This Policy consists of the following sections:
- Section 1. Users of our website : this section applies if you use the PGi website, www.pgi.com (the “Website”), and explains how we use personal information of the users of the Website.
- Section 2. Users of our business solutions : this section applies if: (i) you work for an organisation which uses our business solutions, (ii) if you use the mobile applications (“Apps”) that interface with our business solutions or (iii) if you use our Website subdomains accessible only after login to a customer account (“Product Pages”), and explains how we use personal information in the course of providing our business solutions.
- Section 3. Your rights and our data protection practices : this section applies to the users of our Website and the users of our business solutions and sets out further information on PGi’s data protection practices and your data protection rights.
‘You’ or ‘your’, in this Policy, means you as a natural person, rather than any legal entity which is our customer (such as your employer) which you may represent when you use our business solutions.
When using our Website, if you are a resident of North America, your relationship is with American Teleconferencing Services Ltd. d/b/a Premiere Global Services; if you reside in the European Union, your relationship is with Premiere Conferencing (Ireland) Ltd, which is the data controller with respect to your personal information collected by PGi.
Our legal entity names and their contact details can be found in www.pgi.com/contact under PGi worldwide locations.
1. Users of our Websites
This section applies to you if you are a user of our Website and explains how we process your personal information when you use our Website or submit queries through our Website.
1.1. Information we collect
Internet or electronic network activity information as follows:
- Usage data, such as performance metrics related to your use of the website;
- Log data generated when you use the Website, including Internet Service Provider (“ISP”), browser type, referring/exit pages, the files viewed on our site, referrer URL, key words entered into a search engine, operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Website;
- Device data, such as the configuration of your device.
Identifiers associated with cookies or other technologies that may uniquely identify your device or browser, your Internet Protocol (“IP”) address and your approximate location.
Other identifiers, including your name, company name, title, telephone number, email address and country.
Inferences, including your choices, behavior and preferences when you use the Website and when you open or click on a link in our emails.
Commercial information about the services you purchased or considered.
1.2. Sources of Information
We may collect information from you from the following categories of sources:
- Information you provide, such as other identifiers and commercial information you provide when you communicate with us about or purchase our products and services or when you complete forms on our Website.
- Information collected automatically, such as internet and electronic network activity, identifiers and inferences when you use our Website.
1.3. How and why we use personal information
We collect, process, use and store your personal information for the following business and commercial purposes in accordance with our legitimate business interests and legal requirements or with your consent where required:a. to provide you with information in response to your requests;
b. to maintain the accuracy of the information we collect;
c. to help us develop new services, solutions or features that meet your needs;
d. to manage language preferences and connect you with your nearest account manager;
e. to maintain contact data about you or a third party (such as, your employer);
f. where necessary to protect or conduct our business and pursue our, or our affiliates’, legitimate business interests, which include the security of our systems and our operations and the exercise or defence of legal claims;
g. to comply with privacy laws and other regulations such as to manage consent requirements;
h. to give you a customized interactive experience;
i. to measure interest in various PGi solutions and services;
j. to inform you about new PGi solutions and services or features and functionalities;
k. to inform you of products, services, marketing plan and other business related items from PGi or third parties which may be of interest to you;
l. to occasionally send you push notifications, which you may opt-out of by turning them off at the device level through your settings.
1.4. Lawful bases for processing personal information (applies only in the European Economic Area)
PGi processes personal information where one or more of the following conditions that are set out in the General Data Protection Regulation (GDPR) apply:
a. Where it is necessary in order for us to conduct our business and pursue our, or our affiliates,´ legitimate interests for internal administrative purposes. In particular, we collect, use and store your personal data: (i) to communicate and manage our relationship with our customers; (ii) to maintain contact data about you or a third party (such as, your employer); (iii) to inform you of products, services, marketing plan and other business related items from PGi or third parties which may be of interest to you; (iv) to ensure the security of our systems and our operations, and (v) where appropriate, to establish, exercise or defend legal claims.
c. Where it is necessary in order for us to comply with our legal obligations, such as requirements to process requests by government or law enforcement authorities.
To the extent our Website may include widgets, which are interactive mini-programs that run on our site, to provide specific services from another company (e.g. displaying the news, opinions, music, etc.), personal information, such as your email address, may be collected through the widget and shared with the company that created it. Those third parties may further process and/or use your personal information in accordance with their privacy policies.
1.5.3. Other Third Party Tracking and Advertising
We partner with third parties to display advertising on our Website or to manage our advertising on other sites. For our Website, we may use web analytic cookies, including the use of Google Analytics, Remarketing with Google Analytics and Google Display Network Impression Reporting to advertise online. Websites and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to a website. Our Website also use third-party vendors, including Google and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Website. This helps us make our service to you better.
1.5.4. Mobile Analytics
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. To the extent we automatically link any collected data to other information we collect about you, we do so for reasons such as to improve PGi services we offer you and to improve marketing, analytics, or the Website’s functionality.
To the extent we employ any framing techniques on our Website, please be aware that you are providing your personal information to PGi and not to a third-party site.
To the extent PGi posts customer testimonials/comments/reviews on any of our Website that contain personal information, we obtain any required consent(s) prior to posting the testimonial.
1.7. Social networking and Public Forums
To the extent PGi offers certain publicly accessible blogs and/or community forums on our Website, you should be aware that any information you provide in these areas may be broadly available to others, and can be read, collected, and used by others who access them, potentially inside or outside PGi. When persons external to PGi access the information you choose to submit in such blogs or community forums, they will be responsible for how they use it and we do not have control of such use of your information. Also, please note that individual blogs and/or forums may have additional rules and conditions.
Collection and sharing of personal information on social media apps and websites is governed by the privacy policies and practices of the social media providers. PGi may collect information about you in connection with social networking sites in several ways, including:
a. When you sign in to a PGi app or website using a social networking account;
b. When you use a PGi app on a social networking site or choose to join (or “like”) a PGi page on a social networking site. In these situations, the social networking site may make some information about you available to PGi;
d. When you make information publicly available on your social networking page
We use this information for purposes described in this Policy.
We use a chat feature to help you with any questions or concerns. If our chat feature is offline we may still collect your name, email address and telephone number so that we may reply to your request.
We do not knowingly collect any personal information from children under 13 years old through our Website. However, if the parent or guardian of a child under 13 believes that the child has provided us with personal information, the parent or guardian of that child should contact us using the Privacy Contact Information provided at the end of this policy if they want this information deleted from our files. If we obtain knowledge that we have personal information about a child under 13 in retrievable form in our files, we will delete that information from our existing files. We do not sell the personal information of minors aged 13 to 16.
1.10. Third Party Websites and Cookies
1.11. Sharing personal information
a. Affiliated companies which may use this personal information to offer our services or products to you consistent with the purposes identified in this Policy;
b. Our third party service providers who we have appointed as data processors to perform functions and services on our behalf and who will be provided only with personal information necessary to perform the services on our behalf but are not authorised by us to use such data for any other purposes (e.g. providers of web hosting services, online chat and email services, marketing and advertising services, social networks, data analytic services and data enrichment services);
c. Judicial and government authorities or other law enforcement bodies and regulators, in the context of complying with our legal obligations and processing requests or orders received from those bodies;
d. In the event of legal proceedings, claims, complaints and other enquiries: to courts, legal counsels or other parties where required in this context;
e. In the event that our business is sold or integrated with another business: to our advisers and any prospective purchaser’s adviser and the new owners of the business.
2. Users of our business solutions
This section applies to you if you work for an organisation which uses our business solutions or when you use our business solutions through our mobile application interfaces (“Apps”) that link to this Policy. The business solutions we provide include online meetings with audio, video and screen sharing and/or solutions for hosting interactive webinars or large-scale webcast events (“meeting and event solutions).
We use your personal information to manage our relationship with our customers – your employer – including for billing and contract management purposes, notifications related to software updates, upgrades, and system enhancements, or promote our business solutions where permitted.
We also use your information when we provide our business solutions services. When you use our meeting and event solutions, your employer controls what information we process about you and how this is processed, and they will be responsible for the use of your information. If you require further information or wish to address requests about the use of your information in this context, you are advised to contact your employer directly and to review their personal data protection policy, this Policy does not apply.
2.1. Information we collect
We will collect your name, professional contact details, your job role and/or your signature in order for us to manage our relationship with your business to perform the services agreement, manage the contract, bill or send you product notifications or information our business solutions.
We will also need to process the following information from users: name or username, contact details, IP address and access number. The following information will be generated by the services: usage and traffic information including duration of meeting or event, date and time, number of participants, web browser versions or bit rate to and from our servers and the content recorded of meeting or events and files uploaded to the platform.
2.2. How and why we use personal information
We collect and use personal information for the following purposes: (a) to manage our relationship with our customers, including to inform them about new PGi solutions and services, features and functionalities, (b) where necessary to protect our legitimate business interests, which include the security of our systems and our operations, accounting, billing and audit purposes, and the exercise or defence of legal claims, (c) to enable your communications over the network and where necessary, to provide emergency call services and (d) to comply with our legal obligations (for example, our obligations under telecommunication laws).
2.3. Lawful bases for processing personal information (applies only in the European Economic Area)
PGi processes personal information where one or more of the following conditions that are set out in the General Data Protection Regulation (GDPR) apply:
a. Where it is necessary in order for us to conduct our business and pursue our or our affiliates’ legitimate interests for internal administrative purposes. In particular, we collect, use and store your personal data: to communicate and manage our relationship with our customers; to allow our customers to use our services, to ensure the security and proper performance of our systems and our operations, for accounting, billing and audit purposes, and for the establishment, exercise or defence of legal claims.
b. Where it is necessary in order for us to comply with our legal obligations, such as obligations under telecommunication laws, which include requirements to process requests by government or law enforcement authorities, to enable you to call emergency call numbers, or in some countries to verify the identity of our customers’ representatives.
2.4. Sharing personal information
a. Our third-party service providers that help us run our business, who process it on behalf of PGi for the purposes identified above. These providers are listed in our “Sub-processors and Subcontractors” list available the same from a link, as this is, at the bottom of this Policy. These providers are not permitted to use your information for their own purposes;
b. Other PGi subsidiaries listed in our Sub-processors and Subcontractors list available from a link at the bottom of this Policy;
c. Your employer, to the extent this is required in order for us to perform the services and comply with our contractual obligations towards them;
d. Judicial and government authorities or other law enforcement bodies and regulators, in the context of complying with our legal obligations and processing requests or orders received from those bodies;
e. In the event of legal proceedings, claims, complaints and other enquiries: to courts, legal counsels or other parties where required in this context;
f. In the event that our business is sold or integrated with another business: to our advisers and any prospective purchaser’s adviser and the new owners of the business.
3. Your rights and our data protection practices
3.1. Your rights
You may have specific rights based on where you live. In particular, if you are resident of the European Union or California, USA, you have particular rights, as described below. If you have queries or a concern in relation to how we use your personal information and satisfy your rights, please let us know by using the contact details at the end of this Policy.
3.1.1 Eurpoean Union Residents
If you are a resident of the European Union, you have the right to ask us whether we hold any of your personal information and to obtain a copy of your personal information; you have the right to correct any incorrect or incomplete personal information; in some circumstances, you have the right to delete personal information or restrict (stop any active) processing of your personal information; and you have the right to obtain the personal information you provide to us with your consent in a structured, machine readable format, and to ask us to share (port) this information to another controller. In addition, you can object to the processing of your personal information in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). These rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of these rights or to obtain other information, you can get in touch with us using the “Privacy” contact details set out below. You also have the right to complain to an EU data protection authority.
3.1.2 California Residents
If you are a resident of California, USA, and a user of our Website, you have the right to:
f. If you have further queries or you have a concern in relation to how we use your personal information and satisfy your rights, please let us know by using the contact details at the end of this Policy. Alternatively, if you reside in the European Union, you also have the right to complain to an EU data protection authority.
- Request, up to two times each year, that we disclose to you the categories of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, the categories of personal information (if any) that we sold about you, the categories of third parties with whom we have shared your personal information, and, if applicable, the business or commercial purpose for selling or disclosing your personal information.
- Request your personal information be deleted, subject to certain exceptions.
- Request a copy of the specific pieces of information we have collected about you in a readily usable format.
We do not share your Personal Information with third parties for their direct marketing purposes.
3.2. Communication Preferences
You can set and modify your communication permissions or update your contact information using our PGi Marketing Preference Center, accessible from any email we send you, or by emailing us at email@example.com using the email address we have associated with you. You can also opt-out or further update your email preferences through any promotional or marketing email sent from us. These choices do not apply to transactional service communications that are part of the PGi business solutions or informational communications that have their own unsubscribe option included in the message.
3.3. Retention of Personal Information
a. Where we process personal information of our customers’ employees to manage our relationship with our customers, we do this for as long as we provide our business solutions to our customer and for a maximum period of fourteen (14) months after this.
b. Where we process personal information for marketing or business analytic purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.
c. In all other cases, we will retain your personal information for as long as this is required to fulfill the purposes for which it was collected and for such further period required in order to resolve disputes, to enforce our agreements, or to comply with our legal, regulatory or contractual obligations.
We provide reasonable technical and organizational security controls to protect your personal information. However, despite our efforts, no security controls are fully effective and PGi cannot ensure or warrant the security of your personal information. We recommend that you take every precaution in protecting your personal information when you are on the Internet. For example, change your passwords often, use a combination of letters, numbers, and symbols when creating passwords, and make sure you use a secure browser.
3.5. Transfers of personal information
Your personal information is stored on PGi´s servers and the servers of our service providers located in different parts of the world. Where information from residents in the EEA, Switzerland or the United Kingdom is transferred to, or accessed remotely in, a non-EEA country that is not recognised by the EU Commission as providing an adequate level of data protection, we rely on the EU Commission approved standard contractual clauses. In some instances, where this mechanism does not apply, we may still transfer personal information to third parties outside the EEA after we have obtained your explicit consent for such transfer, where the transfer is necessary in order for us to provide services under a contract for your interest, to exercise or defend legal claims, to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements, or to fulfil compelling legitimate interests in accordance with data protection laws. A copy of the relevant mechanism can be provided for your review on request to the contact details contained in our Privacy Contact Information section below.
3.6. Privacy Certification
PGi participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. PGi complies with the Privacy Shield 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 at www.privacyshield.gov.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website 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.
3.7. Review of Compliance and Policy Changes
We review our compliance with this Policy on a periodic basis, and we reserve the right to update this Policy to reflect changes to our information practices. Please check this Policy on our Website periodically for changes. If we make any material changes, we will also post a notification on our Website or, where appropriate, contact you via email to let you know about those changes prior the changes becoming effective.
3.8. Privacy Contact Information
Should you have any privacy-related questions or comments relating to this Policy or the way we process your personal information, please contact us through the contact information provided below:
Date: Last Revised February 23, 2021