CloudCall Privacy Policies

The CloudCall Group (encompassing CloudCall Group plc, CloudCall Limited, CloudCall Inc. and their subsidiary, parent and holding companies) (“CloudCall”, “we”, “us”, “our”) is committed to respecting the privacy of its website users, customers, prospective customers, suppliers, integration/referral partners, job candidates, and shareholders (“you”, “your”, “you’re”). CloudCall Group plc is a company registered in England and Wales under company number 05509873, with its registered office located at 1 Colton Square, Leicester, United Kingdom, LE1 1QH. CloudCall Limited is a company registered in England and Wales under company number 05557457, with its registered office located at 1 Colton Square, Leicester, United Kingdom, LE1 1QH. CloudCall Inc. is a company registered in the state of Delaware in the United States of America, with its principal office located at 320 Congress Street, Boston, MA 02210, United States of America. These privacy policies are issued on behalf of CloudCall, and so when we mention “CloudCall”, “we”, “us” or “our” in these privacy policies, we are referring to the relevant company in the CloudCall Group responsible for processing your data. Where you enter into any contract with any CloudCall entity, that CloudCall entity will be the controller/processor for your data. These privacy policies describe the personal data/personal information we collect from you and how we use and share that information. It is important that you read these privacy policies together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. These privacy policies supplement our other notices and privacy policies and are not intended to override them. Personal data, or personal information, or personally identifiable information/data, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (e.g. anonymous data).

CloudCall Group plc, CloudCall Limited and CloudCall Inc. declare their commitment to the European Union-United States Privacy Shield Framework and the Swiss-United States Privacy Shield Framework (together the “Privacy Shield”), as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Economic Area member countries and Switzerland. CloudCall Group plc, CloudCall Limited and CloudCall Inc. have certified that they adhere to the Privacy Shield principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, and access, recourse, enforcement, and liability (“Privacy Shield Principles”). The Privacy Shield List (which lists the organisations who have certified that they adhere to the Privacy Shield Principles) can be accessed using the following web link: https://www.privacyshield.gov/list. CloudCall’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission, the United States Department for Transportation or the applicable United States authorized statutory body. Under certain conditions, you may be able to invoke binding arbitration relating to complaints or disputes concerning CloudCall’s adherence to the Privacy Shield Principles in respect of your personal information. In accordance with the “accountability for onward transfer” Privacy Shield Principle, in some cases, CloudCall may be held liable if it were to commit unlawful transfer of your personal data to third parties.

If you have any questions about CloudCall’s privacy policies or wish to submit a complaint/request to CloudCall concerning its privacy practices/personal data practices, please contact CloudCall by email at GDPR@cloudcall.com or by mail to any of the addresses above. You may also contact our Data Protection Officer (Matthew Buswell, Head of Legal & Data Protection Officer, email address: DPO@cloudcall.com) if you have any questions about CloudCall’s privacy policies or wish to submit a complaint/request to CloudCall concerning its privacy practices/personal data practices. For any questions, concerns, or complaints concerning our privacy practices/personal data practices that cannot be handled by CloudCall itself, please contact your local data protection authority (e.g. the UK Information Commissioners Office (www.ico.org.uk) if you are UK based or the EU Data Protection Authorities (https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm) if you are European Union based or the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html) if you are Switzerland based). These authorities may direct you to independent dispute resolution mechanisms to address your complaints and provide appropriate recourse free of charge. For clarity, you have the right to make a complaint at any time to your local data protection authority about our privacy practices/personal data practices. We would, however, appreciate the chance to deal with your concerns/complaints before you approach the local data protection authority, so please contact us in the first instance with any concerns/complaints you may have about our privacy practices/personal data practices.

We will comply with data protection law and principles, which means that your personal data will be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

We keep our privacy policies under regular review. This version was last updated on 14th November 2018.

CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers

Introduction

This section is a CloudCall privacy policy that covers CloudCall website users, existing CloudCall customers and prospective CloudCall customers. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. Once you choose to provide personally identifiable information to us, it will only be used in the context of your relationship with CloudCall. CloudCall will not sell, rent, or lease your personally identifiable information to others. CloudCall will only share your personal data with other CloudCall entities and/or third parties who are acting on CloudCall’s behalf in connection with the provision to you of services/products or the provision to you of content of this website.

Information We Collect and How We Collect It

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about your criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including those summarised below:

  •  Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for, purchase, use, access, enquire about, enter into a contract for, enter into negotiations for, or trial, our products or services;
    • create an account on our website;
    • subscribe to our services or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy on our website for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • (a) analytics providers (such as Google based outside the EU); and
      • (b) search information providers (such as Google based outside the EU).
  • Contact, Financial and Transaction Data from providers of credit reference/check services, technical, payment and delivery services.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU and from biographical information posted by you on the internet.

Moreover, we collect information that you or others provide to us in connection with your use of our services/products. Examples include phone numbers you dial or provide to our services, records you hold in your customer relationship management systems, service setup information, service configurations and settings, recorded calls, messages, and meetings, voicemails, incoming and outgoing faxes, user-saved or stored content shared among users, email and text communications, and call centre customer information you provide to us. Our systems also generate reports and information stored on your account. We maintain this system-generated information in connection with your account.

Children (under eighteen years old) are not eligible to use CloudCall’s website or services or products, and we ask that children do not submit personally identifiable information to us. We do not knowingly collect data relating to children.

Sharing and Transfer of Information (Onward Transfer)

We may share your personal data with the parties set out below:

  • Internal Third Parties as set out in the Glossary section below.
  • External Third Parties as set out in the Glossary section below.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you are UK/European Economic Area (“EEA”) based then the following provisions apply:

  • We share your personal data within the CloudCall Group. This will involve transferring your personal data outside the EEA.
  • Some of our External Third Parties are based outside the EEA so their processing of your personal data will involve a transfer of your personal data outside the EEA.
  • Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
    1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
    2. Where we use certain providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
    3. Where we use providers based in the US, we may transfer data to them if they are part of the E.U.-U.S. Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
  • Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We also may share or disclose your personal information if we receive a request or demand for such information in the form of:

  • A court order to disclose such information;
  • What we believe (in our sole discretion) is lawful process in a criminal investigation or proceeding, such as a search warrant, subpoena, or court order;
  • Judicial or administrative process in civil proceedings, such as subpoenas or discovery requests; or
  • A national security letter or similar request from any regulatory, government, state or law enforcement agency.

We also reserve the right to share or transfer your information if we believe (in our sole discretion) that such sharing or transfer is required under applicable law.

How We Use the Information We Collect

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Where required by applicable law and regulation, we will get your consent before sending direct marketing communications to you. You have the right to withdraw consent to (or opt out of) receiving marketing at any time by contacting us.

We have set out below, in a table format, a summary of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/ActivityLawful basis for processing (including basis of legitimate interest)"
To register you as a new supplier or integration/referral partner.Performance of a contract with you
To perform (and carry out administration in respect of) the contracts or other arrangements entered into between you and us, including: (a) Managing transactions, payments, fees and charges, (b) Collecting and recovering money owed to us, (c) Responding to your enquiries, (d) Recording our calls/emails/other contact with you for quality, monitoring and training purposes.(a) Performance of a contract with you, (b) Necessary for our legitimate interests (e.g. to recover debts due to us and to grow our business by effectively managing and expanding our partner and supplier relationships).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy, (b) Asking you to leave a review or take a survey.(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests (e.g. to keep our records updated).
To enable you to partake in a prize draw, competition or complete a survey.Necessary for our legitimate interests (e.g. to study our suppliers and partners so that we can manage our relationships with them for the benefit of our business).
To administer and protect our business (including fraud prevention, credit checking, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and prevention of unlawful or potentially unlawlul activity(a) Necessary for our legitimate interests (e.g. for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.Necessary for our legitimate interests (e.g. to study and develop our website and advertisements in order to grow our business and inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.Necessary for our legitimate interests (e.g. to define types of customers for our products and services, to keep our website updated and relevant, and to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about our goods and services that may be of interest to you.Necessary for our legitimate interests (e.g. to market our products/services and grow our business).

*In some cases (for example where required by law or where we have simply chosen to get a particular customer’s or prospective customer’s consent) we will have gained your consent as the lawful basis to process your personal data. In such cases, that consent is the lawful basis to process your personal data instead of the grounds specified above in the table (rather than the consent being a back-up, alternative or additional lawful basis to process your personal data). Such consent may be withdrawn by you at any time by contacting us.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy on our website.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we may notify you and we may explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Safeguard the information we collect

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

CloudCall implements practices to ensure that personal information is accurate, complete, and current. If you wish to access the personal information we have on file for you, or to change, add to, or delete the personal information we hold about you, please email us at GDPR@cloudcall.com. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Changes to this Policy

CloudCall reserves the right to make changes to this policy from time to time.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above please contact us by email at GDPR@cloudcall.com or by mail to 1 Colton Square, Leicester, LE1 1QH, UK. You may also contact our Data Protection Officer (Matthew Buswell, Head of Legal & Data Protection Officer, email address: DPO@cloudcall.com) if you wish to exercise any of the rights set out above.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights) is valid. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

CloudCall Privacy Policy Covering its Suppliers and its Integration/Referral Partners

Introduction

This section is a CloudCall privacy policy that covers CloudCall suppliers and CloudCall integration/referral partners. CloudCall is committed to respecting the privacy of its suppliers and its integration/referral partners. Once you choose to provide personally identifiable information to us, it will only be used in the context of your relationship with CloudCall. CloudCall will not sell, rent, or lease your personally identifiable information to others. CloudCall will only share the personal data you provide with other CloudCall entities and/or third parties who are acting on CloudCall’s behalf in connection with the performance (or administration) of any contracts or other arrangements between you and us.

Information We Collect and How We Collect It

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, title, and gender.
  • Contact Data includes address, email address and telephone numbers.
  • Financial Data includes bank account details (and payment card/method details in certain circumstances).
  • Transaction Data includes details about payments to and from you and other details related to the performance (and/or administration of) contracts and arrangements between you and us.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about your criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform and/or administer the contract we have or are trying to enter into with you.

We use different methods to collect data from and about you including those summarised below:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • enter into discussions and/or negotiations with us in connection with becoming our supplier or our integration/referral partner;
    • enter into a contract or other arrangement with us to become our supplier or our integration/referral partner;
    • perform (and/or carry out administration in respect of) a contract or other arrangement between you and us;
    • enter a competition or survey; or
    • give us feedback or contact us.
  • Third parties or publicly available sources.
  • Contact, Financial and Transaction Data from providers of credit reference/check services, technical, payment and delivery services.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU and from biographical information posted by you on the internet.

We ask that children (under eighteen years old) do not submit personally identifiable information to us. We do not knowingly collect data relating to children.

Sharing and Transfer of Information (Onward Transfer)

The “Sharing and Transfer of Information (Onward Transfer)” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

How We Use the Information We Collect

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

We have set out below, in a table format, a summary of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/ActivityLawful basis for processing (including basis of legitimate interest)
To register you as a new supplier or integration/referral partner.Performance of a contract with you.
To perform (and carry out administration in respect of) the contracts or other arrangements entered into between you and us, including: (a) Managing transactions, payments, fees and charges, (b) Collecting and recovering money owed to us, (c) Responding to your enquiries, (d) Recording our calls/emails/other contact with you for quality, monitoring and training purposes.(a) Performance of a contract with you, (b) Necessary for our legitimate interests (e.g. to recover debts due to us and to grow our business by effectively managing and expanding our partner and supplier relationships).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy, (b) Asking you to leave a review or take a survey.(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests (e.g. to keep our records updated).
To enable you to partake in a prize draw, competition or complete a survey.Necessary for our legitimate interests (e.g. to study our suppliers and partners so that we can manage our relationships with them for the benefit of our business).
To administer and protect our business (including fraud prevention, credit checking, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and prevention of unlawful or potentially unlawlul activity).(a) Necessary for our legitimate interests (e.g. for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Necessary to comply with a legal obligation.

*In some cases (for example where required by law or where we have simply chosen to get a particular supplier’s or partner’s consent) we will have gained your consent as the lawful basis to process your personal data. In such cases, that consent is the lawful basis to process your personal data instead of the grounds specified above in the table (rather than the consent being a back-up, alternative or additional lawful basis to process your personal data). Such consent may be withdrawn by you at any time by contacting us.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we may notify you and we may explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Data Retention

The “Data Retention” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

Safeguard the information we collect

The “Safeguard the information we collect” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

Changes to this Policy

CloudCall reserves the right to make changes to this policy from time to time.

Your Legal Rights

The “Your Legal Rights” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

CloudCall Privacy Policy Covering its Job Candidates

Introduction

This section is a CloudCall privacy policy that covers candidates who apply for job roles at CloudCall. CloudCall is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being provided with a copy of this privacy policy because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for.

The Kind of Information We Hold About You

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your curriculum vitae and covering letter.
  • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, and qualifications.
  • Any information you provide to us during an interview.

We may also collect, store and use the following types of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Information about your health, including any medical condition, health and sickness records.

How is Your Personal Information Collected?

We collect personal information about candidates from the following sources:

  • You, the candidate.
  • Various recruitment agencies.
  • Your named referees.
  • Publicly accessible sources such as LinkedIn.
  • Your calls/emails/other contact with CloudCall may be recorded to gather information for quality, monitoring and training purposes.

How We Will Use Information About You

We will use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for the role.
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.
  • Assist us with our internal quality, training and monitoring purposes.

It is in our legitimate interests to process your personal information in order to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role. We also need to process your personal information to decide whether to enter into a contract/contract of employment with you.

Having received your CV/application, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we may then take up references before confirming your appointment.

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for a role and you fail to provide us with relevant details, we will not be able to take your application further.

How We Use Particularly Sensitive Personal Information

We will use your particularly sensitive personal information in the following ways:

  • We may use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
  • We may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information About Criminal Convictions, Automated Decision-Making, and Data Sharing

We do not envisage that we will process information about your criminal convictions/offences. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. We will not share your personal information with third parties for the purposes of processing your application.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. If we wish to retain your personal information on file for longer than this, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a further fixed period on that basis.

Your Legal Rights

The “Your Legal Rights” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

CloudCall Privacy Policy Covering its Shareholders

Introduction

This section is a CloudCall privacy policy that covers CloudCall shareholders. CloudCall is committed to respecting its shareholders’ privacy. Once you choose to provide personally identifiable information to us, it will only be used in the context of your relationship with CloudCall. CloudCall will not sell, rent, or lease your personally identifiable information to others. CloudCall will only share your personal data with other CloudCall entities and/or third parties who are acting on CloudCall’s behalf in connection with your investment(s) in CloudCall.

Information We Collect and How We Collect It

In the event that a shareholder makes an EIS/VCT qualifying purchase of CloudCall shares, certain brokers that handle such investments will provide information to us about the shareholder’s name, postal address, number of shares purchased and price paid. This is given to us for the purposes of us completing and distributing certain HMRC forms in respect of the shareholders. We may also record our calls/emails/other contact with you for quality, monitoring and training purposes.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about your criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract/investment, and you fail to provide that data when requested, we may not be able to perform and/or administer as required in connection with the contract/investment.

We ask that children (under eighteen years old) do not submit personally identifiable information to us. We do not knowingly collect data relating to children.

Sharing and Transfer of Information (Onward Transfer)

The “Sharing and Transfer of Information (Onward Transfer)” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

How We Use the Information We Collect

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform (and/or carry out administration in respect of) the contract/investment we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

We have set out below, in a table format, a summary of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/ActivityLawful basis for processing (including basis of legitimate interest)
Recording our calls/emails/other contact with you for quality, monitoring and training purposes.Necessary for our legitimate interests (e.g. to keep our records up to date and to pass shareholder enquires or information to our brokers, company secretary, registrar or accountants where necessary in connection with the shareholder’s investment in CloudCall).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy, (b) In the event that a shareholder makes an EIS/VCT qualifying purchase of CloudCall shares, certain brokers that handle such investments will provide information to us about the shareholder’s name, postal address, number of shares purchased and price paid. This is given to us for the purposes of us completing and distributing certain HMRC forms in respect of the shareholders.(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation.

*In some cases (for example where required by law or where we have simply chosen to get a particular shareholder’s consent) we will have gained your consent as the lawful basis to process your personal data. In such cases, that consent is the lawful basis to process your personal data instead of the grounds specified above in the table (rather than the consent being a back-up, alternative or additional lawful basis to process your personal data). Such consent may be withdrawn by you at any time by contacting us.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we may notify you and we may explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Data Retention

The “Data Retention” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

Safeguard the information we collect

The “Safeguard the information we collect” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

Changes to this Policy

CloudCall reserves the right to make changes to this policy from time to time.

Your Legal Rights

The “Your Legal Rights” section of the “CloudCall Privacy Policy Covering its Website Users, Customers and Prospective Customers” above applies equally in this privacy policy.

Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience in the context of your relationship with us. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Internal Third Parties means other companies in the CloudCall Group acting as joint controllers or processors and who are based in the UK or USA.

External Third Parties means:

  • Service/goods providers acting as processors based in Ireland, Canada, USA, New Zealand, UK, and Czech Republic who provide IT and system administration services/goods.
  • Professional advisers acting as processors or joint controllers including lawyers, company secretaries, brokers, registrars, bankers, auditors, accountants and insurers based in UK, Australia and USA who provide investment, company secretarial, auditing, consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK and USA who require reporting of processing activities in certain circumstances.