I. INTRODUCTION
ReddyFreddy LLC, Ready Freddy VoIP, and RF VoIP (collectively, the “RF Group”) take your privacy very seriously and act in accordance with the applicable data protection legislation.
II. PRIVACY SHIELD
PARTICULARLY IMPORTANT INFORMATION
WHO WE ARE:
For the purpose of applicable data protection legislation, the data controller of your personal data is the RF Group company that is providing the individual website or other services. All members of the RF Group may be contacted at the following address: Ready Freddy VoIP with its main address at 4255 Business Center Drive, Fremont, California 94538.
MUST READ SECTIONS: We draw your attention in particular to the sections entitled “International Data Transfers” and “Your Rights.”
This section pertains to the processing of your personal data by the RF Group under the Privacy Shield and describes which personal data is collected and for which purposes this personal data is processed by the RF Group. It also states which rights you have under applicable data protection legislation. When you visit our websites (or subdomains), contact us, register with an account on any of our websites such as but not limited to fax.rfvoip.com or *.rfvoip.com (individually, a “Website” or collectively, the “Websites”) or purchase products from us, we collect information from and about you. Some of the information we collect may be classified as personal data under data protection legislation, that is, “any information relating to an identified or identifiable natural person”. It may be collected any time you submit it to us, whatever the reason may be.
COLLECTING YOUR PERSONAL DATA
Information you give to us
This includes personal data collected:
Through our Website or online purchasing process when you register, login, commence or complete an online transaction to use our products and services, you have provided your consent, in order to:
When we do business with you, which will usually include:
Full or partial contact details including names and addresses (including business details), telephone and email details based on the information you have provided to us with our account signup and management process. We collect payment card and/or bank information from you should you choose to use this form of payment for purchasing or guaranteeing use of our products and services.
Information Automatically Collected
This includes information and personal data collected:
Through our Websites, we automatically log information about you and your computer or mobile device upon access. The information about your use of our Websites comprises http header information which your browser transmits to our web server and information collected through the use of cookies and log information. For example, when visiting our Websites, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Websites, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Websites.
Use of Cookies
Some of our web pages use “cookies” or other information collection devices so that we can better serve you with more tailored information when you return to our Website. Cookies are identifiers which a website sends to your browser to keep on your computer to facilitate your next visit to our site. We may track and record your use of our online services, either through cookies or via other means. Cookies enable us and others to monitor your browsing behavior. Information generated by the use of cookies may constitute personal data. We may use the personal data collected in this manner for the purposes as stipulated in this Privacy Statement. If you are subscribed to our email list, we also use this information to deliver more relevant content to your inbox. At any time, you can elect to opt out from the use of tracking cookies by clicking Cookie settings. This will automatically disable tracking cookies and will redirect you back to the page you were originally on. We do not otherwise respond to Do Not Track signals.
IP Addresses/Web Server Log Files
We may use IP addresses and web server log files to analyze trends, administer a Website, track a user’s movement, and gather broad demographic information for aggregate use. Additionally, in areas of a Website requiring registration, we may use this information from time to time to police a Website for unregistered users (but we undertake no obligation to do so). Information of this type may be combined with cookies or other sources of information for these purposes. Specifically, through the use of web server log files, any or all of the following information may be accessed, collected, analyzed, and stored during or after your visits to the Website: the name of the domain name from which you access the Internet; the country from which you access the Website; the date and time you access the Website; the pages you visit on the Website and the sequence in which you visit them; the amount of time you spent on a particular Website page; the Internet address of a website that you visit immediately before or after visiting our Website; the Internet address from which you linked directly to our Website, if any; the type of operating system on your computer; the type of browser that you are using to view a Website. These and similar types of information may also be collected by “web-bugs” or single-pixel gifs and by other means. We use social buttons (such as Facebook, LinkedIn, and Twitter) to enable sharing of material originating from our Websites. The third party social sites used to share information use scripts and these scripts may be gathering your information.
WHY DO WE PROCESS YOUR PERSONAL DATA?
Your personal data will be stored in centralized systems which are under the control of the RF Group and accessible by authorized staff of the RF Group or it’s reseller/channel partners, as applicable.
We use the information we collect about you to process your purchase orders, answer your queries, provide services to you and enable you to manage your accounts with us. With your consent, we will contact you via our marketing and sales channels (email/ phone/ post) about other related products and services we, or our group business, provide which we think may be of interest to you. Our marketing communications are generally sent by email, but we may sometimes use other methods of delivery such as by mail or SMS.
We mainly collect, store and process personal data at two different stages: (i) before you decide to register an account on our Websites and (ii) when you have registered an account on our Websites.
(i) Before you register an account on our Websites
When you visit our Websites, we collect information about your use of our Websites. This includes both information we collect directly from you, and information we collect about your behavior. This information may constitute ‘personal data’ under applicable law. We use this information to provide you with (personal) offers, both on our Websites and via advertisements on other websites you visit.
Advertising
Generally. We may use other companies to serve third-party advertisements when you visit and use our Websites. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to our Websites and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
Targeted Advertising. We use Website information to provide you with (personal) offers, both on our Websites and via advertisements on other websites you visit. In order to serve offers and advertisements that may interest you, we may display targeted advertisements on our Websites, or other digital properties or applications in conjunction with our content based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide personal data to advertisers when you interact with an advertisement.
ii. After you have registered an account on our Websites
When you register on our Websites, you may be required to provide us with your name, email address, phone number, mailing address, credit card or other payment information as applicable. We use this personal data to process your purchase orders, for billing purposes, and to allow us to communicate with you about your purchase orders.
Overview of activities under stage (i) and (ii):
We may at each of the stages outlined above use your personal data but only when and to the extent 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 or regulatory obligation.
Where you have provided your consent.
SHARING YOUR DATA
We may share your personal data as follows:
We do not share your data with any third parties outside of the above processing arrangements and we do not share your data with any business external to our group for their own marketing purposes. From the data we collect, you should only ever receive marketing communications from our own brands.
INTERNATIONAL DATA TRANSFERS
It is necessary to transfer your personal data overseas as most of our centralized data processing is in the United States of America. Any transfers will be made in full compliance with all aspects of the applicable regulations.
When we transfer the data to a country outside of the EEA that does not offer an adequate level of data protection, we will ensure compliance with applicable law.
The RF Group complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. ReddyFreddy LLC has certified to the Department of Commerce that it and the other members of the RF Group adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. RF Group will be subject to the investigatory powers of the Federal Trade Commission (FTC) as a result of its participation in and certification of its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework and under certain circumstances, you may invoke binding arbitration.
In addition to EU-US Privacy Shield-certification, we also rely on model EU privacy clauses and other legally accepted safeguards, as applicable.
YOUR RIGHTS
We provide the following rights to all individuals: i.
For the sake of clarity: without prejudice to the foregoing we are at all times entitled to send you messages that do not constitute direct marketing, i.e. service messages as it relates to your business relationship with the RF Group.
General information relevant for all requests and queries
Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under applicable mandatory data protection law.
We will use reasonable endeavors to respond to your request or query within one month. We are entitled to extend this term by another two months if the complexity of the situation so requires. If your request is manifestly unfounded or excessive, we may either (i) charge you a fee, or (ii) refuse to process your request. With respect to access requests we may also charge you for extra copies. If we decide not to honor your request or answer your query, we will explain our reasons for doing so in our reply.
PROTECTION AND STORAGE OF YOUR DATA
We have used and will continue to use reasonable endeavors to protect your personal data against loss, alteration or any form of unlawful use. Where possible, your personal data will be encrypted and stored by means of state of the art protection measures. A strictly limited amount of people have access to your personal data.
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.
Our Websites take precautions to protect our users’ information. We use standard industry mechanisms to protect customer data from unauthorized access, for example, by using password protection and standard encryption methods. Transactions, access to transactional records, or access to account information occurs over a server that has safeguards such as secure server software (SSL) which encrypts information before transmission. You can confirm that pages are encrypted, and we urge you to do so before submitting or transmitting sensitive information, by viewing the lock icon on the bottom of most browsers. We also take measures off-line to protect your information that is known to us to be financial and business sensitive information to the same extent that we take measures to protect our own such information.
You may edit your account information and account profile at any time using your email address and password. Do not divulge your password to anyone. We will never ask you for your password in an unsolicited telephone call or in an unsolicited e-mail. Remember to sign out of your account and close your browser window when you have finished your work. This may help to protect against access by others to your personal and business information if you share a computer or are using a computer in a public place.
RETENTION OF INFORMATION
We will only retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Statement and your continued business relationship with RF Group or to the extent permitted by law. Should you choose to unsubscribe from our mailing list, please note that your personal data may still be retained on our database to the extent permitted by law.
III. CUSTOMER PROPRIETARY NETWORK INFORMATION (CPNI)
As an interconnected VoIP Provider ReddyFreddy LLC and its wholly owned subsidiaries have access to a highly regulated form of customer personal information known as Customer Proprietary Network Information (CPNI) and shares this access with its wholly owned subsidiaries. Please see https://rfvoip.com/cpni/ for the RF Customer CPNI Policy.
IV. GENERAL
Contact Information for GDPR questions or concerns
If you have a question or a complaint about this privacy policy as pertains to personal data under the GDPR or the way your personal data is processed by Digium Inc. under the GDPR please contact us via email privacy@rfvoip.com
Contact Information for all other privacy questions or concerns
In case you have any questions in relation to this Privacy Statement or our practices in relation to your personal data, CPNI, or other confidential information you may open a Customer Service request at https://rfvoip.freshdesk.com/support/login. We hope to resolve any complaint brought to our attention, however if you feel that a complaint with regard to personal data has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.