VOICE BY ENREACH PRIVACY POLICY

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We hereby provide you, as an end user of the Voice by Enreach application (hereinafter referred to as “App”) with the below information concerning the collection of personal data when making use of the App. Personal data includes all data that relates to you personally, such as: name, address, email address or user behavior.

COMPANY CONTACT INFORMATION

Enreach Oy

Address: Mannerheimintie 117, 00280 Helsinki, Finland

Email: privacy.fi@enreach.com

Phone: +358 40 450 3001

Data Protection Officer

We have a Data Protection Team and a Data Protection Officer (DPO). If you have any questions relating to the processing of your personal data or want to contact our DPO, feel free to us using the details provided below.

Enreach Data Protection Team

Email: privacy.fi@enreach.com

CONTROLLER

In accordance with the General Data Protection Regulation, the data controller of the personal data processed within the App is Enreach. Please note that the App will not work properly without an appropriately configured server, provision by us on the behalf of your employer. The processing of data on this server is the responsibility of the controller who provisioned it from Enreach, in most cases this will be your employer. This relationship will be stated in a data processing agreement defining how Enreach and the other party to the agreement comply with the obligations under the General Data Protection Regulation.

FUNCTIONS OF OUR APP

The functions of our App can only be used in conjunction with a server, for which you, your company or your employer has purchased and configured a licensed version of the Enreach communication software. App functions will be only available after authentication and synchronization of the data with the corresponding servers.

HOW WE COLLECT YOUR PERSONAL DATA

Enreach is the data controller for the processing of your personal data for the purposes described in this statement. If you choose not to provide your personal data, you might not be able to make use of the desired service / function or technical assistance.

For end users

Personal data is collected directly from you or through your employer. If you choose to log in and make use of our services, we will process the personal data needed for the provision of this service.

For business customers and partners

Personal data can be collected through your employer. If your employer or a partner provides us with your personal data, we assume that they have informed you about the scope and purpose of this collection.

WHAT PERSONAL DATA WE COLLECT AND PROCESS?

When downloading the App, the required information is transferred to the respective marketplace, in particular user name, email address and the customer number of your account, time of download, payment information and individual device ID. We do not control the purpose and means for the collection of this data and are therefore not responsible for it. We only process the data to the extent necessary for downloading the App to your device and for other technical purposes related to the availability and development of the App.

Required for the provision of our service

The categories of personal data described below is collected and generated when using the App. This data is required for technical purposes to increase ease of use for App functions and to ensure stability and security.

• User information
• User’s email address and phone number
• Traffic data
• Contacts from the user device (Consent required)
• Make and manage calls (Consent required)
• Photo and media files
• Usage statistics (Consent required)

User information

When you log into our App we will process the user information connected to your profile. This data consists of: user name and password.

We process this data on the basis of a contractual obligation agreed to with your employer.

User’s contact information

If you contact us via email or via our contact form, we will process information required to answer your query. This data consists of: email address and, if provided, your name and telephone number.

We process this data on the basis of our legitimate interest to answer your business related queries.

Traffic data

When using our App, traffic data will be processed. This data is required to transmit communications and implementing our service. Traffic data is generated and processed automatically when end users communicate via the App and consists of: data about the parties of the communication, calling and called number, the connected IP address, the date, the time, the duration of the call, the amount of data used, and when roaming, we register the network that was used.

We process this data on the basis of a contractual obligation agreed to with the party that has provided you with access to the App. In most cases, this will be your employer.

Make and manage calls

When you make use of certain features, we ask you for your consent to make and manage calls, for example when you make use of our App to make calls. We will not use this data if you do not give your consent. If you do not give your consent, you may not be able to use all functions of our App.
You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.

We process this data on the basis of your consent.

Contacts

When you make use of certain features, we ask you for your consent to use your contacts. We will not use this data if you do not give your consent. If you do not give your consent, you may not be able to use all functions of our App.

You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.

If you do give your consent, your data will be accessible from the App, and in some cases transferred to on our servers relating to the party that has provided you with access to the App. In most cases, this will be your employer.

We process this data on the basis of your consent.

Photo and Media

When you make use of certain features in our App, we ask you for your consent to use your photos and media files. We will not use this data if you do not give your consent. If you do not give your consent, you may not be able to use all functions of our App.

You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.

If you do give your consent and make use of the feature, your data will be stored on our servers relating to the party that has provided you with access to the App. In most cases, this will be your employer.

We process this data on the basis of your consent.

Usage statistics

Our App collects usage data for troubleshooting and to determine usage-related statistical indicator that we can use for business intelligence purposes to improve our App and make it more attractive for you as an end user. The usage data also contains personal data (such as email address and user ID).

We process this data on the basis of your consent to troubleshoot and improve the App.

WHO WE SHARE DATA WITH?

In certain circumstances, for example due to legislation, it may be necessary to disclose data to the authorities. Disclosure may also take place if necessary to establish or defend legal claims.

Enreach is a group of undertakings located within the EEA, and as part of our group wide activities we can share aggregated usage statistics about our customers and end users in the form of business intelligence and statistics with members of the group. We do this on the basis of group wide agreements, where we have mapped the transfers and designated the responsibility for compliance with the data protection law amongst the members.

In order to communicate via our App, it is necessary for us to transmit traffic data via operators. Enreach uses several European infrastructure providers and these operators therefore process personal data. These operators are independent data controllers for the processing of data within their respective networks.

We might also disclose your personal data to internal or external third parties acting as (sub) data processors for us. This could be in relation to the hosting of your data, business intelligence analyses, etc.

STORAGE AND RETENTION

All data is, in principle, stored on servers within the EEA and your personal data is therefore not subject to international transfers to third countries.

Uninstalling the App permanently deletes all data in the App. We have no influence over, and are therefore not responsible for, the duration for which data is stored on the servers.

SECURITY

Enreach has implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, alteration or destruction. Only authorized Enreach personnel are provided access to personal data and these employees are contractually or statutory obliged to ensure confidentiality of this data.

Enreach will implement appropriate technical and organizational measures to ensure that the processing of your personal data is performed in accordance with data protection law, in particular ensuring an appropriate level of security.

The App uses SSL encryption for the data connection to the server. The data is therefore not accessible by third parties. 

YOUR RIGHTS

Under the General Data Protection Regulation, you have a number of rights regarding the processing of your personal data. To exercise these rights, please contact us via our contact information.

• Right of access
• Right of rectification or erasure
• Right of restriction of processing
• Right of objection
• Right of data portability
• Right to withdraw consent

As a general rule, you can exercise your rights through the party that has provided you with access to the App, in most cases, this will be your employer.

QUESTIONS OR COMPLAINTS

In case you have any questions with respect to the processing of your personal data, you can contact Enreach or our DPO via the contact information.

Please note that you have the right to lodge a complaint with the competent Supervisory Authority if you are of the opinion that the processing of your personal data by Enreach infringes on the General Data Protection Regulation or other data protection laws.

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