Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (or the why and the how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to contractual restrictions.
As part of our business relationship with our customers, we are often asked to receive, gather, store, analyze, or otherwise process information, which may include personal data, on behalf of our customers. We refer to this type of information and personal data as “customer data.” When we process customer data, we generally act as a processor. This means we process customer data on behalf of our customers subject to restrictions set forth in our contracts with them.
Depending on your country, region, or state of residence, certain rights may apply to you. Please refer below for disclosures that may be applicable to you:
- California: If you are a resident of the State of California, please see the “Additional California Privacy Disclosures” section here.
- Nevada: If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of potential future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at firstname.lastname@example.org.
Personal Data We Collect
What is Personal Data?
We may collect the following types of personal data through the Services:
Personal Data Provided by an Individual:
- Member information, such as your name a contact telephone number used to identify you, a PIN or password, your postal address, e-mail address, and any other contact or information you choose to provide to us.
- Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name and information. We also may collect information pertaining to demographic characteristics, such as your age, and may collect your technology or communications services purchasing preferences
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
- Inferences information. We may generate inferences or predictions about individuals and their interests and preferences based on the other personal data we collect and the interactions we have with the individuals.
- Billing information, such as your credit card information and billing address .
Personal Data Automatically Collected
As is true of most digital platforms, we may collect certain personal data automatically when you visit our online services, including:
- Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.
- Analytics Data, including the electronic path you take to the Services, through the Services and when exiting the Services, as well as your usage and activity on the Services, such as the links and object you view, click or otherwise interact with (also known as “Clickstream Data”). For information, please visit the “Cookies and Other Data Collection Technologies” section below.
- Location Data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device.
- Information You May Post/Submit to our Services. We may collect information about how you use and interact with our Services, including any information and content you post to the Services. If you need to update your permissions, you can do so in the “Settings” app of your device.
Personal Data Provided by Other Sources
We also may obtain your personal data from other sources which we often combine with personal data we collect either automatically or directly from you.
We may receive the same categories of personal data as described above from the following sources and third parties:
- Our Affiliates. We may receive information about you from our other affiliates, so that information you provide to one affiliate may be used by us to provide you Services, communicate with you or provide you advertisements or other personalized content.
- Our Customers: If you engage in our Services through our customers, we may collect your data through the customer(s).
- Service Providers: Our service providers that perform services on our behalf, such as our call center operations vendors, payment processors and analytics providers.
- Social Networks: When you interact with the Services through various social media networks, such as when you “Like” us on Facebook or when you follow us or share our content on Facebook, LinkedIn or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third party websites and social media networks and services before linking or connecting them to the Services.
- Other Third Parties and Publicly Available Sources: From time to time, we may receive information about you from third parties. For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing user information. Where permitted by applicable law, we may also collect information about you that is publicly available, including contact information and product interest information. We may combine this information with the information we collect from you directly.
How Personal Data Is Used
We may collect, use and disclose your personal data for purposes identified at the time of collection, or as otherwise permitted or required by law, including the following purposes:
- To fulfill or meet the reason the information was provided, such as to process your requests or payment in connection with your transactions and to respond to inquiries.
- To personalize your experience and customize content on the Services relevant to your interests, including but not limited to targeted offers and ads through our websites, email, social media channels, third-party sites, or on other devices you may use.
- To communicate with you.
- To operate, maintain, and provide the features and functionality of the Services.
- To complete the performance of the Services pursuant to an agreement between you or our customer(s) and us.
- To send you important information regarding the Services, such as certain changes to our terms, conditions, policies, and/or other administrative information. Because this information may be material to your use of the Services, you may not opt out of receiving such communications.
- To help maintain the safety, security, and integrity of the Services, technology assets, and business.
- For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, evaluating, enhancing the Services, improving the Services and identifying usage trends, and determining the effectiveness of our marketing campaigns.
We will use de-identified or aggregated data to optimize our marketing and product development efforts (such as keyword advertising purchases and search engine optimization), to determine the success of our marketing campaigns, to provide demographic information to sponsors, advertisers and partners, and other relevant commercial purposes. We may also provide such data to our sponsors, advertisers and partners so that they may track the success of their advertising and promotional efforts, for example, to determine the demographic attributes and use preferences of visitors to our website that feature their products or services.
Our Disclosure of Personal Data
- Affiliates: We may disclose personal data between and among IVR Technology Group and its current and future parents, affiliates, subsidiaries, and other companies under common control or ownership.
- Our Customers: If you engage in our Services through our customers, we may share your data with such customer(s).
- Business / Promotional Partners: We may share limited information with third parties with whom we partner to provide contests and sweepstakes, or other joint promotional activities or co-branded services.
- Online Advertising Partners: We may also share personal data with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please see the “Cookies and Other Data Collection Technologies” section below.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership, in compliance with applicable law.
- Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our customers, or any person; or
- as otherwise required by applicable law.
- With Your Consent or At Your Direction: We may disclose personal data about you to certain other third parties with your consent or at your direction.
Cookies and Other Data Collection Technologies
Cookies are small data files that are stored on your computer that allow us and our third-party partners and providers to collect certain information about your interactions with our email communications, websites and other online Services. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).
Third-party partners and providers may also collect personal data about your online activities over time and across different websites when you use our websites and online Services.
We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and online Services; (b) provide and monitor the effectiveness of our websites and online Services; (c) monitor online usage and activities of our websites and online Services; (d) diagnose errors and problems with our websites and online Services; (e) otherwise plan for and enhance our online Services; and (f) facilitate the purposes identified in the “Our Use of Personal Data” section of our Privacy Notice (linked above). We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.
Please note that we link some of the personal data we collect through cookies with the other personal data that we collect about you.
Your Choices About Cookies
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our online Services, as some features and services on our online Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Third-Party Data Collection and Online Advertising
We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We permit third-party online advertising networks, social media companies and other third-party services, to collect information about your use of our online Services over time so that they may play or display ads on the Services, on other websites, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”), which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
Your Choices About Online Ads
We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices or www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again. If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at www.aboutads.info/appchoices.
Cookie Management and the Right to Opt Out of the Sale or Sharing of Personal Data for Targeted Advertising Purposes
For California, Nevada, and Virginia Residents: Unless you have exercised your Right to Opt Out (as described in our Additional California Privacy Disclosures), we may “sell” or “share” your personal data to third parties for targeted or cross-context behavioral advertising purposes. The third parties to whom we sell or share personal data may use such information for their own purposes in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties.
You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional personal data so that we can properly identify you in our dataset and to track compliance with your opt-out request. We will only use personal data provided in an opt-out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
Surveys & Contests
Posted Information and Content; Use of Community Features
To the extent you post any content on the IVR Technology Group website or participate in any forum, chat, message board, or any other interactive or community service or feature on the website, all of the information contained in your submission or communications will become published public information and IVR Technology Group will not have any control over the use of such information by users and third parties with access to that information. IVR Technology Group reserves the right to use all of such information at its discretion without restriction.
Additional privacy policies and other terms may apply to use of any community or interactive feature or service available through the IVR Technology Group Services. Please check the pages containing those features and services for more information.
Third Party Links and Websites
The IVR Technology Group Services are not directed to children under the age of 13. If you are under the age of 13, please do not use our Services or otherwise provide us with any personal data. If a child under 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.
How to Contact Us
You may also write to us via postal mail at:
IVR TECHNOLOGY GROUP LLC
65 Lawrence Bell Drive, Suite 102