We at Deltapath Limited. (“Deltapath”), are committed to protecting the privacy of customers and users of our Deltapath Cloud Services, professional services , users of our websites, www.deltapath.com and deltapath.co.jp and users of our mobile application, CSmile. We have therefore created this policy statement (the “Policy”) to explain our privacy practices and procedures.
INFORMATION WE COLLECT
We collect a variety of personally identifiable information (also referred to as “personal data”) about users of our services and visitors to our website in order to ensure an enjoyable user experience and seamless communications. When we use the term “personally identifiable information,” we mean information that is directly associated with, or could be used to identify, a specific person. Such information includes a name, address, telephone number, e mail address, or information about activities directly linked to that person which would permit the physical or online contacting of that person.
Our definition of personally identifiable information does not include “aggregate information”— data we collect about a group or category of services or users or customers and from which individual user or customer identities have been removed. Aggregate information—for example, a report that indicates that a certain number of our customers reside in a particular state or region of the United States, or a report on how many of our customers visited particular pages of our website—aids us in understanding trends and customer needs. For example, aggregate information allows us to consider new services or tailor existing services to customer preferences, and to provide aggregate statistics (e.g., a Small Business VoIP Usage Index) to customers, potential customers, and business partners.
Our definition of personally identifiable information also does not include your Internet protocol (“IP”) address, unless you have registered with us in the “Preferences” section of our website, in which case your IP address is linked to your personally identifiable information.
We collect the following types of personally identifiable information through use of our website and telephone calls to Deltapath customer service:
- Information You Give Us: We collect information you give us—such as your name, billing address, telephone number, e-mail address, and/or credit card number—when you purchase or use a service, participate in a promotion, or register with us in the “Preferences” section on our website.
- Information We Collect Automatically: We automatically collect certain types of information whenever you interact with us. For example, when you use Deltapath services via your mobile phone carrier or the Deltapath mobile application, Deltapath will collect your mobile phone number and other information about the type of mobile device you use (e.g., operating system, device model) for the purpose of providing the services to you. When you visit Deltapath’s website, our systems automatically provide us with your IP address to tell us what type of web browser you use, which may be linked to personally identifiable information if you have registered with us in the “Preferences” section of our website. When you visit Deltapath’s website by clicking an advertisement on a third-party website, Deltapath automatically collects information about the website you were visiting when you clicked on Deltapath’s advertisement, including the IP address of the website and the date and time that you clicked on Deltapath’s advertisement.
- Information We Obtain from Other Sources: We may obtain information about you from outside sources and add it to, or combine it with, your personally identifiable information, including information such as:
- Credit information, which allows us to complete transactions for the purchase of Deltapath services, and
- Commercially available demographic and marketing information from third parties, which aids us in serving you and informing you of services that may be of interest to you.
Deltapath does not knowingly collect—either actively or passively—any information, including personal information as defined by the Children’s Online Privacy Protection Act, from children under the age of 13.
To see how we use, disclose, and protect the personally identifiable information that we collect, please review the rest of this Policy.
OUR USE OF PERSONALLY IDENTIFIABLE INFORMATION
Our Internal Use: In general, we use personally identifiable information to serve our existing and prospective customers and to enhance and extend our customer relationships. By understanding how you use our services and our website, we are able to customize and personalize our interactions with you. More specifically:
- We use personally identifiable information for billing purposes, to provide services or complete transactions you have requested, to anticipate and resolve problems with your services, and to create and inform you of products or services from Deltapath or others that better meet your needs.
- Subject to your agreement, Deltapath uses e-mail, telemarketing, and direct mail to inform you about Deltapath products or services we think will interest you. If you do not wish to receive these types of communications you can choose at any time not to continue receiving them by contacting us.
- We use mobile device information to conduct anonymous mobile analytics so we have a better idea on how you interact with your mobile device.
While you may choose not to receive marketing information from us, you will continue to receive bills, customer service-related notifications, and other similar information from us electronically or otherwise. You will also continue to receive communications directly related to each service you purchase or subscribe to.
Our Customer Surveys: Periodically, you may be able to participate in our surveys to help us improve our services. Any personally identifiable information that we may collect from you in a survey will ONLY be used internally by Deltapath. And unless otherwise explained in the instructions for a particular customer survey, any personally identifiable information you provide to us for purposes of that survey will be used in accordance with this Policy.
Third-Party Use: To understand when and how Deltapath may disclose personally identifiable information to unaffiliated third parties, please read the Disclosure of Your Personally Identifiable Information section below.
DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION
Because information about our existing and prospective customers is one of our most important business assets, we seek to protect it and keep it confidential. We do not share personally identifiable information with unaffiliated third parties, nor do we sell it to third parties, unless permitted to do so in accordance with this Policy.
Your Consent: Deltapath may disclose your personally identifiable information if you consent to the disclosure in advance. Depending on the service, we may obtain your consent in a number of ways, including:
- In writing;
- Online, by clicking on a link or button; or
- Through the use of a dialing string or buttons on a telephone handset.
In general, we may release personally identifiable information without your consent when we believe release is appropriate to do one of the following:
- Comply with the law (e.g., lawful subpoena or court order);
- Enforce or apply our agreements to sell or provide services to you;
- Bill and collect for services; or
- Protect out rights or property (e.g., to address allegations about fraudulent or unlawful activity on a Deltapath account).
Disclosure to Affiliates: We may share your personal data between our Deltapath group companies and business affiliates where it is necessary to support the services provided to you.
In order to verify payment methods and prevent fraud, Deltapath verifies personally identifiable information, including payment information, with payment providers and fraud prevention services. If at any time you apply for a credit line with Deltapath, Deltapath may perform a credit inquiry with credit reporting agencies, and such inquiry may be noted on your credit record. We may use automated decision making systems to verify payment methods, assess creditworthiness, or prevent fraud, and we may contact you requesting additional information when needed.
For European Economic Area (“EEA”) customers, this may mean that the personally identifiable information (i.e., personal data) you provide us may be transferred to countries outside the EEA. By way of example, this may happen if any of our group servers or companies are located in a country outside the EEA, such as Deltapath, Inc., which is located in the United States. These countries may not have similar data protection laws to the EEA. Nonetheless, if we transfer information outside the EEA in this way, we will take steps to ensure your privacy rights continue to be respected.
For British Telecom (“BT”) Deltapath customers, which are provided in conjunction with BT, we share your personal data, including name, contact details, and information about your Deltapath services and your use of the services, with BT.
Disclosure to Unaffiliated Third Parties: We may share personally identifiable information with unaffiliated third parties only as necessary to complete a transaction or perform a service that you have requested, or to support the technical operation and maintenance of our services and of our website. We may also share personally identifiable information with or to our agents, outside vendors or service providers to perform functions on our behalf. For example, we use third party service providers to perform functions such as analyzing data, providing marketing assistance, providing customer service and processing orders. When the unaffiliated third party acts solely on our behalf, Deltapath requires that party to follow our privacy practices. Deltapath does not sell its customer lists or any personally identifiable information associated with its customers to third parties.
Business Transfers: Information about our users and customers, including personally identifiable information, may be disclosed as part of any merger, acquisition, or sale of company assets. It may also be disclosed in the unlikely event of an insolvency, bankruptcy, or receivership in which personally identifiable information would be transferred as one of the business assets of Deltapath.
Emergency Calls: If you dial for emergency services (e.g., 911 in the U.S., 999 in the U.K.), we may provide personally identifiable location information to a public safety answering point; emergency medical service provider or dispatch provider; public safety, fire service, or law enforcement official; hospital emergency or other medical care facility; or to a service provider that provides such information to such emergency responders.
SECURITY AND DATA INTEGRITY
We maintain a variety of physical, electronic, and procedural safeguards to guard your personally identifiable information. Specifically, we use commercially accepted procedures and systems to protect against unauthorized access to our systems. We restrict access to your personally identifiable information and CPNI to those employees and contractors—all of whom are covered by this Policy—who need to know that information to provide services to you or otherwise assist you. We protect the security of your personally identifiable information during transmission via the Deltapath website by using Secure Sockets Layer (“SSL”) software, which encrypts information you input, so that no one else can read it as it is transmitted over the Internet. And we use an SSL connection to enable you to view, enter, and change the information in the “Preferences” section securely on our website.
You can take additional steps on your own to safeguard your personally identifiable information. For example, you should be sure to sign off when finished using a shared computer. And you should always log out of any website, including the Deltapath website, after viewing personal account information, such as the “Preferences” section of our website.
Please be advised that Deltapath has no control over or responsibility for the security or privacy policies or practices of other sites on the Internet you might visit, interact with, or from which you might buy products or services, even if you visit them using links from the Deltapath website.
OUR USE OF “COOKIES”
Cookies allow us to do the following:
- Complete transactions you have requested;
- Collect information to determine which services and sections of our website are most and least popular;
- Personalize our website and make recommendations to you based on services you have used in the past; and
- Improve the ease of use of our website, sometimes in conjunction with web beacons.
We also use a session-based cookie to maintain continuity of navigation for you when viewing our website during a particular on-line session. After closing the browser, the session cookie simply terminates; it is not stored on your computer’s hard drive thereafter.
Deltapath does not use technology that recognizes “Do Not Track”’ signals from your browser. You can block cookies from your computer using the TRUSTe Consent Manager Here, or your web browser’s settings (see below).:
- Microsoft Internet Explorer: Click the gear icon to the right of the address bar and select “Internet Options”. Select the “Privacy” tab, and you can move the slider to “High” or “Block All Cookies”. In order to delete cookies, select the “General” tab, and under the “Browsing history” section, click “Delete…”. Make sure “Cookies” is selected, and click “Delete” to delete cookies. Click “OK” when you are finished making your changes.
- Mozilla Firefox: Click the “Firefox” menu on the upper-right corner of your browser and select “Options”. Select the “Privacy” tab, and under the “History” section, select “Never remember history” or “Use custom settings for history”. If you select “Use custom settings for history”, you can deselect “Accept third-party cookies” or “Accept cookies from sites”. In order to delete cookies, click “Show Cookies”, scroll to the particular cookies you would like to remove, and click “Remove Cookie”, or click “Remove All Cookies” to remove all cookies. If your history setting is set to “Never Remember history”, click “clear all current history”, make sure “Cookies” is selected, and click “Clear Now”. Click “OK” when you are finished making your changes.
- Apple Safari: Click the gear icon to the right of the address bar and click “Preferences…”. Select the “Privacy” tab, and under the “Block cookies” section, you can select “From third parties and advertisers” or “always”. In order to delete cookies, click “Details…”, scroll to the particular cookies you would like to remove, and click “Remove Cookie”, or click “Remove All” to remove all cookies.
- Google Chrome: Click the wrench icon to the right of the address bar and select “Settings”. Click “Show advanced settings…”, scroll down to the “Privacy” section, and click “Content settings”. Under the “Cookies section”, you can select “Block sites from setting any data” or “Block third-party cookies and site data” to prevent cookies from being set. In order to delete cookies, click “All cookies and site data”, scroll to the particular cookies you would like to remove, and click “x” to the right of the cookies, or click “Remove all” to remove all cookies. Click “OK” when you are finished making your changes.
OUR USE OF WEB BEACONS
Deltapath uses web beacons on its website. A web beacon (sometimes called a “web bug” or “clear GIF”) is a tiny graphic image (usually a 1-by-1 pixel) displayed in a webpage, web-based document, or e-mail message, but it is usually invisible, as it is usually the same color as the background of the webpage, document, or e-mail message. When the user’s web browser reads the HTML code for the web beacon to retrieve the image, it can pass along the IP address of the user’s computer, the time the web beacon was viewed and for how long, and the type of browser used. Web beacons can also be linked to a user’s cookies and any personally identifiable information that may be stored in them.
Deltapath uses web beacons to gather aggregate information, as described above in Information We Collect. Deltapath does not use web beacons that link to cookies or to personally identifiable information on unaffiliated third-party websites. And it does not permit unaffiliated third parties to place such web beacons in advertisements on Deltapath’s website.
CHECKING ACCOUNT AND “PREFERENCES” INFORMATION FOR ACCURACY
Deltapath customers can review or change the information in the “Preferences” section of our website, or by telephoning or writing to Customer Service. For Customer Service contact information, please see the Contacting Us section below. As noted in the Information We Collect About You section above, we may also use updated address information obtained from other sources to update our records. We will respond to your requests to access your records within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services contact us.
SOCIAL MEDIA FEATURES
If you choose to use our referral programs to refer someone to our site, we will ask you for the intended recipient’s name, email address, and phone number. Deltapath will store and use this information to send emails inviting him or her to visit the site. Deltapath stores this information for the sole purpose of sending the emails and tracking the success of our referral program. Your referral may contact us to request that we remove this information from our database.
BLOGS AND FORUMS
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
With your input and your consent, we may post a customer testimonial by you on our website, which may include your name, industry, company, title, or other identifying information. If you want your testimonial removed please contact us.
UPDATING OF OUR POLICY
Deltapath will revise or update this Policy if our practices change or as we change existing services, add new services, or develop better ways to inform you of services we think will interest you. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. You should refer back to this page for the latest information and the effective date of any changes.
If you have any questions, comments or concerns about this Policy, please e-mail us at
legal@Deltapath.com, or call us at +852 3678 9999. Or you can write to us at:
Attn: Privacy Officer
1203-1206 Delta House
3 On Yiu Street, Sha Tin, N.T., Hong Kong