Invoco Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy of everyone who visits our main website, invoco.net, our Customer Portal, portal.invoco.net, and our Partner Portal partner.invoco.net (“Our Sites”), everyone who uses our Invoco Softphone application (“Our Apps”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Sites or Our Apps;|
|“Cookie”||means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in section 13, below;|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Sites or Our Apps. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);|
|“Saas”||means Software As A Service which is software that is centrally hosted and accessed via a web browser;|
means Invoco Ltd, a limited company registered in England under company number 04465219, whose registered address is 11 Avalon Road, Bromsgrove, Worcestershire, B60 2RJ, and whose main trading address is Invoco Ltd, 7 The Courtyard, Buntsford Drive, Bromsgrove, Worcestershire, B60 3DJ.
2. Information About Us
2.1 Our Sites and Our Apps are owned and operated by Invoco Ltd, a limited company registered in England under company number 04465219, whose registered address is 11 Avalon Road, Bromsgrove, Worcestershire, B60 2RJ and whose main trading address is Invoco Ltd, 7 The Courtyard, Buntsford Drive, Bromsgrove, Worcestershire, B60 3DJ.
2.2 Our VAT number is GB825306641.
2.3 Our Data Protection Officer is Jeremy Strong, and can be contacted by email at firstname.lastname@example.org, by telephone on 01527 306 000, or by post at Invoco Ltd, 7 The Courtyard, Buntsford Drive, Bromsgrove, Worcestershire, B60 3DJ.
2.4 We are regulated by Ofcom.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data do We Collect?
5.1.3 business/company name;
5.1.4 job title;
5.1.6 contact information such as email addresses and telephone numbers;
5.1.7 demographic information such as post code;
5.1.8 financial information such as credit / debit card numbers;
5.1.9 IP address;
5.1.10 web browser type and version;
5.1.11 operating system;
5.1.12 a list of URLs starting with a referring site, your activity on Our Sites;
5.2 Among the types of Personal Data that Our Apps collect, by themselves or through third parties there are: Usage Data; Contacts permission; Camera permission; Precise location (non-continuous); Microphone permission; Phone permission; Storage permission; geographic position; Data communicated while using the service; app information; device logs; device information.
5.2.1 Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using Our Apps.
5.2.2 Unless specified otherwise, all Data requested by Our Apps is mandatory and failure to provide this Data may make it impossible for Us to provide Our services. Users who are uncertain about which Personal Data is mandatory are welcome to contact us at any time.
5.2.3 Depending on the User’s specific device, Our Apps may request certain permissions that allow it to access the User’s device Data as described below.
18.104.22.168 Camera permission, used for accessing the cameral or capturing images and video from the device.
22.214.171.124 Contacts permission, used for accessing contacts and profiles on the User’s device, including the changing of entries.
126.96.36.199 Microphone permission, used for accessing and recording microphone audio from the User’s device.
188.8.131.52 Phone permission, used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
184.108.40.206 Precise location permission (non-continuous), used for accessing the User’s precise device location to allow users to share their location with other users. The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for Our Apps to derive the exact position of the User on a continuous basis.
220.127.116.11 Storage permission, used for accessing shared external storage, including the reading and adding of any items.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Sites and Our Apps;
6.2.3 Personalising and tailoring your experience on Our Sites and Our Apps;
6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products and services for you;
6.2.6 Replying to emails from you;
6.2.7 Providing support and technical services.
6.2.8 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the instructions at the bottom of the email.);
6.2.9 Analysing your use of Our Sites and Our Apps and gathering feedback to enable Us to continually improve Our Sites and Our Apps and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
7. How And Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein) or with certain SaaS providers outside of the EEA who comply with EU data export restrictions and fully comply with GDPR.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Sites.
8. Do We Share Your Data?
8.1 Subject to section 8.2, We will only share your data with business partners, contractors, vendors and authorised third-party agents either with Your consent or for business or legal purposes and in accordance with applicable law for the following purposes:
8.1.1 To conduct analytics in order to improve the user experience of Our Apps and Our Sites.
8.1.2 To provide support and technical services.
8.1.3 To operate, deliver, improve and customise Our Apps and Our Sites.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will, however, be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right To Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can you Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in section 14.
13.2 By using Our Sites you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Sites will not be impaired by refusing consent to them.
13.3 All Cookies used by and on Our Sites are used in accordance with current Cookie Law.
13.4 Before Cookies are placed on your computer or device, you will be shown a message requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended.
13.5 Certain features of Our Sites depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Sites may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.6 The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|ASP.NET_SessionId||This Cookie is used to create a session ID for the user, so that the system itself can identify the user as a unique and individual user, distinct from anyone else using our Site. This information is not used or stored outside Our systems, and is held only temporarily while the user is accessing account pages and other pages which require unique and secure access. Without this Cookie, such access could not remain secure, so it is very important.||Yes|
|__RequestVerificationToken||This is an anti-forgery cookie and is designed to stop unauthorized posting of content to our Site. It holds no information about the user and is destroyed on closing the browser.||Yes|
|invocoTelecomPortal||This is a security cookie that is created when you log in to our Customer Portal. Without this cookie your access would not be secure.||Yes|
And the following third party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|Intercom||We use these cookies to provide you with help and support via live chat on our Site.|
|This cookie is used by our video player to remember where you are in a video so that if playback is interrupted (for example, by losing your internet connection) then you can get right back to where you left off.|
|__cfduid||Cloudflare||This cookie is set by the Cloudflare service to identify trusted web traffic. It does not correspond to any user id in the web application, nor does the cookie store any personally identifiable information. See Cloudflare for more details.|
13.7 Our Sites use analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Sites are used. This, in turn, enables Us to improve Our Sites and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.9 The analytics service used by Our Sites use the following Cookies:
|Name of Cookie||Provider||Purpose|
|_ga, _gat||Google Analytics is a web analytics service provided by Google, Inc. (‘Google’), to help us see how our Sites are used. Please see Google for more details.|
13.10 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.11 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Sites more quickly and efficiently including, but not limited to, login and personalisation settings.
13.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us