Privacy Policy

DialogTech provides marketing services related to phone call processing and analytics.

When we receive information for our own purposes, such as the contact or billing information of our clients, the processing of that information is described by this privacy policy. When we receive or process information on behalf of one of our clients, the privacy practices that apply to the processing of that information is governed by our client’s privacy policy.

Types of Information We Collect

We provide marketing and data analytic services to companies. In that capacity we receive very limited personal information from our clients and process that information on behalf of our clients. In other situations, we receive personal information for our own use. The following provides examples of the type of information that we collect about and how we use that information.

Context Types of Data Primary Purpose for Collection and Use of Data
Account Information and Information about Clients We collect the name, and contact information, of our commercial clients and their employees with whom we interact. We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.
Client Information We provide marketing and data analytic services related to inbound phone calls.  In that role we may receive personal information from one of our clients. When we receive personal information from one of our clients in order to carry out a project or a service we process that information on their behalf.  When we act in this capacity, our client determines the purpose for which the information
was collected and how we should use it.
Cookies and First Party Tracking We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. We have a legitimate interest in making our website operate efficiently.
Cookies and Third Party Tracking We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored
to your interests on our website, or on other websites.		 We have a legitimate interest in engaging in behavior-based advertising.
Email Interconnectivity If you receive email from us, we use certain tools to capture data related to when you open or interact with our messages. We have a legitimate interest in understanding how you interact with our communications to you.
Employment If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee.  This may include, among other things, your Social Security Number.  Providing this information
is required for employment.		 We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you.  In some contexts, we are also required by law to collect information about our employees.  We also
have a legitimate interest in using your information to have efficient staffing and work force operations.
Feedback/Support If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mailing List When you sign up for one of our mailing lists we collect your email address or postal address. We have a legitimate interest in sharing information about our products or services.
Online Registration We collect your name and contact information when you create an online account.  We also collect information relating to the actions that you perform while logged into your account. We have a legitimate interest in providing account relating functionalities to our users.
Surveys When you participate in a survey we collect information that you provide through the survey.  If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your
information.		 We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.
Web logs We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or
a date/time stamp for visitors.		 We have a legitimate interest in monitoring our networks and the visitors to our websites.

In addition to the information that we collect from you directly, or from our clients, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

Use and Processing of Information

In addition to the purposes and uses described above, we use information in the following ways:

  • To identify you when you visit our websites.
  • To provide products and services.
  • To improve our services and product offerings.
  • To conduct analytics.
  • To respond to inquiries related to support, employment opportunities, or other requests.
  • To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
  • For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you retain us to provide consulting services we may collect your information to perform our contract with you, but we also collect your information because we have a legitimate interest in understanding who our clients are and what services we perform on their behalf. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

  1. Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or anticipates acquiring, our company, business, or our assets, we will also share information with that company.
  2. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  3. Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or for the provision of services by a third party intermediary.
  4. Public. Some of our websites may provide the opportunity to post comments, or reviews, on a message board or in a public forum. If you decide to submit information on these pages, that information may be publically available.
  5. Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, process or analyze data, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.

Your Choices

You can make the following choices regarding your personal information:

  1. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
  2. Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
  3. Access to Your Personal Information. For information that we collect on our own behalf we will grant you, where required by law, reasonable access to the personal information that we have about you. You may request access to your personal information by contacting us at the address described below. If we are processing your information on behalf of one of our clients, we will forward your request to that client and await instructions on whether access should be granted.
  4. Changes to Your Personal Information. You can contact us at the address described below in order to request that your information be modified. If we are processing your information on behalf of one of our clients, we will forward your request to that client and await instructions on any changes that they believe are appropriate.
    1. For Individual Consumers:
      1. Write or email us at privacynotice@dialogtech.com. Request must include your name, residency address, contact phone number, any other phone number that you may have used to interact with DialogTech.
      2. Call DialogTech at 1-877-295-5100, option number 5.
    2. For DialogTech Clients:
      1. Write or email us at DialogTech, support@dialogtech.com. Requests must include company name, address, contact telephone number, and account number(s) (if applicable) for the business entity(ies) opting out. Incomplete information will delay or possibly prevent our ability to honor your request.
      2. Call DialogTech at 1-877-350-1954.
    3. For Swydo, B.V. Clients:
      1. Write or email us at Swydo, support@swydo.com. Requests must include company name, address, contact telephone number, and account number(s) (if applicable) for the business entity(ies) opting out. Incomplete information will delay or possibly prevent our ability to honor your request.
      2. Call Swydo at +1 917 708 8773 (CET).
      3. Our system will be updated to reflect your privacy preferences within thirty (30) days following receipt of the request with complete information.
  5. Deletion of Your Personal Information. We typically retain personal information that we collect on our own behalf for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may request information about how long we keep a specific type of information, or request that we delete your personal information, by contacting us at the address described above in Section 4. If we are processing your information on behalf of one of our clients, we will forward your request to that client and await instructions from them on whether your information should be deleted.
  6. Revocation of Consent or Objections. You may revoke consent to processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent) by contacting us at the address described in Section 4. If you revoke your consent / object we may no longer be able to provide you services or support your requests for service through your chosen service provider who is a client of DialogTech. In some cases we may limit or deny your request to revoke consent / object if the law permits or requires us to do so, or if we are unable to adequately verify your identity. If we are processing your information on behalf of one of our clients we will forward a revocation of consent to that client and await instructions from them on whether the processing to your information should cease.
  7. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

Note that, as required by law, we will require you to prove your identity. We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, email address, or billing address. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

Information for Authorized Agents

If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

  1. A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
  2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
    If we do not receive both pieces of information, the request will be denied.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites may permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Miscellaneous

The following additional information relates to our privacy practices:

  • Transmission of Information to Other Countries. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. When transferring data out of the European Economic Area to the United States, we utilize Standard Contractual Clauses. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
  • Accessibility. This Privacy Policy is accessible through your browser’s screen reader.
  • Changes to This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
  • Information for California Residents. California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. We do not discriminate against California consumers who exercise any of their rights described in this policy.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

PrivacyNotice@dialogtech.com
DialogTech, Inc.
120 South Riverside Plaza, 11th Floor
Chicago, IL 60606
877-295-5100 option 5

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

Effective Date: July 1, 2020
Last Updated: July 23, 2020

California Information Sharing Disclosure

California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that companies should disclose whether the following categories of information are collected, transferred for consideration, or transferred for an organization’s “business purpose” as that term is defined under California law. Note that while a category may be marked that does not necessarily mean that we have information in that category about you. For example, while we transfer bank account numbers for our business purpose in paying our employees (e.g., direct deposit) we do not collect or transfer bank account numbers of individuals that submit questions on our website’s “contact us” page.

Categories of Personal Information We Collect To Whom We Disclose Personal Information for a Business Purpose
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.
  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Data brokers
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
  • Social networks
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information.
  • Affiliates or subsidiaries
  • Business partners
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Internet service providers
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc.
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Data brokers
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms
  • Social networks
Biometric information
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Data brokers
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms
  • Social networks
Geolocation data
  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Data brokers
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Internet service providers
  • Joint marketing partners
  • Operating systems and platforms
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms
  • Social networks
Audio, electronic, visual, thermal, olfactory, or similar information
  • Affiliates or subsidiaries
  • Business partners
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Internet service providers
  • Operating systems and platforms
  • Other Service Providers
  • Professional services organizations, this may include auditors and law firms
  • Social networks
Professional or employment-related information
Non-public education information (as defined in the Family Educational Rights and Privacy Act)
Inferences drawn from any of the information listed above

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