PRIVACY POLICY

Privacy Policy of Lightspeed Telecommunications LLC, we are committed to protecting the privacy of individuals. This Privacy Policy sets out, subject to applicable laws, our practices regarding personally identifiable information we collect from you, or that you provide to us, including via our websites or our audio and conferencing.

Introduction

This Privacy Policy explains:

1. What information we collect about you

2. How we may use and share that information

3. How you can update or access any personal information we hold about you

If you have purchased services from us, please read this Privacy Policy in conjunction with any other service-specific terms and conditions (however styled) applicable to the services provided to you.

What Do We Mean by the Term Personal Identifiable Information?

When we refer to the term ‘personally identifiable information’, we mean information that can identify you as an individual or is capable of doing so with other information that we may hold about you now or in the future.  The term does not include any statistical, aggregated or anonymized information.

What Information Do We Collect About You?

We may collect and process the following personally identifiable information about you.

1.Information which you may submit to us including your name, address, telephone number and email address. This includes information provided at the time of subscribing to our services (including services not provided solely via our websites) or requesting further services. Such information includes verification details that you provide to us in order to access and use specific features of our services, such as verification details provided to us in order to access our conferencing, audio or online services. This will include any verification details which you provide in order to access, download or play taped records.

2. Debit/credit card information, banking details and any other relevant payment information necessary for us to process your order or to manage your service.

3. Where you are an existing customer, additional information which your company has provided – such as your company’s name and address or your email address.

4. If you contact us by phone, email or otherwise, a record of that communication.

5. Any surveys you complete that are used for research purposes.

6. Details of transactions you carry out through the websites and the fulfillment of your orders for our services.

7. Information about the type, quantity, configuration, destination, location and amount of use of telecommunications services you currently purchase and related billing information and end user information for those services. This information is collected in the normal course of providing telecommunications services to our customers, and is commonly referred to as customer proprietary network information, or “CPNI”.

The submission of your personally identifiable information constitutes your acknowledgment that you have read and understood this Privacy Policy and agree to its terms. You also acknowledge and consent to our collection, storage, transfer and processing of such personally identifiable information in accordance with this Privacy Policy.

How Do We Use Your Personally Identifiable Information?

We take the privacy of our customers and users seriously and respect your right to privacy. Personally identifiable information will be collected, processed, stored, and disposed of in accordance with this Privacy Policy.

We process your personally identifiable information for a number of purposes in order to:

. provide you with access to our websites

. process your order(s)

. supply you with our products and services (including processing any payment information for such products and services)

. inform you of any new promotions, products and services offered, improve the level of service and provide notifications regarding service changes or outages or in order to carry out market research

. process any competitions or surveys that you have participated in

. investigate any complaints or other enquiries you may submit for our attention

. obtain references from previous employers, credit or debt agencies or for the purposes of fraud or money laundering or crime detection and prevention

Where we process personally identifiable information in the course of our conferencing, audio or on-line services, this is done to allow us to provide the services which your company has asked us to provide, for example, by allowing us to create an authorized user ID for you, to allow you to use our services and by allowing us to provide billing and service usage information to your company.

Who Do We Share Your Information With?

We do not sell or disseminate personally identifiable information to third parties without your consent.

Unless we have your permission or are required by law, we only share your personally identifiable information with our controlled subsidiary companies and to our selected business partners who act on our behalf in order to provide the services. We make every reasonable effort to ensure that our subsidiaries and business partners, process your personally identifiable information in accordance with the terms of this Privacy Policy.

We may disclose personally identifiable information and account information in special cases when it is necessary to identify, contact, or bring legal action against someone who may be violating any user agreement or may be causing injury to or interference with us, you, or anyone else that could be harmed by such activities, or in response to 911 requests, or in emergency situations.  We may also disclose personally identifiable information as necessary to collect for the charges related to the services we provide.  With some services, your name and number may be transmitted and displayed on a Caller ID device unless you have elected to block such information. Caller ID Blocking does not prevent the display of your number when you dial certain business numbers, 911, 900 numbers, or toll-free 800, 888, 877 or 866 numbers. In the United States, we provide name and telephone number to entities that publish telephone directories and provide directory assistance.

We reserve the right to disclose your personally identifiable information as explicitly set forth in this Privacy Policy or any user agreement agreed to by you, or as otherwise required by government or law enforcement officials. We can, and you hereby authorize us to, disclose any information to law enforcement or other parties that we in our sole discretion, believe is required or appropriate to comply with the law.

How Long Do We Keep Your Information?

The length of time we keep your information for can vary according to how we use that information. Unless there is a specific legal requirement to keep your information, we will not keep it for longer than we believe is reasonably necessary for the purposes for which the data was collected.

Direct Marketing

We would like to keep you up to date with details of our products and services using the information that you have supplied. We will do this in accordance with applicable privacy laws. If you would like to change these preferences, please contact privacy@lightspeedtelecom.com or speak to your Account Manager.

How to Review and Update your Information

You may request a copy of the personally identifiable information we hold about you, such as contact information, banking details and you may review, correct, update, change or delete this information at any time by submitting a request to privacy@lightspeedtelecom.com  or the local contact you have been provided for this purpose. Please note that in certain circumstances we may withhold access to your information where we have the right to do so under current data protection legislation.

Security

We have implemented reasonable physical, technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure which are in accordance with applicable laws. Our websites have security measures in place to protect against the loss, misuse and alteration of information under our control. However, the internet is an open system and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes.

Customer Proprietary Network Information (CPNI)

CPNI is information that we obtain when we provide telecommunications services to you, including services provided through your local telephone company. It includes the types of telecommunications services you purchase from us, how you use them, and the related billing information for those services. CPNI does not include your telephone number, name and address. CPNI also typically includes the type of information found on your bill, such as call details and the types of local, long distance and other telecommunications services that you have purchased. In the normal course of providing telecommunications services, we collect and maintain CPNI to enable us to make more meaningful suggestions to you when discussing products and services, packages and promotions that best suit your communications needs. In the US, we are obliged to protect the confidentiality of your CPNI in accordance with federal and certain state laws. We do not sell, trade or share your CPNI, including your calling records with anyone outside of our group of companies or to third parties who perform functions on our behalf (such as billing functions) except as described in this Privacy Policy,  required by law or authorized by you. We may use or disclose CPNI to offer telecommunications services of the same type that you already purchase from us. We may also use or disclose your CPNI for legal or regulatory reasons such as to comply with a court order, to investigate fraud,  to protect against the unlawful use of our telecommunications network and services, to protect other users of our services, and to collect bills.

Changes to this Privacy Policy

As we grow and new features are added to our website or to our products and services, or legal requirements change, this Privacy Policy may be modified. Any changes to the Privacy Policy will be posted on our website. All information submitted through our website is subject to the terms and conditions of this Privacy Policy, as amended.

Submission of Personal Details to Us

Any personally identifiable information which you submit to us will be treated and processed by us in accordance with this Privacy Policy. By submitting any such information, you consent to our holding and processing the information, both electronically and manually, for the expressed purpose. You also consent to the transfer, storage and processing of such information among our office.

How to Contact Us

If you have any questions or complaints about this Privacy Policy, the information we collect, or how we use that information please contact us at privacy@lightspeedtelecom.com or the local contact you have been provided for this purpose or by writing to us at the following addresse:

Please contact: Legal Department, Lightspeed Telecommunications LLC, 352 Seventh Avenue, 11th Floor, New York, NY 10001 USA.

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