Account Managers means individuals who act on behalf of an Operator Customer in regard to the ordering, receipt, and administration of Solutions.
End Users means individuals who are lawfully provided access to Our Solutions by an Operator Customer.
You means Account Managers and End Users.
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.
Operator Customer means the telecom operator, service provider, mobile network operator or other entity which has contracted for one or more of the iBASIS Solutions and provided End Users with access to such services.
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.
Solutions refers to the managed voice, roaming enablement, mobile data, cloud numbering, IOT connectivity, fraud prevention, business intelligence and related services described on the iBASIS website, https://iBASIS.com/solutions/.
WHY WE COLLECT INFORMATION FROM YOU
Operator Customers provide us with information about You. We collect and use Your Personal Information for the following purposes:
- to conduct business transactions with current and prospective Operator Customers;
- to provide, maintain and improve the Solutions to Our Operator Customers;
- to monitor and analyze trends, usage and activities in connection with the Solutions;
- 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 Operator Customer accounts;
- to resolve disputes and troubleshoot problems; and
- to prevent improper or illegal use of the Solutions.
These purposes listed above are our legitimate interests which we pursue. These legitimate interests form the legal basis to collect and use Your information.
WHAT INFORMATION WE COLLECT
- contact information of, and other information disclosed to Us by, Account Managers;
- originating and terminating number of a phone call;
- content of a phone call, 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 initiate a data session.
We do not actively record the content of phone calls, except (i) where required to provide the Solutions; (ii) where obliged or permitted by applicable law; and (iii) at the request of an Operator Customer for the purposes of the Operator Customer, such as the monitoring of their End Users. It is the responsibility of the Operator Customer to ensure that their purposes are lawful in the jurisdiction in which they operate.
We may also randomly record phone calls 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
The iBASIS network supports our Solutions. 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 OperatorCustomer identification.
PROTECTION OF YOUR INFORMATION
We require that our third party service providers agree to keep all information We share with them and to use the information only to perform their obligations in the agreements We have in place with them. These third party service providers are expected to maintain privacy and security protections that are consistent with applicable law. While We provide these third parties with no more information than is necessary to perform the function for which We engaged them, any information that You provide to these third parties independently is subject to their respective privacy policies and practices.
DISCLOSURE OF PERSONAL INFORMATION
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, Operator Customers, and End Users, to otherwise protect against the unlawful use of the Solutions, 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 Solutions. 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.
RETENTION OF PERSONAL INFORMATION
ACCURACY OF PERSONAL INFORMATION AND YOUR RIGHTS RELATED 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 Operator Customer (your employer) is accurate, complete and up-to-date, and You should contact Us or the relevant Operator Customer (your employer), as appropriate, should you need to update or review that information.
You may have a right to data portability under applicable law. You may also have a right to access a copy of Your Personal Information, request rectification or erasure of Your Personal Information, object to processing of Your Personal Information, request the restriction of the processing 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. Finally, you may also also have the right to lodge a complaint with a supervisory authority.
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 reach their intended destination.
CONTACT US; OUR DATA PROTECTION OFFICER
ATTN: Kyle Hofmann, Data Protection Officer
10 Maguire Road, Building 3
Lexington, MA 02421, USA
Other individuals may handle the day-to-day collection and processing of Personal Information. The Data Protection Officer or iBASIS’ management may designate other individuals within iBASIS to perform the Data Protection Officer’s responsibilities.
CHANGES TO THIS PRIVACY STATEMENT
Last Updated: March 5, 2019