Privacy Policy

Updated at 01/19/2023
PBXManager (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal
information is collected, used, and disclosed by PBXManager.
This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Service”) alongside our application,
PBXManager. By accessing or using our Service, you signify that you have read, understood, and agree to our collection,
storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

Definitions and key terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, are strictly
defined as:
● Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser,
provide analytics, remember information about you such as your language preference or login information. ● Company:
when this policy mentions “Company,” “we,” “us,” or “our,” it refers to NTS Solutions, 123 doughty blvd inwood 11096 that is
responsible for your information under this Privacy Policy.
● Country: where PBXManager or the owners/founders of PBXManager are based, in this case is United States ●
Customer: refers to the company, organization or person that signs up to use the PBXManager Service to manage the
relationships with your consumers or service users.
● Device: any internet-connected device such as a phone, tablet, computer or any other device that can be used to visit PBXManager and use the services.
● IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address.
These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from
which a device is connecting to the Internet.
● Personnel: refers to those individuals who are employed by PBXManager or are under contract to perform a service on
behalf of one of the parties.
● Personal Data: any information that directly, indirectly, or in connection with other information — including a personal
identification number — allows for the identification or identifiability of a natural person.
● Service: refers to the service provided by PBXManager as described in the relative terms (if available) and on this
platform.
● Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide
our content or whose products or services we think may interest you.
● Website: PBXManager.”’s” site, which can be accessed via this URL:
● You: a person or entity that is registered with PBXManager to use the Services.

Information automatically collected

There is some information like your Internet Protocol (IP) address and/or browser and device characteristics — is collected
automatically when you visit our platform. This information may be used to connect your computer to the Internet. Other
information collected automatically could be a login, e-mail address, password, computer and connection information such as
browser plug-in types and versions and time zone setting, operating systems and platforms, purchase history, (we sometimes
aggregate with similar information from other Users), the full Uniform Resource Locator (URL) clickstream to, through and from
our Website that may include date and time; cookie number; parts of the site you viewed or searched for; and the phone number
you used to call our Customer Services. We may also use browser data such as cookies, Flash cookies (also known as Flash
Local Shared Objects) or similar data on certain parts of our Website for fraud prevention and other purposes. During your visits,
we may use software tools such as JavaScript to measure and collect session information including page response times,
download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and
methods used to browse away from the page. We may also collect technical information to help us identify your device for fraud
prevention and diagnostic purposes.
We automatically collect certain information when you visit, use or navigate the platform. This information does not reveal your
specific identity (like your name or contact information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location,
contact list , information about who and when you use our and other technical information. This information is primarily needed
to maintain the security and operation of our platform, and for our internal analytics and reporting purposes.

Personnel

If you are a PBXManager worker or applicant, we collect information you voluntarily provide to us. We use the
information collected for Human Resources purposes in order to administer benefits to workers and screen applicants.
You may contact us in order to (1) update or correct your information, (2) change your preferences with respect to
communications and other information you receive from us, or (3) receive a record of the information we have relating to you.
Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that
we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion.

Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially
all of the assets of PBXManager or any of its Corporate Affiliates (as defined herein), or that portion of PBXManager or
any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or
have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to
adhere to the terms of this Privacy Policy.

Affiliates

We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy
Policy, “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common
control with PBXManager, whether by ownership or otherwise. Any information relating to you that we provide to our
Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Governing Law

This Privacy Policy is governed by the laws of United States without regard to its conflict of laws provision. You consent to the
exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection
with this Privacy Policy except for those individuals who may have rights to make claims under Privacy Shield, or the Swiss-US
framework.
The laws of United States, excluding its conflicts of law rules, shall govern this Agreement and your use of the app. Your use of
the app may also be subject to other local, state, national, or international laws.
By using PBXManager or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this
Privacy Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement
with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your
personal information will mean that you accept those changes.

Your Consent

We’ve updated our Privacy Policy to provide you with complete transparency into what is being set when you visit our site and
how it’s being used. By using our app, registering an account, or making a purchase, you hereby consent to our Privacy Policy
and agree to its terms.

Links to Other Websites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by
PBXManager. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites
are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to
go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other
website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties
may use their own cookies or other methods to collect information about you.

Cookies

PBXManager uses “Cookies” to identify the areas of our website that you have visited. A Cookie is a small piece of data
stored on your computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality
of our app but are non-essential to their use. However, without these cookies, certain functionality like videos may become
unavailable or you would be required to enter your login details every time you visit the app as we would not be able to
remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you
disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally
Identifiable Information in Cookies.

Contacts

We are committed to prioritizing your privacy and ensuring the security of your contact list. We do not share or store your contact list anywhere.

It is solely required for facilitating fast access dialing on your device and is not shared, stored, or made visible to any third parties. Rest assured that your contact information remains confidential and protected within our systems.

Blocking and disabling cookies and similar technologies

Wherever you’re located you may also set your browser to block cookies and similar technologies, but this action may block our
essential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its features
and services. You should also be aware that you may also lose some saved information (e.g. saved login details, site
preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a
cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your
browser, you should visit your browser’s help menu for more information.

Kids’ Privacy

We do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone
under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data,
please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without
verification of parental consent, We take steps to remove that information from Our servers.

Changes To Our Privacy Policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately
reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before
we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you
continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated
Privacy Policy, you can delete your account.

Third-Party Services

We may display, include or make available third-party content (including data, information, applications and other products
services) or provide links to third-party websites or services (“Third- Party Services”).
You acknowledge and agree that PBXManager shall not be responsible for any Third-Party Services, including their
accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof.

PBXManager does not assume and shall not have any liability or responsibility to you or any other person or entity for any
Third-Party Services.
Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at
your own risk and subject to such third parties’ terms and conditions.

Tracking Technologies

● Cookies
We use Cookies to enhance the performance and functionality of our $platform but are non-essential to their use. However,
without these cookies, certain functionality like videos may become unavailable or you would be required to enter your
login details every time you visit the $platform as we would not be able to remember that you had logged in previously.
● Sessions
$elnombre uses “Sessions” to identify the areas of our website that you have visited. A Session is a small piece of data
stored on your computer or mobile device by your web browser.

Information about General Data Protection

Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of
our Privacy Policy we are going to explain exactly how and why is this data collected, and how we maintain this data under
protection from being replicated or used in the wrong way.

What is GDPR?

GDPR is an EU-wide privacy and data protection law that regulates how EU residents’ data is protected by companies and
enhances the control the EU residents have, over their personal data.
The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our
customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our
baseline standard for all our operations worldwide.

What is personal data?

Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used
on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s
name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP
addresses, physical address, sexual orientation, and ethnicity.
The Data Protection Principles include requirements such as:
● Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a
person would reasonably expect.
● Personal data should only be collected to fulfill a specific purpose and it should only be used for that purpose.
Organizations must specify why they need the personal data when they collect it.
● Personal data should be held no longer than necessary to fulfill its purpose.
● People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data,
and that their data be updated, deleted, restricted, or moved to another organization.

Why is GDPR important?

GDPR adds some new requirements regarding how companies should protect individuals’ personal data that they collect and
process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breach. Beyond
these facts it’s simply the right thing to do. At PBXManager we strongly believe that your data privacy is very important and
we already have solid security and privacy practices in place that go beyond the requirements of this new regulation.

Individual Data Subject’s Rights – Data Access, Portability and Deletion

We are committed to helping our customers meet the data subject rights requirements of GDPR. PBXManager processes or
stores all personal data in fully vetted, DPA compliant vendors. We do store all conversation and personal data for up to 6 years
unless your account is deleted. In which case, we dispose of all data in accordance with our Terms of Service and Privacy
Policy, but we will not hold it longer than 60 days.
We are aware that if you are working with EU customers, you need to be able to provide them with the ability to access, update,
retrieve and remove personal data. We got you! We’ve been set up as self service from the start and have always given you
access to your data and your customers data. Our customer support team is here for you to answer any questions you might
have about working with the API.

California Residents

The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we
use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which
we have explained above.
We are also required to communicate information about rights California residents have under California law. You may exercise
the following rights:
● Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal
Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by
us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information
we have collected about you.
● Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
● Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about
you that we have collected.
● Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please
contact us.
We do not sell the Personal Information of our users.
For more information about these rights, please contact us.

California Online Privacy Protection Act (CalOPPA)

CalOPPA requires us to disclose the categories of Personal Information we collect and how we use it, the categories of sources
from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.
CalOPPA users have the following rights:
● Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal
Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by
us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information
we have collected about you.
● Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
● Right to Delete. You may submit a verifiable request to close your account and we will delete the Personal Information about
you that we have collected.
● Right to request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please
contact us.
We do not sell the Personal Information of our users.
For more information about these rights, please contact us.

 

PBXManager SIP Service Application:

1.1 User subscription data

• Name
• Email address
• IP address used while subscribing
• The user’s password is stored as an MD5 or SHA256 hash, used for SIP digest authentication.
• User’s international phone number, for Users, subscribing from the mobile application.
• User-agent used for subscription: it can be the browser’s user-agent string, or the PBXManager app user-agent string. The user-agent string of mobile apps includes an identifier of the device, for example “Moto G7”, “Samsung SM518”, “Apple Ipad 2”, which is used to allow users to easily track the devices on which they have used their SIP account.

1.1.a. User activity data:

• Calls logs: They comprise the caller’s SIP address, callee’s SIP address, date, time, status (completed or not), and duration.
• Chat message logs: sender’s SIP address, recipient’s SIP address, date, time, status (delivered or not), type (content or delivery notification). For clarity, the actual content of these messages is not stored.
• Registration logs: these logs represent the instants when a user app connects to the service through the network. They contain the date, time, status, and IP address.
• Telephone numbers of User’s mobile phone address book.

 

1.1.d. Debug logs:

For the sole purpose of troubleshooting, NewTel Systems reserves the right to activate the debug logs in the Application and in the software used to provide the Service. Such debug logs contain full protocol information for the calls, chat messages, and other protocol events generated by the Users

 

2.2 WHAT ARE THE PURPOSES OF DATA PROCESSING?

*PBXManager SIP Service Data

2.2.a. User Subscription Data:

• User’s subscription to the Service;
• User’s operation of the Service;

 

2.2.b. User activity Data:

 

• Compliance with NewTel Systems COMMUNICATIONS’s legal obligations
• Ability to proceed with requests from legal or regulatory authorities, regarding User identification or use of the Service;
• Statistical analysis on the use of the Service by Users; such as call peaks, interaction with third-party software, volume, and nature of data exchanged by the time of day; based on fully anonymized data of Users; in order to improve the Service’s operation and functionalities;

 

2.2.c. Group chat activity data:

• providing group chat and secure one-to-one chat services: data collected are necessary to enable the delivery of a message sent by a User to other Users, or members of the group.

 

2.2. d. Debug Logs:

• Support and troubleshooting services;
• Correct operation of the Service

 

3.3 WHAT IS THE LEGAL BASIS FOR SUCH PROCESSING?

*PBXManager SIP Service Data

3.3.a. User Subscription Data:

• The user consented to the processing;
• Processing is necessary to operate the Service, and therefore for the performance of the agreement with the User (Terms and Conditions of Service);

 

3.3.b. User activity Data:

• Processing is necessary to comply with our legal obligations;

 

3.3.c. Group chat activity data:

• Processing is necessary to operate the Service and therefore for the performance of the agreement with the User (Terms and Conditions of Service);

 

3.3.d. Debug Logs:

 

• Processing is necessary to perform the Service or support agreement with the User;
• Processing of the Data is in accordance with our legitimate interest since it enables us to improve the performance of the Service;

 

4.4 HOW LONG IS MY DATA PROCESSED?

*PBXManager SIP Service Data

4.4.a. User Subscription Data:

• Until closing or deletion of the User’s account;
• Data are deleted from the active database, but stored for one year from closing or deletion of the User’s account, pursuant to the provisions of Decree No. 2011-219 of February 25, 2011, relating to the storage and communication of data allowing the identification of any person having contributed to the creation of content published online

 

4.4.b. User activity Data:

• 12 months after collection; i.e. call logs and chat message logs are retained for 12 months from their registration in NewTel Systems systems;

 

4.4.c. Debug Logs:

• 1 month

 

5.5. DO WE DISCLOSE ANY INFORMATION TO THIRD PARTIES?

We do not sell, trade, or otherwise transfer to outside parties your Personal Data, or all type of content that you may upload or send with PBXManager (e.g. text conversations, calls, videos, photos; etc.), unless specifically requested by legally competent authorities, under a judicial or administrative order.

 

 

Contact Us

Don’t hesitate to contact us if you have any questions.
● Via Email: support@newtelsystems.com
● Via Phone Number: 212-681-0000
● Via this Link: newtelsystems.com