Spectralink Corporation

Data Privacy Policy

Your privacy is important to us. This Privacy Policy explains what personal information Spectralink Corporation, and Spectralink Europe ApS (together “Spectralink”) collects from you, through our interactions with you and through our products and services, and how we use that personal information.

References to Spectralink’s products and services in this statement include all Spectralink products, services, websites, applications, software, servers and devices.
The data controllers for the purposes of your personal information are Spectralink Corporation, and Spectralink Europe ApS (which includes the branches of this company located in Denmark and the UK) (together the “Spectralink Group”). This Privacy Policy is issued on behalf of the Spectralink Group so when we mention Spectralink, "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Spectralink Group responsible for processing your personal information.

You do not need to take any action as a result of this Privacy Policy, but you do have certain rights as described below. We will notify you of important updates by providing notice through the Spectralink website or services, or by email.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

This Privacy Policy was last updated on September 23, 2019.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below:


1. What information do we collect about you and when?
2. How will we use the information about you and on what legal basis?
3. Disclosures of your personal information
4. Security and retention of your personal information
5. How to access and control your personal information
6. Third party links and websites
7. Cross-border data transfers
8. Cookies & Similar Technologies
9. How to Contact Spectralink 
 

1. What information do we collect about you and when?
We collect personal information from you when you voluntarily provide it by: (1) providing information to us or our business partners in connection with a transaction or in furtherance of our business relationships; (2) registering for products on our Website or otherwise contacting us to obtain information relating to our products or our services; (3) signing up to enter a promotion, participate in an event or survey, receive newsletters or other literature; or (4) providing information when we (i.e. our customer service representatives or employees) contact you either at trade events or by other means such as email or phone.
In some cases, we collect this information from you directly and we may also receive such information from our business partners (such as resellers) who may collect this information from you in the context of your business relationship with us and/or the business partner.

We also obtain individual’s contact details from third parties for the purposes of sending relevant communications. We will inform you when we first communicate with you if this is the case. We protect information obtained from third parties according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the information. Depending on the circumstances in which your personal information has been obtained by these third-party sources, we will rely on either your consent or our legitimate interests in communicating with you in relation to our products and services, to process this information. These third-party sources vary over time, but include:

• Definitive Healthcare
• Chain Store Guide
• Zoominfo
• Ebusiness prospects
• Electric Marketing

We are not responsible for our business partners’ or such third parties’ privacy practices and you should check their own privacy policies for further information.
In connection with the above activities we collect the following personal information:

• Your name, mailing address, telephone number, e-mail address, and other contact information.
• Occupation, company name and name of position within company.
• Your preferences and use of email updates, recorded by emails we send you.
• The username and password you provide Spectralink’s website for authentication and account access.
• Your IP Address, this is a string of numbers unique to your computer that is recorded by our web server when you request any page or component on the Website. This information is used to monitor your usage of the Website.
• Data recorded by the Website which allows us to recognise you and your preferred settings, this saves you from re-entering information on return visits to the site. Such data is recorded locally on your computer using cookies. If you wish to manage the cookies we use, you can set your browser to notify you when you receive cookies which lets you choose whether to accept it or set your browser to accept any cookies automatically. Please refer to the section on ‘Cookies and Similar Technologies ’ below for further information.

We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We do not knowingly collect or solicit personal information from anyone under the age of 16.  

We will only collect and process personal information about you where we have lawful bases to do so (please see section 2 below ).

You have choices about the personal information we collect. When you are asked to provide personal information, you may decline. But if you choose not to provide personal information that is necessary to send you communications regarding our products and services, we may not be able to send you that information. In certain circumstances, you must provide your personal information in compliance with a statutory requirement, a contractual requirement, or as necessary in order to enter into a contract with us. We will inform you where this is the case, at the time of collecting your personal information and the consequences of not providing the information.

If you are located in the European Union, when you provide any personal information via our Website, you may be asked to consent to Spectralink processing your submitted personal information for the purposes set out above and asked whether you want to opt-in to future communication from Spectralink (see Section 2 below for further details) .


2. How will we use the information about you and on what legal basis?
Spectralink uses your personal information for the following purposes, and pursuant to the corresponding legal basis:
 

Purpose	Legal Basis
To send you information you have requested.	Legitimate interest or consent (as appropriate).
To send you information about our company, our industry specific content and reports.	Legitimate interest or consent (as appropriate).
To keep you informed of Spectralink products and services in which you and your company might be interested.	Legitimate interest or consent (as appropriate).
To send you webinar invites.	Legitimate interest or consent (as appropriate).
To administer promotional offers, contests or other promotional events.	Legitimate interest or consent (as appropriate).
To contact you by email, telephone or other means, regarding questions you may have about our products and services.	Legitimate interest.
To process transactions and requests related to the sale, delivery, and support of Spectralink products and/or services.	Contractual necessity.
To correspond with you regarding orders or delivery of a product or service.	Contractual necessity.

 
In addition, we use the information collected in relation to your use of the Website (1) to personalize your experience on our Website, (2) to conduct internal reviews of our Website and to help us better understand visitors' use of our Website, (3) to help us improve the design and layout of our Website and provide content of interest to you.

At any time, you can update your preferences by clicking the link in any emails you receive from us. You can also stop receiving emails from us using that same link. Please note that where you opt out of receiving marketing emails from us, this will not apply to personal information provided to us as a result of a product or service purchase, warranty registration, or other transactions. For information about managing your contact data, email subscriptions and promotional communications, please contact data.privacy@spectralink.com.

3. Disclosures of your personal information
We share or disclose your personal information with your consent, or as necessary to complete any transaction, or provide any product or service requested, and in order to conduct our business operations. The parties with whom we share your personal information and why, are as follows:

• Affiliates and Subsidiaries of Spectralink: We share your personal information with the branch of Spectralink Europe ApS located in the UK, and with other affiliates and subsidiaries of Spectralink.
• Business Partners: We partner with other organizations to sell our products and provide services and may share information about you in connection with those distribution arrangements.
• Third Party Service Providers: In order to provide you with useful communications, and delivery and support of our products and services we share your personal information with service providers and vendors who are supporting us or acting on our behalf, including pair Networks, Inc. and Velocity Technology Solutions, Inc., both of which provide hosting services for certain applications we use; Auxis Costa Rica Ltd., who assist us in processing orders; Salesforce.com, Inc.; Link Logistics A/S, our distribution hub in Denmark; InTech Electronics Ltd; and T2 Mobile International Limited.
• Third Parties by Law: We share or disclose your personal information if we believe it is required, including: (i) to comply with applicable laws, litigation or requests from governmental authorities, (ii) for the purposes of national security, law enforcement or issues of public importance, or (iii) in the event of a reorganization, merger, sale, acquisition, assignment, or other disposition of all or a portion of our business, assets or shares.

4. Security and retention of personal information
We use appropriate organizational, physical, procedural and technical safeguards to prevent unauthorized access, destruction, use, modification or disclosure of personal information. We train and instruct our employees that all personal information must be handled in accordance with this Privacy Policy and applicable privacy and data protection laws, and any misuse by employees is subject to disciplinary action.
We will retain your personal information for the period necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By law, we have to keep basic information about our customers for seven (7) years from the original date of collection.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal information are available in our data retention policy, which you can request from us by contacting us (see section 9 for contact details ).
5. How to access and control your personal information
At any time after you have submitted personal information to us, you may contact us at data.privacy@spectralink.com or 1-800-775-5330 to:

• You may request access to personal information we have collected regarding you or your company. We will respond to your request as soon as possible and (save for in certain circumstances) within one month.
• You may notify us of changes to your personal information if it is inaccurate or it needs to be updated.
• You may also elect to have personal information we have collected on you deleted from our customer database.
• Restricting Our Use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (unless the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe we no longer need your personal information for the purposes for which it was collected, but you still need your personal information to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
• If you wish to transfer your personal information to another organization as a data controller (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
• Right to Withdraw Consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us at data.privacy@spectralink.com to let us know that you withdraw that consent at any time. If you do not do so, we will continue to rely upon that previous consent to keep using and processing your personal information in the same way.

If you request any such changes, we will contact you by email to confirm those changes.

We do not carry out any automated processing, which may lead to an automated decision based on your personal information.

You will not be penalized or discriminated against for exercising any of your rights contained in this Section. 


6. Third party links and websites
Our website contains links to other websites. No information collected on this website is shared with or provided to these other websites. Spectralink is not responsible for the privacy practices or the content of such third-party websites.

7. Cross-border data transfers
Spectralink is an international organization and we transfer your personal information outside of the European Economic Area to the United States, China and Costa Rica for the purpose of processing transactions and requests related to the sale, delivery, and support of Spectralink products and/or services. Where any such country does not offer the same level of data protection as your country of residence, we take measures to ensure an appropriate level of protection for your personal information. Namely, in respect of transfers to Spectralink located in the United States, we have entered into standard contractual clauses approved by the European Commission as offering an adequate level of protection to personal information. We will only transfer personal information to the third-party service providers located outside the European Economic Area with your consent or where appropriate measures are in place (namely, the entry into of European Commission approved standard contractual clauses or adherence by such third party to the EU-US Privacy Shield).


8. Cookies & Similar Technologies

What is a cookie? 

A cookie is a small piece of text sent to your browser when you visit the Website. It serves a variety of functions, like enabling us to remember certain information you provide to us as you navigate between pages on the Website.  Each cookie expires after a certain period of time depending on what we use it for. Cookies are useful because they help us make your experience on the Website more enjoyable. They allow us to recognize your device (e.g., your laptop or mobile device) so that we can tailor your experience of the Website. 

Why do we use cookies? 

We use first party and third party cookies for several reasons, such as letting you navigate between pages efficiently, remembering your preferences, remembering your username and password, enabling you to keep items in your shopping basket, letting us analyze how well our website is performing, and improving your experience. Some cookies are required for technical reasons in order for our Website to operate. Other cookies enable us and the third parties we work with to track and target the interests of visitors to our Website and across other sites and services. For example, we use cookies to tailor content and information that we may send or display to you and otherwise personalize your experience while interacting with our Website and to otherwise improve the functionality of the services we provide. Third parties also serve cookies through our Website for advertising, analytics, and other purposes. This is described in more detail below.  

What cookies do we use?

Essential

These cookies are strictly necessary to provide you with the Website and to use some of their features, such as access to secure areas or to facilitate log-ins to the Website. Because these cookies are strictly necessary to deliver the Website, you cannot refuse them without impacting how our Website functions. You may be able to block or delete essential cookies by changing your browser settings. Examples of essential cookies we may use include the following services:

Cookies: Google Tag Manager

You can learn more about how Google uses cookies for advertising purposes and opt-out instructions by clicking 

here..

Performance and Analytics, Personalization, and Security

These cookies help us analyze how the Website is being accessed and used, enable us to track performance, and secure the Website. For example, we use cookies to get insights regarding users and Website performance, such as page speed or to help us customize our Website for you in order to enhance your experience. Examples of performance and analytics, personalization, and security cookies we may use include the following services:

Cookies: LinkedIn Analytics (by Microsoft)

Targeting or Advertising Cookies 

You can learn more about LinkedIn Analytics cookies by clicking here..
To opt-out of LinkedIn Analytics, you can visit this link.. 

These cookies are used to make advertising messages more relevant to you and your interests. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited our Website. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after we receive it. This process helps us manage and track the effectiveness of our marketing efforts. Examples of targeting or advertising cookies we may use include the following services:

Cookies: DoubleClick (by Google)

Social Media

These cookies are used when you share information using a social media sharing button or “like” button on the Website or you link your account or engage with our content on or through a social networking site such as Facebook, Twitter, or Instagram. The social network will record that you have done this. This information may be linked to targeting/ advertising activities.

How do I manage cookies? 

Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Website and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.. 

Please visit our Privacy Policy for more information about your choices in connection with your personal information, including additional instructions for opting-out of behavioral-based advertising.

Cookie Policy updates 

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies. The date at the bottom of this Cookie Policy indicates when it was last updated.

Where can you get further information?

If you have any questions about our use of cookies or other technologies, please email us at help@spectralink.com..

9. How to Contact Spectralink
If you have any questions about this privacy policy or Spectralink’s treatment of your personal information, please contact:

Address: Spectralink Corporation, 2560 55^th Street, Boulder, CO 80301

Phone: +1-303-441-7500

E-mail: data.privacy@spectralink.com

If your query or complaint is not resolved by Spectralink to your satisfaction and you wish to make a formal complaint to the relevant national supervisory authority, you can find the relevant details at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Last Revised: Oct. 19th, 2021