2. Mitel’s Contact Information
Mitel’s Privacy Officer may be contacted at:
Attention: Mitel, Inc. c/o Privacy Officer
960 Stewart Drive
Sunnyvale, CA 94085
3. Collection of Information from Prospective Customers
At the time a business becomes a customer, Mitel may already have collected information about that business when it was a prospective customer. Prospective customers may include visitors to Mitel’s website; and those who contact Mitel online to learn more about our products and services.
We gather information from prospective customers through a variety of ways, online and through offline communications, which include in-person meetings, web forms, emails, and phone calls. We collect contact information from representatives of our prospective business customers, such as name, company name, address, email address, and telephone number. As we communicate with these representatives, we may gather additional information from them, such as the potential customer’s industry or revenues. We may also use data-appending methods to gather additional information, such as by reviewing biographical information posted by these representatives on the Internet. We also gather information about representatives’ communications preferences.
In addition, we gather information based on prospective customers’ systems and behavior in viewing our website pages and files on our website, including what pages or files are viewed, when users view them, the time spent on each page, browser and operating system, Internet Protocol address, the domain associated with that address, and physical location. We also collect information based on prospective customers’ behavior in opening and viewing emails, such as whether a user opens an email and how long it is viewed.
After a prospective business becomes a customer, we continue to maintain the information collected during the time in which it was a prospective customer.
Children are not eligible to use Mitel’s services, and we ask that minors (under age eighteen) not submit information to us via online or offline portals.
4. Collection of Information from Mitel Customers
At the time a business becomes a customer, Mitel may collect additional information in order to provide service. For instance, once prospective customers enter into a service agreement with Mitel, we collect and maintain information about the customers’ agreement with Mitel, payment information, and information about individual transactions. Also, we collect information needed to deliver online services, support, and training to customers. For example, we gather information to register customers to use our services, such as a user name and password for each individual account.
Moreover, we collect information that you or others provide to us in connection with a customer’s use of our services. Examples include phone numbers you dial or provide to our services, service set-up information, service configurations and settings, recorded calls, messages, meetings, voicemails, incoming and outgoing faxes, user-saved or stored content shared among users, email and text communications, and call center customer information you provide to us. Our systems also generate and store reports and information related to your account. We maintain this system-generated information in connection with your account.
All calls with Mitel’s Sales, Customer Service and other Mitel employee groups, whether with prospective or current customers, may be recorded to gather information that is used to improve customer service. However, Mitel’s policy is that no call or conversation will be recorded unless all those involved in the call have been made aware in advance that the call is going to be recorded. Customers may state their consent to be recorded, give implied consent by staying on the call, or opt out by asking that their call not be recorded or by simply hanging up.
5. Use of Information
We use the information collected from prospective customers to describe our services and respond to questions and comments about the products that we offer. In addition, we use the information collected from customers to complete transactions with us, such as by billing the customer. We also use contact and transactional information to deliver equipment, carrier services and other products purchased by the customer. In addition, we provide online services, and control access to these services, with information such as user names and passwords. These communications may be conducted electronically, via postal mail or by telephone.
For customers, the information we collect enables us to provide the full range of our products, including carrier services, SaaS and IaaS solutions encompassing hosted communications services, contact center, UC, video web conferencing, dedicated circuits, managed dedicated hosting, virtual private servers, and other services.
Also, we may use the information we collect in order to communicate with our customers and offer them other products and services, noting, however, that we comply with Federal Communications Commission (FCC) consent requirements where customer proprietary network information (CPNI) is involved (see Section 7 on Use of CPNI). We may also use gathered information to communicate with customers in order to respond to their inquiries and provide training and support. We may communicate with customers’ representatives by electronic communications, such as emails, newsletters, and white papers, as well as by postal mail and/or phone calls.
We also reserve the right to use any information we collect from customers or prospective customers to investigate and help prevent unlawful or potentially unlawful activity that threatens either Mitel, our partners, any company affiliated with Mitel, or any of our respective customers.
We retain information, including about former and prospective customers, until we delete that information in accordance with our separate data retention policy and deletion practices, available upon request.
6. Sharing and Transfer of Information
We may disclose to third parties some of the information we collect and store from our customers under this policy for data processing and to facilitate the delivery of Mitel’s products and services. Mitel requires these third parties to protect that information with at least the same level of privacy and security controls that we use in our own collection, storage, and use of the information.
If it’s prohibited by law, Mitel will not transfer information across country borders to a third party unless we obtain a written agreement from such third party agreeing to provide at least the same level of privacy protection as is required by any applicable local laws and privacy principles. As an example, to keep the stored information confidential and to not use or disclose that information without our authorization.
Mitel reserves the right to share your information in connection with any sale, merger, reorganization, or other transfer of our assets (including under bankruptcy proceedings), provided the recipient party agrees to hold the information in confidence. We also may share or disclose your information if we receive a request or demand for such information in the form of:
- a court order to disclose such information;
- what we believe (in our sole discretion) is lawful process in a criminal investigation or proceeding, such as a search warrant, subpoena, or court order;
- judicial or administrative process in civil proceedings, such as subpoenas or discovery requests; or
- a national security letter or similar request from any state or federal law enforcement agency.
Mitel is not obligated to notify you of such a request or demand.
We also reserve the right to share or transfer your information if we believe (in our sole discretion) that such sharing or transfer is required under applicable law.
Finally, we reserve the right to share information provided it is not personally identifiable information, such as aggregated information without personally identifiable elements and any de-identified or anonymized information. As a publicly traded company, Mitel is required to file numerous reports with different administrative bodies and as part of such reports we may provide aggregate statistics about customers, sales, and traffic patterns. None of these reports or statistics will include personally identifiable information.
Except as set forth above, it is Mitel’s policy not to share with third parties any information that we collect under this policy without your permission. Mitel does not sell or rent any lists of customers, prospective customers, or their representatives.
7. Use of Customer CPNI
In the course of providing services to you, we collect and maintain certain customer proprietary network information (CPNI), which is afforded specific protections by U.S. law and regulations adopted by the FCC. According to FCC rules, CPNI refers to the types of services you currently obtain from us and related usage and billing information for those services. Practically speaking, CPNI includes information such as the phone numbers called by a customer; the frequency, duration, and timing of such calls; and any services purchased by the customer.
We value our relationships with our customers and are committed to respecting and protecting your CPNI in accordance with U.S. law. Accordingly, we do not sell, trade, or share your CPNI, with anyone outside of Mitel, including Mitel’s partners and agents, except as authorized by you, as required by law, or as necessary to provide services to which you have subscribed. Generally, but only with your consent, we can use your CPNI to offer additional services to you, for billing and collections purposes, and to provide service to you. We may also use CPNI to investigate fraud and to prevent violation of our Terms of Service and unlawful use of our network and services. Finally, we can also disclose your CPNI for legal or regulatory reasons, including in response to subpoenas and court orders, without your prior knowledge or consent.
Mitel has invested in and deployed a wide variety of industry-standard technology and security features and continues to make reasonable efforts to ensure that the information related to potential and current customers is protected from outside security threats. In addition, Mitel has implemented operational guidelines to ensure that such information is safeguarded throughout our company. Mitel will continue to revise its policies and implement additional security features as new technologies becomes available. However, because no system or service can give a 100% guarantee of security, you acknowledge the risk of third parties gaining unauthorized access to your information when using or accessing our services and our network.
9. Voluntary Disclosure of Information in Public Forums
You should be aware that any private information that you voluntarily include and transmit through publicly accessible forums (i.e., such as chat rooms, blogs, instant messages, etc.) may be viewed and used by anyone with access to such forums. Mitel is unable to control such uses of your private information, and by using such services, you assume the risk that the private information provided by you may be viewed and used by third parties.
10. Customer Access to Information
Through its services and applications, Mitel provides its customers with access to information that Mitel has collected on them. For instance, the customer’s authorized representative(s) can view the information about the customer by accessing and using their account on Mitel’s website or the Mitel application, or by sending email to: firstname.lastname@example.org. After viewing such information, the authorized representative(s) can change, add to, or delete such information.
11. Third Party Web Sites and Services
Our service may contain links to other websites and services not maintained by Mitel. In addition, other websites and services may also reference or link to Mitel. We encourage you to be aware when you leave our service, or surf the Internet, and to read the privacy statements of each and every website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of such other websites and services.
We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time by posting such changes here. Prospective and current Mitel customers should review this policy regularly for changes, noting the Effective Date below. However, if at any time in the future we plan to use your personal information in a way that differs from this policy, we will post such changes here and provide you the opportunity to opt-out of such differing uses. Your continued use of the services following the posting of any changes to this policy means you accept such changes.
13. Terms of Service
14. Effective Date