Your privacy is very important to us at iBasis. iBasis is committed to respecting your privacy and the confidentiality of your Personal Information and the content of your communications. This Privacy Statement is meant to assist End Users and Account Managers in understanding how We use and safeguard the information that We process when providing our Wholesale Services.
Please read this Privacy Statement carefully. This document governs iBasis’ collection, use and disclosure of your Personal Information as well as Non-Personally Identifiable Information in relation to the Wholesale Services.
To help You better understand this Privacy Statement, We provide some basic definitions to use when reading and interpreting this document. The bold type terms used in this Privacy Statement shall have the meaning set forth below.
Account Managers means individuals who act on behalf of a Wholesale Customer in regard to the ordering, receipt, and administration of Wholesale Services.
End Users means individuals who are lawfully provided access to Our Wholesale Services by a Wholesale Customer.
You means Account Managers and End Users.
Wholesale Customer means the entity which has contracted for the iBasis Wholesale Services and provided End Users with access to such services.
iBasis or Us/We/Our means iBasis, Inc. and its affiliates.
Non-Personally Identifiable Information means aggregated, de-identified or other information that we cannot reasonably associate with an individual person.
Personal Information means information about an identifiable individual that is recorded in any form and that We have about You. Personal Information does not include information that is aggregated or otherwise does not identify an individual or does not permit Us to associate such information with an individual.
Privacy Statement refers to this Privacy and Security Statement as updated from time and time and available on the iBasis website.
Wholesale Services re the wholesale global voice termination, signaling, data and analytics services described on the iBasis websites, http://ibasis.com and http://iot.ibasis.com.
Why We Collect Information from You
Wholesale Customers provide us with information about You. We collect and use Your Personal Information for the following purposes:
- to conduct business transactions with current and prospective Wholesale Customers;
- to provide, maintain and improve the Wholesale Services to Our Wholesale Customers;
- to monitor and analyze trends, usage and activities in connection with the Wholesale Services;
- to identify the needs and preferences of End Users;
- to detect and prevent fraud;
- to meet applicable legal and regulatory requirements and obligations;
- to administer and manage Our business operations and Wholesale Customer accounts;
- to resolve disputes and troubleshoot problems; and
- to prevent improper or illegal use of the Wholesale Services.
These purposes listed above are our legitimate interests which we pursue. These legitimate interests form the legal basis to collect and use Your information.
What Information We Collect
We only collect information that we believe is necessary and appropriate for the purposes identified in this Privacy Statement. This information includes the:
- contact information of, and other information disclosed to Us by, Account Managers;
- originating and terminating number of a phone call;
- content of a phone call, as described below;
- content of a data session;
- duration of a phone call;
- End User device identifier and services capabilities; and
- the location of the cell tower which is used when you make a call or initiate a data session.
We do not actively record the content of phone calls, except (i) where required to provide the Wholesale Services; (ii) where obliged or permitted by applicable law; and (iii) at the request of a Wholesale Customer for the purposes of the Wholesale Customer, such as the monitoring of their End Users. It is the responsibility of the Wholesale Customer to ensure that their purposes are lawful in the jurisdiction in which they operate.
We may also randomly record phone calls for maintenance and troubleshooting purposes. Such communications content is used only for those purposes and is retained for a minimal amount of time and thereafter promptly deleted.
We have no access to End User names, email addresses, billing information, or other similar information.
Use of Data Analysis Techniques for Network Planning and Management, and Security
The iBasis network supports our Wholesale Services. We maintain, plan and improve our network and perform management tasks like the routing of traffic, clearance of faults, and monitoring of peak loads and overloads. Analyzing the use made of our network gives us essential network usage and load information. Based on this information, we can expand and enhance our network in a targeted way. iBasis processes traffic data for these technical and statistical analyses. This includes (i) telephony data like your telephone number, date and starting and ending times of a call, the type of service concerned, International Mobile Subscriber Identity (IMSI), International Mobile Equipment Identity (IMEI) and (ii) data such as Customer identification.
Protection of Your Information
We have invested in and deployed technological and organizational security measures to protect information that we process. For instance we maintain firewalls, network segmentation, periodic security scans, patch updates and other technical security measures for our servers and internal networks, and the servers on which Personal Information is stored are located in secure facilities that are available only to authorized personnel. We use restrictive access methods to keep information secure. Our employees are dedicated to maintaining and upholding your privacy and security and are educated regarding this Privacy Statement. Only those employees who require Personal Information to perform a specific function related to the iBasis service are granted access to that information. Our employees are required to use the utmost discretion when accessing Personal Information, and they are prohibited from using Personal Information for purposes unrelated to their job functions. As appropriate, our employees are notified when this Privacy Statement is revised or other privacy or security measures are implemented by iBasis.
We require that our third party service providers agree to keep all information We share with them and to use the information only to perform their obligations in the agreements We have in place with them. These third party service providers are expected to maintain privacy and security protections that are consistent with applicable law. While We provide these third parties with no more information than is necessary to perform the function for which We engaged them, any information that You provide to these third parties independently is subject to their respective privacy policies and practices.
Disclosure of Personal Information
We do not sell your Personal Information to anyone other than your Wholesale Customer in connection with the Wholesale Services provided to them. We only disclose Your Personal Information to third parties where necessary to fulfill the purposes identified in this Privacy Statement or where requested by You.
We may, however, use or disclose your Personal Information for legal or regulatory reasons as necessary or as required to investigate fraud, to protect iBasis, Wholesale Customers, and End Users, to otherwise protect against the unlawful use of the Wholesale Services, or as otherwise described above in the section titled, “Why We Collect Information from You.”
You acknowledge that it is iBasis’ policy and prerogative to respond to all governmental inquiries regarding its Wholesale Services. In the event a competent governmental authority asks iBasis to retain and provide Personal Information about You, iBasis reserves the right to provide any and all assistance and information necessary in its opinion to fulfill the request.
We also may disclose Personal Information in connection with a merger, acquisition or bankruptcy if We should ever file for bankruptcy or merge with another company, or if We should decide to buy another business, or sell or reorganize part or all of our business. We may disclose Your Personal Information to prospective or actual purchasers and other parties. By using the Wholesale Services, You acknowledge that any such transfer of Your Personal Information may occur. It is iBasis’ practice to obtain appropriate protections for Personal Information disclosed in these types of transactions. iBasis cannot, however, guarantee that the Privacy Statement applicable to the Wholesale Services will remain unchanged if iBasis is sold or merges with or is acquired by another company.
Retention of Personal Information
Personal Information will be retained only as long as necessary for the fulfillment of the purposes identified in this Privacy Statement or as otherwise required or permitted by applicable law.
Accuracy of Personal Information and Your Rights Related to Personal Information
iBasis takes reasonable steps to make sure that the Personal Information We process is accurate, complete and up-to-date for the purposes for which it is collected and processed. You should ensure that any information you provide to Us or the relevant Wholesale Customer (your employer) is accurate, complete and up-to-date, and You should contact Us or the relevant Wholesale Customer (your employer), as appropriate, should you need to update or review that information.
You may have a right to data portability under applicable law. You may also access a copy of Your Personal Information, request rectification or erasure of Your Personal Information, object to processing of Your Personal Information, request the restriction of the processing of Your Personal Information, or otherwise exercise your rights afforded under applicable law by contacting us at the address provided below and by providing evidence of your identity. If the information requested does not identify you without us obtaining additional information, we may not be able to honor your request. Finally, you also have the right to lodge a complaint with a supervisory authority.
Transfer of Information
The Personal Information that We collect may be stored and processed on servers located in various countries, including servers located outside of your home country. This is necessary to ensure that your calls reach their intended destination.
Contact Us; Our Privacy Officer and KPN Data Protection Officer
We have designated one or more individuals who monitor Our compliance with this Privacy Statement. The individual responsible for Our compliance has been designated as iBasis’ Privacy Officer. You may also contact the Data Protection Officer or the Case Management Team for our parent company, KPN B.V. Please direct any questions or correspondence regarding this Privacy Statement to the iBasis Privacy Officer, the KPN Data Protection Officer, or the KPN Case Management Team. The Privacy Officer, and the KPN Data Protection Officer and KPN Case Management Team can be reached by sending correspondence to:
ATTN: Mrs. Rachel Marbus, Data Protection Officer
(Manager Case Management Team) PO Box 30000
2500 GA The Hague
Other individuals may handle the day-to-day collection and processing of Personal Information. The KPN Data Protection Officer, iBasis Privacy Officer or iBasis’ management may designate other individuals within iBasis to perform the KPN Data Protection Officer’s and iBasis Privacy Officer’s responsibilities.
Changes to This Privacy Statement
We reserve the right to change this Privacy Statement at any time. The revised Privacy Statement will be effective immediately upon its posting on the website with the new effective date displayed. Any revisions will apply on a prospective basis only, except as described below. You should periodically check this Privacy Statement for any such changes, and you acknowledge that any use of the Wholesale Services after such changes signifies your consent to those changes.
If we intend to use Personal Information we have collected from you in a manner that is materially different from that described in this Privacy Statement, we will seek our Wholesale Customer’s explicit consent.
Last Updated: December 14, 2018