Information Collected by Sinch
In general, Sinch will collect personal data from you based upon our business relationship, your use of the Site, Our services and Our products, as follows:
CONTACT PERSONS AND CONTENT REGISTRATION
In order for Us to communicate and provide our services to you or discuss the services you may provide Us with, you will provide us with your contact information and possibly other information about you. Further, 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 or vice-versa.
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.
See our Cookie Statement.
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.
If you send Us correspondence, such as emails or letters, We may collect such information into a file specific to you.
MOBILE USER INFORMATION
We collect information about you when you submit a job application, resume, survey responses or similar information.
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.
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.
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.
DISCLOSURE TO OUR SERVICE PROVIDERS
Your personal data may be transferred to and processed by third party providers and suppliers which perform services for Us (data processors), to enable these companies to perform the services requested by Company. Only personal data that is necessary to fulfill the purposes will be provided to these companies. All third party providers and suppliers must follow Our instructions and applicable written data processor agreements and any other agreements that are in place between Us and Our third party providers/suppliers, and must implement appropriate technical and organizational measures for the protection of the personal data. For a complete list of Our data processors, please click here.
LEGAL REQUESTS & COMPLIANCE WITH LAWS
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. 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 DPO@sinch.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.
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.
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.
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.
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 firstname.lastname@example.org.
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.
RIGHT TO ACCESS AND RECTIFICATION
You have the right to request access to the personal data relating to you. This includes the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing. You also have the right to rectify or add personal data if the personal data is inaccurate or incomplete.
RIGHT TO ERASURE
You may also request that your personal data be erased if e.g. the personal data is no longer necessary for the purposes for which it was collected, the processing is unlawful, or the personal data has to be erased to enable us to comply with a legal requirement. There are other circumstances where your personal data can be erased; please contact Us if you would like to find out whether your personal data can be erased (see below for contact details). Please note that We may reject your request if the processing is permitted or required according to law or any other relevant legal ground.
RIGHT TO OBJECT
You are also entitled to object to certain processing or request that the processing of the personal data be restricted if you believe the personal data may not be correct, if you believe the processing is unlawful, or if you believe that Sinch no longer needs the personal data for the purposes stated in this policy.
RIGHT TO DATA PORTABILITY
If you request access to personal data about you that you yourself have provided and if the personal data is being processed automatically with your consent or in accordance with a contract between you and Us, you may request that the data is provided in a structured, commonly-used and machine readable format and you may also request that the personal data is transmitted to another controller, if this is technically feasible.