Privacy Policy

In compliance with the applicable Data Protection regulations and in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter "GDPR") provides you with the information of all relevant aspects of the processing of personal data processed by Ting (hereinafter the "Platform").

1. Who is the data controller?

The entity contracting the services of the Platform as a client of Ting ("the Entity" or "Controller") will be the data controller. The Entity is responsible for collecting the data directly from the data subjects, complying with the obligation to inform and ensuring that there is a lawful basis for the processing carried out on the Platform. Ting will process the data on the Platform in its capacity as the Entity's data processor and will carry out the data processing described in this privacy policy.

2. Source and type of data introduced on the platform?

Personal data is collected:

• 2.1. Through telephone and video calls with the Entity: The Entity provides Ting with recordings of the calls it receives or issues for analysis in the Platform. The identification data of the client and the employee who maintain the conversation will be processed, as well as the data provided during the call.
• 2.2. Through emails and other written communications with the Entity: The Entity provides Ting with emails and other written communications that it receives or issues for analysis in the Platform. The identification data of the client and the employee who maintain the conversation will be processed, as well as the data provided within the written communications.
• 2.3. Through the Entity's customer management system: The Entity may provide access to additional information from the customer's file and the history of the relationship. Customer data collected by the Entity during the relationship with the customer in question will be processed.
• 2.4. Through third parties when there is a legal basis: information may be collected for data enrichment from third parties, such as user data (name, email, location, etc), email data (including content, topics, contacts, etc.) and calendar events (date, attendees, etc.).

3. For what purpose and under what lawful basis is your data processed?

• 3.1. The personal data received by the Entity (recording and additional data) will be subjected to an automated analysis process that incorporates Artificial Intelligence (“AI”) components in order to provide information on the reason for the conversation and to extract insights from such conversation and incorporate the resulting information into the Entity's customer file. Lawful basis: The data processing is carried out on the basis of consent provided by the user to the Entity.
• 3.2. To enhance the existing information through the use of third-party data to provide additional information from users to enable the Entity to make decisions more effectively and efficiently. Lawful basis: The data processing is carried out on the basis of consent provided by the user to the Entity.
• 3.3. Client profiling with the aim of providing more efficient and personalised service management, aiming to reduce expenses and enhance customer experience and satisfaction. Lawful basis: The data processing is carried out on the basis of consent provided by the user to the Entity.
• 3.4. To comply with legal obligations, possible judicial resolutions and other decisions determined by the authorities. Including the communication of personal data to law enforcement agencies, whenever there are suspicions or indications of an action that may constitute a criminal offense. Lawful basis: The processing of personal data for these purposes is carried out based on compliance with legal obligations.

4. How long will we retain your personal data?

Personal data will be processed on the Platform as long as the Entity maintains a contractual relationship with Ting, and then it will be kept for as long as it is necessary to comply with the provisions of the relevant laws and regulations, especially in relation to the statutory limitation periods, and for the formulation, exercise, or the defense of claims that may arise.

5. To whom may your data be disclosed?

Depending on the purposes for which the personal data has been collected, the following third parties may have access to the personal data:

• 5.1. Public administrations when there is a legal obligation.
• 5.2. Agencies and/or competent authorities and the law enforcement agencies, in cases where there is a requirement, a legal obligation or consider that there is sufficient evidence and/or suspicion to be before an illicit or criminal offense. In addition, the following third parties may have access to information collected in accordance with sections 2.1 and 2.2 above:
• 5.3. Collaborators and third-party service providers that process information as data processors. With all such third-party service providers, the corresponding data processing agreement has been signed in accordance with the personal data protection regulations.

6. What are your rights when you provide us with your data?

• 6.1. Right to request access to personal data: you may ask if your data is being processed, and if so, you can request access to it.
• 6.2. The right to request rectification if the data is inaccurate, or to request data to be completed if they are incomplete.
• 6.3. Right to request erasure of your data.
• 6.4. Right to request the limitation of processing: in this case, the information will only be kept for the exercise or defense of claims.
• 6.5. Right to object to the processing: personal data will no longer be processed, unless it must continue to be processed for legitimate reasons or for exercising or defending against possible claims.
• 6.6. Right to data portability: in the event that you want your data to be processed by another data controller, your data will be transferred to the new data controller, provided that it is technically possible.
• 6.7. Right to not be the object of automated decision-making regarding your personal data.

Consent given for any specific purpose may be withdrawn at any time. Please note, that the withdrawal of consent will not affect the lawfulness of the processing based on the consent prior to the withdrawal. To exercise your rights, you should contact the Entity, you may also send an email to Ting who will forward the request received to the Entity. Whenever you consider it appropriate, you may file a complaint before the competent data protection authority.

7. Additional information

Updates: The processing of your personal data will be carried out in accordance with the privacy policy in force at the time your information is collected. If any revision or update is done that affects the processing of your personal data, we will inform you.

Contact us: If at any time you feel that the provisions set forth in this Privacy Policy have not been complied with, you may email Ting or the Entity. If you want to escalate an issue regarding data privacy or have any questions regarding this Privacy Policy you may contact Ting.

International data transfer: your personal information may be transferred to a country outside the European Economic Area (E.E.A.) when the processing is carried out by certain service providers. Such transfers are always carried out ensuring adequate protection of personal data through the use of safeguards permitted by law, such as the use of standard contractual clauses approved by the European Commission.

Note that Ting's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Date of update: 05/05/2024