(Date: January 2013)
Personal information. This is information which you provide to us which personally identifies you or another person, such as name, email address or billing information, or other data which we can reasonably link to such personal information.
Trans-border transmission. When you visit our website or use our services, you may submit personal information to us. Personal information collected or processed by Clickatell may be transferred between companies within the Clickatell Group where it is necessary to meet the purpose for which you have submitted the information. By submitting personal information on Clickatell’s website or to our systems, you explicitly consent to trans-border transmission of the information.
Consent. We only collect or process personally identifiable information if it is specifically and voluntarily provided by you. If you provide us with personal information about another person, you warrant that you have that person’s consent to do so and that that person has given explicit consent for Clickatell to collect or process their personal information for the purpose for which you submitted it to us.
- PERSONAL INFORMATION SUBMITTED TO OR COLLECTED BY OUR WEBSITE
- PERSONAL INFORMATION SUBMITTED TO OUR SYSTEMS.
1. 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
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
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.
Sensitive personal information. Clickatell’s intention is not to seek any sensitive information through our website unless legally required for recruiting purposes. Sensitive information includes a number of types of information relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. We suggest 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.
Unnecessary collection. It is Clickatell’s policy to limit the information collected to only the minimum information required to complete a visitor’s request. In any instance where non-mandatory information is sought, the website visitor 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 email@example.com to raise any concerns.
Use of information. Personal information attained by our website is used only for the intended purpose stated at the time that the information is collected. This information is not shared with other companies in the group for secondary or unrelated purposes, or shared with a third party, unless otherwise disclosed at the point of collection or in this policy. If there is an instance where such information may be shared for other purposes, you will be asked for permission beforehand.
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.
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 targeting 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).
Information retention. Some of the information we receive is not retained. Contact information about visitors to our website (such as information generated though registration for access to areas on the site) will be kept 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 only 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 dated by our Human Resources departments.
Choices. 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 firstname.lastname@example.org.
2. 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 long 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. For operational purposes, we store the following numbers on our live systems or in our data archives:
- mobile numbers to which you send electronic communications via our services; 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.
Purpose. We 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.
Disclosure of personal information. There may be situations where the law requires us to disclose your personal information. It may also be necessary for us to disclose or transfer your personal information to suppliers, affiliates or agents in order to provide you with our services. Clickatell sometimes use other companies to perform certain business-related functions, for example email marketing, digital marketing technology, interactive campaign management etc. When we employ another company to perform a function of this nature, 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.
Changes. 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.
Access. 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.
Disclaimer. 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 corrections based on the updated information provided by the authenticated visitor.
Security. We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration or destruction. All Clickatell employees follow a network-wide security policy. Only authorised Clickatell personnel are provided access to personal information and these employees have agreed 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.
Children. 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 13 years of age or younger. It is Clickatell’s policy never to knowingly collect or maintain information about anyone under the age of 13.
Enquiries. Should you have any questions or enquiries regarding this policy, please feel free to direct them to email@example.com for attention: Clickatell Privacy Officer.