Effective Date: 3/16/2020
Invoca, Inc. (“Invoca”, “We”, “Us” or “Our”) is committed to protecting your privacy and ensuring you have a positive experience on our website and when you use our products and services. Invoca owns and operates a proprietary call intelligence technology platform (“Invoca Platform”). Invoca provides networks, advertisers, agencies, publishers, and other businesses (“Clients”), with marketing automation services (the “Services”) using unique phone numbers combined with database management.
This policy outlines how we collect, use, and disclose Personal Data. It covers all Personal Data that you affirmatively provide during your online and offline interactions with us, information that we passively collect when you interact with our products and services, and information that we collect about you from our Clients and third parties. The policy is applicable worldwide, and also describes the rights you may have to control our use of Personal Data and how to exercise those rights.
Collection of your Personal Data
Invoca collects Personal Data directly from individuals (data subjects), from Clients, and from third parties on behalf of our Clients.
Categories of information collected from consumers
Invoca collects your Personal Data directly when you interact with our website or call us. We may gather the following categories of Personal Data about you:
Categories of information collected from our clients
If you are a Client, Invoca collects Personal Data directly from you through the sign up and registration process and through cookies or similar technologies. We may gather the following types of Personal Data about you:
Mostly, we gather this Personal Data directly from you or your devices. Some of this collection happens when you affirmatively send us information. You can choose not to provide Personal Data to Invoca, but you may be unable to access certain options and services if they require Personal Data that you have not provided. Some of the information collection happens passively – that is, the data is automatically collected when you interact with the Invoca Platform and our Services. You can adjust certain settings to reduce the amount of Personal Data we passively collect from you when you use our Products.
Categories of information collected from or on behalf of our Clients
Invoca, as part of our Services, collects or receives Personal Data from consumers who interact with our Clients’ websites and assigned phone numbers. Depending on how a Client configures and uses the Invoca Platform and Services, this may include the content of recorded telephone calls. This information, which we maintain exclusively on behalf and at the direction of our Clients, may include sensitive Personal Data including, without limitation, financial/credit card account data and/or health information. Invoca provides tools to redact/prevent recording of medical and financial health information. Invoca advises Clients to use such tools to prevent the collection and maintenance of sensitive Personal Data, but cannot guarantee that Clients use these tools in all cases. Our clients control this Personal Data and its collection and use is governed by their respective privacy policies, which may differ from Invoca’s policy. We encourage consumers with questions or requests related to Personal Data collected by Invoca’s Clients to contact those entities directly, and we will refer any consumer requests for Personal Data maintained by Invoca on behalf of a Client to that Client.
How we use Personal Data
Invoca processes Personal Data with consent and/or as reasonably necessary to provide our Platform and Services, operate our business, and provide the Platform and Services on behalf and at the direction of our, and for other legitimate commercial and business purposes including:
Disclosure and Sharing of Personal Data
Invoca does not sell Personal Data.
Invoca may disclose Personal Data to affiliated entities and third-party service providers to help us do all of these things. We forbid our service providers from selling Personal Data they receive from us or otherwise collect or process on our behalf, and we limit their use of that Personal Data to that which is necessary to perform the services we have asked of them, or as otherwise required by law.
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
Security of your Personal Data
Invoca takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, exfiltration, or destruction of data. Invoca restricts access to personal information to those employees or third parties who have a need to know such information for the purpose of effectively delivering Invoca Services by means of user login and password requirements. Invoca routinely evaluates its data security practices to identify security threats or opportunities for improvement. No transmission of data over the Internet or the phones is guaranteed to be completely secure. It may be possible for third parties not under the control of Invoca to intercept or access transmissions or private communications unlawfully. While Invoca strives to protect personal information, it cannot ensure or warrant the security of any information a user transmits. If you have any questions about the security of your personal information, you can contact us at email@example.com.
Special Information for residents of California
If you are a California resident, you may have the right to receive a free, yearly accounting of the following information for the preceding calendar year: (1) information identifying each third-party company to whom we may have disclosed, within the past year, personally identifiable information about you for direct marketing purposes; and (2) a description of the categories of personally identifiable information disclosed. You may make such a request by emailing firstname.lastname@example.org.
Commencing on January 1, 2020, if you are a resident of California, you may have additional rights.
You may have a right to know about personal information about you that we have collected, disclosed, or sold, including :
Please note that Invoca does not collect, use, or sell personal information about minors between 13 and 16 years of age without their affirmative authorization, and we do not collect, use, or disclose personal information about children under 13 without verifiable parental permission.
In addition, upon receipt of a verifiable request from you establishing your identity, you may have the right to know about the specific pieces of personal information that we have collected about you and/or shared with third parties in the preceding 12 months.
You may also have the right to request deletion of personal information about your that we have collected or maintain, which we will honor subject to certain limitations set forth in California law.
Prior to honoring a request to know information about specific pieces of information or a request to delete Personal Information, Invoca will verify your identity. If you have a password protected account, we will verify your identity using that account. Otherwise, Invoca will ask you to provide one or two pieces of information (e.g., proof of name, address, or phone number) to protect your privacy.
For more information or to submit a request to know or delete Personal Information, please visit our online portal, call 1-888-989-4996, or contact our us at email@example.com. We will respond to all such requests in a timely fashion and comply with such requests as and to the extent required by applicable data protection law. We reserve the right to reject such requests to the maximum extent allowable by applicable law.
Special Information for residents of the European Economic Area (EEA) and Switzerland
Invoca processes data about residents of the EEA and Switzerland in compliance with applicable law including, without limitation, the General Data Protection Regulation and the Swiss Federal Data Protection Act.
Lawful Basis; Controller and Processor Arrangements
Invoca processes Personal Data about Clients and consumers in the EEA and Switzerland as a Controller on its own behalf and as a Processor on behalf and at the direction of our Clients. In each case, our processing of Personal Data is based on the legitimate and proportionate interests of Invoca and/or its Clients. In certain cases, such as where Personal Data may be used for marketing purposes, we will seek your consent for processing, and that consent may be withdrawn at any time
Transfer and Storage of Personal Data
Invoca’s Platform and Services are hosted and operated in the United States (“U.S.”) through Invoca and its service providers. We may transfer your Personal Data to the U.S., to any Invoca affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using our Platform or Services or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Invoca participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield. Invoca is committed to subjecting all Personal Data received from EU member countries, Switzerland, and the United Kingdom, in reliance on the Privacy Shield Frameworks, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List, https://www.privacyshield.gov/list.
Invoca is responsible for the processing of Personal Data it receives under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Invoca complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, Switzerland, and the United Kingdom, including the onward transfer liability provisions.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, Invoca is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Invoca may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you can invoke binding arbitration when other dispute resolution procedures have been exhausted.
Standard Contractual Clauses
In certain cases, Invoca will transfer Personal Data from the EU in accordance with the European Commission-approved Standard Contractual Clauses, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.
Data Subject Rights
As a resident of the EEA or Switzerland, you may have certain rights with respect to Invoca’s processing of Personal Data about you.
In order to make such a request of us, please visit our online portal, call 1-888-989-4996, or contact our us at firstname.lastname@example.org. We will respond to all such requests in a timely fashion and comply with such requests as and to the extent required by applicable data protection law.
As mentioned above, Invoca’s website offers publicly accessible blogs or community forums. Any user of the Invoca website should be aware that any information provided in these areas may be read, collected and used by others who access these sites. Our blog is also managed by a third-party application that may require you to register to post a comment. We moderate information posted to the blog. To request removal of any personal information from the Invoca blog or other community forum, contact us at email@example.com.
Invoca will only post Client testimonials with the Client’s consent to do so. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
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