Effective March 2015
West Unified Communications Services is a leading provider of conferencing and collaboration services. We value the privacy of our customers, users, and any individual who accesses or uses the West Unified Communications Services websites, products, and services (collectively, the “Services”). This Statement discloses West Unified Communications Services’s practices with respect to the collection, processing, use and disclosure of user information. This Privacy Statement applies to all Personal Information and Sensitive Personal Information collected and processed by West Unified Communications Services whether in electronic, paper or verbal format. Throughout this Statement, if you are based in the EMEA region, the term “West Unified Communications Services” predominantly refers to West Unified Communications Services Conferencing Services Limited (a company registered in England and Wales with registered number 2775270 and whose registered office is at Building C, Imperial Gate Business Park, Barnwood, Gloucester, GL4 3HX, UK), except where the relevant Services are provided by another West Unified Communications Services group company, in which case references to West Unified Communications Services shall, in respect of those Services, be references to that West Unified Communications Services group company. As West Unified Communications Services is a global provider, the provision of the Services to users may also require Personal Information to be shared with other West Unified Communications Services group companies around the world. All such West Unified Communications Services group companies are bound by privacy policies, confidentiality and data transfer agreements as appropriate. In addition, West Unified Communications Services Inc. adheres to the Safe Harbor Framework concerning the transfer of Personal Information from the EEA and Switzerland to the United States.
Collection and Use of Personal Information
In this Privacy Statement, "Personal Information" is any information or data that can be reasonably linked to a data subject, or to a specific computer or other device. "Sensitive Personal Information" is a subset of Personal Information and is data about children, financial information, health information (including PHI as defined by the Health Insurance Portability and Accountability Act), Social Security or other national identification number, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life, criminal convictions, and precise geolocation data.
By providing your Personal Information, you opt-in and consent to its collection, use, disclosure, sharing, and transfer as described in this Privacy Statement.
In connection with the access and use of the Services, you may choose to provide us with your Personal Information when, among other things, you register on the West Unified Communications Services website, use one of our Services, fill out a survey, register to attend a seminar; make a request for information, ask to be included in an email or other mailing list; or enter a sweepstakes or contest through the West Unified Communications Services website or more generally when you submit your Personal Information to West Unified Communications Services for any other reason. We may also capture your telephone number when you use our Services.
Please be aware any information you choose to share on any publicly available portion of the Services or with third parties, including without limitation your personal page, chat messages, forum posts, blogs, resumes, job applications, business cards, or any other information you provide may be collected and used by third parties or other attendees without restriction.
West Unified Communications Services Primary and Secondary Use
West Unified Communications Services will use the Personal Information you provide us in these circumstances to the extent required for the delivery of the Services (such as account set up, billing, debt-collection, customer services, reporting), to satisfy West Unified Communications Services's legitimate business interests (such as customer analysis, fraud-prevention and internal marketing study and analysis) and to provide information you request from us ("Primary Use").
West Unified Communications Services may provide your Personal Information to business partners or third party suppliers that assist West Unified Communications Services in processing such Personal Information for Primary Use (such as partners or agents who are involved in delivering the Services you have ordered or used, credit-reference agencies, fraud-prevention agencies, business-scoring agencies or other credit-scoring agencies, debt-collection agencies or other debt-recovery organizations).
Unless you instruct us not to do so, and unless prohibited by law, West Unified Communications Services (either directly or using business partners or third parties used by West Unified Communications Services) may also use the Personal Information you provide us to contact you regarding additional or new services and features offered by West Unified Communications Services, special offers by West Unified Communications Services, or important information regarding West Unified Communications Services ("West Unified Communications Services Secondary Use").
West Unified Communications Services requires any such business partners or third parties used to assist West Unified Communications Services for Primary Use or West Unified Communications Services Secondary Use to enter into agreements with West Unified Communications Services including contract terms substantially the same as those contained in this Privacy Statement, prohibiting disclosure of the Personal Information to others and restricting its use in providing the contracted Services of West Unified Communications Services.
Third Party Services
West Unified Communications Services may also provide your Personal Information to business partners in case you purchase services of third parties from West Unified Communications Services ("Third Party Services"). Third Party Services are not directly controlled operated or maintained by West Unified Communications Services and West Unified Communications Services's Privacy Statement does not apply to such Third Party Services. Any use of Third Party Services is subject to the privacy statement of the Third Party Services providers. For any Third Party Services you purchase from West Unified Communications Services, we recommend you consult the respective privacy policies of the Third Party Services providers to determine how they will handle your Personal Information.
Third Party Secondary Use
West Unified Communications Services may also provide your Personal Information to other companies who may contact you regarding products, services, and offers that may be of interest to you, but that are not directly related to the Services or the West Unified Communications Services website ("Third Party Secondary Use"). Third Party Secondary Use is subject to the privacy statement of such other companies.
Other Legitimate Use
West Unified Communications Services may also use your Personal Information to create anonymous data records or aggregations of data, to perform statistical analyses and for other purposes, by omitting or removing information that makes the data personally identifiable to you.
West Unified Communications Services will keep your Personal Information for as long as we have to by law. If there is no legal requirement, West Unified Communications Services will keep your Personal Information no longer than strictly required for legitimate purpose for which it was collected.
Any Sensitive Personal Information you provide us will only be used to implement the specific activity or event it was submitted for and will then be destroyed.
As we noted above, we will not use your Personal Information or Sensitive Personal Information for any Third Party Secondary use unless you affirmatively choose to participate in such Secondary Use. You may also stop delivery of informational or promotional mail from us by following the instructions included in the informational or promotional mail itself.
When you register to use any of the Services offered by West Unified Communications Services, West Unified Communications Services will send you a confirmation of your registration showing the Personal Information we obtained from your registration. Also, we will take reasonable steps to give you the opportunity to correct inaccuracies in the Personal Information we retain concerning you and delete Personal Information concerning you upon your request, unless the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than you would be violated. To correct inaccuracies in your Personal Information or delete your Personal Information, or for any other questions, please contact our privacy team through the directions at this link, or by mail, as directed in the “Contact Us” section, below.
You are informed and hereby consent that the whole or any part of your Personal Information in connection to the Services, may be processed by West Unified Communications Services and its affiliates and subcontractors in the United States, in the European Union and the rest of the world, and may be transferred outside the country in which you provided the Personal Information.
International transfers and the U.S.-E.U. Safe Harbor and the U.S.-Swiss Safe Harbor
By accessing and using the Services and providing us with the requested Personal Information, you consent to the collection and use of the information in accordance with this Privacy Statement including transfers from the EEA and Switzerland to the United States or elsewhere where privacy protections may not have been deemed “adequate” by the EEA, Switzerland, or your country of residence. Individuals who do not consent to the collection, use, or disclosure of their Personal Information as outlined in this Statement should not provide any Personal Information to West Unified Communications Services through the Services, the West Unified Communications Services website, or in any other manner.
In accordance with our commitment to protect personal privacy, West Unified Communications Services adheres to the Safe Harbor Framework concerning the transfer of Personal Information from the EEA and Switzerland to the United States. Accordingly, we follow the Safe Harbor Principles and the fifteen FAQs that make up the E.U. Safe Harbor Framework and the Swiss Safe Harbor Framework published by the U.S. Department of Commerce (the “Principles”) with respect to all such Personal Information. If there is any conflict between this Privacy Statement and the Principles, the Principles shall govern. This Privacy Statement outlines our general statement and practices for implementing the Principles, including the types of information we gather, how we process and use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information.
West Unified Communications Services shall take reasonable steps to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Personal Information we collect from you is stored in operating environments that employ reasonable security measures and that are not available to the general public. West Unified Communications Services is not responsible for unauthorized access to such Personal Information by hackers or others who obtain access through illegal measures, in the absence of negligence on the part of West Unified Communications Services. Further, some other websites you may access through the West Unified Communications Services website may have different security practices and you should familiarize yourself with those practices. West Unified Communications Services cannot guarantee the security of Information transmitted via the Internet.
You are responsible for the confidentiality and security of passwords West Unified Communications Services issues to you. If you believe a third party has obtained your password in an unauthorized manner, please notify West Unified Communications Services promptly.
West Unified Communications Services shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, West Unified Communications Services shall take reasonable steps to ensure the Personal Information is accurate, complete, current and reliable for its intended use.
Compliance with Legislation
In connection with the Services, and if applicable, you and West Unified Communications Services shall at all times ensure compliance with any privacy and data protection laws including those in the United States (including but not limited to the Gramm-Leach-Bliley Financial Services Modernization Act, the Health Insurance Portability and Accountability Act and the Fair Credit Reporting Act), in the European Union (including but not limited to Directive 95/46/EC and relevant EU member state legislation), in the Asia-Pacific Economic Cooperation (including but not limited to the Privacy Act along with the Australian Privacy Principles, Singapore’s Personal Data Protection Act and Hong Kong’s Personal Data (Privacy) Ordinance) and anywhere around the world.
Enforcement / Complaints
West Unified Communications Services uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies the statement is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with its principles.
If at any time you believe we have acted contrary to this Privacy Statement, please contact our privacy team through the directions at this link, or by mail, as directed in the “Contact Us” section, below, and we will take steps to investigate and will use reasonable measures to solve the problem. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using BBB EU Safe Harbor as a third party resolution provider for disputes arising with regard to privacy in the EEA and Switzerland. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the BBB EU Safe Harbor website at http://www.bbb.org/us/safe-harbor-complaints
Disclosure for Legal Purposes
We may disclose Personal Information if required to do so by law or in the good-faith belief such action is necessary: (a) to conform to the edicts of the law or comply with legal process served on us or our affiliates; (b) to protect and defend our rights or property or those of our customers and their users; (c) to protect the personal safety of our customers and their users or the public; or (d) in connection with a merger, consolidation or sale of substantial assets of West Unified Communications Services. As we continue to develop our business, we might buy or sell assets related to our business. In such transactions Personal Information generally is one of the transferred business assets. Also, in the event West Unified Communications Services or substantially all of its assets are acquired, Personal Information will be one of the transferred assets.
Please understand, in addition to collecting Personal Information, West Unified Communications Services may also gather information that does not personally identify you regarding your use of the West Unified Communications Services website ("Anonymous Information"). The Anonymous Information we collect regarding your use of this website may be used by us to measure the effectiveness of our marketing efforts, for improving the Services we offer to you, or to improve the West Unified Communications Services website. Generally, you will not be aware when such Anonymous Information is being collected about you. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access the West Unified Communications Services website.
A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognize a user's device.
Cookies are typically classified as either session Cookies or persistent Cookies depending on whether they expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.
Session and Persistent Cookies
Session Cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session Cookies expire after a browser session, so would not be stored longer term. For this reason, session Cookies may sometimes be considered less privacy intrusive than persistent Cookies.
Persistent Cookies – are stored on a users' device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent Cookies may be used for a variety of purposes including remembering users' preferences and choices when using a site or to target advertising.
Accepting Cookies from West Unified Communications Services
Most browsers are initially set to accept Cookies. You may configure your browser to accept all Cookies, reject all Cookies, or notify you when a cookie is set. You can manage your own Cookies preferences by using your browser settings: each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences or delete them.
Please note that you may browse some West Unified Communications Services websites without accepting Cookies from West Unified Communications Services; however, you may not be able to take full advantage of the functionality of the West Unified Communications Services website or the Services if you do so. Other Services, particularly those which require a login and password, require Cookies and cannot be used when you have disabled Cookies in your browser.
For more general information you can visit www.allaboutcookies.org
How do you handle my “Do Not Track” browser settings?
West Unified Communications Services does not track the non-West Unified Communications Services website activity of any internet user with Do Not Track browser settings engaged.
Important Notice regarding certain Services
Some Services of West Unified Communications Services, including in particular virtual event Services allow certain third party organizers and contributors to host virtual events (each, a "Sponsor"). West Unified Communications Services collects the information described below on behalf of such Sponsors. You should consult the privacy policies of each relevant Sponsor to determine how they may handle your Personal Information.
For virtual event Services, depending on the type of event, some of the following fields may be displayed throughout the event: first and last name, company, user ID, and user avatar/image. The Sponsor may enable attendees to search for and find other attendees based on a user's registration information. If you associate your actual name or other personally identifiable information with your user ID, the people to whom you have revealed such information will be able to personally identify your activities on the event. In addition, any Personal Information you choose to share on any publicly available portion of a virtual event may be collected and used by others without restriction. Resumes or curriculum vitae that you have posted to or within a virtual event may be available to all Sponsors of any booth, even if you have not filed a job application with such Sponsor. You should consult the respective privacy policies of these Sponsors to determine how they will handle your Personal Information. This Privacy Statement does not apply to such Sponsors or their use of your Personal Information. West Unified Communications Services does not control Sponsors' use of your Personal Information. If you would prefer that West Unified Communications Services not disclose your Personal Information to any such Sponsor, please contact our privacy team through the directions at this link, or by mail, as directed in the “Contact Us” section, below. Please be reminded, however, that any Personal Information you publicly display or share or that is accessible through the event may already be in such Sponsor's possession, despite such opt-out choice.
Venturing off the website
The website may contain hyperlinks that can take you to websites run by third parties ("Third-Party Websites"). Any hypertext or other links to Third-Party Websites from the website are provided solely as a convenience to you. If you use these links, you will leave the website. West Unified Communications Services has not reviewed all of these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, West Unified Communications Services does not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Websites linked to the website, you do this entirely at your own risk.
Remember, this Privacy Statement only applies to West Unified Communications Services. When you are no longer on an West Unified Communications Services website, you may encounter different privacy and security practices and you should familiarize yourself with those practices each time you visit a new website.
West Unified Communications Services reserves the right to modify this Privacy Statement at any time. Please therefore read through this Privacy Statement. Your continued use of the website and the Services signifies your assent to such modifications.
If at any time you believe West Unified Communications Services has not followed this Privacy Statement, or if you have questions, comments, or complaints regarding this Privacy Statement, please contact our privacy team . By mail, we can be contacted at:
Janette Nelson, Vice President & Deputy General Counsel.
11808 Miracle Hills Drive
Omaha, NE 68154