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 privacy@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 privacy@aspect.com;
- For purposes of the California Consumer Privacy Act, Aspect has disclosed the above categories of information within the past 12 months.
- 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, 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 no longer wish to receive marketing communications from us you can unsubscribe by visiting our Subscription Centre. 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 may transfer your personal information among the different Aspect locations referenced here. 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
EEA Data Subjects
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 may be applicable to any request you make:
Your right of access. For more information
click here.
If you ask us, we’ll confirm whether we’re processing your personal information and, subject to any exemptions, provide you with a copy of that personal information (along with certain other details) within the timescales or extended timescales provided for by the GDPR for complex requests, or where applicable, provide you with an explanation as to why we will not be complying with your request. If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification. For more information
click here.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible and where this would not involve disproportionate. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure. For more information
click here.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your personal information). If you are entitled to erasure and if because we’ve shared your personal information with others, we’ll take reasonable steps to inform those others where possible and where this would not involve disproportionate effort. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing. For more information
click here.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability. For more information
click here.
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
Your right to object. For more information
click here.
You can ask us to stop processing your personal information, and we will do so, if we’re:
- relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
- processing your personal information for direct marketing; or
Your rights in relation to automated decision-making and profiling. For more information
click here.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you, unless such profiling in necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent. For more information
click here.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You may withdraw consent by emailing us at communications@aspect.com.
Your right to lodge a complaint with the relevant supervisory authority. For more information
click here.
If you have a concern about our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant supervisory authority. Those most relevant to us (because we have an office in these jurisdictions are):
You can exercise your rights by submitting a Data Subject Request.
California Consumers
If you are a California resident accessing the Sites, you have certain rights in relation to your personal information. Please note that these rights are subject to verification processes which may be applicable to any request you make:
Your right to disclosure of personal information. For more information
click here.
You may submit your request by clicking here, emailing ccpa@aspect.com, or calling 1-888-547-2481. Upon receipt of the request, Aspect will verify the request in accordance with the law and regulations, which may in some cases require that you submit additional information.
Your right to deletion of your personal information. For more information
click here.
You may submit your request by clicking here, emailing ccpa@aspect.com, or calling 1.888.547.2481”. Upon receipt of the request, Aspect will verify the request in accordance with the law and regulations, which may require you submit additional information depending on the sensitivity of the information requested for deletion. In any event, you will be asked for additional confirmation prior to deletion.
Your right not to receive discriminatory treatment. For more information
click here.
Aspect will not treat you differently if you exercise your rights above. For example, we will not take away a discount or anything else we’ve previously provided to you as a result of your exercise of rights.
Your right to designate an authorised agent. For more information
click here.
You may designate a person or business entity registered with the California Secretary of State to exercise these rights on your behalf. We will require that you provide evidence of authorisation (i.e., written permission) and in some circumstances we may need to work directly with you to verify your identity to fulfill the 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.
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
5 Technology Park Drive
Westford, MA 01886
U.S.A.
978 250 7900 (phone)
978 244 7410 (fax)
legal-info@aspect.com
© 2019 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