Privacy Policy

Introduction

CBIT Inc. and its subsidiaries recognize privacy rights and respect them when collecting and processing personal information. The company developed this Privacy Policy to describe privacy values and guide personal information processing. By purchasing, subscribing to, or utilizing Products/Services, or attending CBIT events, you agree to this Privacy Policy's terms.

The obligations apply to CBIT personnel and are available on CBIT's website. These obligations supplement other applicable policies, agreements, and laws.

Scope

This global policy applies to all CBIT locations and covers personal information in all formats—computerized records, electronic information, and paper files.

CBIT provides cloud unified communications as a service (UCaaS). The platform acts as a conduit for third-party data transmission. CBIT processes personal information controlled by or originating from clients and business partners, and also processes information providing support for CBIT communications products.

CBIT protects personal information, complies with all applicable laws, and processes information only as authorized by data controllers or data subjects. CBIT relies on client guidance as the data controller, who determines processing purposes.

Key limitation: CBIT does not own, control, or direct the use of personal information stored or processed by clients or subscribers. CBIT processes such information only to provide and invoice for Products and Services.

Data Processor

CBIT's UCaaS platform acts as a conduit for third-party data transmission. CBIT processes personal information controlled by or originating from clients and business partners.

CBIT shall protect personal information, comply with regulating laws, and process information only as authorized by data controllers or data subjects. As a data processor, CBIT relies on client guidance determining processing purposes.

CBIT does not own, control, or direct personal information use stored or processed by clients or subscribers. CBIT processes such information only to provide and invoice for Products and Services.

What Information We Collect or Process

CBIT processes and collects personal information as needed to deliver Products and Services and manage its business. Collection occurs in a reasonable and lawful manner.

Clients

CBIT uses personal information for relevant, appropriate, and customary purposes only. CBIT will not share or disclose personal information for other purposes. Capitalized terms have meanings given in the Client's Master Services Agreement (MSA).

Business Contact Information

CBIT collects personal information about individual contacts of clients and others accessing CBIT public websites, knowledge bases, forums, ticket systems, or providing information through other means. Information may include account information, first/last name, company name, title, responsibilities, work email, work mailing address, telephone numbers, login information, device identifiers, and additional information provided in receiving Products/Services or requesting CBIT information.

This information is used for providing Products/Services, support, conducting data analytics and product assessments, and providing information regarding CBIT Products and Services.

Customer Proprietary Network Information (CPNI)

CPNI may include information regarding quantity, destination, technical configuration, location, amount of use, and related billing information of telecommunications, interconnected and/or non-interconnected Voice over Internet Protocol (VoIP) services.

Information may include phone numbers called or messaged to (or received from) through Products and Services. Date, time, and call duration may also be collected. This data is used for billing and service level assurance.

CBIT's Products and Services primarily benefit clients and subscribers through transmitting, routing, switching, or caching information. These act as a conduit for third-party and subscriber data. CBIT does not determine processing purposes and means.

Except for subscriber data provided by clients (the subscriber's service provider) where CBIT provides transmission conduit, subscribed services require CBIT to collect only essential CPNI and billing information. Opting out or declining requested data may hinder service provision or delivery. However, for CPNI data CBIT collects not subject to others' control, CBIT shall obtain user consent for processing.

CBIT collects end-user CPNI providing product support. This data may pertain to CBIT clients or subscribers (end users of CBIT's direct clients). Data may include IP address, telephone number, email address, call detail records, call recordings, and other information sufficient to identify individual end users.

Indirect End User's CPNI

CBIT acts as a data processor regarding indirect end user personal information. Clients act as data controllers. In processing and protecting such data, all use conforms to the data controller's instructions.

Direct End User's CPNI

CBIT typically collects and processes direct end user personal information (clients, vendors, partners) for providing Products/Services, support, conducting data analytics, and managing product performance.

Messaging, Voicemail, Video and Media Files

CBIT provides Products and Services facilitating audio and video recording and storage through features including voicemail, call and conference recording. Users may elect to store or record personal information within these resources at their discretion.

Anonymized, Non-Identifying Voice and Traffic Data

CBIT may use anonymized, non-identifying data collected from Products and Services use. This data may enhance voice activation, improve traffic analysis algorithms and techniques, and recognition algorithms. Processing executes under applicable terms and supports CBIT's legitimate interests in tuning, maintaining, and enhancing Products and Services.

Cookies

CBIT websites may use cookies collecting certain personal information about subscribers or users. For cookie usage information and available choices, refer to the following section.

How We Collect Information

Information is collected in various ways, including when using CBIT Products or Services. CBIT collects and stores information directly provided and collects information about Products and Services use.

Cookies and Similar Collection Methods

CBIT collects technical information about Products and Services usage using various technologies collecting cookie, IP address, device type and identifiers, application state, activity date and time information, and similar data. CBIT may associate this information with user identification and/or account numbers for internal use.

Other Passive Site Tracking

Websites utilize Internet Protocol (IP) addresses and log files identifying network and server concerns and problems. CBIT utilizes web beacons and other passive tracking mechanisms performing standard website traffic analysis similarly to cookie utilization.

Credit Card Information

CBIT collects credit card information only to bill for purchased or subscribed Products and Services. CBIT utilizes third-party credit card payment processing agents (required implementing reasonable and appropriate measures protecting and securing information from loss or misuse) solely for processing payments for purchased or subscribed Products and Services. These payment processors' personal information use is governed by their privacy policies and PCI-DSS standards managed by the PCI Security Standards Council (a joint effort of American Express, Visa, Mastercard, and Discover).

How Does CBIT Utilize Cookies

General Information about Cookies

A cookie (HTTP cookie, web cookie, or browser cookie) is small data sent from a website and stored in a user's web browser while browsing that website. Every website load causes the browser to send the cookie back to the server notifying the website of previous user activity. Cookies reliably remember useful information (shopping cart items) or record user browsing activity (specific button clicks, logins, visited pages over months or years).

Utilization of Cookies

A visit to a page on www.goCBIT.com (or other CBIT website) may generate the following cookie types:

Anonymous Analytics Cookies

Every CBIT website visit generates an 'anonymous analytics cookie' from another organization's software (such as Google Analytics). These cookies indicate whether you have visited the site before. Your browser informs us if you have these cookies; if not, our website generates new ones. This allows CBIT tracking of individual user numbers and visit frequency. Unless signed into www.goCBIT.com (or another CBIT website), these cookies cannot identify individuals. These cookies gather statistics such as page visit numbers. If logged in to the CBIT website, we receive details provided, including username and email address.

Registration Cookies

When registering with a CBIT website, such as www.goCBIT.com, CBIT generates cookies informing us whether you are signed in. Our servers use these cookies determining which account you are signed into and whether you have access to particular Products or Services.

Advertising (Ad) Cookies

These cookies allow CBIT knowing whether you have seen specific ads or ad types and viewing duration. Cookies also help direct targeted advertising.

Other Third-Party Cookies

On some website pages, other organizations may set their own anonymous cookies tracking their products and services success or customizing your experience. Cookies' function prevents our websites accessing third-party cookies, nor can the other organization access CBIT's cookie data. For example, sharing an article or post using social media sharing buttons (Facebook, LinkedIn, or other outlets) on www.goCBIT.com causes the social network creating the button recording this action.

How Do I Turn Cookies Off

It is usually possible to stop your browser accepting cookies or stop accepting cookies from specific websites. Most modern browsers allow changing cookie settings. These settings are usually in the 'options' or 'preferences' menu. Use the 'Help' option for more details. It is solely your responsibility stopping cookies in your browser.

Note: Blocking cookies limits services CBIT can provide and may affect your visitor/user experience.

Vendors, Suppliers and Subcontractors

CBIT may collect personal information about individuals employed by suppliers and vendors. This business contact and payment information strictly administer existing and future business arrangements.

Others

Additional personal information may be collected, processed, and disclosed for purposes for which it was collected and legal compliance purposes, including regulatory reporting, wrongdoing allegation investigation, and legal claim and action management and defense, and compliance with subpoenas, court orders, and other legal obligations. For example, information about individuals visiting CBIT offices or facilities may be collected. Collection shall be relevant, proportionate, and limited to processing purposes.

Choice

Individuals are offered clear, conspicuous, and readily available mechanisms to choose (opt-out) whether personal information is (1) disclosed to third parties (other than third parties acting as agents performing tasks on behalf of and under CBIT instruction) or (2) used for purposes materially different than or incompatible with original use purposes or subsequently authorized by the individual.

Individuals are offered similar mechanisms giving affirmative or explicit (opt-in) choice whether sensitive personal information is disclosed to third parties or used for purposes other than originally collected purposes or subsequently authorized by the individual. However, explicit (opt-in) choice is not required when sensitive personal information disclosure is (1) in the vital interests of the individual or another person; (2) necessary for legal claim or defense establishment; (3) required providing medical care or diagnosis; (4) necessary carrying out employment law obligations, or (5) related to personal information manifestly made public by the individual.

Accountability for Onward Transfer

CBIT will only transfer or provide direct access to personal information covered by this policy to third parties that have:

• Made a commitment respecting data subject privacy rights;
• Limited personal information processing complying with customer and/or data controller instructions; and
• Given CBIT contractual assurances providing at least the same privacy protection level required by applicable privacy laws.

How We Use the Information We Collect

Information is used primarily and as necessary providing CBIT Products and Services, including one or more of the following: creating accounts and allowing Products use, providing technical support and responding to client inquiries, preventing fraud or potentially illegal activities, enforcing other agreements, notifying clients of application updates, and informing clients about new products or promotional offers.

Sensitive Information

CBIT recognizes that some sensitive information requires affirmative express individual consent if such information is to be (i) disclosed to third parties or (ii) processed for purposes other than originally collected purposes or subsequently authorized by individuals through opt-in choice exercise. CBIT shall treat personal information received from third parties where the third party identifies and treats it as sensitive as sensitive.

Marketing Materials

If you provide email address or other business contact information enabling us to provide communications and information, we may use the information providing such communications including press releases and other CBIT marketing materials delivery. You may request no longer receiving CBIT marketing communications following "unsubscribe" instructions in CBIT emails or sending a request to the identified contact.

In the rare and unlikely event CBIT wishes using an individual's personal information for purposes materially different from original collection purposes or subsequently authorized by individuals, CBIT will seek consent in advance as required by applicable law.

Sharing Your Information

Information individually identifying clients, subscribers, or devices may be disclosed or reported in certain circumstances, such as:

(i) If CBIT has good faith belief requiring information disclosure in response to valid legal processes (court orders, search warrants, subpoenas, or defending/responding to legal actions, and as otherwise authorized by law, or in response to lawful public authority requests, including meeting national security or law enforcement requirements);

(ii) Satisfying applicable laws;

(iii) If CBIT believes Products and Services are used in unauthorized, unlawful, or abusive manners, such as committing crimes, including reporting such criminal activity or exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes;

(iv) If CBIT has good faith belief of emergencies posing threats to person health or safety or general public;

(v) Protecting CBIT rights or property, including Intellectual Property Rights enforcement and Agreement terms; and

(vi) All other purposes with your consent.

CBIT may also provide information to third-party companies performing services on our behalf, including payment processing, data analysis, message delivery, hosting services, customer service, and marketing.

If CBIT enters into mergers, acquisitions, or sale of all or portion of its assets or business, client and subscriber information, including personal information, will be transferred as part of or in connection with the transaction as per applicable law.

Information Disclosure

Internal Disclosure

Generally, personal information may be shared within CBIT where legally permitted for reasonable and appropriate corporate purposes. However, even within CBIT, access to personal information is restricted to employees, agents, or contractors needing access carrying out assigned functions.

External Disclosure

CBIT uses vendors and partners for various business purposes, such as helping develop, deploy, and invoice for various Products and Services. Information is shared with vendors and partners when necessary for performing work on our behalf. CBIT requires these vendors and partners protecting customer information and limiting such information use to their respective processing activity. CBIT will only transfer or provide direct access to personal information covered by this policy to third parties that have made a commitment respecting data subject privacy rights; limited personal information processing complying with data controller instructions; and provided CBIT contractual assurances providing at least the same privacy protection level required by applicable privacy laws.

Security of Your Information

Security measures believed reasonable to protect information are implemented. It is important protecting and maintaining account security and you must immediately notify us of any unauthorized account use. Remember, no Internet transmission method or electronic storage method is 100% secure. While commercially acceptable means to protect personal information are strived for, absolute security cannot be guaranteed.

Protecting Personal Information

To help protect personal information confidentiality, CBIT employs security safeguards appropriate to information sensitivity and in accordance with this Privacy Policy. These safeguards include reasonable administrative, technical, and physical measures safeguarding personal information confidentiality and security against anticipated threats and unauthorized access. No personal information transfer will occur to organizations or countries unless adequate controls are in place including data security and other personal information. Additionally, safeguard obligations are conveyed to agents receiving personal information from or on behalf of CBIT in their relationship with our organization as described above in the External Disclosure section.

Transfer of Data

Your information, including personal information, may be transferred to and maintained on computers, servers, or other data storage located outside your state, province, country, or other governmental jurisdiction where data protection laws may differ than your jurisdiction. If you reside outside the United States and choose providing CBIT information, we transfer the data, including personal information, to the United States and process it there.

Your consent to this Privacy Policy followed by information submission represents your transfer agreement.

Retention of Data

Personal information collected by CBIT will be retained as long as necessary and legally permitted for purposes for which it was collected, providing you with Products and Services, enforcing our legal agreements and policies, and conducting our legitimate business interests or where otherwise required by law.

Data Integrity

CBIT employs reasonable means keeping personal information accurate, complete, and current, as needed for purposes for which it was collected.

How to Access and Update Your Information

Individuals are generally provided opportunities examining their own personal information, confirming accuracy and completeness, and having personal information updated, if appropriate.

An individual's personal information access ability is not unlimited, however. Access may be limited, for example, where (i) burden or access provision expense would be unreasonable or disproportionate to individual privacy risks, (ii) information should not be disclosed due to legal or security reasons or protecting confidential commercial information; or (iii) access provision would compromise another person's privacy.

If you created a user profile on a portal, you may access and revise personal information in your user profile when logging into your account.

Individuals wishing to access or update personal information not accessible via a portal should direct such communications to CBIT at: support@goCBIT.com.

Third-Party Websites, Plugins or Widgets

CBIT websites, Products and/or Services may include social network or other third-party plugins and widgets not operated by us. Accessing these links to other sites is done at your own option and is not part of any CBIT offerings. CBIT has no control over and assumes no responsibility for content, privacy policies, or practices of any third-party sites or services. Each privacy policy provided at the respective site should be reviewed.

Health Insurance Portability and Accountability Act

The Health Insurance Portability and Accountability Act of 1996 ("HIPAA") is United States legislation providing data privacy and security provisions safeguarding medical information. Client acknowledges and agrees that unless the CBIT Products and Services description expressly states otherwise, the Products and Services do not comply with Health Insurance Portability and Accountability Act requirements, as amended, and its implemented regulations. Unless the Products and Services description expressly states otherwise, Client agrees it will not use the Products and Services to create, receive, transmit, maintain, store, use, disclose, or otherwise cause the Products and Services to handle Protected Health Information ("PHI") as defined under HIPAA. Client retains complete and full responsibility ensuring Products and Services are only applied to use-case scenarios where the Products and Services provide the necessary security and privacy protection level. CLIENT'S AGREEMENT TO THIS PROVISION IS A MATERIAL CONDITION OF MAKING THE PRODUCTS AND SERVICES AVAILABLE TO CLIENT. In addition to any indemnity requirements in these Terms, Client shall indemnify, defend and hold harmless Company, Company Affiliates and all directors, officers, managers, partners, employees, agents, representatives, heirs, successors and assigns of Company and each of Company's Affiliates against all actions, claims, losses, penalties, fines, assessments, administrative costs, credit protection costs, damages and expenses (including reasonable attorneys' fees) arising out of Client's violation of this section provisions, caused in whole or in part by any Client act or omission, or anyone employed by or acting as a Client subcontractor, representative or agent. Any limitation on liability set forth in the Master Services Agreement terms or any other agreement between Company or its Affiliates and Client shall not apply to Client's liability under this provision.

Changes to Our Privacy Policy

CBIT reserves the right to change this Privacy Policy at our discretion subject to business or legal requirements. You are advised to review and check this Privacy Policy from time to time and particularly before providing personal information to CBIT. Changes to this Privacy Policy are effective when posted on this page. By continuing to use our Products and/or Services you are agreeing to be bound by any changes or revisions made to this privacy policy.

Contacting Us

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email or write to CBIT at:

CBIT Inc.
PO Box 5277
Pasco, WA 99302

Click to view our Acceptable Use Policy and our other agreements on the Legal page.