2.1
In this Section 2 we have set out:
(a)
the general categories of personal data that we may process;(b)
in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;(c)
the purposes for which we may process personal data; and(d)
the legal bases of the processing.
2.2
We may process data about your use of our websites ("
website usage data"). The website usage data may include your IP address, geographical location, browser type and version, device type, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use. The source of the website usage data is our analytics tracking system. This website usage data may be processed for the purposes of analysing the use of the websites and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our websites and services.
2.3
We may process your account details ("
account data") and your information relating to setting up conferences ("
set-up data"). The account data may include your name and email address, while the set-up data may include personal identification numbers (PINs), conference URLs and service settings. The source of the account data is you or your employer or principal. This data may be processed for the purposes of providing our services, ensuring the security of our website and services and communicating with you. The legal bases for this processing are:
(a)
our legitimate interests, namely the proper administration of our business, the performance of our obligations under customer contracts, and the provision of our services to customers and users; and/or(b)
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may also process your account data to contact and offer you promotions and loyalty programmes. The legal basis for this processing is your consent. You can update your consent for receiving email communications from us at:
https://www.powwownow.co.uk/dashboard/my-details/preferences2.4
We may process your personal data included in meta-data regarding conferences ("
call record data"). The call record data is generated by our conferencing systems and includes, with respect to a particular conference, the applicable date, time, duration and caller numbers. We will collect and store the call record data as part of our business records; and the legal basis of this processing is that it is necessary for compliance with a legal obligation to which we are subject. In addition, we may use call record data for the purposes of providing our services, ensuring the security of our services, providing call history information and providing billing details; and the legal basis of this processing is our legitimate interests, namely the provision of our services and the security and proper administration of our business.
2.5
We may process the content of communications sent through our conferencing services (“
call content data”). The call content data includes voice content and shared screens and will be processed for the purposes of the transmission of your communications and the storage of your communications at your request, or as part of the contracted service offering provided. We will never view or listen to your call content, or disclose your call content data, unless we are legally obliged to do so. The legal bases for this processing are:
(a)
our legitimate interests, namely the performance of our obligations under customer contracts, and the provision of our services to customers and users; and/or(b)
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6
Where a call recording has been instructed we may process information about the recording files ("
call recording data"). The call recording data may be processed for the purposes of the preparation and storage of your call recording. We will never view or listen to your call recording, or disclose your call recording data, unless we are legally obliged to do so. The legal bases for this processing are:
(a)
our legitimate interests, namely the performance of our obligations under customer contracts, and the provision of our services to customers and users; and/or(b)
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7
We may process your personal data that are provided or generated in the course of the use of our support services ("
support data"). The support data may be processed for the purpose of providing support services to you. The legal basis for this processing is our legitimate interests, namely the provision of appropriate support in relation to the use of our conferencing services.
2.8
We may process information relating to transactions, including purchases of software and services, that you enter into with us and/or through our websites ("
transaction data"). The transaction data may include your contact details, your card details and the transaction details. We do not store card details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal bases for this processing are:
(a)
our legitimate interests, namely the proper administration of our business, the processing of transactions and the handling of issues relating to transactions; and/or(b)
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.9
If you are a customer or customer relationship contact, then we will store your name and contact details in our customer relationship management system ("
CRM data"). We use CRM data for the purposess of managing our customer relationships and communicating with our customers; the legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with customers. We may also process your CRM data to contact and offer you promotions and loyalty programmes; the legal basis for this processing is your consent. You can update your consent for receiving email communications from us at:
https://www.powwownow.co.uk/dashboard/my-details/preferences.
2.10
We may process information contained in any enquiry you submit to us regarding software and/or services ("
enquiry data"). Enquiry data shall become correspondence data if the enquiry results in you or the relevant person becoming a customer of ours, in which case Section 2.11 shall apply to that data. Subject to this, enquiry data may be processed for the purposes of offering, marketing and selling relevant software and/or services to you. The legal basis for this processing is consent.
2.11
We may process information contained in or relating to any communication that you send to us ("
correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.
2.12
We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.13
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.