“Personal Information,” as used in this Notice, is any information related to an identified or identifiable natural person. Examples of Personal Information include first and last name, mailing address, email address, IP address, other online contact information, or telephone number.
This Notice does not apply to Personal Information relating to our employees, applicants for employment, and temporary contractors providing services to us, or others in relationships with such persons that are relevant to their relationship with us (such as for emergency contact and benefits purposes). Our data usage with respect to these parties is governed by separate notices incorporated into our interactions with those persons. In addition, with respect to customers or other users who have contractual relationships with us, we will use any such user data generated in connection with such relationships in accordance with the terms and conditions of the agreements governing those relationships.
The protection of the data of our customers and other users is very important to us and our data governance and privacy policies and practices described here reflect our commitment to protect the customer and other user data that we collect as part of our interactions with you. We work to minimize the information that we collect to the data needed to conduct our business processes and are committed to (i) protecting both the Personal Information of our customers and other users and the technical and business information that our customers and other users share with us about how they use our software and services in their environments and (ii) processing such data responsibly and in compliance with applicable data protection laws in all countries in which we operate.
Consistent with our compliance with such laws, we have provided a separate General Data Protection Regulation (“GDPR”) Notice (“GDPR Notice”) describing our collection, use and retention of data from our European Economic Area customers and other users here GDPR Privacy Notice. In addition, the State of California has passed the Consumer Data Act (to be effective January 1, 2020) regulating certain businesses’ collection, use and retention of consumers’ “Personal Information” and to the extent that law applies to our data collection, we will comply and update this Notice to describe such compliance prior to the effective date of the law.
HOW WE COLLECT YOUR PERSONAL INFORMATION AND OTHER DATA
We collect Personal Information and other data in three ways:
We collect information you provide to us in optional, voluntary submissions, such as in registration forms on our Customer Portal, user profiles, promotional signups, requests for customer service, software and mobile applications downloads.
We may collect some Personal Information and other data automatically such as when you visit our web-sites.
We may also obtain Personal Information and other data from third party sources to which you have given the right to share such information with us. If we combine data from third parties with Personal Information that we have collected, we will treat the combined information as Personal Information and handle it in accordance with this Notice. In addition, if we solicit third parties to collect Personal Information and other data on our behalf such as social media platform providers, e.g. Linked-In and dicoverorg, and in such cases we instruct those third parties to comply with this Notice and all applicable data protection laws.
We use Google Analytics to collect, use and retain non-personal data in the form of various usage and user metrics when you use our website(s) or use our services (our portals, website and our services are referred to as “Sites and/or Services” in this Notice). These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage data, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar data.
Google Analytics may combine the data collected with other data they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect, use and retain data under their own privacy policies.
You may opt out of the Google Analytics’ cookie by visiting the Google advertising opt-out page or you may opt out of Google Analytics by visiting the Google Analytics opt-out page. Google has additional information available about their Remarketing Privacy Guidelines, and Restrictions.
Your use of the Instant Connect Customer Portal requires cookies to deliver a personalized experience. If cookies are turned off, we will deny you access to the Portal.
In our email communications, we employ some tracking methods (e.g. “targeting, performance, and functionality cookies”). We track “opens” via a tracking pixel in the email- meaning we track who opens our e-mail messages and when you open our e-mail messages; and we track “clicks” via encoded URLs-meaning we track whether you click on the links contained in our e-mail messages. This information is used internally only to help us deliver relevant messaging and is not shared with any third parties.
DATA WE COLLECT
Specifically, the data we collect, use and retain about you includes:
Customer and other user organization data: official organization name, other organization identifiers, organization structure, key contacts, main address and telephone number, business activities with us, licensed products and services, support status.
Customer and other user identity and contact data: full name, title/role, organization, business email, office and mobile phone numbers, mailing address.
Customer and other user account profile data: username/display name, email, password, user preferences.
Customer and other user event registration data: full name, title/role, organization, response to event invitations.
Customer Portal usage records, including username, operating system, page(s) visited, device type, files downloaded, geolocation, datetime stamp of site visits.
Support inquiries and case management data: username, organization, phone number, email address, inquiry summary and description, additional files with case information, case message history.
We may also collect, use and retain data about you from other sources, including our partners and third parties:
Your managers, business administration staff, agents or representatives who are acting on your instructions.
Commercial contact lists that we acquire from other organizations.
Organizations that we acquire or merge with.
Organizations with whom we provide co-branded events, websites, products, and services.
Service Providers including our administrative staff, website developers, IT support providers, cloud services providers, payment services providers, billing service providers, contractors, consultants, B2B contact databases, survey tool providers, customer relationship and customer support service providers, event management platform service providers, instant messaging service providers.
Publicly available sources such as LinkedIn and Google+.
We might also collect, use and retain information about you from other third parties if you have indicated to such third parties that you would like to hear from us.
HOW WE USE YOUR DATA
We only use your data collected, including any Personal Information, as expressly described below in this Notice. If a need arises to use your data for a purpose not described here, we will provide you prior notice of such use.
Communication and Responding to Requests
We use your data collected, including Personal Information, to provide you with customer support, process transactions, respond to users’ requests, send newsletters and product announcements, send special offers and advertisements, seek your opinions and feedback, and connect users to Instant Connect Sites and/or Services, and to products and services of our partners and licensees.
We collect, use and retain your data, including Personal Information, behavioral metrics, and other non-personally identifiable data to operate, provide, improve, and maintain our Sites and Services, to develop new products and services, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.
Data Usage in Instant Connect Business Processes
Specifically, we use your information for:
Sales Interactions – Our sales team and partners capture their interactions with existing and prospective customers to service current and future needs that we can serve.
Product, Service, and Event Communications – Our marketing team relies on customer contact information to target communications to the right audience.
New Customer Identification – Our sales and marketing teams work with partners and 3rd-party information providers to identify prospective customers who may be interested in using our products.
Technical Support – Our technical support team collects user and system information as they respond to inquiries, product issues, and enhancement requests.
Instant Connect Website and Customer Portal – We track visitor activities as they navigate our sites to better understand usage patterns and identify misuse.
Personal Information Usage
Specifically, we use your Personal Information:
To provide access to the Instant Connect Customer Portal, with personalized content relevant to you and your organizations interests.
To process and fulfill your requests for Instant Connect products and services (on the basis of performing our contract with your organization).
To process transactions and payments, and recover money owed to us (on the basis of our contracts with your organization).
To monitor your account and use of services to ensure compliance with contracts and end user agreements, and to identify and prevent unlawful use of our products and site content (on the basis of our legitimate interests to operate a safe and lawful business, or where we have a legal obligation to do so).
To enable you to communicate with other Instant Connect Customer Portal users, partners, and customers (on the basis of your consent to our Customer Portal guidelines).
To manage our relationship with you, notifying you about changes to our policies and terms of service, requesting your feedback about products and services, and to comply with our legal obligations and our legitimate interest to keep our records updated.
To conduct business with you or your organization, including contacting you to manage our business relationship with you and your employer.
To provide customer service and support, such as addressing inquiries, investigating and resolving issues, and which may require sharing your information with our contractors as needed (on the basis of performing our contract with your employer, our legitimate interest in providing the correct products and services, and to comply with our legal obligations).
To work with you and undertake projects with you, including processing of requests that you submit (on the basis of our contract with you and your employer, and our legitimate interest in running our business).
To carry out marketing to let you know about news, events, new or enhanced products and services that we believe may interest you, including sharing your information with our marketing services providers (either on the basis of your consent, or in our legitimate interest to provide you with marketing communications where we may lawfully do so).
To deliver relevant website content and marketing communications to you, measuring the effectiveness of our advertising we serve to you (on the basis of our legitimate interests in understanding how our website/services are used, to improve them, to grow our business, and to inform our marketing strategy).
To interact with users on social media platforms (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals).
To conduct data analytics in order to improve our website, products and services, customer relationships and experiences (on the basis of our legitimate interest in understanding how the website is used and by whom, to keep our website updated and relevant, to develop our business, to provide improved products and services to our customers, and to inform our business and marketing strategy).
To make suggestions and recommendations about the use of Instant Connect Software in your organization, either directly or through sharing with selected third parties such as Tidal partners, so that you can be contacted about items that interest you (on the basis of your consent where we have requested it, or on the basis of our legitimate interest to share details about conversations and meetings with you).
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity (in the basis of our legitimate interest to operate a safe and lawful business, or where we have a legal obligation to do so).
To enable us to comply with our policies and procedures and enforce our legal rights, and to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business, or where we have a legal obligation to do so).
We will use your Personal Information for the purposes listed above either on the basis of:
Your consent (where we request it);
Performance of your contract with us and provision of our services to you;
where we need to comply with a legal or regulatory obligation; or
our other legitimate and lawful purposes or those of a third party (subject to considerations of your legitimate interests).
Reasons We Share Your Personal Information
We do not share your personal information with third parties except as noted herein. We may share your personal information as necessary to maintain business operations, such as with vendors working on our behalf (for example, delivery of services and digital advertising); as required by law or to respond to legal process; to maintain the security of our products; to protect our customers and other users’ rights, or property; as part of a merger or acquisition; or with your express consent.
WHERE WE RETAIN, SECURE AND PROCESS YOUR PERSONAL INFORMATION
We may retain your data collected, including your Personal Information, and process it in our system network in your region, in the United States, and in any other country where we operate and/or have facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this Notice is processed according to the provisions of this Notice and the requirements of applicable law wherever the user who generated the data is located. We may transfer personal data from the European Union or European Economic Area (“EU”) to other countries such as the United States (some of which have not been determined by the European Commission to have an adequate level of data protection).
How We Secure Your Personal Information
We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the internet, we cannot guarantee that data, during transmission through the internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
How Long We Retain Your Personal Information
We retain Personal Information we collect from you where we have an ongoing legitimate and lawful business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate and lawful business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
For purposes of the website, we only collect and retain your Personal Information only for purposes of responding to your query for further information on our products or services. For other purposes subject to this Notice where we have collected data in the course of an ongoing relationship with you, we only collect and retain your Personal Information and other data we have collected for as long as the ongoing relationship remains active. If a user has not visited or contacted us for a period of two years we automatically delete user’s Personal Information and other data from our data base.
How to Access and Control Your Personal Information
You may access and review the Personal Information we store about you and correct any factual errors. Most of your Personal Information may be accessed and corrected by simply logging into your account via the Instant Connect Customer Portal and accessing your profile.
You may access, correct, update or request deletion of your Personal Information.
You can object to processing of your personal information, ask us to restrict processing of your Personal Information or request portability of your personal information.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
You can also exercise your rights by contacting us using the information provided in the “How to contact us” section heading below.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
NOTICE REGARDING THIRD PARTY PRIVACY PRACTICES & SOCIAL MEDIA
This Notice applies solely to our collection and use of data generated by customers and users use of our Sites and/or Services. Our website includes links to other unaffiliated websites. If you access those sites and submit personal information, you are subject to the privacy notices applicable to those sites. We encourage you to carefully read the privacy notice of any website you visit.
GENERAL DATA PROTECTION REGULATION (EEA VISITORS ONLY)
The Instant Connect platform was originally developed by Cisco in the early 2000s, in response to the events of 9/11. The company – and the world – saw a gap in the ability of first responders to communicate across organizational and technical boundaries. Push-to-talk devices and radio networks, while invaluable, were isolated from each other, and connectivity to enterprise communications, mobile devices, and other desktop communications was still unachievable.
Cisco asked the question: What if ALL of these devices – PTT and IP – could share a common environment that allowed users to use any device they wanted, anywhere, to communicate instantly? In other words – what if mobile and other IP devices became push-to-talk devices at the same time?
Innovators at Cisco, led by Charlie Giancarlo, developed a roadmap to communication convergence. Starting with an inexpensive card on a router to digitize land-mobile radio (LMR) push-to-talk (PTT) audio over the Internet, the team developed the software to connect and manage all these audio streams through the network. This product started life as IP Interoperability and Collaboration System (aka IPICS) – which today is called Instant Connect.
Instant Connect is a Delaware limited liability company with its global headquarters located at 222 S Riverside Plaza, Suite 2800, Chicago, IL 60606.
To exercise your data subject rights, navigate to https://support.instantconnetnow.com, select “About,” select “Exercise your Data Rights” and choose one of the options.
CHANGES TO NOTICE
Please note that this Notice may change from time to time. If there are material changes to this Notice or in how we use your Personal Information, we will post a notice on our home page that this Notice has changed. You are also encouraged to periodically review this Privacy Notice to stay informed on how we are protecting your personal information.