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Privacy Policy

Privacy Policy

By using our websites, products, services, or otherwise by interacting with Us, you consent to the following privacy policy (“Privacy Policy”). Please do not engage in any of these activities if you do not agree with the terms of this Privacy Policy.

Your privacy is important to Us. The purpose of this Privacy Policy is to inform you about the information We may gather about you, how We may use that information, whether We disclose it to anyone, and the choices you have regarding Our use of the information We collect.

Information Collected by Sinch
In general, Sinch will collect information from you based upon our business relationship, your use of the Site, Our services and Our products, as follows:

CONTENT REGISTRATION
In order to access and view some content on the Site, you are required to register with Sinch before the content is made available to you. During the registration process, you are required to provide Us with certain contact information, including your name, address, phone number and email address. We use this information to contact you about the services We offer in relation to which you have expressed interest.

CLIENT SUPPORT PORTAL
When you contact Sinch customer support (“Customer Support”) using any Sinch client support portal (the “Client Support Portal”), We may ask you for certain information regarding your enquiry, such as your name, email address or telephone number.

COOKIES
What Are Cookies and How Do I Disable Them?

Cookies are files that web browsers place on a computer’s hard drive. You can disable cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Note that you may be prevented from using the Site or services effectively or at all if cookies are disabled.

How do the Site and services use cookies?

Our customer support portals use session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Us to process your online data and requests. Session cookies help Us make sure you are who you say you are after you have logged in. We use persistent cookies, which only we can read and use, to identify the fact that you are an Sinch customer or prior site visitor.

The site utilizes cookies as follows:

Category Party Name Purpose
Necessary cookies Sinch cardboardfish_session User login session identifier
Functionality cookies ShareThis _unam Tracking page shares for social media widget
Analytical / performance cookies Google Universal Analytics _ga This helps us count how many people visit www.sinch.com by tracking if you’ve visited before
Analytical / performance cookies Google Universal Analytics  _gat Used to manage the rate at which page view requests are made
Analytical / performance cookies  Google Analytics  _utma This works with _utmc to calculate the average length of time you spend on www.sinch.com
Analytical / performance cookies  Google Analytics  _utmc This works with _utmb to calculate when you close your browser
Analytical / performance cookies  Google Analytics  _utmz This tells us how you reached www.sinch.com (eg from another website or a search engine)
Analytical / performance cookies  Pardot  visitor_id  The visitor cookie includes the name “visitor_id”, which is derived from the tracking code placed on this site. The value stored is the unique ID for the visitor. For example, cookie name “visitor_id12345″ stores the visitor value “123456789,” where 12345 is the account identifier and 123456789 represents the visitor ID. This cookie is set by our tracking code on visitors and prospects
Analytical / performance cookies  Pardot  pi_opt_in Opt In Cookie: The persistent cookie named “pi_opt_in” is what we use to stay in compliance with the “Do Not Track” initiative
Analytical / performance cookies  Pardot pardot Pardot App Session Cookie: The session cookie named “pardot” is only set if you’re logged into our app as a user (i.e. prospects will not have this cookie set).
Analytical / performance cookies  Kiss Metrics km_ai, km_lv, km_uq, km_vs, kvcd Performance, A/B testing, analytics

We also may from time to time engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to our websites to help us administer the websites and improve its quality. Such third parties may use cookies to help track visitor behavior. Such cookies will not be used to associate individual website visitors to any Personal Data (defined below). All data collected by such third parties on Our behalf is used only to provide Us with information on site usage and is not shared with any other third parties.

FORUMS AND BLOGS
If you participate in any blog or other forum offered by our website or services, your user ID may be displayed on any content that you post and will therefore be available to the public. Therefore, if you associate your name with your user ID, your name and any related content or posts may be available to the public. You are solely responsible for all liability related to your use of any such blog or forum.

CORRESPONDENCE
If you send Us correspondence, such as emails or letters, We may collect such information into a file specific to you.

MOBILE USER INFORMATION
As part of Our services, We sometimes receive information from wireless carriers and operators in order to provision the specific content and data services requested by individual users. All such information is acquired from either the wireless carrier’s or operator’s website or from the user’s mobile device via the wireless carrier’s or operator’s network. This data is usually limited to the user’s cell phone number. In some cases, such as for prize fulfilment for a mobile contest, the user’s mailing address is also provided. The user must explicitly “opt in” through the wireless carrier or operator in order for any of this information to be collected and its use is governed by this Privacy Policy and any policies or procedures of the user’s wireless carrier or operator. In some cases, We may receive authentication information directly from mobile users, including in the form of a personal information number (PIN) previously sent to a mobile user.

HUMAN RESOURCES
We collect information about you when you submit a job application, resume, survey responses or similar information.

NEWSLETTERS
If you wish to subscribe to Our newsletters, We will use your name and email address to send the newsletter to you. Out of respect for your privacy, you have the option to unsubscribe from receiving some or all of the newsletters. Please see the “Opt-out” section below.

How We Use Information
We may use data We obtain as described above for purposes relating to our website and services, including (a) providing the website and services to you, (b) facilitating third parties to participate in the provision and improvement of the website and services (including without limitation mobile network operators, hosting partners, and other service providers), (c) raising queries with you, and responding to issues you may raise, whether relating to our services or otherwise, (d) communications relating to surveys and other customer satisfaction-related activities, (e) progressing job applications, to perform credit checks and, (f) verification of personal or business data and payment details and other checks before offering our services to customers.

SERVICE-RELATED ANNOUNCEMENT
We will send you service-related announcements when it is necessary to do so. For instance, if Our service is temporarily suspended for maintenance, We might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

CUSTOMER SERVICE
We will also communicate with you in response to your customer service enquiries, to provide the services you request, and to manage your account.

Disclosures and Sharing of Information
As a matter of policy, We do not sell or rent any of your information to third parties for any advertising or marketing purposes. However, the following describes some of the ways that We may disclose your information in the normal course of providing Our services.

LEGAL REQUESTS & COMPLIANCE WITH LAWS
We reserve the right to disclose information as required by law or regulation and when We believe that disclosure is necessary to protect Our rights and/or to comply with a judicial proceeding, court order, or legal process. Notwithstanding any provisions herein, We may disclose Personal Data to governmental authorities when required or reasonably requested to do so by such governmental authorities. This Privacy Policy does not apply to the extent that it is in conflict with any law that may be applicable to the Personal Data of a Data Subject.

PROCESSING OF PERSONAL DATA OUTSIDE EU AND SWITZERLAND
Sinch processes Personal Data on behalf of its clients (“Customers”), that has been collected by or on behalf of those Customers including Personal Data received from the European Union. “Personal Data” or “Personal Data” means information relating to an identified or identifiable person. With the objective to validate transfers of Personal Data under European data protection laws to countries outside EU and Switzerland we are making available the European Commission’s controller-to-processor standard contractual clauses, commonly referred to as “model clauses” (in the form adopted by decision 2010/87/EU of 5 February 2010 and with Appendices 1 & 2. Any Customer of Sinch who undertakes processing activities on the Sinch platform (in respect of Personal Data which is governed by the European data protection laws), should contact privacy@clxcommunications.com for more details.

DISCLOSURE OF INFORMATION TO SINCH AFFILIATES
Because Sinch is a global company, We may share your information with other Sinch affiliates and business units in other parts of the world in order to provide you with Our services. Your Personal Data may be transferred by Us from your home country to Sinch employees in Sinch offices around the world, who may communicate with you regarding your enquiry. Please understand that We limit access to your Personal Data to only those Sinch employees who We believe need access in order to provide services to you or to otherwise perform their duties.

Data Processor
As Data Processor, Sinch will only process Personal Data pursuant to the instructions of the applicable Customer (for example where We act as a Data Processor in relation to the processing activities of Customers on Our platform). Sinch may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such Personal Data by the applicable Customer (including but not limited to the provision of services). Sinch will not be responsible for determining the authenticity of any purported Data Subject’s request to access his or her Personal Data. In the absence of express instructions to do so from the applicable Customer, Sinch will not provide a purported Data Subject with access to his or her Personal Data unless it is demonstrated to Sinch’s satisfaction that the applicable Data Controller has refused such access.

Data Controller
As Data Controller, Sinch receives Personal Data about Our business contacts. Sinch owns and controls such Personal Data as stated in this Privacy Policy. In parallel and in accordance with Recital 47 of the European Data Protection Directive 95/46/EC (as amended from time to time of replace by other EU regulation), We shall act as an independent Data Controller with respect to the processing of Personal Data which is necessary for the operation of Our service which shall include any information processed for the purpose of the conveyance of a communication on an electronic communications network or for the billing thereof.

HIPAA
From time to time, Sinch provides messaging services to health care providers, and serves as a “Business Associate” (as that term is defined pursuant to HIPAA Regulations) to such providers in relation to the handling of protected health information (“PHI”) that is made a part of Our services.

De-identification
Sinch may de-identify or depersonalize data into anonymized and aggregate data that it derives from Customers (“Anonymous Data”). Anonymous Data means data that includes no Personal Data or unique identifiers that could later be used to refer to the Personal Data to which the data was once associated. Sinch uses only Anonymous Data in performing analyses, and may disclose Anonymous Data to its Customers who have requested such analyses and to third parties where We are contractually entitled to do so.

This Site is Not for Use by Children
Protecting the privacy of children is important to Sinch. For that reason, the Site is structured specifically to not attract anyone under 13, nor do We collect or maintain Personal Data on the Site from those who Sinch actually knows are under 13. If Sinch learns or is notified that it has collected information from users under the age of 13, Sinch will immediately delete such Personal Data.

Opt-Out
We provide you the opportunity to ‘opt-out’ of having your Personal Data used for certain purposes, when We ask for this information. For example, if you register with Us but no longer wish to receive Our newsletters and/or related communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing Us at legal@clxcommunications.com.

Security
We take appropriate technical and organizational measures to guard against unauthorized or unlawful processing of your Personal Data and against accidental loss or destruction of, or damage to, your Personal Data. Sinch uses industry-standard security measures to protect the integrity and confidentiality of any Personal Data it owns or processes on behalf of Customers, including, in appropriate circumstances, the use of firewalls, restricted access, and encrypted transmissions. Sinch limits access to Personal Data to those persons in Sinch’s organization who have a business need to process such Personal Data. However, no company, including Sinch, can fully eliminate the security risks associated with such Personal Data. Due to factors beyond Sinch’s control, Sinch cannot ensure that Personal Data will not be disclosed to third parties. For example, Sinch may become legally obligated to disclose such data, or, despite precautions, third parties may circumvent security measures to intercept or access such data.

Disclaimer
We cannot ensure that all of your private communications and other Personal Data will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), We may be forced to disclose Personal Data to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Data that they collect from the Site. Sinch does not review, comment upon, or monitor its Customers’ compliance with their respective privacy policies, nor does Sinch review Customer instructions to determine whether they are in compliance or conflict with the terms of a Customer’s published privacy policy.

Third Parties
Please be advised this Privacy Policy does not apply to the practices of companies that Sinch does not own or control, or to people that Sinch does not employ or manage. This includes links to other websites on the Site as well as any companies from whom you may have ordered services or products that are transmitted over Sinch’s network, and any companies from whom you may be purchasing telecommunications services. Sinch recommends that you be aware when you leave the Site and read the terms of use and privacy policies of any site, product or service that collects Personal Data.

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time, so please review it regularly. If We make changes to this Privacy Policy, We will post the revised Privacy Policy on the Site and other places We deem appropriate. All such changes shall be binding on you 30 days after they are initially posted on the Site unless you are a new user, in which case they are binding on you immediately.

Acquisitions
If another company acquires Sinch or its assets, that company will (a) process that Personal Data held by Sinch, and (b) assume the rights and obligations regarding such Personal Data described in this Privacy Policy.

Update Information / Revoke Choices / Suggestions / Contact Information
If you would like to update or correct any information that you have provided to Sinch through your use of Our services or this website, limit or opt-out of certain communications, revoke prior communication choices you have made, or if you have suggestions for improving this privacy policy, please send an e-mail to legal@clxcommunications.com, or fill out the form in the Contact Us link on this website. We will use reasonable commercial efforts to address any concerns that you may have. Any person – including with inquiries or complaints regarding this privacy policy should contact Sinch’s Privacy Office at:

CLX Communications Inc.
ATTN: PRIVACY OFFICER
1100 Abernathy Road
500 Northpark Towncenter, Ste 1200
Atlanta, GA 30328
United States
or
CLX Communications Limited
ATTN: PRIVACY OFFICER
4th Floor, Cap House
9-12 Long Lane
London, EC1A 9HA, United Kingdom
or
Sinch AB
ATTN: PRIVACY OFFICER
Lindhagensgatan 74, 112 18 Stockholm, Sweden
or
CLX Communications GmbH
ATTN: PRIVACY OFFICER
Wilhelm-Wagenfeld-Str. 20,
D-80807 Munich, Germany
or
CLX Networks AB Telekomünikasyon Hiz. LTD. ŞTİ
ATTN: PRIVACY OFFICER
Uygur İş Merkezi No: 102 D. 1/5,
Barbaros Bul. Nispetiye Mah. Beşiktaş,
ISANBUL, Turkey

Email: legal@clxcommunications.com