PRIVACY

SUMMA CONTACT PRIVACY STATEMENT

1 INTRODUCTION

We value your privacy and are committed to protecting your personal data (‘Personal Data’). This privacy statement (‘Privacy Statement’) explains how we process your Personal Data in accordance with applicable data protection legislation (‘Data Protection Legislation’), what Personal Data we process, for what purposes we process your Personal Data, how we protect your Personal Data, how long we store your Personal Data, how you can exercise your privacy rights in relation to this Personal Data, and any other information that may be relevant to you as an end user (‘Business End User’) of the Contact application (‘App’).

In this Privacy Statement, ‘you’, ‘your’, and ‘yours’ refers to all data subjects (‘Data Subject’) interacting with the App via its desktop and mobile version as a Business End User, whereas ‘Summa, ‘we’, ‘our’, or ‘us’ refers to Summa Communications B.V., as the provider of the App. Additionally, as Summa Communication B.V. is part of the Enreach group, you will see references to the Enreach Group, which includes all Enreach Group entities globally. Further information on the Enreach Group can be obtained by contacting us using the Contact Information provided below.

Summa is the data processor (‘Data Processor’) for the Personal Data we process within the App, or the backend/cloud connected to the App, on behalf of our business customers (‘Business Customer’), in most cases your employer, who have their own purposes for processing the data. For details on such purposes, you should refer to their privacy statements/notices. To the extent Summa processes Personal Data within the App or the backend/cloud connected to the App, in connection with its own legitimate business operations, as identified in this Privacy Statement, Summa will be the (independent) data controller (‘Data Controller).

Without the processing of your Personal Data, you will not be able to access the App. By using the App and submitting any Personal Data, you agree to the use of such data in accordance with this Privacy Statement.

Summa does not share Personal Data with third parties, unless this is (1) legally required, (2) necessary to supply a service, 3) specifically requested by the business customer that has provided the Personal Data, or (4) otherwise Summa has a legitimate interest in doing so, assuming that interest outweighs any potential effects that the sharing of Personal Data might have on the rights and freedoms of the affected Data Subject.

We did our best to provide you with all the necessary information in a clear and readable format in this Privacy Statement. However, if you have any questions about our use of your Personal Data after reading this Privacy Statement, you can of course always contact us through the contact details provided below.

The capitalised words in this Privacy Statement have the meanings ascribed to them in this Privacy Statement and in the Definitions provided below.

 

2 CONTACT INFORMATION

You can contact us here:

Summa Communications B.V.

Address: Verlengde Duinvalleiweg 102, 1361 BR Almere, the Netherlands

Email: dataprotectionteam@enreach.com

Phone: +31 088 889 0889

2.1 Data Protection Officer

We have a dedicated Data Protection Team and a Data Protection Officer (‘DPO’). If you have any questions relating to the processing of your Personal Data or want to contact our DPO, feel free to do so using the details provided below:

Data Protection Team

Email: dataprotectionteam@enreach.com

Phone: +31 088 889 0889

 

3 DEFINITIONS

Below are some key terms relevant to this Privacy Statement:

 

Personal Data: Any information directly or indirectly relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

 

Data Subject (you): Natural person(s) whose Personal Data is processed, specifically in this case, the Business End User.

 

Data Controller: Natural or legal entity that determines the purposes and means for the processing of Personal Data. In the context of this Privacy Statement, this is in most cases your employer, or Summa as an independent Data Controller when we process your Personal Data for our own legitimate business operations, not related to the processing purposes of your employer.

 

Data Processor: Natural or legal entity processing data on behalf of the Data Controller. In the context of this Privacy Statement, this is in most cases Summa as the provider of the App.

 

Business End User (you): Data Subject(s) whose Personal Data is processed while using the App, in most cases, the employees of the Business Customer.

 

Business Customer: The legal entity that has a direct contractual relationship with Summa, or a contractual relationship with Summa partners. In the context of this Privacy Statement, this is in most cases, your employer.

 

Sensitive Personal Data: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a Data Subject’s sex life or sexual orientation.

 

Data Protection Legislation: Data Protection Legislation refers to the applicable laws that govern the protection of Personal Data and privacy. This includes the legislation applicable to the processing of Personal Data in the EU, such as the General Data Protection Regulation (‘GDPR’) and the ePrivacy Directive (‘ePD’), as well any national laws implemented in connection with the aforementioned legislation.

 

4 FUNCTIONS OF THE APP

The functions of the App can only be used in conjunction with a server, for which your employer i.e., the Business Customer has purchased and configured a licensed version of the Summa communication software. App functions will only be available after authentication and synchronization of the data with the corresponding servers.

 

5 WHAT PERSONAL DATA WE PROCESS AND WHY

Summa processes the Personal Data identified in this Privacy Statement to deliver the App and ultimately for the purposes determined by the Business Customer. We only collect Personal Data that is necessary for the intended purposes and in accordance with the Data Protection Legislation.

Our intention is not to collect Sensitive Personal Data through the App. We therefore ask that you do not provide any type of Sensitive Personal Data. If you do wish to provide such Personal Data for any reason, Summa accepts your explicit consent to use that Personal Data in the ways described in this Privacy Statement or as described at the point where you choose to provide us with such data.

Personal Data obtained via the App is used only in the ways described in this Privacy Statement or otherwise for the purpose(s) stated at the time that the data is collected. Summa makes every effort to avoid any excessive or irrelevant collection of Personal Data.

5.1 How do we collect your Personal Data

We may collect Personal Data directly from you or indirectly through the Business Customer. The way we collect your Personal Data differs depending on your relationship with us:

  • Directly from Business End Users: Personal Data may be directly collected from you via the App. If you choose not to provide Personal Data to us, you may experience limited functionality in your desired service, function, or technical assistance.

 

  • Indirectly from Business Customers: Personal Data may also be collected indirectly through your employer. When e.g., your employer has provided us with your Personal Data, we operate under the assumption that your employer as the Data Controller has obtained the necessary valid legal basis to collect the data. For details on such legal basis, you should refer to their privacy statements/notices.

5.2 How do we process your Personal Data and why

5.2.1 On behalf of the Business Customer

We do not control the purposes and means for the collection of your Personal Data when providing our service on behalf of the Business Customer and are therefore not responsible for it. We only process the data to the extent necessary for downloading the App to your device and for other technical purposes related to the availability, development, and usage of the App.

We only process your Personal Data when there is a legal basis for doing so. The Personal Data processed via the App is collected on the basis of:

  • The legal ground(s) established by the Business Customer: Your Personal Data may also be processed based on a valid legal basis determined by the Business Customer, ensuring compliance with the Data Protection Legislation. The Business Customer is responsible to ensure the Personal Data has been collected in a legitimate way.

 

  • Consent: You have given consent to the processing of your Personal Data for one or more specific purposes. You will be asked to provide your consent at any point at which your Personal Data may be processed only with consent. You have the right to revoke your consent at any time.
5.2.2 For our own legitimate business purposes

We may also process your Personal Data for our own business purposes as the provider of the App. Summa will be an independent Data Controller for such processing, The legal basis for this processing is our legitimate interest, which allows us to use your Personal Data in a manner that is necessary and proportionate to our legitimate business objectives. We ensure that such processing is conducted in compliance with the Data Protection Legislation. Summa’s legitimate business objectives consist of the following:

  • Improving the core functionality of the App and customer experience;
  • Answering to business queries;
  • Providing the communication service with external and internal parties; and
  • Rating and billing of communication services.

5.3 What categories of Personal Data do we process

5.3.1 Data processed on behalf of the Business Customer and based on the legal ground(s) established by the Business Customer

We process the following categories of Personal Data:

  • Mandatory user information: When downloading the App, the required information required for proper functioning of the App is transferred to the respective online marketplace. This data consists of your username, email address and the customer number of your account, time of download, payment information and individual device ID. When you log into the App, we will process the user information provided by the Business Customer i.e., your employer, provided by the Business Customer i.e., your employer, connected to your profile. This data consists of your username and password.

 

  • Traffic data: When using the App, traffic data will be processed. This data is required to facilitate communication. Traffic data is generated and processed automatically when Business End Users communicate via the App and consists of information about the participants, calling and called number, the connected IP address, the date, the time, the duration of the call, the amount of data used, and when roaming, the network that was used.

 

  • Chat information: When using the messaging functionality within the App, we will process the data necessary to facilitate communication. This data consists of IP address, login data, chat messages, chat partner, status of the chat messages, and transmitted files. The data is collected in the App and then synchronized with the corresponding server on which the Summa software is installed to the extent necessary to provide the relevant functions. Only you as the Business End User or your corresponding chat party(ies) have access to the chat data stored solely in the App. Your employer as the Business Customer and the corresponding party that has provided you with access to the App, has access to the data located on the server.

 

  • CRM data: We may also process data contained in your Customer Relationship Management (CRM) system based on the access rights provided by the Business Customer. The App seamlessly integrates with your CRM system and our operating platform, allowing Business End Users to push notes, call logs, and access CRM information effortlessly. Additionally, through the backend function, your CRM data can be synchronized daily into a designated third-party Computer Telephony Integration (CTI) server. This allows Business End Users to search and access CRM information within the App.

 

  • Voice data: We may process voice data generated during App usage, including voicemail recordings and real-time call transcriptions. Business End Users can forward incoming calls to voicemail, recorded on our server. The audio is transcribed to text and sent to users via SMS and in-app. Additionally, call screening allows users to forward calls to a bot, with real-time conversation transcribed and presented in the App.
5.3.2 Data processed on behalf of the Business Customer and based on the consent provided by the Business End User

We process the following categories of Personal Data:

  • Contacts: When you make use of certain features, we ask you for your consent to use your contacts. We will not use this data if you do not consent. However, be aware that if you do not consent you may not be able to use all functions of our App.You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.

If you do consent, your data will be accessible from the App, and in some cases used to enrich data, for example your call history. This will only be synchronised and enhanced locally on the device you use. Additionally, when using the desktop version of the App you can add a contact to your personal Summa Contact phonebook.

  • Photo and media: When you make use of certain features, we ask you for your consent to use your photos and related media. We will not use this data if you do not consent. However, be aware that if you do not consent you may not be able to use all functions of our App.You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.

If you do consent and make use of the feature, your data will be stored on our servers relating to the corresponding party that has provided you with access to the App. In most cases, this will be your employer i.e., the Business Customer.

5.3.3 Data processed based on Summa’s legitimate interest

We process the following categories of Personal Data:

  • Contact information: If you want to contact us via email or via our contact form, we will process the information required to answer your query. This data consists of your email address and, if provided, your name and telephone number.

 

  • Usage statistics: We collect anonymous usage data to determine usage-related statistical indicator that we can use for business intelligence purposes to improve our App and make it more attractive for you as a Business End User. The data is anonymized from the outset and cannot be associated with an identified or identifiable person at any time (Data Subject).
5.3.4 Sensitive Personal Data

In our capacity as a Data Processor or independent Data Controller, we do not actively collect Sensitive Personal Data for any of the purposes described in this Privacy Statement.

5.3.5 Anonymous information

We may create anonymous, aggregated, or de-identified data from your Personal Data. We do this by excluding information that makes the data personally identifiable to you.

 

6 HOW DO WE STORE AND RETAIN YOUR PERSONAL DATA

We retain your Personal Data to provide high-quality service compliant with the Data Protection Legislation. Personal Data is stored as long as necessary to fulfil collection purposes, legal obligations, and reporting requirements. All data is stored on servers within the EEA.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure, and whether we can achieve the purposes through other means.

Personal Data may be anonymised in some circumstances rather than deleted. In this event, the anonymised data will no longer be traceable to you and is no longer considered Personal Data.

Uninstalling the App permanently deletes all data in the App. We have no influence over, and are therefore not responsible for, the duration for which data is stored on the servers.

 

7 WITH WHOM WE MIGHT SHARE YOUR PERSONAL DATA

If we deem it necessary for the abovementioned processing purposes, your Personal Data may be shared with one or more third parties, regardless of whether the third party is affiliated with the  , for the purpose of processing Personal Data in accordance with our instructions.

When third parties are given access to your Personal Data in line with the above, we undertake required contractual and organisational measures to ensure that your Personal Data are processed only to the extent that such processing is legitimate and necessary.

We may share your Personal Data with trusted third parties as follows:

7.1 Within the Enreach Group

The Enreach Group is composed of a wider group of undertakings with headquarters in the Netherlands, and entities located in the EU, the UK and Serbia. Summa may transfer your Personal Data to, or otherwise allow access to such data by other entities within the Enreach Group, which may use, transfer, and process your Personal Data for the purposes described within this Privacy Statement. We may also share aggregated data about our customers in the form of business intelligence and statistics with members of the Enreach Group.

7.2 With operators

In order to communicate via our App, it is necessary for us to transmit traffic data via any Wi-Fi or IP network operators. Summa uses several European infrastructure providers, and these operators therefore process Personal Data. These operators are independently Data Controllers for the processing of data within their respective networks.  For further information on the operators we use, please reach out to us using the Contact Information above.

7.3 With Data Processors

We may engage certain Data Processors who may process your Personal Data on our instructions. The Data Processors are contractually obliged to implement appropriate technical and organisational measures to ensure that your Personal Data is processed in accordance with our instructions. We may share your Personal Data with such Data Processors in relation to the hosting of your data, the App chat functionality, business intelligence analyses etc.

We only share your data with Data Processors that can provide sufficient guarantees that they will process your data securely and in accordance with the Data Protection Legislation. Our Data Processors cannot do anything with your Personal Data unless we have instructed them to do it. They will not share your Personal Data with any organisation apart from us or further sub-processors which must process your Personal Data on precisely the same terms and to the same high standards.

7.4 With regulators, authorities, and other relevant third parties

Where necessary for the processing purposes described above or where required by law, your Personal Data may be transferred to regulators, courts and other authorities, independent external advisors, and compliance and investigation teams.

 

8 HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA

We attach significant importance to your privacy. We therefore implement appropriate technical and organisational measures to ensure that the processing of your Personal Data is performed in accordance with the Data Protection Legislation, in particular ensuring an appropriate level of security. We implement suitable physical, electronic, and managerial procedures to safeguard and secure your collected Personal Data. The App uses TLS encryption for the data and audio connection to the server. The data is therefore not accessible by third parties.

 

9 YOUR RIGHTS

Under the Data Protection Legislation, you have a number of rights regarding the processing of your Personal Data within the App, as below:

9.1 Right to be informed about our collection and use of Personal Data

You have the right to be informed about the collection and use of your Personal Data. We ensure we uphold this right through this Privacy Statement.

9.2 Right of access

You have the right to access the information we process about you relating to our provision of the App. Summa does not have access to the data contained within the App. Within the App you can view your Personal Data yourself.

9.3 Right to rectification

You have the right to have incorrect or outdated information about yourself corrected. Summa does not have access to the data contained within the App. Within the App you can correct Personal Data yourself.

9.4 Right to erasure

In exceptional cases you have the right to have information about you deleted. Summa does not have access to the data contained within the App. Within the App you can delete Personal Data yourself.

9.5 Right to restrict processing

In some cases, you have the right to have the processing of your Personal Data restricted. If you exercise this right, we may only process your Personal Data with your consent, or for the purpose of establishing, asserting, defending, protecting, a significant public or private interest, except when we process your data for storage.

9.6 Right to object

In certain cases, you have the right to object to our otherwise lawful processing of your Personal Data.

9.7 Right to transfer your information (data portability)

In certain cases, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format.

9.8 Right to withdraw your consent

You have the right to withdraw your consent at any time in the circumstances where you have given us consent to process your Personal Data. Within the App or your system settings you can revoke your consent at any time.

9.9 Rights in relation to automated processing

An automated decision is one that is made by our systems rather than a person. You have the right to express your concerns and object to a decision taken by purely automated means under some laws such as the GDPR. You also have a right to request that a person review that decision.

This right is unlikely to apply to Summa’s use of your data, as any automated processing we carry out is unlikely to make decisions and would include human intervention. If you would like to discuss this in further detail, please contact us as set out above.

9.10 Right to lodge a complaint

You have the right to lodge a complaint with a competent supervisory authority.

Summa processes your Personal Data solely based on the instructions of the Data Controller, your employer. You can therefore invoke any of the above rights by reaching out to your employer.

For the Personal Data we process in our capacity as an independent Data Controller, you can invoke the rights above by reaching out to us on the Contact Information provided above. When you submit a request, we will ask you some additional questions to verify your identity. We will respond to your request as soon as possible, but at the latest within one month.

 

10 QUESTIONS OR COMPLAINTS

In case you have any questions with respect to the processing of your Personal Data as described within this Privacy Statement, you can contact our  and our DPO via the Contact Information above.

 

11 CHANGES

Summa reserves the right to modify or amend this Privacy Statement at any time. The effective date will be displayed below. It is the user’s responsibility to check this document regularly for changes.

Thank you for taking the time to read our Privacy Statement.

Version 2.0; February 2024