West IP Communications is a leading provider of unified communications services. We value the privacy of our customers, users, and any individual that accesses or uses the West IP Communications websites, products, and services (collectively, the “Services”). This Policy discloses West IP Communications’ practices with respect to the collection, processing, use and disclosure of user information collected through the access and use of West IP Communications Services. This Privacy Policy applies to all Personal Information collected and processed by West IP Communications whether in electronic, paper or verbal format.

Definitions

“Personal Information” or “Information” means information that (1) is transferred from the European Economic Area (“EEA”) or Switzerland to the United States or maintained in the United States; (2) is recorded in any form; (3) is about, or pertains to, a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
 

Collection and Use of Personal Information

Except as otherwise provided in this policy or in other written documentation or policies that may be provided to you regarding the services or website, the only Personal Information we collect about visitors to our website is provided to us voluntarily by you. In general, you can visit our website without telling us who you are or revealing any Personal Information about yourself.

When you use our online services by accessing your account information, ordering a service, requesting a product or service information, or sending us e-mail, we will ask you to provide Personal Information to us. Except as otherwise provided in this policy, when you supply information about yourself for such specific purposes, we use the information for that purpose and to manage the internal operations and security of our website consistent with the terms of use and policies established from time to time governing this site. Such purpose may involve the disclosure of such information to unaffiliated companies or vendors where necessary to and for the limited purpose of processing your request, processing a transaction authorized by you or providing you with Services. We may also share aggregate anonymized data relating to the transactions on the site and use of our services for marketing, research and other purposes.

We also want you to be aware that certain information related to your account with us, such as account information or call detail records, may be Customer Proprietary Network Information (“CPNI”). CPNI is protected by specific federal laws and regulations and as such we are fully committed to comply with such laws and regulations, both through our website and in all other respects. Without your consent, we will only share or disclose your CPNI (i) to market to you services or products among the categories of services or products you currently subscribe, (ii) to initiate, render, bill and collect for our Services, (ii) to protect you or other carriers from illegal or fraudulent use of, or subscription to, our Services or to protect our rights or property, (iii) to provide your call location information in certain specified emergency situations, and (iv) for other legally permissible purposes.
 

Access

When you register online to use any of the Services offered by West IP Communications, West IP Communications will send you a confirmation of your registration showing the Personal Information we obtained from your registration. Also, we will take reasonable steps to give you the opportunity to correct inaccuracies in the Personal Information we retain concerning you and delete Personal Information concerning you upon your request, unless the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than you would be violated.
 

International transfers and the U.S.-E.U. Safe Harbor & the U.S.-Swiss Safe Harbor

By accessing and using the Services and providing us with the requested Personal Information, you consent to the collection and use of the information in accordance with this Privacy Policy including transfers from the EEA and Switzerland to the United States or elsewhere where privacy protections may not have been deemed “adequate” by the EEA or Switzerland. Individuals who do not consent to the collection, use, or disclosure of their personal information as outlined in this policy should not provide any Personal Information through the West IP Communications Services and website.

In accordance with our commitment to protect personal privacy, West IP Communications adheres to the Safe Harbor Frameworks concerning the transfer of Personal Information from the EEA and Switzerland to the United States. Accordingly, we follow the Safe Harbor Principles and the fifteen FAQs that make up the E.U. Safe Harbor Framework and the Swiss Safe Harbor Framework published by the U.S. Department of Commerce (the “Principles”) with respect to all such Personal Information. If there is any conflict between the policies in this Privacy Policy and the Principles, the Principles shall govern. This Privacy Policy outlines our general policy and practices for implementing the Principles, including the types of Information we gather, how we process and use it and the notice and choice affected individuals have regarding our use of and their ability to correct that Information.

You may access the Safe Harbor website at http://www.export.gov/safeharbor/
 

Transfers

Unless you have already consented to such disclosure, prior to disclosing Personal Information to a third party, West IP Communications shall notify you of such disclosure and allow you to opt out of such disclosure. West IP Communications shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
 

Security

West IP Communications shall take reasonable steps to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Personal Information we collect from you is stored in operating environments that employ reasonable security measures and that are not available to the general public. West IP Communications is not responsible for unauthorized access to such Information by hackers or others that obtain access through illegal measures, in the absence of negligence on the part of West IP Communications. Further, the other websites you may access through the West IP Communications website may have different security practices and you should familiarize yourself with those practices. West IP Communications cannot guarantee the security of Information transmitted via the Internet.

You are responsible for the confidentiality and security of passwords West IP Communications issues to you. If you believe a third party has obtained your password in an unauthorized manner, please notify us promptly.
 

Data Integrity

West IP Communications shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, West IP Communications shall take reasonable steps to ensure the Personal Information is accurate, complete, current and reliable for its intended use.
 

Enforcement/Complaints

West IP Communications uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles.

If at any time you believe we have acted contrary to this Privacy Policy, please notify us by e-mail at privacy@westipc.com and we will take steps to investigate and will use reasonable measures to remedy the problem. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using BBB EU Safe Harbor as a third party resolution provider for disputes arising with regard to privacy in the EEA and Switzerland. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the BBB EU Safe Harbor website at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
 

Disclosure for Legal Purposes

We may disclose Personal Information if required to do so by law or in the good-faith belief such action is necessary: (a) to conform to the edicts of the law or comply with legal process served on us or our affiliates; (b) to protect and defend our rights or property or those of our customers and their users; (c) to protect the personal safety of our customers and their users or the public; or (d) in connection with a merger, consolidation or sale of substantial assets of West IP Communications. As we continue to develop our business, we might buy or sell assets related to our business. In such transactions Personal Information generally is one of the transferred business assets. Also, in the event West IP Communications or substantially all of its assets are acquired, Personal Information will be one of the transferred assets.
 

Anonymous Information

Please understand, in addition to collecting Personal Information, West IP Communications will also gather information that does not personally identify you regarding your use of the West IP Communications website (“Anonymous Information”). The Anonymous Information we collect regarding your use of the West IP Communications website may be used by us to measure the effectiveness of marketing efforts on the West IP Communications website, for improving the services we offer to you, or to improve the West IP Communications website. Generally, you will not be aware when such Anonymous Information is being collected about you. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access our website.
 

Cookies

We use cookies to provide you with better service. Cookies are pieces of information a website transfers to your computer’s hard disk for recordkeeping purposes. Cookies can make the Web more useful by storing information about your preferences for a particular website. The use of cookies is an industry standard, and many major websites use them to provide useful features for their customers. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to refuse cookies. However, you may not be able to take full advantage of the functionality of the West IP Communications website or Services if you do so.
 

Venturing off the West IP Communications website

The West IP Communications website may contain hyperlinks that can take you to websites run by third parties (“Third-Party Websites”). Any hypertext or other links to Third-Party Websites from the West IP Communications website are provided solely as a convenience to you. If you use these links, you will leave the West IP Communications website. West IP Communications has not reviewed all of these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, West IP Communications does not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Websites linked to the West IP Communications website, you do this entirely at your own risk.

Remember, this Privacy Policy only applies to West IP Communications. When you are no longer on the West IP Communications website, you may encounter different privacy and security practices and you should familiarize yourself with those practices each time you visit a new website.
 

Modifications

West IP Communications reserves the right to modify the Privacy Policy at any time. Please review the Privacy Policy each time you access and use the West IP Communications website, as your continued use of the West IP Communications website and the West IP Communications Services signifies your assent to such modifications.
 

Contact Us

If at any time you believe West IP Communications has not followed the above Policy, or if you have questions, comments, or complaints regarding West IP Communications’ Policy, please contact us via e-mail at privacy@westipc.com. By mail, we can be contacted at:

West IP Communications, Inc.
Attn: Legal Department
401 South Fourth Street
Louisville, Kentucky 40202

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