Last updated: 03/24/2018
2. Collection and Use
The following sections cover the specifics of the three groups from which data is collected: website Visitors, Consumers, and Users.
2.2 Website Visitors
2.2.1 Purpose of Processing Personal Data
2.2.2 Sharing Personal Data
Ringba may also share such information with service vendors, clients, or contractors in order to provide a requested service or transaction or in order to analyze the Visitor behavior on its website.
2.2.4 Links to Other Sites
Consumers should be aware that in calling phone numbers issued by Ringba, they could be disclosing information that could make them personally identifiable to Ringba Users. The security and privacy protection implemented on Ringba’s platform does not cover this type of transfer or disclosure of personal information. Consumers calling a phone number that may be issued by Ringba and licensed to a Ringba User should be aware that they are making themselves personally identifiable by their phone number’s ‘Caller ID’ and that they are solely responsible for their actions while on the phone with whatever party they requested to speak with. For more detailed information concerning the protection of privacy when calling a Ringba issued phone number may contact the entity they requested to speak with. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law.
If you wish to inquire about your Personal Data that may have been collected in a phone call through Ringba, we recommend that you contact the entity that you called and spoke with. As Ringba is a Processor in this regard, it does not control the Personal Data used or stored from the call, but processes it on behalf of its User.
If you are a User of our platform only, and not just a Visitor then this section is relevant for you.
In order to provide services to its Users, Ringba collects certain types of data from them. Furthermore, Ringba’s Users collect information from Consumers when call a number issued to a Ringba User. This section will describe how these two types of data are collected and used by Ringba as well as geographical differences that effect this policy. Data entered or transferred into Ringba by Users such as campaign names, target names, publisher names, sub-account information, etc., remains the property of the User and may not be shared with a third party by Ringba without express consent from the User.
2.4.2 Collection of User Data
During a User’s registration and later on Ringba’s platform, they provide information such as name, company name, email, address, telephone, credit-card number and other relevant data. This information is used by Ringba to identify the User and provide them with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations. Ringba Users can at any time access and edit, update or delete their contact details by logging in with their username and password to Ringba’s platform. Ringba Users may create more Users with different privilege levels within their account. It is the responsibility of the User that creates other User accounts, to choose the level of access each User should have. Once these new Users log into Ringba, they meet the definition of User in this policy. Ringba will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
2.4.3 Collection of Consumer Data
2.4.4 Geographical Location
Ringba offers a number of data regions. A Ringba “Data Region” is a set of data centers located within a defined geographical area where User and Consumer data is stored, maintained by Ringba or a 3rd party service provider that acts as Ringba’s data processor. Personal Data is not transmitted between Data Regions. For Ringba Users with accounts located in Ringba’s European Data Region, all Personal Data is processed in the EEA. For Users with accounts in the Data Regions: United States of America (US) and Canada, all Personal Data is processed solely in the respective country. For Users with accounts in our Asia Pacific Data Region, all Personal Data is processed in Singapore.
184.108.40.206 Processing in the European Economic Area (EEA)
For Users with accounts located in Ringba’s European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and Ringba’s processing will take place in accordance with the GDPR.
Ringba processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR: The Ringba entity which you as a User entered an agreement with when using Ringba’s platform, will be the Controller for User data, as outlined above in “Collection of User data” section. For Consumer data, as outlined in the “Collection of Consumer Data” section, the User will be the Controller in accordance with Directive and GDPR, and Ringba will be the Processor. Ringba adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, Ringba processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only. All data collected by Ringba Users will be stored exclusively in secure hosting facilities provided by Amazon Web Services, Telnyx, Plivo, and Twilio. Ringba has a data processing agreement in place with its providers, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.
220.127.116.11 Processing in North America
For Users with accounts in the Ringba North America Data Region, Ringba processes data solely in data centers located in the US. Ringba has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the User’s data in Ringba’s possession. Ringba will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data. All data collected by Ringba Users will be stored exclusively in secure hosting facilities provided by Amazon Web Services, Telnyx, Plivo, or Twilio. Ringba’s contract with its hosting provider ensures that all hosting is performed in accordance with the highest security regulations. Ringba’s policy is to protect and safeguard any personal information obtained by Ringba in accordance with United States state or federal laws governing the protection of personal information and data. Accordingly, Ringba adheres to practices and policies that aim to safeguard the data.
18.104.22.168 Processing in Other Regions
For Users with accounts in our Asian Pacific Data Region, Ringba processes data in data centers throughout Asia, and in the US. Ringba has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Users data in Ringba’s possession. Ringba will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data. All data collected by Ringba Users will be stored exclusively in secure hosting facilities provided by Amazon Web Services, Telnyx, Plivo, or Twilio. Ringba’s contract with its hosting provider ensures that all hosting is performed in accordance with the highest security regulations. Accordingly, Ringba adheres to practices and policies that aim to safeguard the data.
3. Retention and Deletion
Ringba will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Consumer data, Ringba’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Consumer data, Users with an active account will therefore have the responsibility to delete data when required. When a users’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.
4. Acceptance of these Conditions
5. Our Legal Obligation to Disclose Personal Information
We will reveal a user’s personal information without their prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Ringba or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have a good reason to believe that this is legally required.
6. Contact Ringba Legal Department
If you have any further questions regarding the data Ringba collects or how we use it, please feel free to contact us by email at: firstname.lastname@example.org or using this contact form.