categories of Information

Personal Identifiers such as:

–       First and last name

–       Company name

–       Email address

–       Contact details

Category of Data Subjects This information is provided by individuals directly to CallTower.
Purpose of Processing CallTower uses this information to provide marketing information to individuals who have expressed an interest in CallTower’s products.
Legal Basis for Processing CallTower gathers this information so it can pursue a commercial relationship with contacts.
Automated Processing or Profiling

Does this product/service/process use automated processing:
Yes☐

No☒

If yes, the general methods and logic used are:

Does the automated processing create affect the rights of data subjects? N/A

 

Data Sharing Categories of Recipients Description of Business Purpose Shared or Sold
Limited third parties who provide CRM and operational support services to CallTower. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. Shared
Whether Personal Information is Transferred Internationally N/A
Retention Period For marketing, CallTower retains this information until an individual opts out of future marketing messages.

 

 

Employee and Prospective Employee Data
Description Data gathered from people who are recruits, candidates, or employees.
Categories of Information

Personal Identifiers such as:

–       First and last name

–       Email address

–       Contact information

–       Social Security Number

–       Government-issued ID

Protected Class Information as required by government regulation or to provide benefits to you or your family:

–       Gender

–       Race

–       Marital Status

Commercial Information such as:

–       Financial account numbers

Internet Data such as:

–       Cookie data

–       IP Address

–       MAC Address

–       Device number

Professional Employment History

Education history

Category of Data Subjects This information is provided by individuals directly to CallTower.
Purpose of Processing CallTower uses this information to recruit and hire prospective employees, distribute benefits to those employees, manage payroll, and manage other HR tasks or administrative tasks pertaining to perspective, current, and past employees.
Legal Basis for Processing CallTower gathers this information pursuant to its employee agreement or to potentially enter into an employee agreement with prospective and current employees.
Automated Processing or Profiling

Does this product/service/process use automated processing:
Yes☐

No☒

If yes, the general methods and logic used are:

Does the automated processing create affect the rights of data subjects? N/A

 

Data Sharing Categories of Recipients Description of Business Purpose Shared or Sold
Limited third parties that generally help  administer and manage HR tasks such as banks, benefits providers, payroll, and retirement accounts. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. Shared
Whether Personal Information is Transferred Internationally N/A
Retention Period

CallTower retains this information up to 4 years after employment as required or allowed by law.

CallTower retains candidate information for prospective employees who do not become employees for up to 4 years as required or allowed by law.