Effective as of July 15, 2019
This Policy applies to all Personal information received by ISI in any format including electronic, paper or verbal. ISI provides customized data processing and reporting services designed to help companies manage their telecom facilities more effectively, optimize employee productivity, improve customer experience and comply with applicable regulatory guidelines.
ISI collects, processes, stores and provides reporting on communications events occurring on corporate telecommunications platforms and/or corporate owned mobile devices. Event records typically represent one or more types of communication events based upon the platforms involved and the service configuration including; voice calls, video calls, IM/chat sessions, file transfers or desktop sharing. Communications events may include internal (peer to peer) conversations, outbound or inbound calls with external parties and conference calls involving multiple parties. Based upon the product offering purchased and customer account configuration, event records may be limited to metadata or may include the content of the conversation. the following types of Personal information may be collected, stored and reported upon:
- Company Name
- Organizational Hierarchy
- Department Name
- Employee Name
- Employee Title
- Employee Telephone Number, Extension Number, or SIP URI
- Call Detail Records include; call date, call time call duration, internal party name and telephone number, extension or SIP URI, telephone number dialled, calling party number, city state and country of call destination or origin
- IM/chat records include date, time and internal party names or SIP URI
- Recorded voice calls include recorded conversation content
- Recorded video calls include recorded conversation and video playback
- Recorded IM/chat sessions include message text
Processed call information is made available to customers via a secured web interface or delivered directly to authorized customer recipients based upon customer instruction. ISI does not own or control any of the information it processes on behalf of ISI's customer. All such information is owned and controlled by ISI's customer. In this capacity ISI receives information transferred from the EU to the US merely as a processor on behalf of its customer and ISI’s customer remains the data controller.
Purposes of data processing
ISI processes data submitted by customers for the purpose of providing ISI’s online services to our customers. To fulfil these purposes, ISI may access the data to provide the services, to correct and address technical or service problems, or to follow instructions of the ISI customer who submitted the data, or in response to contractual requirements.
Inquiries and complaints
ISI is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In compliance with the Privacy Shield Principles, ISI commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact ISI at:
You may also contact us at the mailing address below.
ISI has further committed to refer unresolved Privacy Shield complaints to JAMS Foundation, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit at https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS Foundation are provided at no cost to you.
If neither ISI nor our dispute resolution provider resolves your complaint, you may have the option to engage in binding arbitration through the Privacy Shield Panel.
ISI commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
Third parties who may receive personal data
ISI will not transfer your personal details and any information collected pertaining to your activities (provided that such details and information identify you personally) to any third party, except in the following cases or as otherwise outlined in this Policy:
- We may share your personal information with our agents, service providers, and contractors, including our hosting provider, IT service provider and various SaaS providers in the course of providing you with our services.
- If ISI reasonably believes that it is required by law to share or disclose your information in order to prevent, investigate, or take action regarding illegal activities. In addition, to establish or exercise our legal rights or defend against legal claims;
- Further, your personal information may be disclosed as permitted or required by, or in response to lawful requests by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security;
- In any case of dispute, or legal proceeding of any kind between you and ISI, or between you and other users or third parties with respect to, or in relation with the Services;
- In any case where ISI may reasonably believe that sharing information is necessary to prevent serious damage to your person or property or to the person or property of any third party;
- ISI may share personally identifiable information and information related to your use of the Website, with companies or organizations connected to or affiliated with ISI, such as subsidiaries, sister-companies, parent companies and service providers such as an email service provider to send you emails on our behalf, with the express provision that their use of such information must comply with this policy; or
- ISI is also entitled to transfer or share anonymous, statistic or aggregative information with companies or organizations connected to ISI, and with suppliers, business partners, advertisers, and every third party, according to ISI's absolute discretion; however, ISI will not disclose your identity to them, knowingly or deliberately, without receiving your consent.
- public authorities, including to meet national security, public interest or law enforcement requirements.
Your rights to access, to limit use, and to limit disclosure
Individuals in the EEA and Switzerland generally have the right to access their Personal Data. As an agent processing Personal Data on behalf of its Customers, ISI does not own or control the Personal Data that it processes on behalf of its Customers or their Users and does not have a direct relationship with the Users whose Personal Data may be processed in connection with providing the Service. Since each Customer is in control of what information, including any Personal Data, it collects from its Users, how that information is used and disclosed, and how that information can be changed, Users of the Service should contact the applicable Customer administrator with any inquiries about how to access or correct Personal Data contained in Customer Data. To the extent a User makes an access or correction request to ISI, we will refer the request to the appropriate ISI Customer and will support such Customer as needed in responding to any request.
ISI may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Liability for Onward Transfers
ISI complies with the Privacy Shield’s Principle regarding accountability for onward transfers. ISI remains liable under the Principles if its onward transfer recipients process Personal Data in a manner inconsistent with the Principles, unless ISI proves that it was not responsible for the event giving rise to the damage.
How to Contact ISI
You can contact ISI via e-mail at firstname.lastname@example.org. You may contact ISI via mail or messenger at:
ISI Telemanagement Solutions, LLC.
Attn: Privacy Officer
230 W. Monroe St, Suite 925
Chicago, IL 60606 USA