(Date: March 2015)
- PERSONAL INFORMATION SUBMITTED TO OR COLLECTED BY OUR WEBSITE
- PERSONAL INFORMATION SUBMITTED TO OUR SYSTEMS.
Introduction: Clickatell is committed to business practices in compliance with industry acceptable privacy standards and in compliance with the law. This policy sets out what the categories of personal information we may collect from you or other sources when you make use of our website and how we process that personal information.
If you have any questions about this policy or do not agree with it, please contact us directly at email@example.com for attention: Clickatell Privacy Officer.
Personal information: Personal Information will include information defined by the applicable legislation to be “personal information”. This is information which you provide to us which personally identifies you or another person, such as name, email address, ID number or company registration number, billing information, or other data which we can reasonably link to such personal information.
Collection and use of personal information: We collect personal information about you when you provide information through the website or our systems. We may also collect information about you from other third parties related to our operations or within our business structure. The information we collect is limited to the details we need to provide the specific service that you have requested.
We will only collect personal information for a specified purpose and collect and process personal information only for the purpose for which you give it to us. We do not collect or compile personal information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.
It is Clickatell’s policy to limit the information collected to collect only the minimum information required considering the purpose for which the information was collected. In any instance where non-mandatory information is sought, you will be notified of this at the point of collection. Clickatell makes every practical effort to avoid excessive or irrelevant collection of information. If you believe that our website has collected excessive information, we encourage you to contact our Privacy Officer at firstname.lastname@example.org to raise any concerns.
Unless the law requires otherwise, we only use the personal information you provide to us to deliver the specific information or service you have requested. Without your express consent, we will not use your contact details for any other purpose, except to
- perform our duties in terms of our agreement with you;
- carry out, monitor and analyse our business;
- contact you by email, SMS, letter, telephone or in any other way about our products and services if you request us to do so, unless you tell us that you prefer not to receive communications;
- develop or improve products or services that may be of interest to you;
- carry out market research, business and statistical analysis;
- carry out audits;
- perform other administrative and operational purposes including the testing of systems;
- comply with our regulatory or other obligations;
- carry out any other reasonable business operation considering our business and the relationship between you and us.
We will keep your personal information confidential and only share it with others for the purposes set out in this policy, or otherwise if you have consented thereto, or if we are legally obliged or entitled to do so. We have trusted relationships with carefully selected third parties who perform services on our behalf.
We may share information about you with (i) any payment system we may use; (ii) other divisions or companies within the group of companies; (iii) other companies that provide products or services to us; (iv) regulatory and governmental authorities, ombudsmen, or other authorities, including tax authorities, where we are requested by them to do so; (v) any other third party if allowed to do so in law.
When we employ another company to perform a function on our behalf, we only provide them with the information that they need to perform their specific function. To the extent that that third party requires your information to enable Clickatell to provide you with our services, or perform business-related functions on our behalf, you hereby consent to Clickatell sharing your personal information with such third parties.
Sensitive personal information and children’s information: Clickatell’s intention is not to seek any sensitive information through our website unless legally required or for recruiting purposes. Sensitive information includes information relating to (i) race or ethnic origin; (ii) political opinions; religious or other similar beliefs; (iii) trade union membership; (iv) physical or mental health; sexual life or criminal records. We request that you do not provide sensitive information of this nature. If you do wish to provide sensitive information for any reason, you explicitly consent to our use of that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.
We understand the importance of protecting children’s privacy especially in an online environment. Our website is not intentionally designed for or directed at children. It is Clickatell’s policy never to knowingly collect or maintain information about anyone under the age of 18.
Trans-border transmission: Personal information collected or processed by Clickatell may be shared between companies within the Clickatell Group or be processed by third party service providers where it is necessary to meet the purpose for which you have submitted the information. For these purposes personal information may be processed cross-border and by submitting personal information on Clickatell’s website or to our systems, you explicitly consent to trans-border transmission of the information.
Retention: Some of the information we receive is not retained. Generally information will be retained in terms of our internal retention policies. By way of example, contact information about visitors to our website (such as information generated though registration for access to areas on the site) will be retained as long as the information is required to completely service the contact request or until a user requests that we delete that information. Mailing list information, discussion posts and email are kept for the period of time considered reasonable to facilitate the visitor’s requests. Resumes are disposed of when they are either no longer under consideration, or are considered outdated by our Human Resources departments.
Security: We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration or destruction. We make use of electronic and computer safeguards such as firewalls. We have physical and electronic access control to our buildings.
All Clickatell employees follow a network-wide security policy in terms whereof we only authorise access. Only authorised Clickatell personnel are provided access to personal information and these employees have agreed contractually to ensure confidentiality of this information. Clickatell’s policy is to use secure socket layer technology for our customer’s administration area in order to protect information submitted through web forms.
We are committed to ensure your personal information is kept secure and confidential and not kept for longer than is necessary for the purpose for which we collected it.
Right to request access and changes to personal information: If any of your personal information changes, you must let us know immediately by updating your Clickatell account or contacting our Support team at email@example.com.
Subject to applicable law, you have the right of access to personal information you have submitted to Clickatell. Clickatell is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, Clickatell will delete identifying information from current operational systems. If you want us to remove or update any of your personal information, please contact our Support team at firstname.lastname@example.org.
Clickatell does not assume responsibility for verifying the ongoing accuracy of personal information. When practically possible, if we are informed that any personal information submitted to our website or systems and stored by us is no longer accurate, Clickatell will make appropriate changes. However, Clickatell will not be liable for any damage that you may suffer from any cause what so ever due to inaccurate information being provided to Clickatell or a failure to update information.
2. PERSONAL INFORMATION SUBMITTED TO OR COLLECTED BY OUR WEBSITE
Your personal information. Examples of when you may choose to provide personal information include if you want to:
- download publications
- register for Clickatell’s online products and/or services
- submit resumes or work history information
- participate in “join our mailing list” initiatives
- participate in bulletin boards, discussion or message forums
- contact us for further information
- enter Quick Surveys, Quiz’s or Benchmarking Surveys
- register for events and conferences
Purpose of Collection: Typically, we may collect your personal information in order to:
- register you for certain services
- improve our marketing and promotional efforts, by enabling statistical analysis of site and product usage
- deliver information to you, such as administrative notices and news
- deliver account balance updates
- answer your requests and queries
- consider job applications
- fulfil any of our obligations in terms of the agreement with you or in terms of applicable law
Examples of further instances in which we may collect your personal information include:
- Publication downloads. Most publications are provided as downloads and you will be requested to provide us with some personal information before downloading such publications.
- Purchases. When you make a purchase online we will collect order information in order to facilitate delivery and payment for the product and/or services. Your credit card information will only be collected and stored by our third party payment gateway service provider who is fully PCI compliant, and not by Clickatell. Our third party payment gateway services provider may collect IP address, browser version and other information about the software and hardware resident on the computer you use to make the purchase. This information is collected and used solely for purposes of authentication and security. By making a purchase on our website you authorize such collection and use.
- Contacting us. You are also able to send emails or requests through the website. Your messages will contain your screen name and email address, as well as any additional information you may wish to include in the message. Because we use the website as a tool to provide customer service and product support, a visit to the website may also result in your personal information being sent to an individual within Clickatell.
Use of information: Personal information obtained through our website will be used for the intended purpose stated at the time that the information is collected or for purposes as set out in this policy.
Marketing: Except for the mailing list initiative described above, where you explicitly choose to receive specific Clickatell marketing or other materials, Clickatell will not use personal information collected from our websites to facilitate unsolicited marketing activities. You may at any time log into your Clickatell account to enable or disable the marketing newsletter or weekly account balance update newsletter feature in your account preferences. You may also select to unsubscribe from any email newsletter or SMS notification by following the unsubscribe and opt-out directions in the body of such email or SMS. Clickatell will not sell your personal information obtained through the website.
Log files: In order to properly manage our website we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.
Display advertising: We use third-party advertising technology to serve ads when you visit our website and sites upon which we advertise. This technology uses information about your visits to our website and the sites upon which we advertise, to serve our ads to you. In the course of serving our advertisements to you, unique third-party cookies may be placed or recognized on your browser. In addition, we may use web beacons, provided by our third-party ad server, to help manage and optimize our online advertising. These web beacons enable our ad server, on our behalf or on behalf of our agent, to recognize a browser’s cookie when a browser visits this site, and to learn which banner ads bring users to our website. Our third-party ad server is performing its functions on our behalf or on behalf of our agent, and we may, directly or indirectly, instruct such ad server to enable other service providers to receive information about our site related to our online advertising.
Email advertising: We share web site usage information about visitors to our web site, who have consented to and received a targeted promotional campaign, with a reputable third-party advertising company for the purpose of targeted future campaigns and upgrading visitor information used in reporting statistics. For this purpose, we and our third-party advertising company note some of the pages you visit on our web site through the use of pixel tags (also called clear gifs).
Login: As a policy, visitors are not required to register to gain access to areas of the Clickatell’s websites. In certain cases in the future, as your Clickatell website experience expands, we may require visitors to register in order to obtain a user-id and password for authentication and secure access to a transaction or certain business confidential or proprietary information services on premium websites.
Unsubscribe: You voluntarily provide us with personal information. Should you subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate website area or in communications to you; or you may contact Clickatell Support at email@example.com.
3. PERSONAL INFORMATION SUBMITTED TO OUR SYSTEMS.
Processing and Storing of Content: Electronic communications or transactions submitted to our systems for processing or transmission may contain personal information about you or another person. We will only process such personal information for the purpose of effectively providing the relevant service to you. Content of your electronic communications or transactions may be stored on our live systems or in our data archives for operational purposes such as reporting and trouble shooting. We delete message content completely from our systems and data archives when it is no longer required for operational purposes and in terms of our internal company policies. By submitting electronic communications or transactions containing personal information of other persons to us for transmission, you confirm that you have obtained the explicit consent of each such other person for Clickatell to process and store their personal information. We do not accept any liability resulting from our processing or storage of personal information you submit to our systems for which you do not have the necessary consent.
Processing and storage of numbers
- the subscriber from whose mobile number a transaction is initiated; and
- mobile numbers to which direct prepaid airtime is loaded via our systems.
By submitting electronic communications to us for transmission to recipients, you confirm that you have obtained the explicit consent of each recipient for Clickatell to process and store their mobile numbers. By submitting transactions to our systems for processing or allowing others to do so, you confirm that the following persons have given their express consent for Clickatell to process and store their mobile numbers:
- the subscriber from whose mobile number a transaction is initiated; and
- in the event of direct prepaid airtime top-up, the subscriber whose mobile number is topped up as a result of a transaction done via our systems.
We do not accept any liability resulting from our processing or storage, during the provision of our services to you, of subscribers’ mobile numbers.
Processing and storage of personal information by Clickatell’s suppliers: When you submit electronic communications or transactions to our systems, we transmit these communications to our service providers, including mobile networks and aggregators. Our service providers may in turn transmit this data to their upstream service providers in the transmission chain. We have no control over how our service providers or other third parties collect, process or store mobile numbers to/from which electronic communications are sent/received or personal information contained in any electronic communications or transactions. We do not accept any liability resulting from the unlawful collection, processing or storage of personal information by our suppliers or any other third party.