Privacy Notice for Vodafone Business UC with RingCentral Service

This short form Privacy Notice is served by Vodafone to provide you with general information on the data processing activities of the involved controllers when you use the Vodafone Business UC with RingCentral Service.

 

The Vodafone Business UC with RingCentral Service (the "Service") is an enterprise-grade, cloud-based communications solution for voice, video meetings, messaging and team collaboration. This Service contains Vodafone as well as RingCentral elements and features, which is why both may act as independent controllers with regard to the processing of your personal data or, in the case of RingCentral, as a processor as well. Also, the Service is in use by Business Customer, which also may act as independent controller with regard to particular processing activities, employing Vodafone as a processor in these cases.

 

This Privacy Notice aims at providing an overview of each independent controller’s area of responsibility.

In this Privacy Notice

“Vodafone”, “we”, “us”, “our” means the Vodafone entity providing the Service to the Business Customer as per the applicable Service Agreement; 

 

“Business Customer” means the business customer, which has entered into a Services Agreement with Vodafone for the Service and makes the Service available to you;

 

“RingCentral” means the RingCentral entity providing the RingCentral elements and features in the Service in your market: (i) For the UK, that means RingCentral UK LTD, Ealing Cross, 85 Uxbridge Road, London W5 5TH, United Kingdom; (ii) For Germany, excluding where the MNC version of the Service is provided, that means RingCentral Germany GmbH, Poststraße 33, 20354 Hamburg, Germany; and (iii) For the rest of the world, including where the MNC version of the Service is provided, means RingCentral France SAS, 3-5 rue Saint-Georges, 75009 Paris, France. (Get in touch with the Business Customer to understand what version of this Service they have purchased from us);

 

“you” using the Service includes:

  • (i) you using the Service actively as an employee of the Business Customer or a person that the Business Customer has authorized to use the Services purchased by them (“End-User”); and 
  • (ii) you using it passively by being the one communicating with the End-User using the Service; and

third party” means someone who is not you, us, RingCentral or the Business Customer.

Personal data collected about you and purposes of use

In order to deliver the Service agreed with the Business Customer, various types of personal data are processed. The types of personal data include:

  1. Content Your meetings and conversations, chats, voicemail, shared files, recordings and transcriptions. This is used to provide the Services.
  2. End-User Account Data  This includes your E-mail address, profile picture, and phone number. This is used to associate you with a Business Customer and to provide the Business Customer with the Service.
  3. Call History A detailed history of the phone calls you make, which allows you to go back and review your own call records and to provide the Business Customer with analytics dashboards for quality monitoring, troubleshooting and usage management of the Service.
  4. Call Quality data Details of meetings and call data are available to your Business Customer system administrators. This allows your Business Customer’s administrators to diagnose issues related to poor call quality and service usage.
  5. Support/Feedback data Information related to troubleshooting tickets or feedback submitted. This is used to respond to support requests.
  6. Diagnostic and Service data Diagnostic data related to Service usage. This personal data allows us to deliver the Service (troubleshoot, secure and update the product and monitor performance) as well as perform some internal business operations, such as:
    • Determine revenue
    • Develop metrics
    • Determine service usage
    • Conduct product and capacity planning

Additional details on the personal data subject to the processing activities of Vodafone, RingCentral and the Business Customer will be provided by each of them through their respective privacy notices  in their respective role as an independent controller, as applicable.

Roles of Vodafone, RingCentral and the Business Customer

The Business Customer is independent controller for the personal data of you provided to Vodafone where you are an End-User in order to set up an individualized access to the Service for you. The Business Customer also is independent controller for the content of your communication where you are an End-User using the Service. The Business Customer determines the legal bases for the processing of this personal data, and Vodafone, in turn, processes the personal data on the Business Customers' instructions as a processor (to the extent not acting as independent controller) in these cases and RingCentral does so as Vodafone’s sub-processor.

Note that the Business Customer may have its own privacy notices with regard to the personal data they process as independent controller, and you should contact them if you have any questions about those privacy notices or the processing activities carried out by the Business Customer as an independent controller.

 

Vodafone, to the extent it is acting as a telecommunications provider, will be an independent data controller as well. This includes for example, personal data related to:

  • (i) transmission of your communications through our network in order to provide you with connectivity services as contracted by the Business Customer and in accordance with communications laws and regulations; 
  • (ii) billing the Business Customer and account management; 
  • (iii) internal reporting and modelling (e.g., forecasting, revenue, capacity planning, product strategy); 
  • (iv) combatting fraud, cybercrime, or cyber-attacks that may affect the Service; 
  • (v) internally use for development and improvement of our network or Service; and 
  • (vi) compliance with a mandatory legal obligation, including for example accounting and tax requirements, which are subject to strict internal policies (such as retention periods), and procedures.

For more details and information on how to exercise your privacy rights in relation to personal data processed by Vodafone as independent controller, as applicable, please see the respective Vodafone Privacy Notice in section “Main Vodafone Privacy Notices” of this notice.

 

RingCentral provides the digital telephone system, which is part of the Service you use. 

 

RingCentral will be an independent controller for limited personal data related to the digital telephone system they operate. This will be data required for RingCentral to ensure the correct functioning of the digital telephone system, to monitor Service quality, to prevent fraud and abuse and to identify users as necessary to provide the Service. 

 

For any other personal data RingCentral processes in relation to the Service you use, RingCentral will follow Vodafone and/or Business Customer’s instructions as a processor or sub-processor.

 

For details on the processing of your personal data and to exercise your privacy rights in relation to personal data processed by RingCentral contact RingCentral at privacy@ringcentral.com or write to: 

 

If you are based in the UK -RingCentral UK LTD, Ealing Cross, 85 Uxbridge Road, London W5 5TH, United Kingdom – “ATTN: LEGAL”

If you are based in Germany – RingCentral Germany GmbH, Poststraße 33, 20354 Hamburg – “ATTN: LEGAL”

If you are based outside the UK and outside Germany - RingCentral France SAS, 34 boulevard des Italiens 75009, Paris, France – “ATTN: LEGAL”

Is your personal data disclosed to third parties?

We may employ other group companies and/or service providers supporting the Service, and these companies shall have access to your personal data only to the extent that it is required to act on our behalf under the terms of a data processing agreement in accordance with Art. 28 GDPR.  

 

We may also need to release your personal data to comply with our legal obligation to respond to the authorities’ lawful demands, for example law enforcement agencies, government bodies, courts or other public authorities. Your personal data shall only be provided when we are obliged to do so in accordance with the law.

 

We may also share your personal data with a third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

How long we keep personal data for

We will retain your personal data for no longer than is necessary to fulfil the purposes for which the personal data 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.

International transfer

We may need to transfer your personal data internationally to other Group companies or service providers supporting the Service.  This kind of data transfer may happen if servers (i.e. where personal data is stored) or our suppliers and service providers are based outside the country where we offer the Service, or if you use the Service while visiting other countries.  

 

If we transfer your personal data internationally, it is done in compliance with the applicable legislation in force to protect your personal data.

Main Vodafone Privacy Notices

This text constitutes the short form Privacy Notice for the Service. The local Main Vodafone Privacy Notices applicable to you depending on what country you are based in are available in links listed below, or if not listed below in our Privacy Portal at, https://www.vodafone.com/cookie-policies. In the Main Vodafone Privacy Notices you can find further information about, for example, details of Vodafone’s processing activities or how to contact us to exercise your privacy rights.

However, note that if the version of this Service that you are using is the MNC version, then the main privacy notice is available at www.vodafone.com/business/privacy-policy. The MNC version is the Vodafone Business Global solution, different to the Vodafone local market solution. Please get in touch with the Business Customer to understand what version of this Service they have purchased from us. 

How to Contact Us

To contact us please check the relevant Main Privacy notice mentioned above. You can also email us at: 

 

For global MNC solution, enterpriseDPO@vodafone.com  

 

For UK local solution, data.protection@vodafone.com

 

For Germany local solution, datenschutz@vodafone.com

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