Privacy Statement

BroadData (hereafter referred to as “BroadData” or “We”) is a leading provider of conferencing services and unified communications services. We value the privacy of our customers, users, and any individual who accesses or uses the BroadData websites, products, and services (collectively, the “Services”). This Statement discloses BroadData’s practices with respect to the collection, processing, use and disclosure of user information. This Privacy Statement applies to all Personal Information and Sensitive Personal Information collected and processed by BroadData whether in electronic, paper or verbal format. As BroadData is a global provider, the provision of the Services to users may also require Personal Information to be shared with other BroadData group companies around the world. All such BroadData group companies are bound by privacy policies, confidentiality and data transfer agreements as appropriate.

Collection and Use of Personal Information and Customer Proprietary Network Information

In this Privacy Statement, “Personal Information” is any information or data that can be reasonably linked to a data subject, or to a specific computer or other device. “Sensitive Personal Information” is a subset of Personal Information and is data about children, financial information, health information (including PHI as defined by the Health Insurance Portability and Accountability Act), Social Security or other national identification number, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life, criminal convictions, and precise geolocation data.

We also want you to be aware that certain information related to your account with BroadData may be Customer Proprietary Network Information (“CPNI”). CPNI is information that we obtain solely by providing teleconferencing to you.  It includes the type, technical arrangement, quantity, destination, location, and amount of services you purchased and related billing information.  CPNI does not include your telephone number, name and address, or aggregate customer information or data that is not specific to you.  The protection of your information is important to us, and you have a right, and we have a duty, under U.S federal law, to protect the confidentiality of your CPNI.  We may use or disclose CPNI without your consent to (a) initiate, render, repair, maintain, bill, troubleshoot, and collect for our services, (b) protect our rights and property or to protect our subscribers or other carriers from the unlawful or fraudulent use of our services, (c) provide call location information required in connection with emergency services, (d) market services formerly known as adjunct-to-basic services, (e) market our services within the categories of services to which you already subscribe, and (f) respond to a valid request from law enforcement, a court order, or other appropriate authority.  Absent your consent, we will not access, use or disclose your CPNI to market categories of telecommunications or VoIP products and services that you do not already subscribe to or share your CPNI with unrelated third parties for their own use.

By providing your Personal Information, you opt-in and consent to its collection, use, disclosure, sharing, and transfer as described in this Privacy Statement.

In connection with the access and use of the Services, you may choose to provide us with your Personal Information when, among other things, you register on the BroadData website, use one of our Services, fill out a survey, register to attend a seminar; make a request for information, ask to be included in an email or other mailing list; or enter a sweepstakes or contest through the BroadData website or more generally when you submit your Personal Information to BroadData for any other reason. We may also capture your telephone number when you use our Services.

Please be aware any information you choose to share on any publicly available portion of the Services or with third parties, including without limitation your personal page, chat messages, forum posts, blogs, resumes, job applications, business cards, or any other information you provide may be collected and used by third parties or other attendees without restriction.

BroadData Primary and Secondary Use

BroadData will use the Personal Information you provide us in these circumstances to the extent required for the delivery of the Services (such as account set up, billing, debt-collection, customer services, reporting), to satisfy BroadData’s legitimate business interests (such as customer analysis, fraud-prevention and internal marketing study and analysis) and to provide information you request from us (“Primary Use”).

BroadData may provide your Personal Information to business partners or third party suppliers that assist BroadData in processing such Personal Information for Primary Use (such as partners or agents who are involved in delivering the Services you have ordered or used, credit-reference agencies, fraud-prevention agencies, business-scoring agencies or other credit-scoring agencies, debt-collection agencies or other debt-recovery organizations). Unless you instruct us not to do so, and unless prohibited by law, BroadData (either directly or using an affiliate or using business partners or third parties used by BroadData) may also use the Personal Information you provide us to contact you regarding additional or new services and features offered by BroadData or its affiliates, special offers by BroadData or its affiliates, or important information regarding BroadData or its affiliates (“BroadData Secondary Use”).

BroadData requires any such affiliate companies, business partners or third parties used to assist BroadData for Primary Use or BroadData Secondary Use to enter into agreements with BroadData including contract terms substantially the same as those contained in this Privacy Statement, prohibiting disclosure of the Personal Information to others and restricting its use in providing the contracted Services of BroadData.

Third Party Services

BroadData may also provide your Personal Information to business partners in case you purchase services of third parties from BroadData (“Third Party Services”). Third Party Services are not directly controlled operated or maintained by BroadData and BroadData’s Privacy Statement does not apply to such Third Party Services. Any use of Third Party Services is subject to the privacy statement of the Third Party Services providers. For any Third Party Services you purchase from BroadData, we recommend you consult the respective privacy policies of the Third Party Services providers to determine how they will handle your Personal Information.

Third Party Secondary Use

BroadData may also provide your Personal Information to other companies who may contact you regarding products, services, and offers that may be of interest to you, but that are not directly related to the Services or the BroadData website (“Third Party Secondary Use”). Third Party Secondary Use is subject to the privacy statement of such other companies.

Other Legitimate Use

BroadData may also use your Personal Information to create anonymous data records or aggregations of data, to perform statistical analyses and for other purposes, by omitting or removing information that makes the data personally identifiable to you.

BroadData may release your Personal Information if required to do so by law or if it is reasonable for the purpose of protecting us against fraud, defending our rights or property, to enforce our terms of use or to protect the interests of our customers.

BroadData will keep your Personal Information for as long as we have to by law. If there is no legal requirement, BroadData will keep your Personal Information no longer than strictly required for legitimate purpose for which it was collected.

Any Sensitive Personal Information you provide us will only be used to implement the specific activity or event it was submitted for and will then be destroyed.

You may stop delivery of informational or promotional mail from us by following the instructions included in the informational or promotional mail itself.

Security

BroadData shall take reasonable steps to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Personal Information we collect from you is stored in operating environments that employ reasonable security measures and that are not available to the general public. BroadData is not responsible for unauthorized access to such Personal Information by hackers or others who obtain access through illegal measures, in the absence of negligence on the part of BroadData. Further, some other websites you may access through the BroadData website may have different security practices and you should familiarize yourself with those practices. BroadData cannot guarantee the security of Information transmitted via the Internet. You are responsible for the confidentiality and security of passwords BroadData issues to you. If you believe a third party has obtained your password in an unauthorized manner, please notify BroadData promptly.

Data Integrity

BroadData shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, BroadData shall take reasonable steps to ensure the Personal Information is accurate, complete, current and reliable for its intended use.

Enforcement/Complaints

BroadData uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies the statement is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with its principles. If at any time you believe we have acted contrary to this Privacy Statement, please contact us as directed on the “Contact Us” page on our website and we will take steps to investigate and will use reasonable measures to solve the problem.

Disclosure for Legal Purposes

We may disclose Personal Information if required to do so by law or in the good-faith belief such action is necessary: (a) to conform to the edicts of the law or comply with legal process served on us or our affiliates; (b) to protect and defend our rights or property or those of our customers and their users; (c) to protect the personal safety of our customers and their users or the public; or (d) in connection with a merger, consolidation or sale of substantial assets of BroadData. As we continue to develop our business, we might buy or sell assets related to our business. In such transactions Personal Information generally is one of the transferred business assets. Also, in the event BroadData or substantially all of its assets are acquired, Personal Information will be one of the transferred assets.

Anonymous Information

Please understand, in addition to collecting Personal Information, BroadData may also gather information that does not personally identify you regarding your use of the BroadData website (“Anonymous Information”). The Anonymous Information we collect regarding your use of this website may be used by us to measure the effectiveness of our marketing efforts, for improving the Services we offer to you, or to improve the BroadData website. Generally, you will not be aware when such Anonymous Information is being collected about you. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access the BroadData website.

Cookies

A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognize a user’s device. BroadData uses cookies or other similar tracking technologies (“Cookies”) to provide you with better Services. Cookies are pieces of information a website transfers to your computer’s hard disk for recordkeeping purposes. Cookies can make the web more useful by storing information about your preferences for a particular website or a service.

The use of Cookies is an industry standard, and many major websites use them to provide useful features for their customers. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer.

Cookies are typically classified as either session Cookies or persistent Cookies depending on whether they expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.

Session and Persistent Cookies

Session Cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session Cookies expire after a browser session, so would not be stored longer term. For this reason, session Cookies may sometimes be considered less privacy intrusive than persistent Cookies. Persistent Cookies – are stored on a users’ device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent Cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising.

Accepting Cookies from BroadData

Most browsers are initially set to accept Cookies. You may configure your browser to accept all Cookies, reject all Cookies, or notify you when a cookie is set. You can manage your own Cookies preferences by using your browser settings: each browser is different, so check the “Help” menu of your browser to learn how to change your Cookie preferences or delete them. If you prefer, you can set your browser to refuse Cookies. You block Cookies by activating the setting on your browser which allows you to refuse the setting of all or some Cookies.

Please note that you may browse some BroadData websites without accepting Cookies from BroadData; however, you may not be able to take full advantage of the functionality of the BroadData website or the Services if you do so. Other Services, particularly those which require a login and password, require Cookies and cannot be used when you have disabled Cookies in your browser. For more general information you can visit www.allaboutcookies.org.

How do you handle my “Do Not Track” browser settings?

BroadData does not track the non-BroadData website activity of any internet user with Do Not Track browser settings engaged.

Important Notice regarding certain Services

Some Services of BroadData, including in particular virtual event Services allow certain third party organizers and contributors to host virtual events (each, a “Sponsor”). BroadData collects the information described below on behalf of such Sponsors. You should consult the privacy policies of each relevant Sponsor to determine how they may handle your Personal Information.

For virtual event Services, depending on the type of event, some of the following fields may be displayed throughout the event: first and last name, company, user ID, and user avatar/image. The Sponsor may enable attendees to search for and find other attendees based on a user’s registration information. If you associate your actual name or other personally identifiable information with your user ID, the people to whom you have revealed such information will be able to personally identify your activities on the event. In addition, any Personal Information you choose to share on any publicly available portion of a virtual event may be collected and used by others without restriction. Resumes or curriculum vitae that you have posted to or within a virtual event may be available to all Sponsors of any booth, even if you have not filed a job application with such Sponsor. You should consult the respective privacy policies of these Sponsors to determine how they will handle your Personal Information. This Privacy Statement does not apply to such Sponsors or their use of your Personal Information. BroadData does not control Sponsors’ use of your Personal Information.

Venturing off the website

The website may contain hyperlinks that can take you to websites run by third parties (“Third-Party Websites”). Any hypertext or other links to Third-Party Websites from the website are provided solely as a convenience to you. If you use these links, you will leave the website. BroadData has not reviewed all of these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, BroadData does not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Websites linked to the website, you do this entirely at your own risk.

Remember, this Privacy Statement only applies to BroadData. When you are no longer on a BroadData website, you may encounter different privacy and security practices and you should familiarize yourself with those practices each time you visit a new website.

Modifications

BroadData reserves the right to modify this Privacy Statement at any time. Please therefore read through this Privacy Statement. Your continued use of the website and the Services signifies your assent to such modifications.