SpeakSpace LLC Privacy Statement

Effective February 11, 2021

This Privacy Statement applies to SpeakSpace LLC and its affiliates (“SpeakSpace” “we” “us” “our”) unless the affiliate has a separately posted privacy statement. SpeakSpace values the privacy of our customers, users, and any individual who accesses or uses the SpeakSpace websites, products, and services (collectively, the “Services”). Your privacy is an important factor SpeakSpace considers in the development of each of our products and services. This Privacy Statement explains generally how we receive Personal Information about you, and what we do with that Personal Information once we have it.

As SpeakSpace is a global provider, the provision of the Services to users may require Personal Information to be shared with other SpeakSpace companies around the world. All SpeakSpace companies are bound by privacy statements, confidentiality, and data transfer agreements as appropriate.

 

What do we mean by “Personal Information”?

For us, “Personal Information” means information or data that relates to an identified or identifiable individual. “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 certain information related to your account (for example, accounts provided by SpeakSpace IP Communications) may be Customer Proprietary Network Information (“CPNI”). CPNI is information we obtain solely by providing telecommunications services or interconnected Voice over Internet Protocol (VoIP) services 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 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.

 

What type of Personal Information is collected?

We may collect data, including Personal Information, about you as you use our websites, services and interact with us. This information may include name, address, email address, IP address, phone number, login information (username, password), marketing preferences, or payment card number. If we link other data with your Personal Information, we will treat that linked data as Personal Information. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.

Please understand, in addition to collecting Personal Information, SpeakSpace may also gather information that does not personally identify you regarding your use of the SpeakSpace website (“Anonymous Information”). We may use the Anonymous Information we collect regarding your use of this website to measure the effectiveness of our marketing efforts, for improving the Services we offer to you, or to improve the SpeakSpace website. Generally, you will not be aware when we collect such Anonymous Information. 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 SpeakSpace website.

 

How do we receive Personal Information about you?

We learn Personal Information about you when:

Unless we receive your information through your school, if you are under 13, we do not want your Personal Information, and you must not provide it to us. If you are a parent and believe your child who is under 13 has provided us with Personal Information without your express consent, please contact us to have your child’s information removed.

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

 

What do we do with your Personal Information once we have it?

SpeakSpace does NOT sell your personal information.

When you give us Personal Information, we will use it in the ways for which you’ve given us permission, or ways in which our clients who provided us the Personal Information instruct. Generally, we use your Personal Information to help us provide and improve our products and services for you and our clients with which you have a business relationship. We may also use the Personal Information you provide to contact you regarding additional or new services and features offered by SpeakSpace, or important information regarding SpeakSpace.

We may use the Personal Information to enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws and prevent or detect use or abuse of our services.

Important Notice Regarding Unified Communications Services, Webcasting, and Virtual Event Services
SpeakSpace processes Personal Information as part of delivering the above noted services on behalf of its customers.  The customer is the data controller of the information.  For these services, SpeakSpace only collects Personal Information necessary to fulfill our contractual obligations with the customer.  We may collect contact data such as name, e-mail address and company details you provide us during the registration process and during your use of the services.  We may also collect product usage data, such as the date on which you viewed a webcast, the duration of your viewing and the part of the webcast you viewed.

SpeakSpace 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.

If you have provided Personal Information to our customer, their respective privacy statement will also apply to the processing of your data. You should familiarize yourself with their statement.

 

How long will we retain Personal Information?

We will retain your Personal Information only as long as needed to fulfill the purposes for which it was collected or as required by law. Your information will be deleted, anonymized or pseudonymized once it is no longer needed to comply with our business requirements, legal obligations, resolve disputes, protect our assets, or enforce our agreements.

 

When do we share your Personal Information with others?

We will/may share your Personal Information with others:

 

How do we protect your Personal Information?

We are committed to protecting your Personal Information once we have it. We implement industry standard physical, administrative, and technical security measures. If, despite these efforts, we learn of a security breach involving your Personal Information, when required by law or contractual obligations, we will notify you or our client so appropriate protective steps can be taken. SpeakSpace is not responsible for unauthorized access to such Personal Information by hackers or others that obtain access through illegal measures in the absence of negligence on the part of SpeakSpace.

You may have access to other sites through the SpeakSpace websites. These sites may have different security practices and you should familiarize yourself with those practices.

 

How can you protect your Personal Information?

Electronic communication (e.g., email, online chat, or instant messaging, etc.) you send to us may not be secure unless we advise you in advance security measures will be in place prior to you transmitting the information. For this reason, we ask you do not send Personal Information such as financial information, social security numbers or passwords to us through unsecured electronic communication. Users should also take care with how they handle and disclose their Personal Information. Please refer to the Federal Trade Commission’s Web site at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

The SpeakSpace 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 SpeakSpace website are provided solely as a convenience to you. If you use these links, you will leave the SpeakSpace website. SpeakSpace has not reviewed all these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, SpeakSpace 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 SpeakSpace website, you do this entirely at your own risk. Remember, this Privacy Statement only applies to SpeakSpace. When you are no longer on an SpeakSpace website, you may encounter different privacy and security practices and you should familiarize yourself with those practices each time you visit a new website.

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.

 

What about cookies and other tracking technology?

A cookie is a small file, typically of letters and numbers, downloaded onto a device when the user accesses certain websites. Cookies can make the web more useful by storing information about your preferences for a particular website or a service. 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.

SpeakSpace uses cookies or other similar tracking technologies to provide you with better Services.

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 you may browse some SpeakSpace websites without accepting Cookies from SpeakSpace; however, you may not be able to take full advantage of the functionality of the 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?

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

 

Does SpeakSpace use any other tracking technology?

SpeakSpace employs a software technology called transparent images to help us better manage content on our site by informing us what content is effective.  We use extremely small, transparent images with a unique identifier, similar in function to cookies, used to track the online movements of Web users.  The main difference between the two is transparent images are invisible on the page and are very small, about the size of the period at the end of this sentence.  In some instances, transparent images are tied to users’ personally identifiable information.  In particular, we use transparent images in our HTML-based e-mails to let us know which e-mails have been opened by the recipients.  This allows us to gauge the effectiveness of certain communications.  Users may opt out of these e-mails by replying to the unsubscribe link at the end of the e-mail message.

 

How does SpeakSpace ensure compliance with legal obligations?

In connection with the Services, and if applicable, you and SpeakSpace shall at all times ensure compliance with any privacy and data protection laws including those in the United States (including but not limited to the Gramm-Leach-Bliley Financial Services Modernization Act, the Health Insurance Portability and Accountability Act, California Consumer Privacy Act and the Fair Credit Reporting Act), in the United Kingdom (including but not limited to the Data Protection Act), in the European Union (including but not limited to relevant EU member state legislation and the General Data Protection Regulation), in the Asia-Pacific Economic Cooperation (including but not limited to Australia’s Privacy Act along with the Australian Privacy Principles, Singapore’s Personal Data Protection Act, Japan’s Act on the Protection of Personal Information and Hong Kong’s Personal Data (Privacy) Ordinance) and anywhere around the world.

We’re a global organization and our information systems are in several countries around the world. We also use service providers whose information systems may also be in various countries. This means your Personal Information might end up in one of those information systems in another country, and that country may have a different level of data protection regulation than yours. The whole or any part of your Personal Information in connection to the Services may be processed by SpeakSpace, its affiliates and subcontractors in the United States, United Kingdom, the European Union, Philippines, India, Canada, Mexico, and the rest of the world, and may be transferred outside the country in which you provided the Personal Information. By giving us Personal Information, SpeakSpace may conduct such transfers of your Personal Information. SpeakSpace uses Standard Contractual Clauses approved by the European Commission as an international data transfer mechanism.  No matter what country your Personal Information is in, we comply with applicable law and will also abide by the commitments we make in this Privacy Statement.

 

What choices do you have regarding your Personal Information?

We are aware you have several rights in respect to how we process your Personal Information, which include but are not limited to, a right to access your Personal Information, be forgotten, restrict and/or object to processing in some circumstances and request your Personal Information be transferred to you or your nominated third party.

You may choose not to have your information disclosed to a third party (unless SpeakSpace is legally required to share it).  You may also choose to not have your information used for a purpose materially different than the purpose for which it was originally collected or subsequently authorized by you.

We will take reasonable steps to give you the opportunity to correct inaccuracies in the Personal Information we retain concerning you and delete Personal Information concerning you upon your request, unless the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than you would be violated.  We may deny a request to delete your data if we have legal obligations to retain it.  Any such data will be subject to our standard retention guidelines.

You are entitled to know whether we hold personal data about you and, if we do, to have access to that personal data and require it to be corrected if it is inaccurate. In some circumstances, you may have the right to oppose the use or disclosure of your data or have your data deleted. You can do this by contacting us as directed in the “Contact Us” section below.

To correct inaccuracies in your Personal Information, limit purpose of use and disclosure, delete your Personal Information, or for any other requests or questions, please contact us as directed in the “Contact Us” section below. Once we have verified your identity, we will complete the request from you or an authorized agent you have designated.  We will make all efforts to verify your identity using information we already have but may need to request additional data if we are unable to make the verification on this data alone.  If you designate an agent to make requests for you, we reserve the right to ask for proof of the agency.

SpeakSpace will not discriminate against any individual for exercising their privacy rights outlined above. This includes but is not limited to; denying goods or services, change in pricing or lower quality goods or services.

 

What if we change this Privacy Statement?

We may need to change this Statement and our notices. Unless otherwise required, the updates will be posted online. If the changes are substantive, unless otherwise required, we will announce the update through SpeakSpace’s websites. Unless further steps are necessary related to the changes, your continued use of the product or service after the effective date of such changes constitutes your acceptance of such changes. To make your review more convenient, we will post an effective date at the top of the page.

 

How to Contact Us?

If you want to make a correction to your Personal Information, or you have any questions about our privacy statement, please contact the privacy team by emailing privacy@SpeakSpace.com, or by mail, we can be contacted at:

US
General Counsel
SpeakSpace LLC
Legal Department
600 Superior Ave. E, Suite 1300
Cleveland, OH 44114