Last Updated: May 25, 2018
This website and portal is owned and operated by Ooma International Limited, of 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN with a company number 10614778 ("Ooma", "we" or "us").
We are the data controller in respect of your personal data. We can be contacted using the following details: Ooma International Limited, 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN; 0 800 91 08 67.
Ooma is committed to your privacy. We comply with all applicable laws governing the processing of personal data.
The aim of this policy is to explain how we collect and use any personal information about individuals who register for, subscribe to, or otherwise purchase (whether in an individual or corporate capacity), the managed or 'carrier-grade' voice over Internet protocol ("VoIp") telephony service offered by Ooma (the "Ooma Office Service") via this website or portal by telephone or otherwise ("WeWork Members" or "you"). Ooma does not knowingly offer the Ooma Office Service to, or knowingly solicit or collect personal information from, anyone under the age of eighteen (18). Please note that if you are under the age of eighteen (18), you may not use the Ooma Office Service.
Ooma collects the personal information set out below from you when you register for, subscribe to, or otherwise purchase (either via the website and portal, by telephone or otherwise) the Ooma Office Service. This is information is mandatory if you wish to use the Ooma Office Service and its processing is necessary for the adequate performance of the contractual relationship, which constitutes the legal basis for the processing:
your traffic data (including data necessary to identify the source, destination, date, time duration and type of communication, and the equipment used for it), where required by the applicable legislation;
your company name;
your telephone number;
your postal address;
your email address; and
your credit/ debit card information. Please note that all payment card details are encrypted and tokenized by a third-party provider on our behalf, and we use a trusted third party provider to process payments on our behalf. We do not retain your full payment card details ourselves.
You may also choose to provide the following personal information, in which case you expressly authorise Ooma to process such information (being your consent the legal basis for the processing):
if you use our mobile app and set your mobile device to share this with us, content on your mobile device, such as your contact lists and address book, camera, microphone and photos may be accessed by us;
your location information, if you consent to our mobile app sharing this with us, based on the location of your mobile device at any given time; and
if you register or access our services through your account with a third-party service, such as Facebook, Google or Twitter, or use a social media feature through our services, certain personal information from those third party social media services may be shared with us; such information may include your interests, "likes" and friends list but this will depend on your privacy settings with your social media provider. We may use this information, for example, to personalise your service experience and marketing communications, to enhance our services and to better serve you. You can control this data sharing via options in your social media accounts.
In addition, we may automatically collect information about the website/ app that you came from or are going to. We may also collect information on which pages of our website and portal you visit, IP addresses, the type of browser you use and the times you access our website and portal. However, this information is aggregated and is not used to identify you.
While providing the Ooma Office Service to you, Ooma may collect and maintain certain operational data. This refers to information such as the date, time, duration and cost of your communication, as well as other traffic routing and usage information ("Traffic Data") (and the phone numbers that you call and send messages to, and the phone numbers you receive calls and messages from). Ooma is required by the applicable laws or regulations to process this information, and the need to comply with such laws or regulations is the legal basis in which the processing is based on.
During the provision of the Ooma Office Service to you, Ooma may record or monitor any conversations you have with an Ooma employee or representative only as required by applicable law or where you grant your consent for this processing operation. The need to comply with a legal obligation and your consent, respectively, are the basis in which the processing of this categories of personal data are based on
Storage of Information: Ooma stores your call logs, voicemails and other information related to your account as a convenience to you. You agree that Ooma has no obligation, responsibility or liability for the deletion or failure to store any of such information. You agree that Ooma may establish limits, at its sole discretion, as to the amount of messages and information it retains and the duration for which it is retained.
When we ask you to supply us with information we will make it clear whether the information we are asking for must be supplied so that we can provide the products and services to you (and therefore the legal basis for the processing is the need to ensure the fulfilment of the contractual relationship), or whether the supply of any information we ask for is optional, in which case you authorise us to process such information (in this scenario your consent would be the legal basis for the processing).
HOW WILL INFORMATION ABOUT YOU BE USED?
We will use the information we collect to:
provide the Ooma Office Service to you as requested by you;
verify your identity and details of your payment method or credit/ debit card amount;
administer our website and portal and provide customer services;
meet legal, regulatory and compliance requirements;
monitor and analyse the use of any account for quality control purposes, and to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime;
investigate and help prevent potentially unlawful activity that threaten the integrity of the Ooma Office Service;
gather management information to form statistical and trend analysis;
communicate with you, including about billing, collection, support, advertising, promotion, account and debit/credit card verification;
identify customer needs and preferences;
engage in research and development and to evolve and create new service offerings;
investigate any complaints about the website and portal;
with your consent, recommend other products and services provided by us from time to time, based on your use of our products and services. Please see section 6 below for more information;
for other purpose disclosed when you provide us personal information; and
as otherwise required or permitted by law.
Ooma may periodically conduct both business and individual surveys. We encourage WeWork Members to participate in these voluntary surveys because they provide us with important information that helps us to improve the types of services we offer and how we provide them to you. Your personal information will only be processed provided that you provide your consent, and such personal information and your responses will remain confidential, even if the survey is conducted by a third-party. Ooma uses the information we receive from individuals in response to our surveys and combines (or aggregates) this information with that provided by other WeWork Members to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you, and to develop new products and services. This aggregated information may be shared with third-party affiliates.
Further, we will use your Traffic Data to deal with customer enquiries, and for billing and collections purposes. We can also use your Traffic Data to investigate fraud and monitor potentially unlawful use of our network, services, and abuse of other customers.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interest or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under section 14.
WITH WHOM DO WE SHARE INFORMATION?
We may share your information with:
telephony operators and other communications service providers as necessary for proper routing and connectivity, and to provide the Ooma Office Service. The need to ensure the adequate performance of the contractual relationship is the basis that justifies this disclosure of data;
our subsidiaries and controlled affiliates as we believe necessary for business purposes. Ooma's legitimate interest in controlling the data flows of its business that justifies this disclosure of data;
our trusted suppliers under appropriate non-disclosure and data security obligations for the purposes of providing products or services to us; and
government authorities or other third parties when Ooma believes such action is necessary or desirable to respond to legal process or government demands; to protect WeWork Members; to protect lives or property rights; to maintain the security of our products or services; to investigate fraud or other unlawful action. The need to comply with legal requirements and Ooma's legitimate interest in protecting its business activities are the bases that justify these disclosures of data.
Like many businesses, Ooma contracts with other companies to perform certain business-related functions, such as internet and telecommunications service providers, website hosting companies, data hosting companies, mail delivery companies, analytics companies, fulfilment companies, credit card processors, tax integration services and other service providers. When we do, we may share with them information that they require to perform their specific functions. Suppliers to Ooma that have access to your personal data are required to keep the data confidential, maintain appropriate security and are not permitted to use the data for any purpose other than to carry out the services they are performing for Ooma.
Your information may also be transferred in a corporate reorganization transaction such as a sale or divestiture of the company, or any combination of its products, services, or assets. We may also transfer or assign such information in the course of a bankruptcy, dissolution or similar transactions or proceedings. In such cases the transfer of data will based on the need to ensure the adequate provision of the service or the need to comply with applicable legal obligations.
WHERE IS INFORMATION WE COLLECT STORED?
Personal information collected by Ooma is kept on servers that are owned and operated either by Ooma in the European Economic Area (“EEA”) and the United States, or by Colt Technology Services in the EEA. Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws in your country (and in some cases, may not be as protective).
We ensure that we comply with the applicable legal requirements when transferring your personal information outside the EEA. We put in place European Commission approved standard contractual clauses to protect this data. A copy of these clauses is available for your review upon request to us using the detail provided above.
From time to time, we would like to send you information, by email and/ or text, about similar products or services provided by us which may be of interest to you (including, for example, newsletters and promotional communications).
We will do this only if you consent at the point of registration with the portal. Thereafter, you may opt-out of receiving this information at any time by clicking on the "unsubscribe" button shown at the bottom of any such email, or by replying to any such text with "stop".
COOKIES AND RELATED TRACKING TECHNOLOGIES
Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page.
We use Category 1 and 2 Cookies on the Ooma Office Manager web portal, and we use Category 2, 3 and 4 Cookies on our website, www.ooma.es.
Category 1: Strictly Necessary Cookies
These cookies are essential to enable you to move around the website and portal and use its features. Without these cookies, services you have asked for, such as remembering your login details or shopping basket items, cannot be provided.
Category 2: Performance Cookies
These cookies collect anonymous information about how people use our website and portal. For example, we use Google Analytics cookies to help us understand how customers arrive at our website and portal, browse or use our website and portal and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established. Third parties may access the information collected through these cookies, such as Google Inc.
Category 3: Functionality Cookies
These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Category 4: Targeting Cookies or Advertising Cookies
These cookies collect information about your browsing habits to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies such as Adroll to provide you with more personalised adverts when visiting other websites.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
Please note that by deleting strictly necessary cookies, you may not be able to access certain areas or features of the Ooma Office Service.
To find out more about cookies please visit: www.allaboutcookies.org or see which contains further information about behavioural advertising and online privacy.
Use of Web Beacons and Tracking Scripts on our website and portal
Some of our website and portal pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.
In addition, we may use such devices in our HTML-based emails to track the usage of such emails in much the same manner as we track usage of our web sites.
WHAT RIGHTS ARE AVAILABLE IN RESPECT OF YOUR INFORMATION?
You may have various rights with respect to our use of your information:
Marketing : As stated above in section 6, with respect to Ooma’s email/ text marketing programme, you may opt-out of receiving such emails/ texts at any time by clicking on the "unsubscribe" button shown at the bottom of any such email, or by replying to any such text with "stop". You are also entitled to object to the processing operations carried out by Ooma for profiling purposes, and to withdraw any consent that you had initially provided to Ooma.
Cookies/ Similar Technology: As stated above in section 7, please visit www.allaboutcookies.org or see www.youronlinechoices.eu to find out more about cookies and your choices in respect of them.
Access: You are entitled to see the information held about you. If you wish to do this, please contact us as specified in section 14 below. We may require you to provide verification of your identity and to pay an administration fee (which is currently £10) to provide a copy of the information we hold. Please note that in certain circumstances we may withhold access to your personal information where we have the right to do so under current data protection legislation.
Accuracy: We aim to keep your information accurate, current, and complete. If you believe or suspect the information you have previously submitted to us is now inaccurate, please contact us as specified in section 14 below to update, correct or delete the information.
Data Portability: You have the right to receive the personal data provided to Ooma, in a structured, commonly used and machine-readable format (and to have it transmitted to other data controller, if technically feasible) where the processing of such personal data is based on your consent.
Restriction of processing: You may obtain from Ooma restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by You, for a period enabling Ooma to verify the accuracy of the personal data; (b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead. Lodge Complaints: You have the right to lodge complaints before the competent data protection authority in your country.
You can exercise the above rights by contacting us as specified in section 14 below at any time. All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum.
There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another person or if we are prevented from disclosing such information by law.
HOW LONG DO WE KEEP YOUR INFORMATION?
Ooma will retain your information, whether or not your account is active, for as long as it is necessary for the business relationship, to achieve the above-mentioned purposes, or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts. Your personal data will be erased no later than 5 years after termination of the business relationship.
Our website and portal contains links to other websites over which we have no control. We are not responsible for the privacy policies or practices of other websites to which you choose to link from this website and portal. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your personal information.
We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure both during transmission and once it is received . However, the Internet is an open system and no website, mobile app or service is completely secure, and we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use your personal information for improper purposes. Ooma 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 by products or services, even if you visit them using links from our website.
SALE OF THE BUSINESS
Further to section 4, if the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
UPDATING YOUR PERSONAL INFORMATION
You may review, correct, update or change your personal information at any time by contacting us using the details provided below in section 14.
HOW TO CONTACT US
If you have any questions about this policy or your personal information, please write to us Ooma International Limited, 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN, or you may call us toll free at 0 800 654 160 or at 0 800 91 08 67.