“Personal Information” or “Information” means information that is (1) accessed, processed or transferred outside the EU as part of the delivery and support of Applicable’s services (this relates to Applicable offices in the United States of America and Australia and datacentre locations in the UK, USA, Singapore and Australia); (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
Applicable is a participant in the U.S. Department of Commerce's EU-U.S. Privacy Shield and has certified that we adhere to the EU-US. Privacy Shield Principles. Applicable is subject to the investigatory and enforcement powers of the Federal Trade Commission.
For more information about the EU-US Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield website
Personal Data Collected
During its activities and delivery of Unified Communication business solutions Applicable may gather the following information: name of caller and callee, email address, IP address, location, connections, durations, quality of interface, conversation history (if configured), call recording (where contracted). All of this information is necessary for the service delivery as well as to maintain and improve the service offering.
Adherence to European Union Privacy Principles
Applicable has installed policies and procedures to ensure that it adheres to the European Union Privacy Principle as part of its broader information security management system. This includes provision to involve an independent third party to resolve privacy disputes when necessary.
Disclosure to Law Enforcement
Applicable may disclose Personal Data, with or without notice (a) if required by a judicial or administrative order, (b) where required by law, or (c) at our sole discretion, where we deem it necessary to protect the safety of any individual, the general public, or to prevent violation of the rights of Applicable or any third party.
Change of Ownership
In the event of change in ownership, or a direct merger or acquisition with another entity, we reserve the right to transfer all of Applicable information, including Personal Data, to a separate entity. Applicable would use commercially reasonable efforts to notify of any change of ownership; merger or acquisition by a third party. Modifications required would be addressed at that time.
When supplied with information by its clients or gathering information internally agree and conform the purpose for which that personal information was collected; how it may be accessed or processed; and agree the Applicable locations where this may be stored or accessed from.
- Applicable are not supplied or do not intentionally collect information from under 13s.
- Applicable does not take or process online payments
- Applicable does not sell or rent any personally identifiable information to third parties.
- Applicable retains information only in line with data protection and legal retention guidelines and defined within the Applicable Retention Policy.
Applicable will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a non-agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Onward Transfers to Agents
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Applicable Limited remains liable. Sharing of data only occurs where it is necessary for the purposes of delivering, analysing and improving the service. Applicable will obtain assurances and monitor its agents that they will safeguard personal information consistent with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating at least the same level of protection as is required by the relevant Privacy Shield Principles, being subject to EU Directive 95/46/EC (the Data Protection Directive), Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding. Where Applicable has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Applicable will take reasonable steps to prevent or stop the use or disclosure.
Applicable shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Applicable has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction verified under its ISO27001:2013 registration. Applicable cannot guarantee the security of Information on or transmitted via the unsecured Internet.
Applicable shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. To the extent necessary for those purposes, Applicable shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
Upon request, Applicable will grant individuals reasonable access to personal information that it holds about them. In addition, Applicable will take reasonable steps to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Any questions or concerns regarding the use or disclosure of personal information should be directed to Applicable at the address given below. Applicable will investigate and attempt to resolve complaints and disputes regarding use and disclosure or personal information in accordance with the principles contained in this Policy. Applicable has further committed to refer unresolved privacy complaints under the US-EU Privacy Shield Principles to an independent dispute resolution mechanism when necessary. Applicable uses Privacy Trust Visit www.privacytrust.com/drs/applicable to file a complaint.
Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
Information Subject to Other Policies
Questions, comments, or complaints regarding the Company’s Privacy Shield Policy or data collection and processing practices can be mailed or emailed to:
3130 Great Western Court