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Effective as of March 25, 2018

Introduction

TelStrat, LLC (“TelStrat,” “we,” “us,” “our”) provides call recording and related solutions that enable entities to manage data associated with their consumers’ interactions with their business (the “Services”). In connection with providing its Services, TelStrat may receive personally identifiable information (“personal information”) from its merchant customers about a variety of online and offline consumer transactions. This policy sets forth TelStrat’s general privacy and security practices with respect to this information. While this policy sets forth our general privacy and security practices, the detailed obligations and commitment of TelStrat is set forth in the contractual arrangements with our customers. In the event of a conflict between this policy and a contract with the customer, the contract prevails.

This Privacy Policy (“Privacy Policy”) applies to the data that we, and our Affiliates’ (which includes any person or entity that controls us, is controlled by us, or is under common control with us, such as our subsidiary, parent company, or our employees and includes Serenova, LLC) behalf, and on behalf of our customers and business partners when providing the Services. Specifically, this Privacy Policy applies when 1) you visit certain of our publicly-accessible websites, which include www.telstrat.com, www.serenova.com, and our other websites where this privacy policy is posted, provided, however, that this policy does not describe how personal data is collected and processed by our resellers to their customers or by customers who obtain personal information directly from consumers, 2) you sign up for Services as our customer, or 3) sign up for an account with TelStrat and access that account. This Privacy Policy also describes your rights and choices regarding use, access, erasure, portability, restriction of processing, and correction of your personal information.

Types of Information We May Collect and How We May Use It

Visitor Data – TelStrat collects information from individuals who visit the web sites maintained by TelStrat, LLC and information submitted by visitors who register with the site or associated services or who request certain materials from us.

This may include information about your interest in and use of our web sites, products and services, and personal information that you voluntarily submit such as personal identification and contact information, including but not limited to a first and last name, a national identification number, an email address, postal or physical address, telephone number or other contact information, occupation or industry, company information, and payment and billing information such as bank account information.

Customer Account Data – We collect all the data that relates to the relationships between us and our customers. We collect this information as we need it in order to provide our customers with the Service. This includes data such as our customers’ names, contact information, billing information and records. If you sign up for a free trial through our website, we collect the information that you submit through the online form.

Customer Content – This consists of the content made accessible to TelStrat as a result of you utilizing the Service. Customer content can be collected for both on-premise and hosted solutions.

Customer Usage Data – This includes operational data like call logs, origination and termination points, traffic routing information or other information generated by usage of the Services.

With respect to data we collect when you visit our website, we may use your information for a number of purposes, including:

> To register or provide a service or feature that you request, such as giving you access to requested materials, including but not limited to white papers, technical briefs, product/service offerings and other materials

> For advertising and marketing purposes, such as to send you promotional communications regarding events, seminars, webinars, podcasts, teleconferences or executive roundtable, products, services

> To engage in subsequent communications with you via telephone, email, web chat, SMS, messaging, social media and other means with your consent

> To assess and evaluate visitors who have applied for career opportunities or other Human Resources activities, such as by submitting information to the Careers portion of the site

> For assessment and analysis of our market, customers, products, and services (including asking users for their opinions on our products and services)

> As otherwise provided for in a supplement to this Privacy Policy or a contract with respect to specific TelStrat products or services

We may also track non-personal information (also see Use of Cookies, Web Beacons and other Technologies in this Privacy Policy). This includes standard information about your browser, and the number of times such content is accessed by a specific visitor. TelStrat collects this non-personal information in an effort to improve the quality of its website and also to answer questions, as well as improve delivery and quality of information to visitors of TelStrat’s websites, and for sales and prospecting efforts

Telstrat reserves the right to use or disclose information provided if required by law, or if we reasonably believe that use or disclosure is necessary to protect our rights.

We may supplement the data that we collect with additional data received from third party sources to help us provide our Services and to optimize our marketing efforts. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include name, address, and contact number in order to provide services and optimize marketing efforts.

Cookies, Web Beacons, IP Address Tracking and Other Technologies

We, Serenova, LLC and our partners use cookies or similar technologies for the following purposes:

> To analyze trends, statistics and patterns

> To help provide better customer service

> To better serve you when you re-visit a webpage

> To monitor the regions from which visitors navigate our web sites

> To provide you with advertising and direct marketing based upon your browsing activities and interests

Also, when we collect data, including personal data, from you in a transaction, we may extract some information about that transaction in a non-directly-identifiable format and combine it with other non-directly-identifiable information such as clickstream data. This information is used and analyzed only at an aggregate level to help us understand trends and patterns. This information is not reviewed at an individual level. If you do not want your transaction details used in this manner, you can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

> Passive Collection:

>> As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

Please note that our websites include Social Media Features, such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Data Integrity and Purpose Limitation

We do not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual. With respect to visitors to our web sites, we only collect information that we believe to be relevant to our business. With respect to data that we process on behalf of our customers, we only process personal information to the extent that such processing is necessary for us to provide our Services, and in accordance with our agreements with our customers. In all instances of data collection or receipt, we take reasonable steps to ensure that personal data we collect or receive from our customers is reliable for its intended use.

Disclosure to Third Parties

Unless you give us your permission, we will not disclose your information to third parties for any purpose other than what is disclosed in this privacy statement. TelStrat may share data with third parties only in the following limited circumstances:

TelStrat shares transaction data with third parties only in the following limited circumstances: (1) personal information may be accessible to third-party service providers processing data on behalf of Serenova; however, any such service providers are required by contract to implement privacy and security safeguards; (2) personal information may be disclosed to third parties as directed by the merchant customer which sent the information to Telstrat; (3) TelStrat may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; and (4) personal information may be provided to a third party to the extent TelStrat enters into a merger, or transaction for the acquisition of all or substantially all of TelStrat’s assets. You will be notified via a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

International Data Transfers

TelStrat may transfer EU personal data to the United States, Canada, El Salvador, Peru and other countries where our sub-processors are located. For transfers of personal data from the EU to Canada, TelStrat relies on the EU’s Article 45 designation of ‘adequacy’. For transfers of personal data from the EU to the United States, El Salvador, Peru or any other country, TelStrat complies with Articles 46 and 49 of the General Data Protection Regulation.

Data Subject Rights

Your data subject rights when we act as a data controller:

Upon request TelStrat will provide you with information about whether we hold any of your personal information. You have the right to correct (rectify) the record of your personal information maintained by TelStrat if it is inaccurate. You have the right to request the erasure of your personal information, subject to certain exceptions. You may also have the right to request that TelStrat ceases to use your personal data for the purpose of direct marketing. Where technically feasible, TelStrat will, at your request, provide your personal data to you or transmit it directly to another controller.

We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service. If you have concerns about the way TelStrat is processing your personal data, in some jurisdictions you have the right to lodge a complaint with the appropriate data protection authority.

Your data subject rights when we act as a data controller:

TelStrat acknowledges that you have the right to access your personal information. TelStrat has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the TelStrat Reseller or customer of the TelStrat Reseller (the data controller). If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Security

We have security measures in place to help protect against the loss, misuse or alteration of information that we have collected from you. TelStrat also utilizes electronic and physical security controls to reduce the risk of improper access to or manipulation of information during transmission and storage. When sensitive information is submitted we encrypt the transmission.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Customers of TelStrat are responsible for maintaining the security and confidentiality of their usernames and passwords. If you have any questions about the security of your personal information, you can contact us at the contact information below.

Data Retention

Your personal data is stored by TelStrat. TelStrat only retains the data for as long necessary based on the defined business purpose, and/or legal and compliance obligations. For more information on where and how long your personal data is stored, please contact privacy@serenova.com

Service Quality Monitoring

Certain transactions may also involve you contacting us, or TelStrat contacting you. Please be aware that it is TelStrat’s general practice to monitor and in some cases record calls for training or quality assurance purposes.

Promotional communications

If you would like to opt out of promotional materials from Telstrat, you may indicate this preference by selecting the unsubscribe instructions at the end of email communications or by contacting us here. Please note that if you opt out of messages from us, we may continue to send you account-related updates so as to continue to support your account.

SMS

If you have requested to receive SMS messages from TelStrat, you may discontinue service at any time by replying “STOP” to any message you receive or by texting “STOP” to the short code from your mobile device. You will not receive any additional messages.

Before Telstrat is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavor to respond within an appropriate timeframe.

Children

Our services are not intended for or to attract children. Accordingly, we do not solicit nor knowingly collect any personal information from children under the age of thirteen (13). If we learn that personal information is, has been submitted by, or collected from a child under the age of thirteen (13), we will immediately delete such information.

Enforcement

TelStrat performs ongoing monitoring of privacy and security controls to validate compliance with applicable laws and regulations.

Amendments to Privacy Policy

TelStrat reserves the right to change this Privacy Policy. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Site (www.TelStrat.com) prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. You can check the “Effective Date” posted at the top to see when the Privacy Policy was last updated. By accessing or using our Services after we have placed such a notice, you consent to the new practice(s) identified in the update.

CONTACT FOR QUESTIONS

Any questions, comments or concerns about how we handle your personal information, you may contact us at: privacy@serenova.com or as follows:

Serenova, LLC
attn: Legal/Privacy Compliance
Global HQ
7300 Ranch Road 2222
Building III, Suite 200
Austin, TX 78730

To Contact TelStrat’s Data Protection Officer, please contact DPO@serenova.com