PRIVACY POLICY – IoT
Your privacy is very important to us at iBASIS. iBASIS is committed to respecting your privacy, the confidentiality of your Personal Information and the content of your communications. This Privacy Policy is meant to assist You in understanding how We use and safeguard the information that We collect from the Website and in providing our services to You. To protect your privacy, the Personal Information that iBASIS collects from You is used in the manner and for the purposes described in this Privacy Policy.
Please read this Privacy Policy carefully. This document governs iBASIS’ collection, use and disclosure of your Personal Information as well as Non-Personally Identifiable Information. By providing Your Personal Information to iBASIS in the ways described in this Privacy Policy, You agree that You are authorized to provide that information, You acknowledge that Your Personal Information will be handled as described in this Privacy Policy, and You are accepting this Privacy Policy and any supplementary privacy statement that may be relevant to You. In order to register, create an account and utilize our services, You will need to agree to this Privacy Policy.
Definitions
To help You better understand this Privacy Policy, We provide some basic definitions to use when reading and interpreting this document. The bold type terms used in this Privacy Policy shall have the meaning set forth below.
Customer or You means individuals to whom this Privacy Policy applies. Customers include anyone who registers with iBASIS to receive its Global Access for Things Services.
iBASIS or Us/We/Our means iBASIS and, as applicable, the underlying service providers of iBASIS’ services, iBASIS, Inc. and its group companies (“iBASIS”). This Privacy Policy only applies to customers who register with iBASIS through the Nordic Portal. Additional information regarding the iBASIS Global IoT Service is available at www.iBASIS.com/iot/ and additional information about iBASIS is available at www.iBASIS.com.
Non-Personally Identifiable Information is aggregated or other information that cannot be associated with an individual person.
Personal Information or Customer Proprietary Network Information (also known as CPNI) is information about an identifiable individual that is recorded in any form and that We have about You. Your Personal Information does not include Non-Personally Identifiable Information. Personal Information may include but is not limited to, a Customer’s name, address, e-mail address, Call Detail Information, phone number(s), data destinations, International Mobile Subscriber Identity (IMSI) and International Mobile Equipment Identity (IMEI), eSIM ID (EID), Integrated Circuit Card Identifier (ICCID) or other device identifier and service capabilities, the location of the cell tower which is used when You create a session, credit card information, credit history, payment and banking information, and information or feedback or content You provide regarding Your marketing preferences, in surveys, or promotional offers, or to the Website or apps and those of third parties. Personal Information also includes the following information about Your use of our Website through cookies, web beacons, log files and other technologies: Your domain name, Your browser type and operating system, web pages You view, Your IP address, the length of time You visit Our Website or use Our services, Your activities on Our Website or services (including Your movement through Our Website), and the referring URL or the webpage that led You to Our Website. Please see the description of “Cookies” and “action tabs” below for more information.
Privacy Policy refers to this iBASIS Global Access for Things Service Privacy Policy and Security Statement as updated from time and time and available on the Website.
Session Detail Information – is a type of CPNI that consists of records that contain your session history, including the destinations accessed, media types, time, location and duration of all sessions. You will have access to your Session Detail record information via a support request or via password protected Management Portal or API when you convert to a production account.
Website refers to the iBASIS website at https://iBASIS.com.
Why We Collect Personal Information
We collect and use Personal Information from Customers for the following reasons:
- to provide service, products, and support to Our Customers;
- to maintain commercial relations and to communicate with Our Customers (which may include, but is not limited to, billing, collection, advertising, promotion, account and credit verification, and other actions to customize, measure, and improve Our services);
- to monitor and analyze trends, usage and activities in connection with our services to Our Customers;
- to identify the needs and preferences of Our Customers;
- to meet applicable legal and regulatory requirements;
- to administer and manage Our business operations and personal accounts;
- to resolve disputes and troubleshoot problems;
- to detect and prevent fraud; and
- to enforce Our Terms and Conditions and prevent improper or illegal use of services.
These purposes listed above are our legitimate interests which we pursue. These legitimate interests form the legal basis to collect and use Your information. Personal Information will not be collected, used, or disclosed for purposes other than as set forth in this Privacy Policy except with your consent or as otherwise required or permitted by applicable law.
What Information We Collect
We require You to provide certain Personal Information so that You can order services from iBASIS, and We limit the collection of Personal Information to that information we believe is necessary or appropriate for the purposes identified in this Privacy Policy.
Customers who purchase services from iBASIS are required to provide credit card or other payment information for billing purposes. Except as described in this Privacy Policy, all financial information is kept confidential. We use a third party to process credit card orders, including card authorization and billing. Any such third party is contractually authorized to use the Personal Information provided by You solely for the purpose of conducting iBASIS business. They may not release your Personal Information to any other person except as required or permitted by applicable law or court order or to defend the third party’s rights in a legal dispute.
“Cookies” and “action tags” (action tags are also known as single pixel gifs or web beacons) are information that a website transfers to your computer’s hard disk for record-keeping purposes. Cookies and action tags do not personally identify users, although they do identify a user’s computer. iBASIS uses cookies and action tags to deliver content specific to Customers’ interests, maintain Customer preferences, and for other site functionality.
We require that Our third party service providers agree to keep all confidential 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 and channel partners are expected to maintain privacy and security protections that are consistent with iBASIS’ privacy and information security policies. 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.
Protection of Your Personal Information
Protecting the confidentiality of your Personal Information is your right and our responsibility under federal law. We have invested in and deployed technological and physical security measures to protect the Personal Information and other information that we collect. For instance, when Our registration form asks You to enter Personal Information, that information is encrypted and is protected with the encryption software most commonly deployed in the ecommerce industry, Secured Socket Layer (“SSL”). If you use an SSL-enabled Internet browser, such as used in the current versions of Microsoft Internet Explorer, Google Chrome or Firefox, your transmissions of Personal Information to Us through them will be secured through SSL technology. You can verify whether the information that is transmitted is using SSL encryption by confirming the presence of https:// nomenclature in the address bar of your browser window. To learn more about SSL, follow this link http://ssl.comodo.com/.
In addition, 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 Policy. 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 Policy is revised or other privacy or security measures are implemented by iBASIS.
iBASIS makes no representations or warranties with regard to the sufficiency of these security measures. By accepting this Privacy Policy or using iBASIS’ services, You agree that iBASIS shall not be responsible for any actual, indirect, or consequential damages (or any other damages or liability of any kind whatsoever, whether as a result of negligence or otherwise) that may result from our non-compliance with this Privacy Policy.
Use/Disclosure of Personal Information to Support and Promote iBASIS Services
As We describe in more detail below, We do not sell or disclose your Personal Information to anyone outside of Our group of companies or with anyone not authorized to perform service related functions on Our behalf, except as may be required by law or as authorized by You. By agreeing to this Privacy Policy, You agree to any such transfers of Your Personal Information as described below may occur. It is iBASIS’ practice to obtain appropriate protections for Personal Information disclosed in these types of transactions.
Generally, we are permitted to use CPNI to assist us in our provision of your iBASIS services, including billing and collection of those services, or to provide you with information on new discounts or special offers relating to the iBASIS services. If we use a third party to assist us in the performing any of the above functions on our behalf, We require that they only use Your information for the purposes provided and protect Your Personal Information consistent with our privacy policies described in this Privacy Policy. We do not provide Your Personal Information to third parties for the marketing of their services to You. We may, however, share Your aggregate or de-identified information with third parties for marketing, advertising, research or similar purposes.
We may use or disclose your Personal Information to Our group companies, for legal or regulatory reasons as necessary or required to investigate fraud, to protect other users, or to otherwise protect against the unlawful use of the iBASIS Service.
You acknowledge that it is iBASIS’ policy and prerogative to respond to all governmental inquiries regarding its service or its Customers. In the event a competent governmental authority asks iBASIS to retain and provide Personal Information about a Customer, iBASIS reserves the right to provide any and all assistance and information necessary in its opinion to fulfill the request.
We also may be required to 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 be required to disclose Your Personal Information to prospective or actual purchasers and other parties. Any purchaser or successor may continue to use your Personal Information as described in this Privacy Policy.
Retention of Personal Information
Personal Information will be retained as long as necessary for the fulfillment of the purposes identified in this Privacy Policy or as otherwise required or permitted by applicable law.
Accuracy of Personal Information and Customer Rights Related to Personal Information
iBASIS takes reasonable steps to make sure that the Personal Information You provide is accurate, complete and up-to-date for the purposes for which it is collected and processed. Upon written request, You can learn what Personal Information iBASIS holds about You. You will not be charged for requesting such access. However, any information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available to you. You may request rectification of Your Personal Information. If you notify Us that any Personal Information that We have is incorrect, We will review such information. If we agree that the Personal Information is incorrect, we will correct our records. If We do not agree that your Personal Information is incorrect, You may submit a short statement of dispute, which we will include in any future disclosure of disputed information. You may have a right to data portability under applicable law. You may also request erasure of Your Personal Information, object to processing Your Personal Information, or restrict the processing of Your Personal Information. Finally, You also have the right to lodge a complaint with a supervisory authority.
Transfer of Data
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 provide iBASIS’ service. The laws of other countries may not provide the same degree of protection for your Personal Information as Your home country. As a result of such transfers, Your information may be subject to access by law enforcement and government entities in countries other than Your country of residence, including courts and tribunals in accordance with laws applicable in those jurisdictions. By accepting this Privacy Policy, You expressly acknowledge and consent to the transfer of your Personal Information to countries outside your home country, including to the United States. If You do not agree to the transfer of your Personal Information as provided in this Privacy Policy, We may not be able to provide service to You.
Links to Outside Websites
The Website may contain links that will let Customers leave the Website and access other websites. Linked websites are not under Our control. It is possible that these websites have privacy policies and standards that are different than those of iBASIS. This Privacy Policy applies only to Personal Information that is acquired by Us on the Website. iBASIS accepts no responsibility or liability for our Customers’ use of other websites.
Children’s Privacy Protection
Children under 13 years of age are not permitted to be iBASIS Customers. Children under 13 should not send Us any information about themselves. If a child under 13 submits information through any part of Our Website, and We become aware that the person submitting the information is a child, We will attempt to delete this information as soon as possible. Because We do not knowingly collect any Personal Information about children under 13, We do not knowingly use or disclose such information.
Changes to This Privacy POLICY
We reserve the right to change this Privacy Policy at any time. The revised Privacy Policy will be effective immediately upon its posting on the Website with the new effective date displayed. You should periodically check the Website for any such changes. By accepting the terms and conditions of this Privacy Policy, You agree that your continued use of iBASIS’ services after a revised Privacy Policy is posted on the Website constitutes your acceptance of the revised Privacy Policy except as follows. Specifically, if we intend to use Your Personal Information in a manner that is materially different from that described in the Privacy Policy when You subscribed to iBASIS, we will send You a notice in advance of the change by using your provided e-mail address and You will be given a choice as to whether to accept or reject such a change.
Our Data Protection Officer
We have designated one or more individuals who monitor Our compliance with this Privacy Policy. The individual responsible for Our compliance has been designated as iBASIS’ Data Protection Officer and can be reached by sending correspondence to the following address:
iBASIS, Inc.
ATTN: Data Protection Officer
10 Maguire Road, Building 3
Lexington, MA 02421, USA
info@iBASIS.net
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 assist the Data Protection Officer or to perform the Data Protection Officer’s responsibilities.
Questioning iBASIS’ Compliance With This Privacy POLICY
If You believe that We have not complied with the terms and conditions of this Privacy Policy, You may send correspondence to Our Data Protection Officer to the following address:
iBASIS, Inc.
ATTN: Data Protection Officer
10 Maguire Road, Building 3
Lexington, MA 02421, USA
info@iBASIS.net
iBASIS will investigate all such inquiries and will respond as appropriate. We may seek advice from internal and external advisors before responding to Your inquiry. If We determine that a complaint is justified, We will take appropriate remedial measures, in Our sole discretion, including modifying Our policies and practices.
CONTACT US
Questions or correspondence regarding this Privacy Policy should be directed to Us at the following address:
iBASIS, Inc.
ATTN: Data Protection Officer
10 Maguire Road, Building 3
Lexington, MA 02421, USA
Last Updated: September 2011