Invoca Privacy Policy

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.

As used in this Privacy Policy, “Personal Data” means any information that can be used to identify or is reasonably linkable to a specific person or, in some cases, household.  It may include, but is not limited to, name, email address, postal or other physical address, credit or debit card number, title, and other information linked to a persistent identifier assigned or linkable to the individual.

This policy may be updated from time to time to reflect changes in operational practices or regulatory requirements, so we recommend that you review our Privacy Policy when returning to our website. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

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:

  • Information commonly used to identify you, such as your name, email address, phone numbers, and other similar identifiers
  • Information about your device, network, and internet connection, such as your IP address(es), MAC address, other device ID (UDID), device type, operating system type and version, and browser type and version
  • Information about your usage of the Invoca site, including the pages and files viewed and the referrer URL and exit pages
  • Information about your calls to us, including phone numbers and recordings
  • Other information you provide or create, such as comments you make on articles and blogs or posts in community forums

Mostly, we gather this Personal Data directly from you and/or your devices.  Some of this collection happens when you affirmatively send us information, like when you use the chat function on our website or submit a request for a Services demonstration.  Some of our collection happens passively – that is, it’s automatically collected when you interact with our Website.  You can adjust certain settings to reduce the amount of Personal Data we passively collect from you when you use our website, such as setting your browser to refuse cookies or automatically terminate cookies at the end of your session.

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:

  • Information commonly used to identify you, such as your name, username, physical address, email address, phone numbers, and other similar identifiers
  • Information about your job, such as your title and employer
  • Credit/debit card or other payment information
  • General information about your product and service preferences and behavior 
  • Information about your device, network, and internet connection, such as IP address(es), MAC address, other device ID (UDID), device type, operating system type and version, and client version
  • Information about usage of or other interaction with our Services, including actions taken, date and time, frequency, duration, quantity, performance information, and other feature usage information
  • Other information the Client uploads, provides, or creates while using the Services including, without limitation, call recordings, which may include Personal Data about consumers.

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:

  • To provide, run, personalize, improve, operate, maintain, and, in some cases, market the Invoca Platform and our Services 
  • As a service provider, to facilitate access to and use of that information by our Clients in pursuit of their individual commercial and business purposes and subject to their privacy policies
  • For accounting, auditing, and performance reporting
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity
  • To understand website usage, administer the website, determine the relevance of content, fix bugs, and conduct internal research in order to enhance the Invoca Platform and Services
  • To keep you up to date on the latest Invoca Platform and Services announcements, special offers, and other information
  • To comply with our legal obligations, protect our rights and the rights of third parties

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. 

Data Retention

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 legal@invoca.com.

Special Information for residents of California

As required by the California Consumer Privacy Act (CCPA), this Privacy Policy describes the categories of Personal Data collected, processed, and disclosed by Invoca, the categories of sources for that data, and the business or commercial purposes for which that data is collected, processed, and disclosed.   

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 legal@invoca.com.

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 :

  • The categories of personal information about you that we have collected in the preceding 12 months and the categories of sources of that information,
  • The categories of sources from which we have collected that information in the preceding 12 months,
  • The commercial or business reason(s) we have collected, used, disclosed, or sold that information, and
  • The categories of third parties to whom we have disclosed or sold that information in the preceding 12 months.  

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 privacy@invoca.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.

  • Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data. 
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. In certain cases you can correct some of this information directly by logging into your service account. Please contact us as soon as possible if you notice inaccurate or incomplete Personal Data associated with your account.
  • Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems. 
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you may have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
  • Right to File Complaint: You have the right to lodge a complaint about Invoca’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

In order to make such a request of us, please visit our online portal, call 1-888-989-4996, or contact our us at privacy@invoca.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.

Other

Public Forums

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 legal@invoca.com

Testimonials

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 legal@invoca.com.

Third-Party Web Features

The Invoca website and Platform may include links to other websites or may utilize framing techniques to serve content to/from our partners while preserving the look and feel of our website.  If you submit personal information to any of those sites, your information is governed by that third party’s privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Invoca’s corporate website (www.invoca.com) includes social media features and widgets, such as the Facebook “Like” button and the “Share This” button, or other interactive mini-programs that run on the site.  Social media features and widgets are either hosted by a third party or hosted directly on the Invoca website.  A user’s interactions with these Features are governed by the privacy policy of the company providing them.

Contact Us

If you have any privacy-related questions or comments related to this privacy policy, please send an email to legal@invoca.com. You can also contact us by writing to this address:

Invoca, Inc. 
Attention: Privacy
419 State Street
Santa Barbara, CA 93101