This policy describes how CallTower, Inc. collects, uses, and shares your information. When you use our sites, products, or services or otherwise form a relationship with us, we may obtain data from you and the devices you use to interact with us.
This policy is designed to provide transparency into our privacy practices and principles in a format you can navigate, read, and understand.
We commit to treat your personal information with care and respect and give you methods to contact us should you have any questions or concerns about the use of your information.
Finally, you may have received additional privacy documentation from us when you used a specific site, product, or service from us. In that case, the documentation you received should be read in conjunction with this Notice.
This policy explains:
This Policy describes the processing of information provided or collected on our sites and applications where this privacy policy is posted. In some instances, we may provide additional data privacy notices specific to certain products, practices, or regions. Those terms should be read in conjunction with this policy.
If you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. That third-party site or platform’s privacy practices will govern the use of your information. Choices you make on that third-party platform will not apply to our use of the information we have collected through our sites, products, or services.
If you are a resident of certain states or countries, you may have the right to know, access, correct, transfer, restrict the processing of, opt-out from certain types of processing (e.g., targeted advertising, the sale of personal data, limit the use and disclosure of sensitive information, and profiling, as defined by the applicable state law(s)), and delete your personal information. If you choose to exercise any of these options, we will not discriminate against you for making that decision.
You can exercise your privacy rights by clicking the “My Privacy Choices” link at the bottom of our website and select the applicable request, or by contacting us at privacy@calltower.com. When we receive a request to exercise a privacy right, we will review information we have collected about you (if any) with identifying information you may have provided us (such as a login, email address, mailing address, zip code, or transaction or order number) to authenticate your identity. If you use an authorized agent to submit a request, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to directly confirm with us that you provided the authorized agent permission to submit the request.
There may be situations where we cannot grant your request. In such a situation, we will explain our reasoning to you and will honor your right to appeal when applicable.
In the preceding 12 months, CallTower, Inc. may have collected or processed the categories of personal information that are identified below. We generally collect the information listed below to secure, improve, and provide our services to our customers.
The sources from which personal information may have been collected or processed are the following: information that you provided to us, online tracking technologies, automatic data collection technologies, social media platforms and networks, business partners, etc. The purpose of such collection or processing include: providing our products and services, communicating with you, administering programs, marketing and promotional purposes (which may include targeted advertising), analytics and personalization, security and fraud prevention, legal obligations, core business functions, the job applicant process, etc.
CallTower, Inc. does not believe to have Sold (for monetary or other valuable consideration) or Shared (for cross-context behavioral advertising purposes) your personal information in the last 12 months, as defined by certain state laws. However, we may disclose your information to our subsidiaries and affiliates, along with our service providers and third-party processors to provide services to you. We may also disclose your information with service providers and third parties when necessary to comply with laws and regulations; respond to subpoenas and court orders; exercise our legal rights or defend against legal claims; investigate, prevent, or take action regarding illegal activities, suspected fraud, potential threats to our property or the physical safety of any person, or violations of our usage instructions and applicable terms and conditions; facilitate the financing or insuring of our business or a disposition of all or part of our business or assets, or as otherwise permitted or required by law. We may disclose anonymized or aggregated data at our discretion, in accordance with applicable laws.
If you post your information or content to our online forums or media sites, this information is public on the Internet. We are unable to prevent or control further use of this information and refer you to the third-party sites’ privacy policies and terms of use to learn more about their privacy practices.
You can control how and when you want to receive marketing emails from CallTower, Inc. by clicking on the “unsubscribe” link located at the bottom of our email communications to you. This will not affect your receipt of administrative emails (for example, emails about your account, transactions, or policy changes) for your registered account.
Our services are not intended for children under the age of 16. We do not knowingly collect information via our sites, products, and services from users under the age of 16. If you use our Services, you represent that you are at least the age of majority under the laws of the jurisdiction of your place of residence. If you believe your child has provided us with personal information, please alert us at privacy@calltower.com. If we learn that we have collected personal information from a minor, we will promptly take steps to delete such information and terminate the minor’s account.
Cookies are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. We recommend you keep cookies activated. We have broken up our cookies into categories to help you understand what they do.
You can manage your cookie preferences on our cookie banner that pops up when you first visit our website.
If you would like to control the use of cookies and similar internet technologies on your computer, you can use web browsers listed with the Global Privacy Control tool built into them. These browsers limit cookie technologies and how they work while you browse the internet. You can find a list of browsers with the Global Privacy Control tool built into it here: https://globalprivacycontrol.org/#download.
The use of the website and web browsers located at the site above is at your own risk, subject to the agreements from those web browsers’ developers, and subject to their privacy policies. CallTower, Inc. does not accept any liability associated with your use of the website above or the content you may download from that website.
We have a duty, under federal law, to protect the confidentiality of certain types of services, including (1) information about the quantity, technical configuration, type, destination, location, and amount of your use of services, and (2) information contained on your telephone bill concerning the services you receive when matched to your name, address, and telephone number (“Customer Proprietary Network Information,” or “CPNI”). Examples of CPNI include information typically available from telephone-related details on your monthly bill, technical information, type of service, current telephone charges, long-distance, and local service billing records, directory assistance charges, usage data and calling patterns.
CPNI does not include things like customer name, address, or telephone number; aggregate information or data that is not specific to a single customer; customer premises equipment; and Internet access services.
We may not use this CPNI to market products and services to you other than for services you currently purchase if you don’t approve.
We have the ability to use the CPNI on file to provide you with information about our or our business partners’ communications-related products and services or special promotions unless you opt-out. YOU MAY DENY OR WITHDRAW OUR RIGHT TO USE YOUR CPNI FOR MARKETING PURPOSES AT ANY TIME BY EMAILING TO marketing@calltower.com. Denying or restricting approval for us to use your CPNI for marketing purposes (also known as “opting-out”) will not affect any of our services to which you subscribe. Any denial or restriction of approval remains valid until you affirmatively revoke or limit such denial or restricted approval.
Federal privacy rules require us to authenticate the identity of its customers prior to disclosing or discussing CPNI. Customers calling our customer service center can discuss their services and billings with our representative once that representative has verified the caller’s identity. There are four methods by which we will conduct customer authentication:
In the event the customer fails to remember their password and/or PIN, we will send the password and/or PIN to the Customer’s email address of record in order to authenticate the customer.
We notify customers whenever certain account changes occur. For example, whenever an online account is created or changed, or a password or other form of authentication (such as a “secret question and answer”) is created or changed, we will notify the account holder. Additionally, after an account has been established, when a customer’s address (whether postal or email) changes or is added to an account, we will send a notification. These notifications may be sent to a postal or email address, or by telephone, voicemail or text message.
We use numerous methods to protect your CPNI. This includes software enhancements that identify whether a customer has approved use of its CPNI. Further, all our employees are trained on how CPNI is to be protected and when it may or may not be disclosed. All marketing campaigns are reviewed by our Chief Revenue Officer to ensure that all such campaigns comply with applicable CPNI rules. We maintain records of our own and our business partners’ sales and marketing campaigns that utilize Customer CPNI.
In the event, we experience a privacy breach and CPNI is disclosed to unauthorized persons, in certain circumstances federal rules require us to report such breaches to law enforcement and/or regulatory authorities. We will inform our customers of a CPNI breach as and when required under applicable rules. Additionally, we maintain records of any discovered breaches in accordance with federal rules and will retain these records for not less than two (2) years.
We store and process your personal information on our servers located within the United States but may transfer your personal information to other countries outside of the United States for the purposes describe in this Privacy Policy. By using our websites, products, or services, you agree to the global transfer, process, and storage of your personal information.
If you would like to lodge a complaint against us, you may contact your local privacy regulator. If you have trouble locating a privacy regulator, please contact our privacy office at privacy@calltower.com and they will help you contact the appropriate enforcement agency.
If you have any questions about how we process your information, you can contact us at:
The Privacy Office
10701 River Front Parkway
South Jordan, UT 84095
Last modified: May 23, 2023
| Description | Data gathered throughout the customer/end user relationship with CallTower. | ||
| Categories of Information | Personal Identifiers Internet Data | ||
| Category of Data Subjects | This information is provided by the customer’s/end user’s business/organization. | ||
| Purpose of Processing | CallTower uses this information for activities such as: – Creating an account with CallTower – Providing services to the customers/end users device – Account management – Billing – Customer support – Authentication – Device/account configuration | ||
| Legal Basis for Processing | CallTower processes this information pursuant to the agreements between CallTower and organizations seeking to provide CallTower’s services to such organizations’ employees. | ||
| Automated Processing or Profiling | Does this product/service/process use automated processing: Automated processing may exist to create customer/end user accounts. Automated processing does not occur to profile individuals or to sell personal information to third parties. No☐ If yes, the general methods and logic used are: Automated routines take information from CallTower’s customers and create accounts and user profiles. Does the automated processing create affect the rights of data subjects? No. | ||
| Information Sharing | Categories of Recipients | Description of Business Purpose | Shared or Sold |
| Limited third parties to provide specific services that have been selected by the customer/end user. | Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. | Shared CallTower shares this information with service providers for a business purpose. | |
| Sensitive Personal Information | Category of Sensitive Personal Information Collected | Retention Period | |
| N/A | N/A | ||
| Whether Personal Information is Transferred Internationally | For our international clients. Information is shared internationally pursuant to global transfer mechanisms under appropriate privacy law. | ||
| Retention Period | CallTower retains this information throughout the life of the agreement between CallTower and its customers. | ||
| Description | Data gathered from visitors to CallTower’s website. | ||
| Categories of Information | CallTower only gathers information from web visitor when they input information into CallTower’s online forms. When visitors fill out those forms, they may provide the following: Personal Identifiers | ||
| Category of Data Subjects | This information is provided directly by website visitors. | ||
| Purpose of Processing | CallTower uses this information to provide marketing information to individuals who have expressed an interest in CallTower’s products. CallTower may also use this information when an individual expresses an interest in a job at CallTower. | ||
| Legal Basis for Processing | CallTower gathers this information so it can prepare either a recruitment relationship or marketing relationship a web visitor. | ||
| Automated Processing or Profiling | Does this product/service/process use automated processing: Automated processing may exist. Automated processing does not occur to profile individuals or to sell personal information to third parties. No☐ If yes, the general methods and logic used are: Information typed into a webform is routed to related departments within CallTower so that CallTower can respond to the information and potential requests placed in the webform. Does the automated processing create affect the rights of data subjects? No. | ||
| Information Sharing | Categories of Recipients | Description of Business Purpose | Shared or Sold |
| Limited third parties to provide specific services that have been selected by the customer/end user. | Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. | Shared CallTower shares this information with service providers for a business purpose. | |
| Sensitive Personal Information | Category of Sensitive Personal Information Collected | Retention Period | |
| N/A | N/A | ||
| Whether Personal Information is Transferred Internationally | N/A | ||
| Retention Period | For marketing, CallTower retains this information until an individual opts out of future marketing messages. For employment, CallTower retains this information throughout the candidate’s employment until the employment relationship has ended. Alternatively, CallTower deletes this information if an employment relationship does not form between a candidate and CallTower. | ||
| Description | Data gathered from Sales Representatives and their contacts. | ||
| Categories of Information | Personal Identifiers Geolocation Data Professional Employment Information | ||
| Category of Data Subjects | This information is provided by the sales representatives of directly from a representative’s contacts. | ||
| Purpose of Processing | CallTower uses this information to provide marketing information to individuals who have expressed an interest in CallTower’s products. | ||
| Legal Basis for Processing | CallTower gathers this information so it can pursue a commercial relationship with representatives’ contacts. | ||
| Automated Processing or Profiling | Does this product/service/process use automated processing: Automated processing may exist. Automated processing does not occur to profile individuals or to sell personal information to third parties.
No☐ If yes, the general methods and logic used are: Information typed into a webform is routed to related departments within CallTower so that CallTower can respond to the information and potential requests placed in the webform. Does the automated processing create affect the rights of data subjects? No. | ||
| Information Sharing | Categories of Recipients | Description of Business Purpose | Shared or Sold |
| Limited third parties who provide CRM and operational support services to CallTower. | Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. | Shared CallTower shares this information with service providers for a business purpose. | |
| Sensitive Personal Information | Category of Sensitive Personal Information Collected | Retention Period | |
| N/A | N/A | ||
| Whether Personal Information is Transferred Internationally | N/A | ||
| Retention Period | For marketing, CallTower retains this information until an individual opts out of future marketing messages. | ||
| Description | Data gathered from CallTower’s vendors and distributors. | ||
| Categories of Information | Personal Identifiers Geolocation Data Professional Employment Information | ||
| Category of Data Subjects | This information is provided directly from vendors and distributors. | ||
| Purpose of Processing | CallTower uses this information to contact vendors and distributors with an interest in selling CallTower’s products. | ||
| Legal Basis for Processing | CallTower gathers this information so it can pursue a commercial relationship with vendors and distributors. | ||
| Automated Processing or Profiling | Does this product/service/process use automated processing: Automated processing may exist. Automated processing does not occur to profile individuals or to sell personal information to third parties. No☐ If yes, the general methods and logic used are: Information typed into a webform is routed to related departments within CallTower so that CallTower can respond to the information and potential requests placed in the webform. Does the automated processing create affect the rights of data subjects? No. | ||
| Information Sharing | Categories of Recipients | Description of Business Purpose | Shared or Sold |
| Limited third parties who provide operational support services or provide specific features to vendors and distributors. | Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. | Shared CallTower shares this information with service providers for a business purpose. | |
| Sensitive Personal Information | Category of Sensitive Personal Information Collected | Retention Period | |
| N/A | N/A | ||
| Whether Personal Information is Transferred Internationally | N/A | ||
| Retention Period | Throughout the commercial relationship with the vendor or distributor. | ||
| Description | Data gathered from individuals at trade shows. | ||
| Categories of Information | Personal Identifiers | ||
| Category of Data Subjects | This information is provided by individuals directly to CallTower. | ||
| Purpose of Processing | CallTower uses this information to provide marketing information to individuals who have expressed an interest in CallTower’s products. | ||
| Legal Basis for Processing | CallTower gathers this information so it can pursue a commercial relationship with contacts. | ||
| Automated Processing or Profiling | Does this product/service/process use automated processing: No☒ If yes, the general methods and logic used are: Does the automated processing create affect the rights of data subjects? N/A
| ||
| Information Sharing | Categories of Recipients | Description of Business Purpose | Shared or Sold |
| Limited third parties who provide CRM and operational support services to CallTower. | Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. | Shared CallTower shares this information with service providers for a business purpose. | |
| Sensitive Personal Information | Category of Sensitive Personal Information Collected | Retention Period | |
| N/A | N/A | ||
| Whether Personal Information is Transferred Internationally | N/A | ||
| Retention Period | For marketing, CallTower retains this information until an individual opts out of future marketing messages. | ||
| Description | Data gathered from people who are recruits, candidates, or employees. | ||
| Categories of Information | Personal Identifiers Protected Class Information Commercial Information Internet Data Professional Employment History Education history | ||
| Category of Data Subjects | This information is provided by individuals directly to CallTower. | ||
| Purpose of Processing | CallTower uses this information to recruit and hire prospective employees, distribute benefits to those employees, manage payroll, and manage other HR tasks or administrative tasks pertaining to perspective, current, and past employees. | ||
| Legal Basis for Processing | CallTower gathers this information pursuant to its employee agreement or to potentially enter into an employee agreement with prospective and current employees. | ||
| Automated Processing or Profiling | Does this product/service/process use automated processing: No☒ If yes, the general methods and logic used are: Does the automated processing create affect the rights of data subjects? N/A
| ||
| Information Sharing | Categories of Recipients | Description of Business Purpose | Shared or Sold |
| Limited third parties that generally help administer and manage HR tasks such as banks, benefits providers, payroll, and retirement accounts. | Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. | Shared CallTower shares this information with service providers for a business purpose. | |
| Sensitive Personal Information | Category of Sensitive Personal Information Collected | Retention Period | |
Social security, driver’s license, state identification card, or passport number. Racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. CallTower only collects sensitive personal information, as defined in the applicable state privacy laws, with your consent and does not use sensitive personal information for inferring characteristics about you. | CallTower retains this information up to 4 years after employment as required or allowed by law. CallTower retains candidate information for prospective employees who do not become employees for up to 4 years as required or allowed by law. | ||
| Whether Personal Information is Transferred Internationally | N/A | ||
| Retention Period | CallTower retains this information up to 4 years after employment as required or allowed by law. CallTower retains candidate information for prospective employees who do not become employees for up to 4 years as required or allowed by law. | ||