Blank Point Communications, Inc. and its worldwide affiliates and subsidiaries (collectively “Blank Point”, “us”, “we”, “our”) are committed to protecting your privacy while providing you with a positive experience on our website and in using our products and services.
This Privacy Notice (“Notice”) explains our privacy practices and provides information on how and why we collect, use and share your personal information through our interaction with you in relation to our products and services, when you visit our websites, and associated sub-domains ("Website"), when you use our desktop, IP desk phone, mobile applications, our integrated business apps or our lab solutions ("Apps") or when you use our cloud communications and collaboration solutions ("Services"). The Notice also describes choices that may be available to you regarding use, access, deletion and correction of your personal information.
Additional information on our personal information practices may be provided in supplemental terms and conditions, supplemental privacy statements, or notices provided prior to or at the time of data collection.
We recommend that you read this Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Notice, then you can click on the relevant link below to jump to that section.
HOW WE COLLECT YOUR PERSONAL INFORMATION
· We collect your personal information when you actively provide it to us through your interactions with us.
· We may automatically collect personal information from you as you use our Apps and Services, or visit our Websites as a user or a participant, including recording communications, when enabled.
· We may receive personal information about you from a business or commercial partner or another user of our Apps and Services.
· We may infer or derive personal information based on other information we collect, such as with Service features that provide conversational intelligence.
WHAT PERSONAL INFORMATION WE COLLECT
Personal Information you actively provide to us or we collect from third parties, business partners, other users, and service providers
Your Contact Information/Identifiers:
· Name, username, email address, phone number, identity documents, IP address, and any other identifiers a user provides when accessing or using the Service.
Your payment information:
· Billing name, address, and credit card or other payment information.
· Social media profiles, LinkedIn URLs and custom profiles.
Personal information we collect through your interactions with Blank Point Communications, our Websites, Apps and Services as a user or a participant
· Account holders’ usernames and account numbers, Blank Point Communications phone number, language preference, title, department.
Information about your use of non-Blank Point Communications Services through integrations with our Websites, Apps and Services or otherwise:
· Social media account information, single-sign-on service tokens, Google/Apple/Microsoft sign in tokens.
· Files, any content of communication or other information you or another user or participant upload, provide, grant access to or otherwise implement.
*Note that users and participants control the content that they provide, and it may include any category of personal information.
Service Usage Data:
· Internet Protocol ("IP ") address, MAC address, other device ID (“UDID”), device type, operating system type and version, client version, type of camera, microphone or speakers, connection type and other related information.
· User feedback ratings, internal feature usage analytics, usage logs, cookie identifiers.
· Traffic data about the communications that take place through our platform (such as chat, video conferencing), network monitoring data.
· Call Detail Records produced by a telephone call or other telecommunications transactions. The Call Detail Record contains various attributes of the call, such as time, duration, completion status, source number and destination number.
· Fraud data such as blacklist history and security logs.
· Metadata such as session logs and join & leave time of participants.
· Log data including IP address, Internet Service Provider ("ISP"), browser type, referring/exit pages, operating system, date/time stamp, and/or clickstream data.
· Publicly available data from End User accounts.
· Information about where you are located when using the Services.
· A user hosting a phone or video conferencing meeting may choose to record the session, and if so, the host is responsible for obtaining any required consent from you. Blank Point Communications helps hosts obtain consent from other users by providing visual and audio cues to alert users of a recording.
· As with all user content, recordings may contain personal data and may be stored with Blank Point Communications at the request of the meeting host. A meeting host may choose to store a recording of a meeting on the host’s local storage device, not with Blank Point Communications. When a host chooses to do that, Blank Point Communications does not have any control over the recording. Transcripts, which may also contain personal data, are treated the same way as recordings.
· Blank Point Communications may access or use the recording or transcripts stored with us as requested by the host or customer (such as providing technical support), to improve our Services, or as otherwise permitted by our agreement with the customer.
· Content of blocked SMS messages that violate our spam rules.
Inferred or derived data:
· Inferred or derived data may include a summary of information included in recorded content processed by conversational intelligence. Users and participants control the content they provide.
Your communications with us:
· Surveys, calls (including recordings), emails and messages, etc.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for the following purposes: Communicate with you; Verify your identity to prevent fraud in compliance with applicable law; Create your account; Provide you with Blank Point Communications Services including respond to your requests for support; Develop and improve the Blank Point Communications Services; Manage your order and our customer relationship; Market and advertise our Services; Perform surveys; Provide internal training and ensure quality assurance; Improve and optimize your interactions with our teams; Connect you to and optimize your experience using our Website, Apps, and Services; Provide customers dashboards and reports; Conduct fraud and threat analysis and, detect and prevent spam or unlawful or abusive activity or other violations of our (“AUP”); Monitor performance of our data centers and networks; Conduct analytics to improve Blank Point Communication’s Website, App and Service performance; Personalize your experience with our Websites, Apps and Services; Comply with applicable law including those regulating call detail records; and Perform billing for our Services.
We may use artificial intelligence, machine learning, or other similar technology to provide, maintain, support, and improve our Services.
Lawful basis for processing personal information (EEA, Switzerland and UK only)
When we collect personal information about you in connection with offering our Website, Apps or Services within the European Economic Area (EEA), Switzerland and the United Kingdom (UK), our lawful basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you where we need the personal information to perform a contract with you (e.g., when you order a Service), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (e.g., to market and provide our Services). In some cases, we may also have a legal obligation to collect and process the personal information in question (i.e. Service Usage Data) or we may process your personal information where we have your consent to do so. You may withdraw your consent at any time as instructed in the communications or in the Apps or Services, or you contact us as explained below.
Limited Use for APIs
Blank Point Communication’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
COOKIES AND SIMILAR TECHNOLOGIES
HOW, WHY, AND WHAT PERSONAL INFORMATION WE SHARE WITH THIRD PARTIES
We do not sale your information to any Third Party source.
HOW WE RESPECT YOUR PRIVACY RIGHTS
We provide you with the opportunity to access, review, modify, and delete your personal information that we process.
Requests from End Users regarding personal information we process on behalf of our Customers as a Data Processor
In general, when processing the content of communications such as voicemails, faxes, recordings etc. in connection with our Services, we do so on behalf of our customers and in accordance with their instructions as a data processor. This means that if you believe Blank Point Communications may have collected or stored personal information about you on behalf of a Blank Point Communications customer as a data processor or if you wish to access, review, modify or delete any content of your communications, under applicable law or otherwise, you should direct your request to that Customer.
Your Additional Privacy Rights as an EEA/UK/Swiss Resident
· Access: You can request more information about the personal information we hold about you. You can request to download a copy of the personal information.
· Rectification: If you believe that any personal information, we are holding about you is incorrect or incomplete, you can request that we change, correct, or supplement the data. If you are a customer, you can also correct some of this information directly by logging into your Service account. Please contact us as soon as possible if you notice any inaccuracy or incompleteness.
· Objection: You can let us know that you object to the collection or processing of your personal information for certain purposes.
· Restriction of Processing: You can ask us to restrict further processing of your personal information. (This just means you can ask us to stop using it for the reasons we have been using it.) This may mean that we have to delete your account.
· Erasure: You can request that we erase some or all of your personal information from our systems. You can also delete some of this information directly by logging into your Service account, if you are a customer.
· Portability: You can ask for a downloadable copy of your personal information in a machine-readable format. You can also request that we transmit the data to someone else where it’s technically possible.
· Withdrawal of Consent: If you have consented to our use of personal information for a specific purpose, you have the right to change your mind at any time. Any such decision will not affect any processing that has already occurred nor will it affect processing of your personal information conducted in reliance of lawful processing grounds other than consent. Withdrawing your consent may mean your access to the Services will be limited or suspended, and your accounts may be terminated, as applicable. Where you withdraw your consent, but we are using your information because we or a third party (e.g. your employer) have a legitimate interest in doing so, or we have different legal basis for using your information (for example, fulfilling a contract with you), we may continue to process your information, subject to your rights to access and control your information.
· Right to File Complaint: You have the right to lodge a complaint about Blank Point Communications’s practices with respect to your personal information with your supervisory authority (contact details available here: for the EU; for the UK; and for Switzerland).
· No Automated Decision Making: We do not undertake decision-making about you based solely on automated processing, including profiling; however, certain features of our Services could be used by our customers for decision-making purposes.
Your Additional Privacy Rights as a Resident of Certain U.S. states
We will not share your personal information with third parties for the third parties’ direct marketing purposes unless you have agreed to such disclosure.
We will verify your request using your name and email. Depending on the nature of your request, we may need additional information to verify your identity. You may authorize an agent to make a request on your behalf to exercise your privacy rights under applicable Georgia privacy laws.
If you are a Colorado resident, you may have the right to appeal Blank Point Communication’s denial of an individual rights request.
HOW WE KEEP YOUR PERSONAL INFORMATION SECURED
Keeping your information secure is important to us. We have taken appropriate steps designed to reduce the risk that your personal information may be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction.
For more information on Blank Point Communications security measures, please visit the Security Trust Center.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We will retain your personal information for no longer than is necessary to fulfill the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.
Where we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.
INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. Specifically, information collected in the European Economic Area ("EEA") and the UK, may be transferred to and stored on our servers in the United States and Switzerland, and potentially in other countries where our group companies and third-party service providers and partners operate. These countries may have data protection laws that are different to the laws in your country (and in some cases, may not be as protective).
Data Privacy Frameworks (EU-U.S. DPF, UK Extension, Swiss-U.S. DPF)
Data processed and purposes of data processing
As a processor to our customers, Blank Point Communications processes personal data that customers choose to submit to the services as customer-generated content, call detail records, usage data, and account information. The purposes for such processing is the provision, maintenance, support, and improvement of the services.
Independent Recourse Mechanism
If you have any questions, comments or concerns about this Notice, you may contact us at [email protected]. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Blank Point Communications commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. Under certain conditions, individuals may invoke binding arbitration through the Data Privacy Framework Panel. For more information, please see Annex I of the EU-U.S. Data Privacy Framework Principles.
The Federal Trade Commission has jurisdiction over Blank Point Communication’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
Lawful Requests for Personal Information
Please see for information regarding how Blank Point Communications responds to lawful requests by public authorities for Blank Point Communications to disclose personal information.
Individual rights to access and to limit use and disclosure
Please see the relevant section in this Notice for information regarding how individuals can exercise their rights to access their personal data and to limit the use and disclosure of their personal data.
Liability for Onward Transfers
In the context of an onward transfer, Blank Point Communications has responsibility for the processing of personal information it receives under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. Blank Point Communications shall remain liable under the EU-U.S. DPF Principles if its agent processes such personal information in a manner inconsistent with the principles, unless Blank Point Communications proves that it is not responsible for the event giving rise to the damage.
Standard Contractual Clauses
Blank Point Communications has taken (i) appropriate safeguards, including adherence to the Standard Contractual Clauses adopted by the European Commission for the transfer of your personal information outside the EEA, the UK and Switzerland to Blank Point Communications, and (ii) further technical and organizational measures to ensure that personal information will remain protected in accordance with this Notice and any applicable laws.
Blank Point Communications does not knowingly provide products or services directly to children under the age of 16, or knowingly collect or solicit personal information from or about children under the age of 16 outside of the school offering, which is subject to the Children’s COPPA notice. If you believe that a child under the age of 16 has disclosed personal information to Blank Point Communications outside of the school offering, please contact [email protected]
This Notice does not apply to, nor are we responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website or Apps link including but not limited to social media sites. The inclusion of a link on the Website or Apps does not imply our endorsement of the linked site or service. You should check the privacy notices of those sites before providing your personal information to them.
BLOGS AND FORUMS
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blog or community forum, you can submit a request through our online portal. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all users to exercise caution when providing personal information in blogs and community forums.
UPDATES TO THIS NOTICE
We may update this Notice from time to time in response to changing legal, technical, or business developments. If we make changes to our Notice, we will post those changes on this page in addition to updating the "Last Updated" or effective date at the top of this webpage. If we make material changes, we will notify you either by emailing you or by posting a notice of such changes prominently on this page prior to such material changes taking effect.
If you have any questions, comments or concerns about this Notice, please e-mail our data protection officer at [email protected] Or, you can write to us at:
Blank Point Communications, Inc.
Attn: Blank Point Communications Chief Privacy Officer
3343 Peachtree Rd. 145-204
Atlanta, Georgia 30326