Your privacy is very important to us at iBasis. iBasis is committed to respecting your privacy and the confidentiality of your Personal Information and the content of your communications. This Privacy Statement is meant to assist End Users and Account Managers in understanding how We use and safeguard the information that We process when providing our Wholesale Services.

Please read this Privacy Statement carefully. This document governs iBasis’ collection, use and disclosure of your Personal Information as well as Non-Personally Identifiable Information in relation to the Wholesale Services.

Definitions

To help You better understand this Privacy Statement, We provide some basic definitions to use when reading and interpreting this document. The bold type terms used in this Privacy Statement shall have the meaning set forth below.

Account Managers means individuals who act on behalf of a Wholesale Customer in regard to the ordering, receipt, and administration of Wholesale Services.

End Users means individuals who are lawfully provided access to Our Wholesale Services by a Wholesale Customer.

You means Account Managers and End Users.

Wholesale Customer means the entity which has contracted for the iBasis Wholesale Services and provided End Users with access to such services.

iBasis or Us/We/Our means iBasis, Inc. and its affiliates.

Non-Personally Identifiable Information means aggregated, de-identified or other information that we cannot reasonably associate with an individual person.

Personal Information means information about an identifiable individual that is recorded in any form and that We have about You. Personal Information does not include information that is aggregated or otherwise does not identify an individual or does not permit Us to associate such information with an individual.

Privacy Statement refers to this Privacy and Security Statement as updated from time and time and available on the iBasis website.

Wholesale Services are the wholesale voice termination, and data services described on the iBasis website, http://ibasis.com/.

Why We Collect Information from You

We collect and use information from You for the following reasons:

  • to conduct business transactions with current and prospective Wholesale Customers;
  • to provide, maintain and improve the Wholesale Services to Our Wholesale Customers;
  • to monitor and analyze trends, usage and activities in connection with the Wholesale Services;
  • to identify the needs and preferences of End Users;
  • to detect and prevent fraud;
  • to meet applicable legal and regulatory requirements and obligations;
  • to administer and manage Our business operations and Wholesale Customer accounts;
  • to resolve disputes and troubleshoot problems; and
  • to prevent improper or illegal use of the Wholesale Services.

What Information We Collect

We only collect information that we believe is necessary and appropriate for the purposes identified in this Privacy Statement. This information includes the:

  • contact information of, and other information disclosed to Us by, Account Managers;
  • originating and terminating number of a phone call or short message service (“SMS”);
  • content of a phone call or SMS, as described below;
  • content of a data session;
  • duration of a phone call;
  • End User device identifier and services capabilities; and
  • the location of the cell tower which is used when you make a call or send an SMS.

We do not actively record the content of phone calls or SMS, except (i) where required to provide the Wholesale Services; (ii) where obliged or permitted by applicable law; and (iii) at the request of a Wholesale Customer for the purposes of the Wholesale Customer, such as the monitoring of their End Users . It is the responsibility of the Wholesale Customer to ensure that their purposes are lawful in the jurisdiction in which they operate.

We may also randomly record phone calls or SMS for maintenance and troubleshooting purposes. Such communications content is used only for those purposes and is retained for a minimal amount of time and thereafter promptly deleted.

We have no access to End User names, email addresses, billing information, or other similar information.

Use of Data Analysis Techniques for Network Planning and Management, and Security

iBasis is responsible for a telecommunication network used to carry telephone traffic. We maintain, plan and improve our network and perform management tasks like the routing of traffic, clearance of faults, and monitoring of peak loads and overloads. Analyzing the use made of our network gives us essential network usage and load information. Based on this information, we can expand and enhance our network in a targeted way. iBasis processes traffic data for these technical and statistical analyses. This includes (i) telephony data like your telephone number, date and starting and ending times of a call, the type of service concerned, International Mobile Subscriber Identity (IMSI), International Mobile Equipment Identity (IMEI) and (ii) data such as Customer identification.

Protection of Your Information

We have invested in and deployed technological and organizational security measures to protect information that we process. For instance we maintain firewalls and other technical security measures for our servers and internal networks, and the servers on which Personal Information is stored are located in secure facilities that are available only to authorized personnel. Our employees are dedicated to maintaining and upholding your privacy and security and are educated regarding this Privacy Statement. Only those employees who require Personal Information to perform a specific function related to the iBasis service are granted access to that information. Our employees are required to use the utmost discretion when accessing Personal Information, and they are prohibited from using Personal Information for purposes unrelated to their job functions. As appropriate, our employees are notified when this Privacy Statement is revised or other privacy or security measures are implemented by iBasis.

Disclosure of Personal Information

We do not sell your Personal Information to anyone other than your Wholesale Customer in connection with the Wholesale Services provided to them. We only disclose Your Personal Information to third parties where necessary to fulfill the purposes identified in this Privacy Statement or where requested by You.

We may, however, use or disclose your Personal Information for legal or regulatory reasons as necessary or as required to investigate fraud, to protect iBasis, Wholesale Customers, and End Users, to otherwise protect against the unlawful use of the Wholesale Services, or as otherwise described above in the section titled, “Why We Collect Information from You.”

You acknowledge that it is iBasis’ policy and prerogative to respond to all governmental inquiries regarding its Wholesale Services. In the event a competent governmental authority asks iBasis to retain and provide Personal Information about You, iBasis reserves the right to provide any and all assistance and information necessary in its opinion to fulfill the request.

We also may disclose Personal Information in connection with a merger, acquisition or bankruptcy if We should ever file for bankruptcy or merge with another company, or if We should decide to buy another business, or sell or reorganize part or all of our business. We may disclose Your Personal Information to prospective or actual purchasers and other parties. By using the Wholesale Services, You acknowledge that any such transfer of Your Personal Information may occur. It is iBasis’ practice to obtain appropriate protections for Personal Information disclosed in these types of transactions. iBasis cannot, however, guarantee that the Privacy Statement applicable to the Wholesale Services will remain unchanged if iBasis is sold or merges with or is acquired by another company.

Retention of Personal Information

Personal Information will be retained only as long as necessary for the fulfillment of the purposes identified in this Privacy Statement or as otherwise required or permitted by applicable law.

Accuracy of Personal Information and Your Access to Personal Information

iBasis takes reasonable steps to make sure that the Personal Information We process is accurate, complete and up-to-date for the purposes for which it is collected and processed. You should ensure that any information you provide to Us or the relevant Wholesale Customer (your employer) is accurate, complete and up-to-date, and You should contact Us or the relevant Wholesale Customer (your employer), as appropriate, should you need to update or review that information.

You may also access a copy of Your Personal Information or otherwise exercise your rights afforded under applicable law by contacting us at the address provided below and by providing evidence of your identity. If the information requested does not identify you without us obtaining additional information, we may not be able to honor your request.

Transfer of Information

The Personal Information that We collect may be stored and processed on servers located in various countries, including servers located outside of your home country. This is necessary to ensure that your calls and SMS reach their intended destination.

iBasis is based in the United States, and the information we collect is governed by U.S. law. By accessing or using iBasis services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries. iBasis complies with the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework and has certified its adherence to the Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement with respect to personal data collected from individuals in the EU and Switzerland. For more information about the Safe Harbor program and to view our certification, please visit the U.S. Department of Commerce’s Safe Harbor website. For questions or complaints regarding our compliance with the Safe Harbor Frameworks, please contact our Privacy Officer as indicated below. For complaints that cannot be resolved between iBasis and the complainant, iBasis has agreed to participate in the dispute resolution procedures of JAMS International for disputes arising under or regarding the Safe Harbor principles.

Contact Us; Our Privacy Officer

We have designated one or more individuals who monitor Our compliance with this Privacy Statement. The individual responsible for Our compliance has been designated as iBasis’ Privacy Officer. Please direct any questions or correspondence regarding this Privacy Statement to the Privacy Officer. The Privacy Officer can be reached by sending correspondence to:

iBasis, Inc.
ATTN: iBasis Privacy Officer
20 Second Avenue
Burlington, MA 01803, USA
info@ibasis.net

Other individuals may handle the day-to-day collection and processing of Personal Information. The Privacy Officer or iBasis’s management may designate other individuals within iBasis to assist the Privacy Officer or to perform the Privacy Officer’s responsibilities.

Changes to This Privacy Statement

We reserve the right to change this Privacy Statement at any time. The revised Privacy Statement will be effective immediately upon its posting on the website with the new effective date displayed. Any revisions will apply on a prospective basis only, except as described below. You should periodically check this Privacy Statement for any such changes, and you acknowledge that any use of the Wholesale Services after such changes signifies your consent to those changes.

If we intend to use Personal Information we have collected from you in a manner that is materially different from that described in this Privacy Statement, we will seek your explicit consent.

Last Updated: June 29, 2015