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Simplii Privacy Policy
Simplii and its subsidiaries and other affiliates recognize and support the privacy rights of all
persons, and Simplii respects these rights when collecting and processing personal
information (“PI”). Simplii has developed and adopted this Privacy Policy to describe Simplii’s
privacy values and guide processing of personal information. By purchasing, subscribing to,
or utilizing the Products and/or Services, or registering to attend, attending and/or
participating in any Simplii sponsored events or software in which Simplii participates, you
agree to the terms and conditions of this Privacy Policy.
The obligations and responsibilities set out in this Privacy Policy are applicable to Simplii and
its personnel. The obligations and responsibilities set out in the Privacy Policy are in addition
to any other applicable policies or agreements entered into with Simplii and any applicable
laws and/or regulations.
Statement
Simplii offers Voice over Internet Protocol (VoIP) and related technologies to improve the
telecommunications industry and the lives of individuals throughout the world. Simplii’s
goal is to deliver carrier-grade communication services to all its Customers, at a
reasonable price and to make available all the benefits that VoIP offers as broadly as
possible. In order to achieve this goal, a Privacy Policy is necessary.
Scope
This policy is global, applying to all Simplii locations. It applies to personal information
regardless of format. For example, the policy applies to computerized records and electronic
information as well as paper-based files.
It is also applicable to all personal information that is collected, maintained or processed by
Simplii. The concepts outlined in this policy will guide Simplii’s selection and expectations of
its Customers, partners, agents and/or contractors to whom Simplii transfers and relies on for
processing of personal information.
Simplii provides the technology platform for hosted or “cloud” unified communications as a
service offerings (UCaaS). These Products merely act as a conduit for data transmitted by
third parties and Subscribers. Simplii processes personal information that is controlled by or
originated from other companies, such as Simplii Customers or other business partners.
Simplii also processes personal information in the course of providing support for Simplii
communications products. Simplii shall protect the personal information, comply with all laws
that regulate the processing of such personal information, and process the information only
as authorized by the data controller or the data subject. Accordingly, Simplii relies on
guidance and direction of the Customer (as the data controller), who determines the
purposes of processing such personal information. While Simplii does process data in its role
of providing a technology platform, it does not own, control or direct the use of any of the
personal information stored or processed by any Customer or Subscriber. Simplii only
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processes such personal information in order to provide an invoice for purchased and/or
subscribed Products and Services.
Data Processor
Simplii provides the technology platform for hosted or “cloud” unified communications as a
service offerings (UCaaS). These Products merely act as a conduit for data transmitted by
third parties and Subscribers. Simplii processes personal information that is controlled by or
originated from other companies, such as Simplii’s Customers or other business partners.
Simplii also processes personal information in the course of providing support for Simplii
communications products.
Simplii shall protect the personal information, comply with all laws that regulate the
processing of such personal information, and process the information only as authorized by
the data controller or the data subject. Accordingly, and in its role as a data processor, Simplii
relies on guidance and direction of the Customer (as the data controller), who determines the
purposes of processing such personal information. In some cases, Simplii may collect and
process personal information to better assist in supporting application of Simplii’s software.
While Simplii does process data in its role of providing a technology platform, it does not own,
control or direct the utilization of customers personal information stored or processed by any
Customer. Simplii only processes such personal information in order to provide an invoice for
purchased and/or subscribed Products and Services.
What Information Simplii collect or Process
Simplii processes and in certain situations collects personal information as needed to deliver
its Products and Services and manage its business. When collecting personal information,
Simplii does so in a reasonable and lawful manner.
The types of information and the purposes for which Simplii collects or processes personal
information may include:
Indirect End Account Phone Contact Information (Personal Identifiable Information)
Simplii acts as a data processor with regard to indirect Customer information and Simplii’s
Customers act as the data controller of such data. In the course of Simplii’s processing and
protection of such data will be in conformity with the data controller’s instructions.
Specifically, only when enabled via system permission on Simplii Android and Simplii iOS,
Simplii shows personal contacts within the respective application. When the account owner
sends an SMS message to one of his/her phone contacts, or when the account owner
initiates a call to one of his/her phone contacts, the phone number is sent securely through
Simplii’s API. Simplii does not store this number with any other platform, and it cannot be
directly or indirectly attributed to any person or persons; Simplii stores only the phone
number and pertinent metadata so as to be compliant with all applicable state and federal
laws, and Simplii does not share this data with any advertisers or third parties under any
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circumstances. An individual can revoke phone contact access on his/her mobile device at
any time, and his/her app experience is not hindered or interrupted.
Customers
Simplii will not share or disclose personal information for purposes other than as described
herein. Capitalized terms used in this Privacy Policy shall have the meaning as given in
Customers Master Services Agreement (MSA). The following are examples of some of the
personal information Simplii may process.
Business Contact Information:
Simplii may collect personal information about individual contacts of Customers and others
who access Simplii public websites, knowledge bases, forums, ticket systems, or provide
personal information through other means. Such information may include but is not limited to
account information, first/last name, company name, title, and responsibilities, work email
address, work mailing address, telephone numbers, login information, device identifiers, as
well as additional information provided by such individuals in the course of receiving Products
and Services from Simplii and/or requesting information about Simplii. Simplii will apply such
information for the purposes of providing Products and Services, support, conducting data
analytics, payment processing, and product assessments and related activities, and providing
information regarding Simplii Products and Services.
Customer Proprietary Network Information (CPNI):
Customer Proprietary Network Information (CPNI) may include information regarding quantity,
destination, technical configuration, location, amount of use and related billing information of
telecommunications, interconnected and/or non-interconnected Voice over Internet Protocol
(VoIP) services. This may include but is not limited to the phone numbers that you call or
send messages to (or the phone numbers that you receive these calls and messages from)
through Simplii’s Products and Services. The date, time and duration of the calls may also be
collected. This data is utilized for billing and service level assurance.
Simplii provides Products and Services that are primarily for the benefit of Customers and
Subscribers in that Simplii transmits, routes, switches or caches information. These Products
and Services merely act as a conduit for data transmitted by third parties and Subscribers.
Simplii does not determine the purposes and means of processing this information. Except for
Subscriber data provided by the Customer (the Subscribers service provider) for which
Simplii is merely providing a conduit for transmission, the subscribed services are of such a
nature that, in most instances, Simplii requires and collects only essential CPNI and billing
information; and opting out or declining to provide the requested data may hinder the
provision or delivery of subscribed services. However, for CPNI data that is collected by
Simplii that is not subject to the control of others, Simplii shall obtain consent from the
customer for the processing of this data.
Simplii collects end-customer CPNI in the course of providing Product support. This data may
pertain to Customers of Simplii or Subscribers (eg: end customer of Simplii). This data may
include IP address, telephone number, email address, call detail records, call recordings and
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other information sufficient to identify an individual customer.
Indirect Customer CPNI:
Simplii acts as a data processor with regard to indirect customer personal information and
the customer acts as the data controller of such data. In the course of Simplii’ processing
and protection of such data, processing will be in conformity with the data controller’s
instructions.
Direct Customer CPNI:
Simplii typically collects and processes direct customer (eg: Customers, vendors, and
partners) information for the purposes of providing Products and Services, support,
conducting data analytics and managing product performance.
Messaging, Voicemail, Video and Media Files:
Simplii provides Products and Services that facilitate the recording and storage of audio and
video by way of features such as but not limited to voicemail, call and conference recording.
Customers may elect to store or record information within these resources at their
discretion.
Anonymized, Non-Identifying Voice and Traffic Data
Simplii may manage anonymized, non-identifying data collected from operation of Simplii
Products and Services. This anonymized, non-identifying data may be applied to enhance
such items, but is not limited to, voice activation, improve traffic analysis algorithms and
techniques, and recognition algorithms. This processing is executed under applicable terms
and supports Simplii’s legitimate interests in tuning, maintaining and enhancing Simplii’s
Products and Services.
Cookies
Simplii websites may ask for cookies to collect certain kinds of personal information about
Subscribers. For more information on how Simplii applies cookies and choices available to
Subscribers please refer to the following section.
How Simplii Gathers Information
Simplii collects information in various ways, including the following:
When you activate one of Simplii’s Products or Services, Simplii gathers, and stores certain
information provided directly from the customer. Simplii also collects information about
Simplii’s customer account activity.
Cookies and Similar Collection Methods
Simplii also collects technical information on Products and Services Simplii provides, and
Simplii has various technologies to collect information about cookies, IP addresses,
device type and device identifiers, application state and the date and time of activity with
Simplii’s Products and Services. Simplii may associate this information with account
identification and/or account number to better assist and support Simplii customers.
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Other Passive Site Tracking
Simplii’s website and telephony portal may utilize Internet Protocol (IP) addresses and log
files to identify network and server concerns and problems. Simplii also utilizes web beacons
and other passive tracking mechanisms to perform standard website traffic analysis in a
similar manner to how Simplii utilizes cookies.
Credit Card Information
Simplii only collects credit card information in order to bill for purchased or subscribed to
Products and Services. Simplii utilizes third-party credit card payment processing agents
(where these agents are required to implement reasonable and appropriate measures to
protect and secure this information from loss or misuse) solely for the purpose of processing
payments for Simplii’s Products and Services purchased or subscribed to. These payment
processors are governed by their privacy policies, as well as adhering to the standards set by
PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands
like American Express, Visa, Mastercard, and Discover.
Changes to Simplii’s Privacy Policy
Simplii reserves the right to change this Privacy Policy at Simplii’s discretion performed by
The Management Team. As a Simplii customer it is advised to review and check this Privacy
Policy from time to time and particularly before you provide personal information to Simplii.
Changes to this Privacy Policy are effective when they are posted. By continuing to subscribe
to Simplii’s Products and/or Services you are agreeing to changes or revisions made to
Simplii’s privacy policy.
References
•ISO 27002: 6, 8, 11, 12, 16, 18
•NIST CSF: ID.AM, PR.IP, PR.DS, PR.PT, DE.CM
•Change Control Policy
•Encryption Policy
•Encryption Standard
•Information Classification and Management Policy
•Media Reuse and Destruction Standard
•Technology Purchasing Standard
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Waivers
Waivers from certain policy provisions may be sought following the Simplii Waiver
Process.
Enforcement
Personnel found to have violated this policy may be subject to disciplinary action, up to and
including termination of employment, and related civil or criminal penalties. Any vendor,
consultant, or contractor found to have violated this policy may be subject to sanctions up to
and including removal of access rights, termination of contract(s), and related civil or criminal
penalties.