What personal information do we collect from the people that visit our blog, website or app?
Summa Communications B.V., 22.05.2019
1 What is this privacy statement for?
This is the privacy statement of Summa Communications B.V.. Summa develops and provides innovative communication services. As a result, Summa processes personal information. This privacy statement applies to all Summa services including, desktop, mobile and online applications or websites. Do you use any of these Summa services? Then this privacy statement is intended for you. In this privacy statement, you can read all about the information Summa collects, what Summa uses this information for, how Summa protects privacy and personal information, how long the information is stored and how you as a data subject can control certain aspects of this.
Summa does not share personal data with third parties, unless this is (1) a legal obligation, (2) is necessary for providing our services or (3) at the explicit request of the customer.
When we refer to “Summa”, we mean the Summa Communications B.V. entity that acts as the controller or processor of your information.
1.1 Legal requirement
Summa is legally obliged to store certain information of its customers for the purposes of legal investigations. Summa must cooperate with requests for personal information from the judicial authorities or other authorized government institutions, as well as with requests for information we process and store as part of our normal business operations. For example, information of your phone records or about your data usage. When the storage period has expired, stored information is destroyed or made anonymous.
1.2 Necessary for providing our service
Summa does not always supply its services directly but uses Wholesalers/resellers to supply its services. In such a case, it is necessary that we share the information that is required for the provision of certain services with Wholesalers/resellers. For example, when Summa shares information with its Wholesaler, the Wholesaler must comply with the conditions specified by Summa and the same privacy requirements we adhere to also apply to that company.
1.3 At the request of the customer
It is also possible that you as the customer use certain services/features for which personal information is used. For example, sharing your location with someone in an App that uses GPS data. In such cases you can use your phone to specify whether you wish to share this information, and then give this permission to the App provider. You can change your permissions at any time within the settings of your phone.
1.4 Who is responsible and who can I ask questions about my information?
As an end-user, your main contact should be your reseller. Naturally, we would be happy to answer any questions you have regarding either your personal information, this Privacy Statement, or how to exercise any of your statutory rights. You can ask your questions by sending an email to firstname.lastname@example.org or at our address below:
Summa Communications BV
Data Protection Officer
Verlengde Duinvalleiweg 102
1361 BR Almere
1.5 Where can I find the latest version of the Privacy Statement?
Rapid technological developments, legislation or changes to business processes mean that Summa has to alter this Privacy Statement regularly. The date at the top of this Privacy Statement shows when it was last updated. Summa can change this Privacy Statement unilaterally. We therefore recommend that you regularly check this privacy statement on https://summa.io for changes.
Summa has the duty and responsibility to maintain the confidentiality, integrity and availability of all information you provide. Summa is officially ISO 27001 certified. With this certificate we prove that our procedures comply to the highest international security standards. Information security guidelines are applied to all our processes, systems and services.
2 What information do we collect?
2.1 Personal and Account Information
When you use a service/app from Summa, or when you contact us, Summa processes your personal information. Personal information is information that can be traced to an individual. The word ‘process’ has a very broad definition. It refers to all actions relating to personal information, including the collection, storage, changing, viewing and using, provision, grouping, shielding, erasing and destruction of information.
The information requested by Summa (in some cases provided by your employer/account admin) when you use one of our services is your: name, address, phone number, email address and password. In some apps an avatar can also be uploaded by you (optional) that will be visible to other users within your organization.
When you want to make use of the Reach app or call forwarding functionality in one of our apps, the app will request permission access to your contacts. Once this permission has been provided by you, you can withdraw the access at any time in the settings of your phone. We use the information only to make changes in call routing based on your personal preferences. When you make use of call forwarding to one specific number or contact, we only store the specific number/contact. Creating reach profiles mostly require us to store your entire contact list to provide the best experience.
2.3 Voicemail messages and greetings
Some of our apps provides you with the possibility to record greetings for use in your voicemail or Reach. When you make these recordings, they are stored within our platform to provide voicemail capabilities. Voicemail messages left on your number will also be stored, and these will be available to you for as long as you decide to keep it. You can manage/delete these messages from within the app.
2.4 Device info
When using our apps, we process some information about your device for system management and troubleshooting. This includes the brand and type of device, operating system used and your IP address. These logs are stored no longer than two weeks.
2.5 Communication data
We make a separation between traffic data and the actual content of the communication. When you place a call (audio or video + audio) we transfer the content of the communication to the other party. Your conversations are private, and we do not store this data within our platform. Traffic data is something we do store. It concerns any data that is required to set up communication and contains such things as the sender and destination numbers called, the date, time and duration of the call, and the fees that were charged for this.
In case you make use of the chat/messaging services, we do store the content of the communication to provide you with this service and give you the ability to read your chat history.
2.6 Information you share
We also process information that you choose to share through our apps. For instance, sharing your location, using Fileshare to store or share files and possible other data you decide to disclose.
When you visit our head office, you will be registered as a guest. We use this registration for safety purposes, so that we can quickly evacuate the premises in case of a disaster, without leaving anyone behind.
We also use camera recordings as a safety measure in our offices. We do this to protect our guests, personnel and the building. You will be clearly informed about the presence of cameras when on our premises.
3 What do we use this information for?
3.1 Providing services and invoicing
Summa uses the aforementioned information primarily for the provision and improvement of services purchased by you. For example, setting up a phone call and providing the chat history.
Based on these services and the use thereof, Summa drafts an invoice. This invoice shows the fees charged for each service, specified by type of use. You can see fees incurred abroad, call costs, data usage and more. The invoice does not show an overview of all calls or data sessions. A detailed overview, for monitoring or administrative purposes, can be found in Operator.
3.2 Traffic management, network planning and quality of services
For the purpose of maintenance and the improvement of our platform, we analyze information about the use of our network. We do this so that we can, among other things, redirect traffic in case of potential overloading, but especially so that we can prevent this by planning and implementing targeted improvements. In addition, we can use the information to see when malfunctions occur on the platform.
3.3 Investigation and preventing security issues and abuse.
Based on analyses of call and usage behavior, Summa can proceed to restrict certain destinations when excessive usage is detected. Higher usage than the average call behavior may indicate fraud. A blockade can limit fraud and misuse and prevent you from receiving a huge bill for fees that you have not incurred yourself. Summa also uses advanced techniques (such as firewalls, spam filters and virus scanners) to protect against security breaches, viruses, spam and malware.
3.4 Caller ID
Summa always displays your phone number to the called number. This means that your number will be visible to the call recipient on the display of their phone. This can be turned off by calling anonymously. However, we are legally obliged to always reveal your number when you call an emergency number.
3.5 Legal requirements
In some cases, Summa is legally required to give your information to third parties. For example, the provision of information in the context of a criminal investigation, to authorities, and – at your request – to other providers for the purposes of shielding the called number in the records.
4 Data Retention
Summa processes personal identifiable information for as long as required to provide the service to the customer. Summa may also retain this information for as long as necessary for the other purposes described in this Privacy Statement.
When using Coligo Meetings, meeting hosts have the option to make recordings. These recordings are made and stored locally on the client of the host. Summa does not process this information in any way. When creating, storing or otherwise processing such recordings, the host is fully responsible to be compliant with all applicable laws, rules and regulations, including but not limited to data privacy laws.
6 Viewing and correcting your personal information
6.1 How do you view your personal information?
If you wish to view your personal information, then you can submit a request to us to provide the information. This means that you can ask which personal information about you is registered and for what purposes it is being used. You can submit this request by email. Our email address is email@example.com If you are a Summa Wholesaler or you use our services as an end user via our Wholesalers, then you can view the personal information via Operator Online as both Wholesaler and end user. Should you have any questions about this as end user, then you can pose them to your supplier, our Wholesaler.
6.2 How do you correct your personal information?
The Summa reseller can correct the personal information of its customers, the end users. The Wholesaler cannot correct its own personal information in Operator. To do this, they must submit an Operator ticket to Summa, after which an answer will be given within 2 weeks. If you are a Wholesaler or end user, you can submit a request for correction by email. Our email address is firstname.lastname@example.org.
6.3 Right of erasure & Right to be forgotten
If you choose to stop using Summa’s products you can terminate your subscription by contacting your reseller. By standard procedure all personal identifiable information will then be removed after the time needed for Summa to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
6.4 Right to object
You can oppose the processing of personal information by Summa if your personal information is used for purposes that are not necessary for the implementation of an agreement or for compliance with legal obligations. You can submit your objection by email. Our email address is email@example.com.
7 Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Summa’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Dutch Data Protection Commissioner, which is Summa’s lead supervisory authority in the European Union.
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