Privacy Policy - California Addendum - Archive Dec, 2019
This addendum to our Privacy Policy explains the rights of California customers when using Dialpad Services, as guaranteed by the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy law.
Your Rights and Choices as a Customer
The CCPA provides California residents with specific rights regarding their personal information. If you are a customer and a California resident, this section describes your CCPA rights and how to exercise them.
Right of Access to Information
You have the right to request information about our collection and use of your personal information over the past 12 months. Once we verify your request, we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business purpose for collecting and/or sharing that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also known as data portability)
If we disclosed your personal information for a business purpose or sold it, we will provide two separate lists disclosing:
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained; and
identifying the personal information categories that each category of recipient purchased; and
Right to Deletion
You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. Once we verify your request, we will delete your personal information from our records and direct our service providers to do the same. Certain exceptions apply, such as being necessary to complete our contract with you, protect the security of Dialpad’s services, or comply with legal requirements.
Right of Non-discrimination Under CCPA
You have the right not to be discriminated against for exercising any of your CCPA rights. You should feel free to exercise any of these rights knowing that we will not not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your Access, Data Portability, and Deletion Rights
Many common tasks, such as viewing or deleting account data and managing user accounts can be done immediately by you or your company’s Dialpad Administrator through the administrator settings. Dialpad does not sell customer information from the use of its services, and customers may opt out of analytics cookies on Dialpad websites via Dialpad’s cookie portal. For other access, data portability, and deletion requests, visit Dialpad’s Data Subject Access Request Portal.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request related to your personal information.
You may only request a report twice within a 12-month period. Your request must provide enough information that we can verify your identity as the person who is entitled to the information, and it must provide sufficient detail that we can understand and respond to it.
You do not need to create an account to make a request with us. We will only use personal information provided in the request to verify your identity and authority to make the request.
Response Timing and Format
Our goal is to respond to every request within 45 days of its receipt. If we need more time (up to 90 days), we will explain the reason and extension period in writing. If you have an account with us, we will respond to the email account on file. If you do not have an account with us, we will respond by mail or email, at your option.
Any disclosures we provide will only cover the 12-month period preceding your request. If we can’t comply with part of your request, we will explain why.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Information We Collect
The table below summarizes the categories of information that Dialpad collects, and the subset of that information that we share for a business purpose:
CCPA Category | Examples | Collected | Shared for Business Purpose | Sold |
Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES | YES | NO |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES | YES | NO |
Protected classification characteristics under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO | N/A | N/A |
Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO | N/A | N/A |
Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO | N/A | N/A |
Internet or other similar network activity | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES | YES | YES (Google Analytics only) |
Geolocation data | Physical location or movements. | YES | YES | NO |
Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | YES | YES | NO |
Professional or employment-related information | Current or past job history or performance evaluations. | NO | N/A | N/A |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | N/A | N/A |
Inferences drawn from other personal information | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO | N/A | N/A |
We obtain the categories of personal information listed above from the following categories of sources:
Directly from our customers or their agents. For example, from information that you enter directly into the Services, or import through third party services that you have authorized to integrate with Dialpad.
Indirectly from our customers or their agents. For example, through information collected in the course of providing the Services.
Directly and indirectly from activity on our websites (www.dialpad.com and www.uberconference.com). For example, from submissions through our website or website usage details collected automatically.
Use of Personal Information
We use and/or disclose the personal information we collect for one or more of the following business purposes:
To provide you with the Services that you request from us.
To communicate with you about the Services, including marketing, if permitted.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis and product development.
To protect the rights, property or safety of us, our clients or others.
To respond to legal requirements.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the third party to both keep your personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Identifiers, California Customer Records personal information categories, Internet or other similar network activity, Geolocation data, and Sensory data.
We disclose your personal information for a business purpose to the following categories of third parties: our affiliates; service providers; and third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Dialpad does not sell customer data from the use of its telephony services. Dialpad’s website uses the free Google Analytics platform to understand how customers and prospective customers use our websites. Under CCPA, this service may represent “other valuable consideration”, but Dialpad receives no income from this analysis. You may opt out of this collection via the Do Not Sell My Info link on www.dialpad.com.
California Service Provider Statement
Dialpad does not retain, use, or disclose personal information of customers for any purpose other than for the specific purpose of performing the services specified in the contract for the business, or as otherwise permitted by the California Consumer Privacy Act or with the consent procedures identified herein.
Contact Information
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
General questions or exercising CCPA rights: [email protected]
Exercising CCPA rights: Data Subject Access Request Portal