Privacy Policy

Effective September 4, 2024

INTRODUCTION

Our goal at iovox is to be as plain spoken and understandable in our policies as we possibly can. This Privacy Policy includes important information about how we treat any personal data shared by you with us. We take privacy very seriously as we strive to earn and keep your trust. To that end, iovox has never sold, nor will it sell, any personal information shared with us.

Importantly, when you use iovox’s services ("Services"), we are a data processor as defined in the General Data Protection Regulation ("GDPR"). A data processor simply handles information provided to it, and as instructed, by a data controller; in this case that would be you as our customer.

That being said, iovox does play the role of data controller in the limited cases where it relates to our billing relationship with you where you’ve provided us with information on how to charge you for Services or in the case where we are marketing our Services to you based on your consent. The scope of this privacy policy addresses the relationship when we are the data controller, not the data processor.

POLICY

We respect your privacy and do not sell, rent or loan any personally identifiable information ("Personal Data") collected on the iovox website ("Site") or when you use the Services. Any Personal Data that you provide to us via the Site or we collect when you are using the Services will be treated in a careful and secure manner.

In most cases when you use our Services, iovox is the data processor and you are the data controller. For the purpose of this Privacy Policy and applicable data protection legislation ("Legislation"), when we are marketing to you, iovox is the data controller of the Personal Data that we hold about you. This means that, in relation to the processing of Personal Data described in this policy, we determine the purposes for which and how the Personal Data are processed. We comply with the requirements of the Legislation and are registered with the UK’s supervisory authority, the Information Commissioner’s Office.

This policy describes:

• How to contact us.
• What Personal Data we collect.
• How we use your Personal Data and why.
• Who we share your Personal Data with.
• How we use cookies.
• How we keep your Personal Data secure.
• Your Rights relating to your Personal Data.
• Marketing communications preferences.
• How long we store your Personal Data.

Please read the following policy carefully to understand our practices regarding your Personal Data and how we will treat it. Personal Data is the data that relates to you or identifies and/or can be used to identify you (this includes information relating to your name, email address, or other identifiers relating to you such as IP address). Personal data does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person). This policy explains how we collect, use and store the Personal Data you provide to us when you use our Services or Site.

We will only use personal information in the manner permitted by the relevant legislation and in accordance with the content of this policy, as amended from time to time. If you want to contact us about anything in this policy, please see the Contact section at the end of this document.

HOW TO CONTACT US

You can contact us here.

WHAT PERSONAL DATA WE COLLECT

All the Personal Data we collect as a data controller is outlined in the table below:

Category of Personal Data collected	Information which may be included in this category
Identity Data	First name, last name, username or similar identifier, title.
Contact Data	Your billing address, email address and telephone numbers.
Financial Data	Any bank or credit card information needed to process invoices for our Services.
Transaction Data	A record of invoices that we’ve sent to you and when they were paid.
Marketing and Communications Data	Your preferences in receiving marketing from us.
Behavioural Data	Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into "segments" (e.g., there may be a segment for men, living in London and aged under 25, who like sports).
Technical Data	Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose ("Aggregated Data"). Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We do not collect any of your Personal Data form third party sources.

HOW WE USE YOUR PERSONAL DATA AND WHY

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@iovox.com.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a "legal basis" for that use. We will only use your Personal Data when the GDPR allows us to – most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform a contract, we are about to enter or have entered into with you ("Contractual Necessity").
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below. However, broadly speaking, Legitimate Interests means our interests in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests.
• Where we need to comply with a legal or regulatory obligation ("Compliance with Law").

Generally, we do not rely on your consent as a legal basis for using your Personal Data. However, we may need and ask for your consent in relation to sending you third party direct marketing communications to you via email.

We have set out below the relevant purposes and legal bases for which we use your Personal Data – in addition, where relevant, we have also identified what our legitimate interests in that use might be.

Note that we may process your Personal Data for more than one legal basis depending on the specific purpose. Please contact us at privacy@iovox.com if you need details about the specific legal basis we are relying on to process your Personal Data in a specific circumstance where more than one basis is set out in the table below:

Purpose	Category(ies) of Personal Data involved	Why do we do this	Our legal basis for this use of data
Account Creation	Identity Data Contact Data	To register you as a new customer.	Contractual Necessity
To process payments for the Services	Identity Data Contact Data Finance Data Transaction Data	To manage payments for the Services.	Contractual Necessity
Relationship Management	Identity Data Contact Data Marketing and Communications Data	To manage our relationship with you which will include responding to inquiries and notifying you about changes to our terms or Privacy Policy.	Contractual Necessity Compliance with Law Legitimate Interests – we have a legitimate interest keeping our records updated and studying how users use our Services or Sites.
Fraud Prevention	Identity Data Contact Data	To keep the Site and Services and associated systems operational and secure.	Legitimate Interests - we have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
Troubleshooting, testing and research	Technical Data	To track issues that might be occurring on our systems and to keep the Site safe and secure.	Legitimate Interests - it is in our legitimate interests that we can monitor and ensure the proper operation of our Sites and Services.
Marketing	Identity Data Contact Data Marketing and Communications Data	To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased a subscription to the Services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.	Legitimate Interests - we have a legitimate interest in providing you with updates on our Site and Services where you have purchased similar services from us.

WHO WE SHARE YOUR PERSONAL DATA WITH

The table below describes who we share your Personal Data with, what we share and why we share it.

We share your Personal Data within the iovox Group. This will involve transferring your data outside the European Economic Area ("Europe"). Some of our service providers may also be based outside Europe. We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
• If we elect to use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
• As a group of companies, we are compliant with the data transfer requirements of GDPR through intragroup data transfer agreements between our parent company and our subsidiaries. These agreements include the Model Clauses which have been approved by the EU for transfers of data outside the EU.

Recipients	Category(ies) of Personal Data we share	Why we share it	Location(s)
Professional advisers	Identity Data Contact Data	Our lawyers, bankers, auditors and other professionals provide consultancy, banking, legal, insurance and accounting services among other things.	Within Europe
Service Providers	Identity Data Contact Data Technical Data	Our service providers provide us with IT and system administration services.	Within Europe
Regulators and other authorities	Identity Data Contact Data	Authorities may require reporting of processing activities in certain circumstances.	Within Europe

GOOGLE ANALYTICS

We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include: Google Analytics Demographics and Interests Reporting, Remarketing with Google Analytics and Google Display Network Impressions Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include https://optout.networkadvertising.org and https://thenai.org/opt-out/mobile-opt-out/. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

HOW WE USE COOKIES

For a detailed summary of our Cookie Policy please visit https://www.iovox.com/cookies.

THE USE OF ARTIFICIAL INTELLIGENCE-BASED PRODUCTS

We offer certain products powered by artificial intelligence, machine learning, or similar technologies (collectively “AI Products”). These tools are designed to provide value to our customers. The terms in this privacy notice govern your use of the AI Products with our Services.

OUR AI PRODUCTS

Our AI Products are designed for the following functions; AI insights, AI predictive analytics, AI automation and may include the use of machine learning models and natural language processing.

HOW WE PROCESS YOUR DATA USING AI

All personal information processed using our AI Products is handled in line with our Privacy Policy and our agreement with third parties, if any. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data’s safety. To opt out from any processing of your personal information via AI Products you may contact us at: privacy@iovox.com.

HOW WE KEEP YOUR PERSONAL DATA SECURE

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

By law you have the right to:

• Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
• Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent. This right only exists where we are relying on consent to process your Personal Data ("Consent Withdrawal"). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

If you want to exercise any of the rights described above, please contact us at privacy@iovox.com.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at privacy@iovox.com. We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that you have the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

MARKETING COMMUNICATIONS PREFERENCES

No Spam, not now, not ever! You will receive emails from us for information update purposes. However, we will never supply, sell or rent your email address or any other information to any third party, other than if we sold some or all the company to another party.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving marketing messages, this will not apply to Personal Data provided to us because of your use of our Services where we may need to inform you of changes to the Service offered or interact with you regarding technical or customer support related services among other things.

HOW LONG WE KEEP YOUR DATA

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Data	Retention period
Identity Data	For so long as retention is necessary to fulfill the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.
Contact Data	For so long as retention is necessary to fulfill the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.
Financial Data	For so long as retention is necessary to fulfill the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.
Transaction Data	For so long as retention is necessary to fulfill the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.
Marketing and Communications Data	For so long as you remain a customer of ours or continue to opt-in to receive communications from us.
Behavioural Data	For so long as retention is necessary to fulfill the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.
Technical Data	For so long as retention is necessary to fulfill the purposes/use for which it is used. For example, continued interactions with you as a customer of ours.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

OUR POLICY ON CHILDREN

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.

CONTACT

If you have any questions or comments regarding this policy, or your dealings with our team, please contact us at privacy@iovox.com.