Fonolo Privacy Policy

Your Privacy is Important To Us!

Foncloud, Inc. (DBA Fonolo, herein known as “Fonolo”, “we”, or “us”) take both the privacy of your data, and how that data is used, very seriously.

This privacy policy describes Fonolo ‘s privacy practices in relation to information that we collect through websites operated by us, through our social media pages and apps (on services such as Facebook, Twitter, Instagram, and others), and other services provided by us both online and offline (collectively, “Fonolo Sites”); as well as through email messages that we send to you.

This privacy policy does not apply to the privacy practices of third parties that Fonolo does not own or control, or to individuals that Fonolo does not employ or manage.

You can request a copy of this privacy policy by contacting us at privacy@fonolo.com.

What Types of Information Does Fonolo Collect?

• Personal information (“Personal Data”) is information that directly or indirectly identifies you or another individual, this may include: name, title, company name, job function, expertise, postal address, telephone number, email address, browser and device information (including IP address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers in connection with the Fonolo Sites, you represent that you have the authority to do so and permit us to use the information in accordance with this privacy policy.
• Other information (“Other Information”) is any information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Fonolo Sites and for other purposes described below.

How Does Fonolo Collect Information?

Fonolo and its service providers, collect Personal Data and Other Information in a variety of ways, including:

• Through the Fonolo Sites. For example: when you register for a trial or demo, register for a webinar, contact us, subscribe to our email newsletter, download content (e.g. white papers and case studies), or register to use Fonolo Sites and services.
• For example: when you attend one of our events, during a phone conversation with a Fonolo representative, or when you contact a Fonolo representative.
• Directly from you. Fonolo collects information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Data, this information does not personally identify you or any other user of the Fonolo Sites.
• Information from other sources. In order to enhance our ability to provide relevant marketing, offers, and services to you, we obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
• Through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Fonolo Sites you are using. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access Fonolo Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications, and other services. Fonolo uses IP Addresses to calculate usage levels of Fonolo Sites, help diagnose problems with its servers, administer Fonolo Sites, and for monitoring the regions from which you navigate to Fonolo’s Sites.
• Through cookies and other similar technologies. “Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with Fonolo Sites. When you visit Fonolo Sites, we may send one or more cookies to your device. They enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse Fonolo Sites and enhance the level of services and functions provided. Fonolo recognizes automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions.
• By aggregating information. Aggregated Personal Data does not personally identify you or any other user of Fonolo Sites.

How Does Fonolo Use Collected Information?

We may use personal information to provide the services you’ve requested. We may also use personal information for auditing, research, and analysis to operate and improve the Fonolo Sites. We may use third parties to assist us in processing your personal information, and we require that such third parties comply with our privacy policy and any other appropriate confidentiality and security measures. We may use certain other information collected from you to help diagnose technical problems, administer the Fonolo Sites, and improve the quality and types of services delivered. We may provide non-identifying and aggregate usage and volume statistical information derived from the actions of our visitors and account holders to third parties in order to demonstrate the value we deliver to users.

The information we collect is not shared or sold to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission, or under the following circumstances:

• As required by law, such as to comply with a subpoena, legal proceedings, or similar legal process.
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
• To investigate potential violations of the Fonolo Terms of Service.
• To any other third party with your prior consent to do so.
• To any of our affiliate partners, whom strictly comply with our privacy policy.
• If Fonolo is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Fonolo Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. We will collect and use your Personal Data where the processing is in our legitimate business interests, such as for providing Fonolo services related to our Call-Back products.

Our legal basis for processing Personal Data in certain circumstances will also be based on your consent to do so or where we need the Personal Data to perform a contract with you or in order to enter into a contract with you. In some cases, we may also have a legal obligation to collect Personal Data from you.

If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Cookies and Other Tracking Technologies

Fonolo and our analytics providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Fonolo Sites, tracking users’ movements around the Fonolo Sites, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

You can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Fonolo Sites, but your ability to use some features or areas of the Fonolo Sites may be limited.

How Does Fonolo Secure Personal Data About Me?

We have implemented appropriate organizational, technical, and administrative measures to protect Personal Data within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorized access, modification, and disclosure, you should be aware that no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Questions, Concerns and Complaints” section below.

How Can I Access, Correct, Amend, and Remove Information About Me?

If you would like to access, correct, amend, remove, or limit the use or disclosure of any Personal Data about you that has been collected and stored by Fonolo, or have it transferred to another organization, please notify us at privacy@fonolo.com so that we may consider and respond to your request in accordance with applicable law. If you would like to object to the processing of your Personal Data for direct marketing purposes, please refer to the “What Choices Do I Have” section below.

For your protection, we only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we need to verify your identity before implementing your request. We will respond to your request within 30 days.

Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such access, change, or deletion.

How Long will Fonolo Retain my Information?

We will retain your Personal Data for a period of time consistent with the original purpose of collection, including: to pursue our legitimate business interests, comply with our legal obligations, resolve disputes, and enforce applicable agreements.

What Choices Do I Have?

You can always opt not to disclose information. However, if you elect to do so, we will likely be limited in responding to your inquiry or providing services to you.

You can opt-out of receiving marketing messages from Fonolo by unsubscribing through the unsubscribe or opt-out link in an email, or by unsubscribing via the Fonolo unsubscribe page at https://fonolo.com/optout/, or by sending an email to privacy@fonolo.com. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages related to your Fonolo services.

Can Children Use Fonolo’s Sites and Services?

The Fonolo Sites and services are not intended for minors under the age of 18. Fonolo does not knowingly or specifically collect information about minors under the age of 18 and believes that children of any age should get their parents’ or legal guardians ‘ consent before providing any Personal Data.

If you believe that we have mistakenly or unintentionally collected such information, please notify us at privacy@fonolo.com so that we can delete the information from our servers.

Third Party Sites

Fonolo Sites include links and other embeddable components, to other web sites whose privacy practices may differ from those of Fonolo. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.

Sensitive Information

We ask that you not send us or disclose any sensitive Personal Data (including, but not limited to: social security numbers, information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Fonolo Sites or via other means.

Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Fonolo Sites prior to the change becoming effective. We encourage you to periodically review this privacy policy for the latest information on our privacy practices.

Questions, Concerns, or Complaints

Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact us by email at privacy@fonolo.com, or by mail at: 20 Maud St, Suite 100, Toronto, Ontario, Canada, M5V 2M5, ATTN: Privacy Advocate.

Because email communications are not always secure, please do not include any sensitive information in your emails to us.

Fonolo will take any privacy complaint seriously, and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

You may have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.