Our Commitment to Privacy

Introduction

Your privacy is of the utmost importance to us and we want to be transparent about the personal data we collect, why we collect it, how we collect it, and how we share it. We also want you to understand your rights and choices regarding processing, access, correction, and deletion of personal data about you.

 

Who we are

We, the Televerde Group, provide sales and marketing solutions to help our clients’ businesses accelerate sales and generate revenue and to help third parties learn about and decide to purchase our clients’ products and services.

The Televerde Group consists of:

  • Our US parent company: Pegasus Research Group, LLC dba Televerde (Televerde US), a limited liability company registered in Arizona, USA at 4636 E University Drive, Suite 150, Phoenix, AZ 85034.
  • Our European holding company: Televerde UK Holdings Ltd, a limited liability company registered in Scotland with registered number SC521991 and having its registered office address at 3rd Floor 53 Bothwell Street, Glasgow, G2 6TS, Scotland, UK.
  • Our European trading company: Televerde Europe Ltd (Televerde EU), a limited liability company registered in Scotland with registered number SC521993 and having its registered office address at 3rd Floor 53 Bothwell Street, Glasgow, G2 6TS, Scotland, UK.
  • Our Argentinian trading company: Televerde Argentina SRL, Figueroa Alcorta 185 Piso:11 Dpto:8, Cuidad de Cordoba SUR, 5000 Cordoba, Argentina.
  • Our Australian trading company: Televerde Australian HQ, 5th Floor, 171 Collins Street, Melbourne 3000, Australia.

 

How to contact us

The Televerde Group has appointed a data protection officer who is responsible for our compliance with relevant data protection legislation.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data protection officer using the details set out below.

By post: The Data Protection Officer, Pegasus Research Group, LLC dba Televerde, Arizona, USA at 4636 E University Drive, Suite 150, Phoenix, AZ 85034

By email: dataprotection.officer@televerde.com or privacy@televerde.com

By phone:+1 888-925-7526

 

Privacy information

This privacy notice applies to all members of the Televerde Group, subject to any variations due to local laws (please see below for further details).

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

This version of our privacy notice was last updated on 6 August 2018.

 

Data controller / Data processor

For most purposes, the Televerde Group is a data controller of any personal data that it obtains and processes. In certain circumstances, we may act as a data processor on behalf of our Client, in which case the privacy statements of the relevant Client will apply to any personal data that we process in the course of providing such services.

Televerde EU is a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and is registered as a data controller with the Information Commissioner’s Office (ICO) (the supervisory authority for data protection issues in the United Kingdom). Our registration number is ZA286468.

 

Clients / Prospects

In this privacy notice, we refer to our clients (whether they are incorporated organizations, partnerships, sole traders or any other organization) as Clients, and we refer to third party businesses (whether they are incorporated organizations, partnerships, sole traders or any other organization) who are interested in learning more about our Clients or who our Clients are interested in targeting as Prospects.

 

To whom does this Privacy Notice apply?

This privacy notice applies to:

  • Website Users: all individuals who visit our website at www.televerde.com (or any other domain name registered in the name of any member of the Televerde Group) (Website);
  • Registered Website Users: all individuals who create an account on the “My Account” section of our Website;
  • Individual Clients: all individuals who are or have been our individual Clients (being sole traders or partners of a traditional or limited partnership or members of an unincorporated association);
  • Client contacts: all individuals who are our Client contacts where the individual is an employee, director or other representative of an organization which is or has been our Client;
  • Individual Prospects: all individuals who are or have been our individual Prospects (being sole traders or partners of a traditional or limited partnership or members of an unincorporated association);
  • Prospect contacts: all individuals who are our Prospect contacts where the individual is an employee, director or other representative of an organization which is or has been a Prospect; or
  • Business contacts: all individuals who are our business contacts where the individual or the individual’s organization is a supplier or sub-contractor, supplies goods or services to us, provides professional
    services, has expressed an interest in us (including by contacting us by post, telephone, e-mail, social media or other means) or has any other business relationship with us (including where the individual’s organization is a public authority, an industry body or regulatory authority or similar).

This privacy notice also does not apply to existing, former or prospective employees or workers of the Televerde Group. We have a separate privacy notices for such purposes.

 

Information about our Website

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

Please see our Cookie Notice for further details.

 

Protecting children’s privacy

For the purposes of our data protection policies, we consider anyone under the age of 13 to be a child.

Our Website is not intended for children and we do not knowingly collect any personal data relating to children. We do not intend for our products and services to be used, accessed or stored by children and we do not target children for marketing purposes.

If you are a parent or guardian and believe we may have collected information about a child, please contact our data protection officer at dataprotection.officer@televerde.com or via any of the other methods set out in paragraph 3 (How to contact us).

About the personal data we collect and hold

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been permanently removed (anonymous data).

The table set out in SCHEDULE 1 summarizes the personal data we collect and process, how we use it (our processing purposes) and why we use it (the lawful bases of processing).

We do not collect any “special categories of personal data” 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). We also do not collect any information about criminal convictions and offences.

 

How is your personal data obtained?

We use different methods to collect personal data from and about you including through:

Direct interactions generally. You may give us your identity, contact, financial, transactional or similar personal data when you correspond with us by post, phone, e-mail, social media, live chat, via our Website or otherwise, including when:

  • you inquire about our products or services; or
  • you or your organization negotiate and/or enter into a contract or purchase order with us; or
  • you or your organization receive products or services from us;
  • you participate in or attend a webinar, seminar or event hosted or organised by us;
  • you respond to a questionnaire or survey; or
  • you give us some feedback.

Direct interactions with business contacts. You may give us your identity, contact and other business related personal data when you correspond with us, including when:

  • you or your organization negotiate and/or enter into a contract or purchase order with us; or
  • you or your organization provide services or products to us; or
  • you provide us with your business card.

Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • where you are a Client contact, Prospect contact or business contact, your organization or business may provide us with your identity, contact and employment data and we may receive information from third party references or from professional advisors.
  • we may obtain identity, contact and employment data from publicly available sources such as social media (e.g. LinkedIn, Facebook, Twitter), any official registers of companies (e.g. Companies House in the UK) or other organizations’ websites.
  • we may obtain contact, financial and transaction data from providers of payment and credit card services.
  • we may obtain technical data (relating to the use of our Website) from analytics providers or search information providers.

Recording telephone calls and live chat sessions. We record incoming and outgoing telephone calls and live chat sessions, although we will always inform you of this during the call/chat session.

 

Failure to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

Marketing

With regard to marketing-related communications (whether by e-mail, telephone, post, social media or otherwise) and direct marketing activities, we differentiate between individual consumers and individuals who are representatives of a business or organization.

If you are an individual consumer (e.g. an individual Client, individual Prospect or individual business contact):

  • we will only provide you with direct marketing communications by e-mail where you have consented to receive such communications.
  • we may from time to time contact you by post or by telephone with direct marketing communications where we feel that this may be relevant to you (based on services that we have previously provided to you) and you have not previously opted out of receiving such communications. When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
  • you can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us on info@televerde.com or +1 888-925-7526 or following this link,
  • you can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us on info@televerde.com or +1 888-925-7526 or by clicking “unsubscribe” at the bottom of any marketing e-mail.

If you represent another business (e.g. a Client contact, Prospect contact or corporate business contact):

  • we may from time to time contact you and provide you with direct marketing communications in any format (by e-mail, telephone, post, social media or otherwise) where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
  • you can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us on info@televerde.com or +1 888-925-7526 or following this link.
  • you can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us on info@televerde.com or +1 888-925-7526 or by clicking “unsubscribe” at the bottom of any marketing e-mail.

Where you opt out of receiving these marketing-related communications, this opt-out will not apply to personal data provided to us for any other purpose.

 

With whom do we share your personal data?

For the purposes of providing our products and services to our Clients where we are acting as controllers, we may share information about our Client (and the relevant Client contacts) with Prospects and we may share information about Prospects (and the relevant Prospect contacts) with our Clients.

Where we are acting as a data processor on behalf of a Client, we may transfer personal data of Client contacts, Prospects and Prospect contacts to such Client or to a third party in accordance with instructions received from the relevant Client. In those circumstances, the privacy statement of the relevant Client will be applicable.

There may be other circumstances in which we may need to share your personal data with certain third parties (strictly on a confidential, business need-to-know basis), acting in our capacity as controllers. The third parties to which we may transfer your personal data include:

  • any member of the Televerde Group for the purposes of fulfilment of contracts with Clients, group restructuring, internal reporting, risk management, product/service diversification and compliance with this privacy notice (for example to ensure that all members of the Televerde Group comply with a withdrawal of consent to processing).
  • your business or organization, for the purpose of providing our services to your business or organization or receiving products or services from your business or organization, or working together with your business or organization.
  • accreditation bodies and trade associations.
  • service providers (acting as processors) who provide IT and system administration services, including cloud storage, a live chat facility and a webinar facility.
  • service providers (acting as processors) who provide advertising and marketing services.
  • service providers (acting as processors) who provide data and marketing analysis services.
  • service providers (acting as processors) who provide event management services.
  • professional advisers including lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • banks or other finance providers.
  • any relevant regulatory authority or law enforcement agency, including Inland Revenue Service (US), HM Revenue & Customs (UK), any other relevant tax authority, and courts or tribunals where we are legally obliged to disclose personal data or if we need to do so in order to protect our legal rights or those of a third party.
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Any sharing of your personal data (where we are acting as controllers) will only take place either where you have provided your consent to such sharing, where we are legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in our legitimate interests to do so, including as follows:

  • to perform (including enforce) a contract with our Clients;
  • to perform (including enforce) a contract with our sub-contractors and suppliers;
  • to maintain network and information security;
  • to develop and improve our products and services in order to remain competitive;
  • to establish, protect and defend our legal rights;
  • to pursue our commercial objectives where this does not override your rights and freedoms as a data subject.

 

International transfers

The Televerde Group is a global group of companies which provides products and services and engages third party service providers within as well as outside of the European Economic Area (EEA). As a consequence, whenever the Televerde Group is processing personal data originating in the EEA in accordance with this privacy notice, Televerde may transfer such personal data to countries and territories outside of the EEA.

Whenever we are required to transfer your personal data originating within the EEA outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:

  • We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers and for intra-group transfers within the Televerde Group, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use service providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the USA. For further details, see European Commission: EU-US Privacy Shield. Please note that our parent company, Televerde US, is registered with Privacy Shield (see below at paragraph 22 (EU/US Privacy Shield and Swiss/US Privacy Shield) for further details.
  • We may transfer your personal data to countries outside of the EEA with your explicit consent.

 

Automated-decision making or profiling

We do not use automated decision-making (including profiling) to make any decisions which would produce a legal or similarly significant effect on a data subject.

 

How long do we retain your personal data?

We use different methods to collect personal data from and about you including through:

We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your data will only be retained for as long as it is still required to provide you with services or is necessary for legal reasons.

Generally speaking, we will usually retain your personal data for six (6) years following expiry of any contracts or arrangements between us, unless we are obliged to retain your personal data for a longer period as a result of an overriding legal obligation or in order to establish, defend or exercise legal rights.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

When we determine that personal data can no longer be retained (including where you exercise a right of erasure (see below for further details)), we ensure that this data is securely deleted or destroyed.

For more details about our retention periods, please contact us using the details above.

 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the relevant data protection supervisory authority of a breach where we are legally required to do so.

 

Data security – Registered Website Users

PROTECTING YOUR USERNAME AND PASSWORD FROM UNAUTHORIZED ACCESS IS YOUR RESPONSIBILITY. While we use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with the Website, we cannot guarantee that these efforts will always be successful.

WE DO NOT REPRESENT, WARRANT, OR GUARANTEE THAT OUR SAFEGUARDS WILL PROTECT THE PERSONAL DATA ABOUT YOU. PERSONAL DATA ABOUT YOU MAY BE ACCESSED AND VIEWED BY OTHER INTERNET USERS, WITHOUT YOUR KNOWLEDGE AND PERMISSION, WHILE IN TRANSIT TO OR FROM US. WE CANNOT AND DO NOT ENSURE, REPRESENT, WARRANT, OR GUARANTEE THE SECURITY OF ANY INFORMATION YOU TRANSMIT THROUGH THE WEBSITE.

 

Your rights

With regard to any personal data that is processed by the Televerde Group, you may:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, following your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us using the details above at paragraph 3 (How to contact us) or by completing the form here.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Your California privacy rights

California law permits users who are residents of California to request the following information regarding our disclosure of their personal information to third parties for those third parties’ direct marketing purposes:

  • a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year;
  • the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and
  • examples of the products or services marketed (if we have that information).

If you are a California resident and would like to make such a request, please email us at privacy@televerde.com.

 

EU/US Privacy Shield and Swiss/US Privacy Shield

Televerde US participates in and has certified its compliance with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]

Televerde US is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Televerde US complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Televerde US is subject to the regulatory enforcement powers of the US Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including for purposes of meeting national security or law enforcement requirements.

 

Complaints

You have the right to make a complaint at any time to an appropriate data protection supervisory authority, as set out below. We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance on privacy@televerde.com or dataprotection.officer@televerde.com.

  • EU / GDPR: Under the GDPR, you have the right to complain about how we are processing your personal data to a relevant data protection supervisory authority within the European Union. Our lead supervisory authority for the purposes of the GDPR is the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (who can be contacted via www.ico.org.uk), but if you are a resident of the European Union you may also lodge a complaint with the data protection supervisory authority of the EU member state in which you live.
  • US / rest of the world: you may lodge a complaint through our US-based third-party dispute resolution provider (free of charge) at https://feedbackformtrustecomwatchdogrequest.
  • Privacy Shield: Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

 

Changes to this privacy notice

We may update this privacy notice to reflect changes to our information practices. 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 our Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.