Update as of 11/07/2018 Zultys, Inc. and its worldwide subsidiaries are committed to protecting your privacy. This Privacy Notice explains our privacy practices and provides information on how and why we collect, use, and share your personal data through our interaction with you and through our products and services and when you visit our international websites, available at www.Zultys.com; our desktop, IP desk phone, and mobile applications (“Apps”) or use our unified cloud communications and collaboration platform (“Services”). The policy also describes your choices regarding use, access, deletion, and correction of your personal information. Zultys’ Privacy Notice applies to Customers (including Customer’s End Users) and Users (all other individuals who use the Zultys products or website) provided directly to us when they use our Website, Apps, or Services. If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided at the bottom of this Notice. QUICK LINKS We recommend that you read this Notice in full to ensure you are fully informed.

Table Contents

INFORMATION WE COLLECT
INFORMATION WE USE
SHARING AND DISCLOSURE OF INFORMATION TO THIRD PARTIES
YOUR PRIVACY RIGHTS
THIRD-PARTY SITES
BLOGS AND FORUMS
SECURITY
DATA RETENTION
INTERNATIONAL DATA TRANSFERS
CHILDREN’S PRIVACY
UPDATES TO THIS NOTICE
CONTACT US

INFORMATION WE COLLECT

The personal information that we may collect about you broadly falls into the following categories: Information which you provide to us Certain parts of our Website and applications may ask you to provide certain information which is appropriate to the level of service you are requesting. We collect information which you provide directly to us when you use our Website, Apps, or Services. The types of personal information we may collect directly from you include email addresses, postal addresses, phone numbers, employee names, usernames, information about the type of service required, job titles, credit card payment information, transactional information (including Services purchased), as well as any communications, inquiries, contact, or other information you choose to provide during your use of the Services. When you provide this personal information, we will only use this information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at Privacy@Zultys.com. Information we collect automatically when you visit our Website or Apps or use our Services When you visit our Website, or use our Apps or Services, we may collect certain information automatically from your device. In some countries, including in the European Economic Area, this information may be considered personal data under applicable data protection laws: Usage information — We keep track of your activity in relation to the Website, Apps, or Services, the configuration of their computers; and performance metrics related to their use of the Website, Apps, or Services. For example, when you use our Services, we may collect:

1. Traffic data about the communications that take place through our platform (such as calls, team chat, video conferencing, and SMS) to enable us to transmit those communications effectively and efficiently;
2. Network Monitoring data to enable us to maintain the security and agility of our internal networks;
3. Log data about you when you use the Services, Website or Apps including Internet Protocol (“IP“) address, Internet Service Provider (“ISP”), browser type, referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site;
4. Device data about any device including mobile phone number and other information related to mobile devices like operating system and model if you use our Services via our Apps. For other devices, information collected by cookies and other similar technologies, we use various technologies to collect information which may include saving cookies to your computers;
5. Call Detail Records of data record produced by a telephone call or other telecommunications transactions. The record contains various attributes of the call, such as time, duration, completion status, source number and destination number;
6. Meta data, which is data created about other data which can include size, formatting and other characteristics of a data item;
7. Emails/Communications with us;
8. Billing data, which includes any payment data;
9. Crash reports and overall usage statistics.

Cookies and other similar technologies — We use various technologies to collect information which may include cookies when you visit our Website or use our Apps or Services. Information we collect from third parties We work with our Channel Partners to service your needs. Often the Channel Partner is servicing the end customer and the data we collect from the Channel Partner is only to provision and support your needs and services. The Channel Partner is the main contact in these cases for your data. In the event the Channel Partner is the service provider via a Zultys product, then the Channel Partner is the sole custodian of your data.

INFORMATION WE USE

We may use the information we collect from you for a range of purposes, including:

• To administer, operate, protect, and maintain the Website, Apps, or Services;
• To process and complete transactions, and send related information, including transaction confirmations and invoices;
• To manage and improve the customer experience of the Website, Apps, or Services;
• To prepare and provide you testimonials regarding the Website, Apps, and/or Services;
• To help deliver our Website, Apps, or Services to Customers for service and support;
• To investigate and prevent fraudulent activities; unauthorized access to the Website, Apps, or Services; and other illegal activities;
• For any other purposes about which we notify and receive your consent from you;
• To respond to inquiries and requests and to provide you with information and access to resources that you have requested;
• To aggregate and analyze your and use of the Website, Apps, or Services for trend monitoring and application performance; and
• To send you technical alerts, updates, security notifications, and administrative communications.

Legal basis for processing personal information (EEA only) If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only when we have your consent to do so, when we need the personal information to perform a contract with you, or when the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we ask you to provide personal information to comply with a legal requirement or enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our or a third party’s legitimate interests and those interests are not already listed above (see “Information We Use” section), we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” section below.

SHARING AND DISCLOSURE OF INFORMATION TO THIRD PARTIES

We will not rent or sell ANY information about you. We may share and disclose your information that we collect with the following third parties:

• Zultys or any of its worldwide affiliates consistent with this Notice for data processing;
• Business partners, contractors, vendors, and authorized third party agents, to:
  • Operate, monitor, deliver, improve and customize our Services
  • Provide support and technical services;
  • Law enforcement agencies, regulatory or governmental bodies, or other third parties in order to respond to legal process, comply with any legal obligation; protect or defend our rights, interests or property or that of third parties; prevent or investigate wrongdoing in connection with the Website, Apps or our Services;
  • Any third parties in connection with prospective or actual, sale, merger, acquisition, financing or reorganization of our business.

YOUR PRIVACY RIGHTS

Update and access to your information Where we process personal information collected via our Website or Apps or via our Services for our own account management, billing or marketing purposes and where required by applicable law, we provide individuals with the opportunity to access, review, modify, and delete any such personal information that we process. Your Privacy Rights as an EEA Person In addition, if you are from the EEA, you may have broader rights to access and delete your personal information, to object to or restrict processing of your personal information, or request portability of your personal information. To make such requests, you can send an email to Privacy@Zultys.com. We will consider and handle all requests in accordance with applicable laws. If we have collected and processed 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 also have the right to complain to your local data protection authority at any time. In general, when processing personal information to provide our Services, we do so only on behalf of our EEA Customers and in accordance with their instructions. This means that if you wish to access, review, modify or delete any personal information we process on behalf of a Zultys Customer, under applicable EEA law or otherwise, you should contact that Customer with your request. We will then help them to fulfill that request in accordance with their instructions.

THIRD-PARTY SITES

This Notice does not apply to, nor are we responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website links including but not limited to social media sites. The inclusion of a link on the Website does not imply our endorsement of the linked site or service. You should check the privacy notices of those sites before providing your personal information to them.

BLOGS AND FORUMS

Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blog or community forum, contact us at Privacy@Zultys.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all Users to exercise caution when providing personal information in blogs and community forums.

SECURITY

Keeping your information secure is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information both during transmission and once it is received. Zultys has no control over or responsibility for the security or privacy policies or practices of other sites on the Internet you might visit, interact with, or from which you might buy products or Services, even if you visit them using links from our Website. Please note that no website, mobile app or service is completely secure and so, while we endeavor to protect our Customers’ information using the measures described above, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will not occur. We endeavor to provide an extremely secure environment.

DATA RETENTION

We will retain your personal information for no longer than is necessary to fulfill the purposes for which the information 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 DATA TRANSFERS

All data stays within our US-based data centers.

CHILDREN’S PRIVACY

Zultys does not provide products or services that are designed for use by children under the age of 16, or knowingly collect personal information from or about children under the age of 16. If you believe that a child under the age of 16 has disclosed personal information to Zultys, please contact Privacy@zultys.com.

UPDATES TO THIS NOTICE

We may update this Notice from time to time in response to changing legal, technical, or business developments. If we change our Notice, we will post those changes on this page in addition to updating the “Last Updated” date at the top of this webpage. If we make changes, we will notify you more directly, for example by posting a notification or message on the Website or by emailing you prior to such changes taking effect. We encourage you to review this Notice regularly to stay informed of the latest modifications.

CONTACT US

If you have any questions, comments or concerns about this Notice, please email us at Privacy@zultys.com. Zultys Inc. 785 Lucerne Drive Sunnyvale, CA 94085