Privacy Policy Ringover

Information notice on the protection of personal data.

Summary

• 1. Preamble
• 2. What personal data do we collect, purposes and legal basis?
• 3. Data recipients
• 4. Access to and transfer of your personal data
• 5. Where your data is stored?
• 6. How do we secure your personal data?
• 7. Retention period for personal data
• 8. Your rights
• 9. Exercise your rights
• 10. Deletion of personal data
• 11. Modification of the Notice
• Cookies
• 1. Information about the use of the cookies
• 2. Cookie’s definition
• 3. Data retention period
• 4. Cookies setting
  • 4.1. On Ringover’s website
  • 4.2. On the browser
  • 4.3. On mobile device
  • 4.4. On a cookie management platform
• 5. Partners

1. Preamble

When using the Services, RINGOVER SAS, a simplified joint stock company with a capital of 1,532,135 euros, registered in the Nanterre Trade and Companies Register under number 480234210, whose registered office is located at 50 bis rue Maurice Arnoux, 92120 Montrouge, France, hereinafter referred to as “RINGOVER”, is required to process personal data concerning you.

RINGOVER, is committed to ensuring the protection, confidentiality and security of your personal data that it collects and that constitute an essential element of our relationship, in compliance with Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR”), (together the “Applicable Regulation”).

This privacy notice (the “Notice”) describes: The personal data collected, its purposes and legal bases, its recipients, the persons authorized to access it, the places where the personal data is hosted and its security, the period of time for which the said data is kept, the rights you have over it and how to exercise them and finally the modification of this Notice.

Terms beginning with a capital letter and not defined in this Notice have the meaning given to them in our General Terms and Conditions of Sale, which can be accessed here: https://www.ringover.com/terms.

2. What personal data do we collect, purposes and legal basis?

The table below specifies the data that may be processed and collected by RINGOVER and their purposes and legal bases:

Purposes	Data collected	Legal bases
Identification of the Customer/User Fight against fraud	Mailing address, name, phone number, postal address, copy of an identify document	Legal obligation
Use of the Service	Email address, IP address, connection logs, call and SMS logs, answering machine messages, date and duration of calls, incoming or outgoing call numbers, operator identification number (RIO), proof of address, portability mandate, bank identification statement (RIB)	Execution of a contract
Use of the Service	Data (documents, images, audio files, etc.) can be downloaded to synchronise them with other platforms All data created by you while using the Service (imported or user-created phone contacts, call comments, tags, greetings, music on hold, etc.) If the Application is used, the User may synchronise the contacts on the terminal (the contacts are not imported onto our servers). The User may change this authorisation at any time from the Application settings All data imported from Google Calendar when using the Service	Consent
Customer Relationship Management	Summary of trade exchanges, packages, options, commitment period, invoice and payment status, chat conversations, LinkedIn exchanges	Execution of a contract
Evaluation of the quality of the Service and/or training of employees	Recording of telephone conversations when the function is activated	Consent
Customer development	All data filled in on the contact form, by a partner or indicated in contest participation forms (surname, first name, email address, telephone number)	Consent
Sponsorship	All data provided on the sponsorship form (first names, surnames, e-mail addresses, telephone number…)	Legitimate interest

We wish to inform you that RINGOVER will act as a controller only for traffic and billing data necessary for the operation of the Service.

In addition, the contests we organize can take place on different platforms. In addition to the processing of personal information by us, personal data is also processed by the operator of the platform. Furthermore, we would like to point out that RINGOVER is not responsible for the processing of personal data on any other platform.

3. Data recipients

Your personal data are intended for:

• RINGOVER and its authorized personnel who, by virtue of their duties, need to have knowledge of it for the purposes of the processing;
• The banking institution in charge of the payment of your subscription to the Services;
• The service providers, as data processors, that RINGOVER uses to provide the Service;
• Public bodies to meet legal obligations and court orders.

4. Access to and transfer of your personal data

Ringover takes all necessary measures to ensure compliance with the GDPR and, therefore, the confidentiality of your personal data. For this reason, only a limited number of people can have access to your personal data, knowing that measures of Personal Data protection were set up with all these recipients, in particular by means of contractual provisions.

For the provision of the Services, RINGOVER may have to transfer certain personal data provided by the Customer to sub-processors, who may be located outside the European Economic Area and do not ensure an adequate level of protection of personal data.

To this end, RINGOVER undertakes, in accordance with the GDPR, to set up a mechanism to cover such a transfer in a manner that complies with the GDPR and in particular with the standard contractual clauses adopted by the European Commission to govern the transfer of personal data to sub-processors located outside the European Economic Area.

In this case, Ringover’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

In order to comply with American legislation, some of your data, for example your phone numbers, first and last names, will be transferred to TCR, based in the United States of America, so that you can conduct your prospecting and commercial campaigns. If you do not register, you will not be able to legally carry out your campaigns in the United States of America. For further information, you can read TCR’s privacy policy hereby: https://www.campaignregistry.com/privacy-policy.

5. Where your data is stored?

All the personal data we collect, outside the US market, is hosted on our servers in France or the European Union. We have facilities at six points of presence in the Paris region and in the French overseas departments.

We do not use service providers to host your personal data.

6. How do we secure your personal data?

RINGOVER implements all the technical and organizational measures necessary to guarantee the security and confidentiality of the personal data collected and processed, and in particular to prevent them from being distorted, damaged or communicated to unauthorized third parties, by ensuring a level of security appropriate to the risks associated with the processing and the nature of the personal data to be protected, taking into account the level of technology and the cost of implementation.

Calls made from Ringover Applications are encrypted (SRTP). Requests to the API are made using HTTPS only (TLS).

Incoming and outgoing calls (except intra-Ringover calls) are handled via direct interconnections with the telephone operators providing the transit.

In any case, Ringover undertakes to:

• Notify any personal data breaches in accordance with the provisions of Articles 33 and 34 of the GDPR.
• Inform the Customers and Users concerned in the event of personal data breaches likely to give rise to a high risk to their rights and freedoms, in simple and clear terms and describing the likely consequences of the breach as well as the measures implemented by RINGOVER in order to remedy the breach, including those aimed at mitigating the possible negative consequences.

Note that each User or Customer contributes to the protection of his or her personal data by respecting the rules prescribed in the general terms and conditions of sale, in particular concerning his or her login identifiers.

7. Retention period for personal data

Your personal data is retained for the time necessary to meet the legal and contractual obligations to which RINGOVER is subject. The data retention period depends on its nature:

Type of Data collected	Retention period
Identification	Customers: 1 year after termination of the contract Contest: Duration of the contest Prospects: 3 years after the last contact
Use of the Service	1 year after the last contact 5 years after termination of invoices
Recordings of conversations	Varies according to the duration determinated by the User and the applicable regulation When the file is manually deleted
Recordings of chats	1 year after the chat conversation
Cookies	13 months

Where required by law, RINGOVER retains certain information for a period of time necessary to comply with the legal and regulatory provisions applicable to its activities.

8. Your rights

Subject to an express request and to providing proof of identity to Ringover where necessary, Customers have various reasonable rights upon their personal data:

• Access: allows you to obtain a copy of your data;
• Rectification: allows you to update your data;
• Erasure: allows you to request the total or partial deletion of your personal data;
• Object: allows you to object to the processing of your personal data at any time;
• Limitation: allows you to limit the processing of your personal data;
• Portability: allows you to have your data moved, copied or transferred to another controller.

Furthermore, when Customers and Users have given their consent for a particular processing operation, they have the right to withdraw it at any time.

For more information, please refer to the following link: https://www.cnil.fr/fr/respecter-les-droits-des-personnes.

Ringover undertakes, except in the case of complex requests or other difficulties, in which case the deadline may be extended by two (2) months, to respond to your request within one (1) month.

In cases where, as a result of the regulations in force, the exercise of your rights is restricted, Ringover will inform you of this within the same period.

9. Exercise your rights

In order to exercise your rights as set out in the previous article, you simply need to contact the Data Protection Officer (DPO) appointed by Ringover, who can be contacted as follows:

• by mail to the following address: BJT PARTNERS, 50 bis rue Maurice Arnoux, 92120 Montrouge, France;
• by Email : [email protected].

10. Deletion of personal data

The Data Protection Officer (DPO) must be contacted by email at the following address: [email protected], if you wish to exercise your right to deletion, i.e. request the erasure of personal data. The request will be processed within the deadlines set out in Article 8, according to which RINGOVER undertakes to respond to your request within one (1) month (except in the case of complex requests or other difficulties).

Some data can be manually deleted directly from the Dashboard. For all data that cannot be deleted on the Dashboard or for any request of deletion of all user data, you can submit an erasure of personal data request from https://support.ringover.com.

If you do not request the deletion of your personal data, your data will be retained by RINGOVER for the periods set out in Article 7.

11. Modification of the Notice

We may amend this Notice from time to time to reflect changes in our practices, to further clarify our practices or to ensure compliance with regulations. In this case, you will be informed by a message on this site inviting you to view the updated Notice.

Cookies

1. Information about the use of the cookies

Some of the personal data collected by Ringover comes from cookies placed when you browse various websites (ringover.com/ringover.fr/ringover.es/ringover.co.uk), hereinafter referred to as “the Site”, or on the Ringover Application and is intended to distinguish you from other Users.

This personal data helps us to provide you with a pleasant experience when you browse this Site, and also to improve it.

We use different kinds of cookies:

• Technical: The lifespan of these cookies is limited to the time of the session and only includes cookies that are strictly necessary in order to obtain the information required for browsing our Site and our Application. These cookies enable you to use the main functionalities of the Site or Application, but also to implement security measures.
  

  Cookie name	Purposes
  COOKIE_CONSENT	Allows you to remember the User’s choice regarding the deposit of cookies
  PHPSESSID	User session identification
  CONSENT_NEED	Determines whether or not consent is required
  ShowEventBanner	Does not show the banner for the duration of the session
  Currency*	Choice of currency
  Chosen_Plan	Plan code selected by User
  Hide_livechat_greeting	Keeps the chat hidden if the User has decided to minimise it
  showCTA	Popin with the contact form

• Functional: Like technical cookies, they have a very short lifespan and, in the longest cases, do not exceed one year. They are used to give you access to specific functionalities and to recognise you, to indicate that you have passed through one of the pages and to improve your browsing comfort by adapting the presentation according to your display preferences on your terminal, to memorise passwords or any information relating to a form you have filled in on the Site or Application.
• Analytics and audience measurement: These cookies, issued by us or our technical service providers, enable statistical analyses to be made of the browsing habits of Users of the Site and the Application. The results of these analyses are processed anonymously and for statistical purposes only. In addition to analysing the number of visitors, they make it possible, where necessary, to detect browsing problems and, consequently, to improve the ergonomics of our Services. The traffic analysis services used by the Site and the Application only produce and send to our technical service providers aggregated statistics and traffic volumes. The lifetime of these cookies is thirteen (13) months. We also use tools to measure the effectiveness of our email campaigns, enabling us to take relevant commercial action based on the information collected.
  

  Cookie name	Partner	Purposes
  _GA*	Google Analytics	Allows you to track traffic and interactions on the Ringover Site
  _GID	Google Analytics	Stores and counts pages visited
  1P_JAR	Google Ads	Advertisements
  SSID	Google Ads	Allows Users’ interests to be targeted in order to provide them with the most interesting advertisements
  __Secure-3PSID	Google Ads	Allows Users’ interests to be targeted in order to provide them with the most interesting advertisements
  __Secure-1PSIDCC	Google Ads	Allows to use the Site’s options and Services
  IDE	Google Ads	Advertisements
  __Secure-ENID	Google	Secures data
  __Secure-3PAPISID	Google	Allows Users’ interests to be targeted in order to provide them with the most interesting advertisements
  __Secure-1PAPISID	Google	Allows Users’ interests to be targeted in order to provide them with the most interesting advertisements
  APISID	Google	Optimising Google Ads
  __Secure-1PSID	Google	Allows Users’ interests to be targeted in order to provide them with the most interesting advertisements
  SAPISID	Google	Optimising Google Ads
  HSID	Google	Fraud prevention
  SID	Google	Optimising Google Ads
  NID	Google	Saves preferences
  __Secure-3PSIDCC	Google	Optimising Google Ads
  AEC	Google	Prevents spam and other abuses
  SIDCC	Google Maps	Identifies trusted web traffic
  _uetsid	Bing Ads	Enables visits to sites to be stored and traced
  _uetvid	Bing Ads	Enables visits to sites to be stored and traced
  MUID	Microsoft Clarity	Stores the browser used
  CLID	Microsoft Clarity	Identify the User
  _cfuvid	Cloudflare	Enables the application firewall to distinguish between different people sharing the same IP address
  -fbp	Facebook	Enables visits to sites to be stored and traced
  datr	Facebook	Fraud prevention
  Ln_or	LinkedIn	Determines whether the Oribi analysis can be performed on a specific domain
  Li_sugr	LinkedIn	Stores User’s identity
  Bcookie	LinkedIn	Stores the browser used
  Lidc	LinkedIn	Optimises the selection of data centers
  AnalyticsSyncHistory	LinkedIn	Enables visits to sites to be stored and traced
  UserMatchHistory	LinkedIn	Advertisements

Except those necessary for proper operation, your consent is required for the use of cookies. To configure your consent, simply follow the “Manage cookies” link at the bottom of the page on our Site and follow the consent menu concerning cookies.

2. Cookie’s definition

A cookie is not just a little cake that you give to Santa Claus at the foot of the tree. It is also a small text, image or software file that is placed and stored on your terminal.

For more information on cookies, please consult the following link: https://www.cnil.fr/fr/definition/cookie.

3. Data retention period

Your choice is retained for a period of six (6) months. At the end of this period, you will be asked to renew your consent when consulting the Ringover Sites.

Your consent is not absolute and you may revoke it at any time.

4. Cookies setting

4.1. On Ringover’s website

You can configure the use of cookies on our Site by clicking on “Manage cookies” at the bottom of our Site.

4.2. On the browser

You can always refuse to accept cookies by using the appropriate browser settings for cookies, private browsing mode or the “Do Not Track” setting on your browser (DNT).

Depending on your browser, the User has the following options: accept or reject cookies from any source or from a given source, or programme the display of a message requesting the User’s consent each time a Cookie is placed on the terminal.

To express or reconsider their choices, Users can refer to the help menu or the dedicated section of their browser:

• Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
• Safari™: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
• Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• Firefox™: https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites
• Opera: https://help.opera.com/fr/Windows/10.20/fr/cookies.html

4.3. On mobile device

On mobile terminals, the installation of advertising cookies can be configured directly in the terminal settings.

For your information, you will find the steps to follow for the main mobile operating systems:

• Apple / IOS: 1. Settings / 2. Privacy / 3. Advertising / 4. Disable "Limited Ad Tracking" to disable tracking by iAd (Apple’s ad network).
• Android: 1. Open / 2. Account or Sync (depending on your device) / 3. Google / 4. Privacy or Advertising (depending on your device) / 5. Click on Disable ads by interest.
• Windows: 1. Settings / 2. Ad settings / 3. Change the options.

The procedures described above were those existing when this Notice was drafted; the operators of these operating systems may at any time change the procedure to access these settings.

4.4. On a cookie management platform

For better knowledge and control of cookies of any origin and not only those of our Site, the Users are invited to visit the site Youronlinechoices, published by the Interactive Advertising Bureau France (IAB) in order to know the companies registered with this platform and which offer the possibility of refusing or accepting the cookies used by these companies to adapt the browsing information and the advertisements likely to be displayed on the terminal: https://www.youronlinechoices.com/be-fr/controler-ses-cookies.

5. Partners

Ringover cookies are used to personalize content and ads, provide social media features, and analyze traffic. We also share information about your use of the website with our social media, advertising, and web analytics partners, who may combine it with other information you have provided to them or that they have collected from your use of their services:

• Google: https://policies.google.com/technologies/partner-sites?hl=en
• Bing: https://privacy.microsoft.com/en-us/privacystatement
• Facebook: https://www.facebook.com/privacy/policies/cookies/
• LinkedIn: https://www.linkedin.com/legal/cookie-policy
• Youtube: https://policies.google.com/technologies/partner-sites?hl=en
• Gartner: https://www.gartner.com/en/about/policies/privacy/cookie-policy

This Privacy Policy was last updated March 15th, 2024.

Summary

• Ringover INC., privacy policy – US
• What personal information we collect and why
  • Children
• Other recipients of the personal information
• How we protect your information
• Customer proprietary network information (CPNI)
• Your California privacy rights
• Changes and updates to this policy
• Cookies and tracking technology
  • Types of cookies used on the Site
  • Your preferences on cookie placement

Ringover INC., privacy policy – US

Ringover Inc., (“Ringover,” “we” or “us”) provides enterprise communications services including Voice over Internet Protocol (VoIP) telephone services and related products and software (the “Services”).

This Privacy Policy contains important information on how we use, maintain and disclose personal information collected about you on this website and webpages owned and operated by Ringover as well as the Services provided on our website through the customer portal for business customers. By accessing this website or providing information to us through this website, including our customer portal, you accept the terms of this Privacy Policy.

What personal information we collect and why

Purpose	Type of information
Identify and contact	First and last names, email, proof of identity, service address(es), mailing address, phone number
To use the service	Email, IP address, usernames, call and text message logs, voicemails, chats, information related to incoming and outcoming calls, bank routing number, documents necessary to port phone numbers in or out our system
By using the service	Imported and created contacts, call comments, tags, greetings, hold music, information necessary to the integration of professional tools
Commercial dealing	Subscriptions, options, commitment duration, status of invoices and payments

You may voluntarily provide informations as recorded phone conversations in case of activation of this feature. In the case of use of the Ringover Android or iOS apps, if you give your consent, the app can access contacts in your User phone for the sole purpose of allowing you to call these contacts via Ringover (contacts in your phone are not imported to our servers). The User may change this authorisation at any time from the Application settings.

Other information needed to provide you with the information or services you are requesting.

You may enter this information through our contact us form or through our customer portal, available at Ringover.com. We are not responsible for the privacy practices of third parties, even those that have websites linked to or from our website or who act as our marketing agents, dealers or who are designated as Ringover Marketing Partners. We encourage you to review the respective privacy policies of any such third parties.

When you browse our website, you do so anonymously. As with most websites, our website collects certain information automatically, such as the internet domain from which you access our websites, IP address, the type of browser and operating system you use, the date and time of access, pages visited, and the address of the website from which you linked to our website. Like many websites, our website uses cookies to collect information about how you use the website and to assist us in improving our website by understanding how it is used by customers. We do not link this automatically collected data to any personal information. Please see below for more information about our cookies and tracking policy.

We may use the information we collect about your through our website to administer your account; improve Services; correspond with you, particularly when you submit an inquiry, or sign up to receive products or Services, or other communications and updates from us; to maintain the security and integrity of our website, products and Services; to administer, review and improve our website, products or Services; or, should you become a customer, for purposes permitted by your agreements with us, if any, to enable us to provide you with and bill you for certain products or Services. Your information can also be used for the following purposes: recording your Subscription to the Service and assigning a Ringover number; call, fax and text message routing; integrations with your professional tools; management of contacts and user sound files; generating and providing statistics on your calls; access to and use of your personal space (app.ringover.com and dashboard.ringover.com); payment management; managing signatures for contractual documentation; and sending newsletters, updates and other information on your calls.

Children

We are committed to protecting the privacy of children. We do not knowingly attempt to solicit or receive information from children under the age of 13, nor send them requests for personal information. In the event that we determine that we possess personal information from children under the age of 13, we will delete that information.

Other recipients of the personal information

Some products and services may be provided by third-party vendors, such as the manufacturers of various equipment or devices which may be purchased or leased from Ringover.

We will not share or sell your personal information with third parties, other than to our Marketing Partners, agents, and dealers; third party telecommunications carriers and Internet backbone providers; vendors, licensors and suppliers, including payment processors, software or hardware providers, our customer portal host, and others who perform similar functions on our behalf and require such information to provide, bill for or maintain the products and services you have ordered; to protect our network and customers and the networks of our telecommunications carriers and Internet backbone providers; in connection with certain advertising on our website (see more below in the section on cookies); and as otherwise required or permitted by law.

We may disclose your personal information when such disclosure is required or authorized by law or through legal process, or when pertinent to judicial or governmental investigations or proceedings, to protect our legal rights, or to defend and protect the rights of others; in connection with a sale, purchase, merger, reorganization, liquidation or dissolution involving Ringover; and when necessary to respond to an emergency, which includes protecting your safety or the safety of others.

How we protect your information

We make reasonable efforts to maintain the security of our servers and computer networks in order to help prevent the loss, misuse, and modification of the personal information we collect on our website. We protect the security of your personal information by using specialized software during the Service application process, enrollment, or when you pay for Services via our customer portal. We also maintain reasonable administrative, technical, and physical safeguards to protect the personal information in our possession. We have established security protocols to ensure that we are doing our part to protect against any anticipated threats or hazards to the security and integrity of our systems. Even though we take reasonable steps to maintain information security, and expect our vendors to do the same, we cannot guarantee the security of personal information.

We also encourage our customers to do their part in protecting their personal and sensitive information, including being responsible for maintaining the confidentiality of their account login information and other passwords.

Customer proprietary network information (CPNI)

Certain of the information that we collect from you may constitute Customer Proprietary Network Information, or CPNI. CPNI is certain information that we obtain solely by virtue of providing you with the VoIP Services, and that concerns the VoIP Services you purchase, including the type, destination, technical configuration, location and amount of use of such Services, along with related billing information.

From time to time, we will use the CPNI information we have on file to provide you with information about our communications-related products and services or special promotions. Ringover’s use of CPNI may also enhance our ability to offer products and services tailored to your specific needs. Ringover may use your CPNI to let you know about communications-related services other than those to which you currently subscribe that Ringover believes may be of interest to you. In some instances, Ringover will want to share Customer’s CPNI with parties who are authorized to offer Ringover’s services or who perform functions on Ringover’s behalf, such as independent contractors, suppliers, agents or “Marketing Partners,” in order to provide Customer with information about Ringover’s communications-related products and services or special promotions. Your signature on a service agreement or sales order signifies Customer’s consent that Ringover may use and disclose CPNI as described herein.

Nonetheless, you do have the right to restrict Ringover’s use of your CPNI. Customer may deny, withdraw or restrict our right to use CPNI at any time by advising Ringover via email message to [email protected]. If Customer denies or restricts its approval for Ringover to use Customer’s CPNI, Customer will suffer no effect, now or in the future, with regard to how Ringover provides any Services to which Customer subscribes. Any denial or restriction of Customer’s approval remains valid until Customer’s Services are discontinued or Customer affirmatively revokes or limits such approval or denial.

Ringover may disclose CPNI without your consent, and without asking for Customer’s authorization, in any of the following circumstances:

• When disclosure is required by law or court order.
• To protect the rights and property of Ringover or to protect Customer and other carriers from fraudulent, abusive, or unlawful use of services.
• For directory listings.
• To provide Ringover Services to the Customer, including assisting Customer with troubles associated with its Services. Without limiting the foregoing, if you purchased your Ringover Services through a designated Ringover “Marketing Partner,” that entity will provide you with certain support services, and Ringover will share your CPNI with that Marketing Partner as necessary to enable it to provide you with customer support.
• To bill the Customer for Services.
• When Customer has approved use of their CPNI for Ringover, or Ringover’s partners, affiliates, or independent contractors.

Federal privacy rules require Ringover to authenticate the identity of the Customer calling Ringover prior to disclosing CPNI. Customers calling Ringover can discuss their Services and billings with a Ringover representative once that representative has verified the caller’s identity. There are three methods by which Ringover will conduct Customer authentication:

• By having the Customer provide a pre-established password and/or PIN;
• By calling the Customer back at the telephone number associated with the Services purchased; or
• By mailing the requested documents to the Customer’s address or email address of record.

In the event the Customer fails to remember their password and/or PIN, Ringover will ask the Customer a series of questions known only to the Customer and Ringover in order to authenticate the Customer. You may manage your password in the online customer portal available at [email protected].

Ringover will notify you of changes to your account. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.

In addition to the protections described elsewhere in this Privacy Policy, Ringover employees are trained on how CPNI is to be protected and when it may or may not be disclosed. Ringover maintains records of its own and its joint venture partners and/or independent contractors (if applicable) sales and marketing campaigns that may utilize Customer CPNI. Ringover also keeps records of instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.

In the event Ringover experiences a privacy breach and CPNI is disclosed to unauthorized persons, Ringover will notify law enforcement as required by Federal regulations. Ringover cannot inform Customer of the CPNI breach until at least seven (7) days after notification has been sent to law enforcement, or later if law enforcement directs us to postpone disclosure pending investigation. Ringover is required to maintain certain records regarding any breach involving the release of CPNI and retain these records for a period of not less than two (2) years.

Your California privacy rights

If you are a California resident, you may request information regarding the disclosure of your personal information by Ringover to a third party, if any, for a third party’s direct marketing purposes once per calendar year. If applicable, this information would include the categories of information and the names and addresses of businesses with which we shared information in the prior calendar year.

To make such a request, please send an email to [email protected], with “Request for California Privacy Information” in the subject line or body of the email or letter.

If you have any questions about this Privacy Policy, you can reach us by sending an email to [email protected].

Changes and updates to this policy

We will change and update this Privacy Policy from time to time. When we do, the Privacy Policy version date, at the top of this page, will be updated to reflect that revision. We encourage you to periodically re-read this Privacy Policy to see if any changes could affect you.

Cookies and tracking technology

Like many other websites, Ringover collects data with cookies during browsing of the websites Ringover.com or Myringover.com (“Site”) or the Ringover Application. A cookie is a small text, image or software file that is placed and stored on the User’s or Customer’s computer, smartphone or any other device allowing internet browsing (“Terminal”).

Cookies are very useful for allowing a website to recognize a User or Customer, marking their passage from one page to another and bringing additional benefits such as: increased ease of browsing, secured connection and adaptation of web page content according to their preferences and Terminal.

A cookie does not directly identify a user (it does not contain names or first names), but rather your Terminal’s browser or the application used. However, it allows the actions of the same user to be followed using the unique identifier contained in the cookie file. The term "cookie" is also used generically to refer to other similar technologies such as web beacons or invisible pixels, which are small digital images invisible to the user integrated on web pages or in emails and associated with the placement of cookies used to track and analyze the same user’s navigation.

The information stored by cookies, during a period of limited validity, includes pages visited, advertisements on which the User clicks, the type of browser used and their IP address as well as the information they have entered on the Site.

Types of cookies used on the Site

1. Technical and feature cookies

Technical cookies include the cookies necessary to obtain information required for navigation of our Site and applications (session identifiers, your operating system version, and the version of the application used), allowing you to use principal features of the site or application. Feature cookies allow you to access specific features and be recognized, marking your movements from one page to the next as well as improving your ease of navigation; adapting site presentation to your Terminal’s preferences (language used, resolution), memorizing passwords and other information using forms you have filled out on the Site or Application (sign-up or access through the MyRingover space). Technical cookies also allow the implementation of security measures (for example, when you are asked to log in again to the MyRingover space after a certain period of time has elapsed).

We do not ask your permission for the placement of these cookies. Nonetheless, you can object to the use of these cookies and delete them in your browser settings, although such a step may prevent you from being able to access the Site, the Application or services.

These cookies have a very short lifespan: strictly necessary cookies last for the duration of the session, and for feature cookies, from a few hours at least to a year at most.

2. Analytical and traffic measuring cookies

Cookies measuring traffic are emitted by us or by our technical contractors.

Cookies are used for statistical analysis of the navigation modalities for Users of the Site and Application. The results of this analysis are treated anonymously and exclusively for statistical purposes, and only if the service provider uses cookies related to the browser or other Terminals used to navigate the Site.

In addition to traffic analysis, they allow, if necessary, the detection of navigation problems, therefore improving the practicality of our services.

The traffic analyzing services used by the Site and Application produce and send to our technical service providers only aggregated statistics and traffic volumes, with the exclusion of any individual information.

These traffic analytics cookies will not last beyond 13 months.

We also use tools to measure the effectiveness of our email campaigns, which enable us to engage in relevant commercial actions based on information collected (for example, sending a new message or a personalized offer).

You can choose to opt out of analytics cookies from your browsing data. To do this, please see the information below under “Your preferences on cookie placement.”

3. Advertising cookies

Use of advertising space on our Site and Application contributes financially to the content and services that we provide to you. Use of advertising cookies allows you to view ads or follow sponsored links that we determine (or that our partners determine) to be most adapted to your user profile according to your areas of interest, your Terminal, your browsing history or geographic position. It also allows ads from other sites to be adapted to your user profile.

The relevance of public content opened on our Site or third party sites can be achieved thanks to third party technology, through the association of navigation information on the Terminals that you use to connect to our Sites and Application or other sites or applications, and with the data you provide to us during your registration or access to any of our services.

To prevent the use of third party cookies, please see the information below under “Your preferences on cookie placement.”

Refusal of these advertising cookies will not impact the use of our Sites or Application. However, refusing them will not block ads. It instead will only result in showing ads unspecified to your areas of interest.

4. Sharing cookies (social media)

Our Sites and Application contain cookies for links to Facebook and other social media sites, allowing you to share content from our Site with others, make them aware of your tips or opinions concerning the Sites or Application, or even to connect in order to access the entirety of Ringover’s Services via your login information on these social media networks.

This is notably the case with sharing buttons for such social media sites as “Facebook,” “Twitter,” or ”LinkedIn,” which are present on our blog, for example. The social networks providing these buttons are likely to identify you with them, even if you do not use them while consulting our Sites and Application.

These cookies are directly placed by the social media networks. If you are connected to social media while browsing our Sites and Application, the buttons allow content to be shared via your user account.

We invite you to consult these social media networks’ policies on the protection of private life to become more aware of the uses of navigation information, mainly for advertising purposes, gathered through these application buttons.

These cookies do not last longer than 13 months.

Your preferences on cookie placement

When you access the Site or use the Application, you have the possibility of adjusting the settings for cookie placement on your Terminal, notably via the information banner appearing when you access the Site.

You can prevent the placement of all cookies except technical cookies essential to the functioning of the Site, or you can manually prevent the placement of each type.

You also have the following options for managing cookie types:

1. Cookie settings in your browser

Ringover’s website does not respond to “Do not Track” signals.

Depending on the browser, the User has the following options: accept or reject cookies of all types and origins or program a pop-up window asking for User permission each time a cookie is placed on the Terminal.

To refine or review options, Users can refer to the help menu or the dedicated section of their browser:

• Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
• Safari™: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
• Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• Firefox™: https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites
• Opera: https://help.opera.com/fr/Windows/10.20/fr/cookies.html

2. Mobile terminal cookie settings

On mobile devices, the placement of advertising cookies can be modified directly in the Terminal’s settings.

You’ll find information on the steps to follow for the main mobile operating systems:

• Apple / IOS: 1. Settings / 2. Privacy / 3. Advertising / 4. Disable "Limited Advertising Tracking" to disable iAd Tracking (Apple’s Ad Network)
• Android: 1. Open / 2. Account or Sync (depending on your device) / 3. Google / 4. Privacy or Announcement (depending on your device) / 5. Click “Deactivate interest-based ads”
• Windows: 1. Settings / 2. Ads Settings / 3. Edit Options

The procedures described above are those existing at the time of the initial writing of this Privacy Policy; operators of these operating systems may at any time modify the procedures to access these settings. Ringover will have no responsibility to update this Privacy Policy to reflect changes in third party procedures.