Privacy Policy

Updated May 17, 2018

1. Scope

This Privacy Policy describes how and why Aspect Software, Inc. (Aspect, we, our, or us) processes the personal information you provide on our websites www.aspect.com and www.voxeo.com and related sub-domain sites (e.g., blogs.aspect.com, support.aspect.com) and our mobile and social media platforms and applications (collectively, the Sites). It also describes your available options regarding our use of your personal information and how you can access and update this information.

Further details about who we are and who to contact in respect of anything in this Privacy Policy are in Section 15 (About Aspect/Contact Us) below.

2. What Personal Information We Collect and for What Purposes

This Privacy Policy informs you of Aspect’s policies with respect to personal information processed by Aspect through the use of our Sites.

Information Collection

The personal information we collect is organised into the following categories:

• information relating to you which you voluntarily submit to us during your use of the Sites, which may include, e.g., your first and last name, address, telephone number, email address, or billing information.
• information collected through the Sites as you use them and may include device identifier information about the type of device, operating system and browser you use, server name, IP address, MAC address of your device, date and time you access the Sites, pages you access while at the Sites, and internet address of the websites, if any, from which you linked directly to the Sites. This includes the information described in our Cookie Policy. Such information is collected to the extent necessary to enable you access to all the functionality of the Sites and to help give you the best possible experience of the Sites.

Use of Information

We may use the personal information collected through the Sites for the following purposes:

• establishing and verify your identity;
• opening, maintaining, administering, and servicing your accounts;
• providing services and support to you including responding to your questions, comments, and instructions;
• processing, servicing, or enforcing transactions and sending related communications to you;
• improving the Sites, including tailoring them to your preferences;
• providing product or service updates, promotional notices and offers, and other information about Aspect and our affiliates including (where we have a lawful basis to do so) sending you marketing communications;
• presenting digital advertisements to you on third party online locations;
• conducting the Aspect GEM Award program, along with other contests or online or in-person activities in which you participate
• complying with our Cookie Policy;
• providing services on Social Media and Mobile Platforms and through our applications as set out in the respective sections 10 and 11 below;
• maintaining the security and integrity of our systems including protecting our systems from fraud and unlawful access;
• sharing necessary information with our affiliates for the purpose of managing our globally organised business structure;
• in relation to a merger, acquisition, or sale of all or a portion of our assets;
• to enforce the Terms of Use or other policies applicable to the Sites;
• compliance with legal requirements, such as in response to an authorised subpoena;
• to protect the rights, property, life, health, security, and safety of individuals; and
• fulfilling any other purposes consistent with our statements under this Privacy Policy or disclosed at the time you provide personally identifiable information to us.

3. Legal Basis for the Processing

• Performance of a contract
  Our processing may be necessary for performance of a contract with you or to take steps at your request to enter into a contract. This applies to carrying out our contractual duties which we fulfil with the help of the Sites: e.g., helping to establish and verify your identity; opening, maintaining, administering, and servicing your accounts; providing services and support to you including responding to your questions, comments, and instructions; processing, servicing, or enforcing transactions and sending related communications to you; and providing services on Social Media and Mobile Platforms and through our applications as set out in sections 10 and 11 below.
• Legal obligation
  Our processing may be necessary for complying with our legal obligations. This applies to the performance of any legal or regulatory obligations: e.g., maintaining the security and integrity of our systems including protecting our systems from fraud and unlawful access; enforcing the Terms of Use or other policies applicable to the Sites; and complying with legal requirements, such as in response to an authorised subpoena;
• Legitimate interest
  Our processing may be necessary for our legitimate interests or those of a third party. This may apply to legitimate interests such as: e.g., improving the Sites, including tailoring them to your preferences; providing product or service updates, promotional notices and offers, and other information about us and our affiliates including (where permitted) sending you marketing communications; presenting digital advertisements to you on third party online locations; sharing necessary information with our affiliates for the purpose of managing our globally organised business structure ; in relation to a merger, acquisition, or sale of all or a portion of our assets; fulfilling any other purposes consistent with our statements under this Privacy Policy or disclosed at the time you provide personally identifiable information to us.
  
  Your information will not be processed on this basis if our interests or those of a third party are overridden by your own interests, rights, or freedoms.
• Consent
  Our processing might take place on the basis of your consent, given at the time and point of collection on the Sites, for one or more specific purposes. This may apply to your consent to: e.g. receive product or service updates, promotional notices and offers, and other information about Aspect and our affiliates including (where permitted) receipt of marketing communications; allow us to present digital advertisements to you on third party online locations; allow us to use cookies in accordance with our Cookie Policy; allow us to share necessary information with our affiliates for the purpose of managing our globally organised business structure.
  
  Where our use of your personal information requires your consent, you can provide such consent at the time and point of collection on the Sites and following the instructions provided therein; or by informing us by email at communications@aspect.com.
• Vital interests
  Our processing may be necessary to protect the vital interests of an individual or some other natural person: e.g., to protect the rights, property, life, health, security, and safety of individuals.

4. Recipients / Disclosure of Information

• Internal Use
  The personal information you voluntarily submit to us during your use of the Sites will be placed into our customer relationship management (CRM) system. We may access that information in accordance with this Privacy Policy, provided that the access is lawful. Because of our global organisation structure, our CRM system is accessible to all our affiliates worldwide as set out in the section 13 (Information Security) below.
• External Use
  We will only disclose your personal information to a third party if such disclosure is in accordance with this Privacy Policy and provided that it is lawful to do so. We conduct an appropriate level of due diligence and put in place any necessary contractual documentation that may be required to ensure compliance with our legal and regulatory obligations.
  
  Third parties to whom we may disclose personal information include:
  • Our affiliates. Further details of our affiliates are available upon request from gdpr@aspect.com;
  • Third party service providers and partners who help maintain and operate the Sites or who help us to provide our services to you or whose products or services may be integrated with our products and services. These include third parties processing information in relation to our CRM system, the hosting of the Sites, the provision of our IT systems, electronic communications service providers, and payment processors. Further details of such third parties are available upon request from gdpr@aspect.com;
  • Any third party necessary to help us enforce our legal rights or those of others;
  • Potential or new owners of our business or any part of it;
  • Any third party to whom you instruct us to disclose your personal information (provided it is lawful for us to do so);
  • Regulators and law enforcement agencies or any other third party who has satisfied us that we are required by law to disclose the personal information to them.
  
  We may also disclose aggregated information about the Sites or the information collected through them which has been through a process of de-identification (i.e. anonymisation or pseudonymisation) to potential business partners (e.g. for purposes of search engine optimisation).

5. Communications and Marketing

We may use the information you provide to us (or which we observe about you from your interactions with the Sites, your email communications, your participation in the Aspect GEM Award Program along with other contests or online or in-person activities in which you participate, and/or your interactions with our products and services) to contact you about us, our affiliates, or our products and services. Where you have consented or where we have another lawful basis to do so, we may send you marketing communications and may share your information within the Aspect group for such purposes. If at any time you receive marketing communications from us and no longer wish to do so you can unsubscribe or notify us by emailing: communications@aspect.com. You can also exercise your rights under the Your Rights with Regard to Your Personal Information section below.

6. Transfers to Third Country and Safeguards

We have a global business structure and as such we do transfer your personal information outside the European Economic Area (“EEA”) to one or more Aspect locations referenced here https://www.aspect.com/company/contact-us/global-office-locations. We also transfer your personal information to third parties as explained in section 4 above to locations throughout the world.

We ensure that such transfers are lawful and that there are appropriate safeguards in place to ensure an adequate level of protection for the personal information transferred.

The European Commission has decided that certain countries to which we transfer your personal information do not provide an adequate level of protection in relation to your personal information. We have therefore entered into Commission-approved agreements often referred to as ‘Standard Contractual Clauses’ or ‘Model Clauses’ where necessary.

If you wish to see details of these safeguards, please reach out to us as set forth in Section 8 (Your Rights with Regard to your Personal Information) section.

7. Information Retention

We will keep your personal information in accordance with our retention policies but will not keep it for longer than is necessary. In general, we will keep your personal information for the duration our business relationship with you and for a certain period afterwards. In considering retention timeframes, we take into account the nature of the information, the nature of our relationship with you, the relevance of the information, and our obligations to comply with applicable laws and regulations.

8. Your Rights with Regard to Your Personal Information

If you are accessing the Sites from within the EEA, you have certain rights in relation to your personal information. Please note that these rights are subject to certain exemptions which be applicable to any request you make:

You can exercise your rights by submitting a Data Subject Request.

9. Links

The Sites may contain links to other websites that are not maintained by or related to us. You may also be directed to a third-party website for certain purposes, such as registering with us or submitting a job application. Please note that these other website privacy and cookie policies may differ from ours. We encourage you to read the privacy and cookies statement of any website you may visit via the Sites. We are not responsible for any content, representations, or policies on such third-party websites.

10. Social Media

Our Sites may include social media features or links to social media sites. These social media features may use tracking technologies to collect information about you, such as your IP address, which page you are visiting on the Sites, and may set a cookie to enable the social media feature to function properly. If you use social media features, information you post or provide access to may be publicly displayed on our Sites or by the third-party service that you use. Similarly, if you post information on a third-party service that references our Sites (e.g., by using a hashtag associated with Aspect), your post may be used on or in connection with our Sites. Also, both Aspect and the third party may have access to certain information about you and your use of our Sites and the social media features. Social media features are operated by a third party and governed by the privacy policy of the third party providing it. We are not responsible for and make no representations regarding the policies or business practices of any third parties and encourage you to familiarise yourself with and consult their privacy policies and terms of use.

Aspect’s Facebook Fanpages

Aspect operates certain Facebook fan pages (“Pages”) for which we act as data controller of your personal information jointly with Facebook for the processing activities set out herein. When you decide to follow our Pages or you interact with us (e.g. when you "Like", share, or comment on a post) we have access to your name, age, gender, country city and device. We don't store your personal information, nor extract it to be incorporated in any separate database. We only use the above information to interact with you on the Pages. We can delete some of your comments if they are not compliant with our policies on the use of the Pages (e.g., if comments provided are offensive, unlawful, or do not observe good faith principles), but we cannot modify them, nor operate your data in any other way.

We also use Facebook Insight, a native analytics application provided by Facebook which, by the installation of Cookies in the devices of users visiting this site, collects some information and provides statistics according to some pre-defined criteria. This information can be subsequently read by the installer of the Cookie with different purposes, like getting information on the browsing behavior of a user or device. Aspect does not administer nor control the cookies installed by Facebook, but uses Facebook Insight, namely reports based on aggregated data (no personal data) such as statistics. Facebook Ireland therefore takes primary responsibility for the lawful processing of Facebook Insight data and your personal information is subject to Facebook's Terms and Conditions and Policies on Privacy and Cookies . Please read these policies carefully to be fully aware of them. Remember that you can delete or edit any comment you make or any post you may publish by using Facebook's functionalities, and that Cookies administered by Facebook can be also deleted by using the setting options of your browsing software.

Should you ask Aspect to exercise any of your rights as set forth in Section 8 (Your Rights with Regard to Your Personal Information) we will no longer process your personal information unless permitted by applicable law and will forward all relevant information to Facebook Ireland to allow Facebook Ireland to answer such request in accordance with its obligations. Aspect is not authorized to act or answer on Facebook Ireland’s behalf.

11. Mobile Platforms

Our Sites may include the use of mobile media platforms. These platforms may use tracking technologies to collect information about you, such as your IP address, which locations you are visiting on the Sites, and may set a cookie to enable the platform features to function properly.

12. Children’s Privacy

The Sites are not directed toward or designed for use by children. We do not solicit or knowingly collect personal information from children. If we learn that we have collected personal information of a child, we will take reasonable steps to delete that information from our systems. Additionally, a child’s parent or legal guardian may request that the child’s information be deleted from our files by contacting us as set forth in the about Aspect/Contact Us section below. We also encourage you to seek further advice for protecting children’s privacy online as appropriate (for example by visiting the U.S. Federal Trade Commission’s website).

13. Information Security

We are committed to keeping your personal information confidential and secure. We maintain appropriate physical, electronic, procedural, technical and organisational measures to help safeguard personal information from loss, theft, misuse, unauthorised access, disclosure, alteration and destruction. Access to your personal information is limited to those who need the information to fulfill the task for which the personal information was collected. All our employees, contractors and agents who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all visitors to the Sites and all users of our services.

Please be aware, however, that any email or other transmission you send through the internet cannot be completely protected, and we cannot guarantee the security of your information you transmit to our Sites. We recommend you take every precaution to protect your personal information when you are on the internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords and make sure you use a secure browser.

14. Changes to this Privacy Policy

We may make changes to this Privacy Policy at any time. When we do, we will change the “updated” date at the beginning of this Privacy Policy. By using the Sites or the service, after the changes take effect, you agree to be legally bound and to abide by the revised Privacy Policy.

15. About Aspect/Contact Us

For further information about our privacy practices, please contact:

Aspect Software, Inc.
Legal Department
2325 East Camelback Road
Suite 700
Phoenix, AZ 85016
U.S.A.
978.250.7900 (phone)
978 244 7410 (fax)
legal-info@aspect.com

© 2018 Aspect Software, Inc.

Data protection law differentiates between a “controller” and “processor” of personal information. Different Aspect entities around the world carry out different functions and provide different products and services. In some instances, certain entities are controllers; and in others they are processors.

In relation to the personal information collected through the Sites anywhere outside the EEA; Aspect Software, Inc. is the data controller.

In relation to the personal information collected through the Sites anywhere within the EEA; the following Aspect entities are the data controllers:

Aspect Software GmbH
Legal Department
Von-Der-Wettern-Strasse 27
51149 Cologne, Germany
legal-info@aspect.com

Aspect Software SL
Legal Department
Palacio de Miraflores, Carrera de San Jeronimo, 15, pl. 2, 28014 Madrid, Spain
legal-info@aspect.com

Aspect Software Italy SrL
Legal Department
Piazza del Popolo, 18, 00187 Rome, Italy
legal-info@aspect.com

Aspect Software BV
Legal Department
Rotterdam Brainpark Lichtenauerlaan 102-120, Rotterdam, 3062 ME, Netherlands
legal-info@aspect.com

Aspect Software UK LTD
Legal Department
The Record Store, 15 Pressing Lane, Hayes UB3 1EP, UK
legal-info@aspect.com

Aspect Software Ireland Ltd.
Legal Department
70 Sir John Rogerson’s Quay, Dublin 2. Ireland D02 R296, Ireland
legal-info@aspect.com

Qivox Limited
Legal Department
7th Floor Yorkshire House, 18 Chapel Street, Liverpool L3 9AG, UK
legal-info@aspect.com

Voxeo Europe LTD
Legal Department
The Record Store, 15 Pressing Lane, Hayes UB3 1EP, UK
legal-info@aspect.com

Voxeo Germany GmbH
Legal Department
Von-Der-Wettern-Strasse 27
51149 Cologne, Germany
legal-info@aspect.com