Effective Date: August 1st 2016
In this Privacy & Cookies Policy, the terms “you,” “your,” and “yours” refer to the customer using our website www.tropo.eu (the "Website") or our Services (as defined in the Terms of Service) all owned and operated by Tropo (Europe) Limited, a wholly owned subsidiary of Cisco Systems Inc,. The terms "Tropo", “we,” “us,” and “our” refer to Tropo (Europe) Limited. This Privacy & Cookies Policy is governed by our Terms of Service.
Your privacy is important to us. The aim of this Privacy & Cookies Policy is to tell you how we will use and disclose personal information collected from and about you when you use our Website and Services, as well as your ability to control certain uses of it. Please read it carefully before you proceed.
Personal Information Collection and Use
By using this Website and by accepting our Privacy & Cookies Policy when signing up to our Services, you have consented to the data practices below
Personal Information Collection and Use
We will collect the following types of personal information referred to below from and about you when you use our Website and Services.
Providing your personal information is generally optional and you are free to omit part or all of such information. However, under certain circumstances (we will provide you information about these circumstances when they arise, e.g. marking such information in the registration forms), your personal information is essential to obtain our Services (and a failure to do so may mean you cannot use our Services).
You do not have to give us any personal information to use most of our Website but we will process any personal data you give us when you contact us via the Website for general enquiries or support.
We (and other third parties acting on our behalf) also collect certain information automatically about you such as the website that you came from or are going to, which pages of our Website you visit, IP addresses, the type of browser or device you use and the times you access our website. We use this information so that we can administer and improve our Website, analyse trends, track users' movements, gather broad demographic information for aggregate use and detect suspicious or fraudulent transactions.
Registered users of our Services
If you wish to use our Services (including the Tropo API), you will need to sign up for an account with us and we will collect your name, email address, user name, password and billing information and we will keep records of your communications and transactions with us and your billing history ("Account Data"). Please note that all payment card details are encrypted and tokenized by a third party on our behalf and we use a trusted third party provider to process payments on our behalf. We do not retain your full payment card details ourselves.
Once you start to use our Services, we will also collect operational data such API requests and phone numbers that you call and send messages to (and the phone numbers you receive calls and messages from) as well as date, time, duration and cost of your communications as well as other traffic routing and usage information ("Traffic Data").
In addition, if you use our Services to send text messages or to record messages, we will also receive User Information as defined in the Terms of Services.
Note that many of our customers use our Services to build communications features and capabilities into their own Applications as defined in the Terms of Service. As such we do not interact directly with the ultimate end users (as they will interact with the Applications). Please note that we are not responsible for the collection of data by these Applications except to the extent that we receive any personal data via these Applications in connection with our Services. With respect to user information and otherwise, Tropo will not be liable to you for any harm that arises out of or in any way relates to the acts or failures to act of any third party.
Your Traffic Data will be used by us to deal with customer enquiries, for billing purposes, to prevent or detect fraud, and to appropriately manage and route customer traffic or as otherwise permitted by applicable law
Other personal information will be used by us for the following purposes:
- to administer our Website and verify and operate your account;
- to allow you to access and use our Services and associated support;
- to communicate with you and resolve any problems associated with our Website or our Services;
- for billing;
- to monitor and analyse the use of any account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime and to maintain the security, integrity and quality of our Services which may include interception, monitoring or records in accordance with applicable law;
- to carry out research and analysis and monitor customer use of the Website and Services to identify general consumer trends and to understand better our customers' behaviours and partner with other businesses to create new services and to improve and develop our products and services for you, as well as personalise your Website experience and the products and services we offer you(only with your permission where required by local law); and
- to meet legal, regulatory and compliance requirements.
In addition, with your permission, we will use your email address to send you information about Tropo's products, services and events you might be interested in. You can choose to not receive marketing emails from us by contacting us using the contact details below or by following the unsubscribe option included in each email.
Personal Information Sharing
Tropo respects your privacy. Unless you give us your permission, we don’t share personal information with third parties except as described below:
- Telephony operators and other communications service providers as necessary for proper routing and connectivity and in order to provide the Services;
- Third party service providers or consultants. For example, we will share relevant Account Data with our payment processor so it can process payments on our behalf or our storage provider for storing your personal information on our behalf. These third party providers are limited to only accessing or using your personal data to provide services to us and must provide reasonable assurances that they will appropriately safeguard the data in accordance with applicable data protection laws;
- We will disclose your personal data to a third party if (i) we believe that this is reasonably necessary to comply with any applicable law, legal process or an official government request (ii) to protect our rights and enforce our agreements and policies (iii) to protect our safety or the safety of others or (iv) to investigate fraud or other unlawful action. This includes exchanging information with other companies and organisations for identity verification and fraud protection purposes to the extent permitted by applicable laws;
- If Tropo is involved in a merger, acquisition, or sale of all or a portion of its assets, personal information we have collected about you may be transferred in connection with the transaction. Any successor or acquirer of Tropo may continue to use your personal information as set out in this Privacy & Cookies Policy;
- We may share your personal information with our Affiliates. We will only use your personal information as described in this Privacy & Cookies Policy
We may also share aggregate or de-identified data with third parties for analytics purposes.
International Data Transfer
Tropo may transfer some of your personal information to countries outside the European Economic Area ('EEA') such as the US and China. Some of these countries may not have equivalent data protection legislation protection for the use of your personal information. However we will take steps to ensure that there is adequate protection for your personal information. By using our Website or registering for our Services, you consent to this transfer of your personal information.
The Security of Your Personal Information
We will take appropriate technical and organizational measures to protect personal information in our possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We follow generally accepted industry standards, like secure socket layers (SSL) to protect the personal information submitted to us such as credit card number, both during transmission and once we receive it, as well as logical and physical access controls for user access to personal information. No method of transmission over the Internet or method of electronic storage is, however, 100% secure. Therefore, we cannot guarantee the absolute security of your personal information
Tropo does not process personal information in a way that is incompatible with the purposes for which it was collected or with the instructions provided by the subscriber. Tropo takes reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current.
Except as otherwise provided in this policy, Tropo may retain personal information associated with your account for as long as is necessary to fulfill the business or legal purpose for which it was obtained and in accordance with applicable law.
Cookies / Tracking Technologies
We may use the following categories of cookies on our Websites:
- Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Website and use our features (e.g. to submit forms to contact and send information to Tropo, to remember your login details). Without these cookies, services you have asked for, cannot be provided. We don’t use these cookies to gather information about you that could be used for profiling, advertising or remembering where you've been on the internet.
- Functionality Cookies: These cookies remember choices you make such as the country you visit our Website from and language. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
- Targeting/Advertising Cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers.
In order to place cookies on your device, we require your consent. If you don’t want to receive cookies, You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Websites or take full advantage of all of our offerings and services. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences.
To opt out of being tracked by Google Analytics across our Sites visit http://tools.google.com/dlpage/gaoptout.
Tropo may directly or allow companies that we work with to use technologies such as beacons, tags and scripts in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports from our partners based on the use of these technologies on an individual as well as aggregated basis.
Forums and Comments
If you use the forum or post comments on this Website, you should be aware that any personal information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. Tropo is not responsible for any personal information you choose to submit. You can request the removal of your personal information from our community forum, by contacting us at firstname.lastname@example.org In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Links to Other Sites
This Website may contain links to other sites that are not owned or controlled by us. Please be aware that Tropo is not responsible for the privacy policies of such other sites. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that collects personal information.
Single Sign On
Social Media Widgets
Our Website and Services are not designed for use by children under the age of 18, and we do not knowingly collect personal information from children under the age of 18 online. If we learn that we have collected personal information on a child under the age of 18 online, we will delete that data from our systems.
If you wish to access your personal information you should contact Tropo using the contact details in the section below and give sufficient information to enable you and your information to be identified.
You may also have the right to ask us to rectify, block, complete, and delete your personal information or restrict its use or request information about the source of your data or obtain a list of data processors that we use. You can also access and/or change your personal information or amend your consents by logging into your account. You may also have the right to request further information about the processing of your data or to object to the processing
You can exercise the above rights by contacting us at any time using the contact details provided in the section below. There are exceptions to these rights; for example, access may be refused if this would breach privacy rights of others.
If you choose to close your Tropo account or your account is not used for a prolonged period, we will retain your account information as a historical business audit record only. We archive all closed accounts, and delete the users’ ability to log into them or to recover and/or change passwords. We also no longer send automated correspondence about your closed account via email. From date of closure of your account, we will only use your account information as necessary to comply with our legal obligations, resolve disputes, protect against fraud, and enforce our agreements or otherwise in accordance with applicable law.
You also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached
Changes to this Privacy & Cookies Policy
This is our entire and exclusive Privacy & Cookies Policy and it supersedes any earlier version. Our Terms of Service take precedence over any conflicting Privacy & Cookies Policy provision. We may change this Privacy & Cookies Policy by posting a new version of this Privacy & Cookies Policy on this Website which it is your responsibility to review. If we make any material changes we will notify you by email or by means of a notice on this site prior to the change becoming effective. We encourage you to periodically review this Privacy & Cookies Policy to stay informed about how we are protecting the personal information we collect. Your continued use of this Website and our Services constitutes your agreement to this Privacy & Cookies Policy and any updates.
If you have questions
Tropo is the data controller of your personal information. Any questions or concerns regarding the use or disclosure of personal information should be directed to Tropo through the contact information listed below:
Tropo (Europe) Limited
70 Great Bridgewater Street
Manchester, M1 5ES, United Kingdom