Introduction

Affiliated Technology Solutions LLC and its subsidiaries and other affiliates (“ats”) recognizes and supports the privacy rights of all persons, and we respect these rights when we collect and process personal information (“PI”). We have developed and adopted this Privacy Policy to describe our privacy values and guide our processing of personal information. By purchasing, subscribing to, or utilizing the Products and/or Services, or registering to attend, attending and/or participating in any ats sponsored events or other events in which ats participates, you agree to be bound to the terms and conditions of this Privacy Policy.

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The obligations and responsibilities set out in this Privacy Policy are applicable to ats and its personnel and will be made available on ats’ website. The obligations and responsibilities set out in the Privacy Policy are in addition to any other applicable policies or agreements entered into with ats and any applicable laws and/or regulations.

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General Statement

ats is dedicated to the use of Voice over Internet Protocol (VoIP) and related technologies to improve the telecommunications industry and the lives of individuals throughout the world.

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ats’ goal is to deliver carrier-grade communications services to all its Clients, at a reasonable price and to make available all the benefits that VoIP offers as broadly as possible. In order to achieve this goal, a Privacy Policy is necessary.

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Scope

At ats, privacy matters.  ats respects the privacy of its Clients and other individuals with whom ats has business interactions

This policy is global, applying to all ats locations. It applies to personal information regardless of format.  For example, the policy applies to computerized records and electronic information as well as paper-based files.

It is also applicable to all personal information that is collected, maintained or processed by ats. The concepts enumerated in this policy will guide ats’ selection and expectations of its Clients, partners, agents and/or contractors to whom ats transfers and relies on for processing of personal information.

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ats provides the technology platform for hosted or “cloud” unified communications as a service offerings (UCaaS). These Products merely act as a conduit for data transmitted by third parties and Subscribers.  ats processes personal information that is controlled by or originated from other companies, such as our Clients or other business partners. ats also processes personal information in the course of providing support for ats communications products. ats shall protect the personal information, comply with all laws that regulate the processing of such personal information, and process the information only as authorized by the data controller or the data subject. Accordingly, ats relies on guidance and direction of the Client (as the data controller), who determines the purposes of processing such personal information.  In some cases, ats may collect and process personal information for our own business purposes and shall comply with the applicable privacy laws concerning ats processing.

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While ats does process data in its role of providing a technology platform, it does not own, control or direct the use of any of the personal information stored or processed by any Client or Subscriber.  ats only processes such personal information in order to provide and invoice for purchased and/or subscribed Products and Services.

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Data Processor

ats provides the technology platform for hosted or “cloud” unified communications as a service offerings (UCaaS). These Products merely act as a conduit for data transmitted by third parties and Subscribers. ats processes personal information that is controlled by or originated from other companies, such as our Clients or other business partners. ats also processes personal information in the course of providing support for ats communications products.

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ats shall protect the personal information, comply with all laws that regulate the processing of such personal information, and process the information only as authorized by the data controller or the data subject. Accordingly, and in its role as a data processor, ats relies on guidance and direction of the Client (as the data controller), who determines the purposes of processing such personal information. In some cases, ats may collect and process personal information for our own business purposes and shall comply with the applicable privacy laws concerning ats processing.

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While ats does process data in its role of providing a technology platform, it does not own, control or direct the use of any of the personal information stored or processed by any Client or Subscriber. ats only processes such personal information in order to provide and invoice for purchased and/or subscribed Products and Services.

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What Information We Collect or Process

ats processes and in certain situations collects personal information as needed to deliver its Products and Services and manage its business.  When collecting personal information, ats does so in a reasonable and lawful manner.

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The types of information and the purposes for which ats collects or processes personal information may include:

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CLIENTS

ats uses such personal information only for relevant, appropriate, and customary purposes. ats will not share or disclose personal information for purposes other than as described herein. Capitalized terms used in this Privacy Policy shall have the meaning as given in Client’s Master Services Agreement (MSA). The following are examples of some of the personal information ats may process.

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Business Contact Information

ats may collect and use personal information about individual contacts of Clients and others who access ats public websites, knowledge bases, forums, ticket systems, or provide personal information through other means. Such information may include but is not limited to account information, first/last name, company name, title, and responsibilities, work email address, work mailing address, telephone numbers, login information, device identifiers, as well as additional information provided by such individuals in the course of receiving Products and Services from ats and/or requesting information about ats. We will use such information for the purposes of providing Products and Services, support, conducting data analytics and product assessments and related activities, and providing information regarding ats Products and Services.

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Customer Proprietary Network Information (CPNI):

Customer Proprietary Network Information (CPNI) may include information regarding quantity, destination, technical configuration, location, amount of use and related billing information of telecommunications, interconnected and/or non-interconnected Voice over Internet Protocol (VoIP) services. This may include but is not limited to the phone numbers that you call or send messages to (or the phone numbers that you receive these calls and messages from) through our Products and Services. The date, time and duration of the calls may also be collected. This data is used for billing and service level assurance.

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ats provides Products and Services that are primarily for the benefit of Clients and Subscribers in that ats transmits, routes, switches or caches information. These Products and Services merely act as a conduit for data transmitted by third parties and Subscribers. ats does not determine the purposes and means of processing this personal information. Except for Subscriber data provided by the Client (the Subscribers service provider) for which ats is merely providing a conduit for transmission, the subscribed services are of such a nature that, in most instances, ats requires and collects only essential CPNI and billing information; and opting out or declining to provide the requested data may hinder the provision or delivery of subscribed services. However, for CPNI data that is collected by ats that is not subject to the control of others, ats shall obtain consent from the user for the processing of this data.

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ats collects end-user CPNI in the course of providing Product support. This data may pertain to Clients of ats or Subscribers (eg: end users of ats’ direct Clients). This data may include IP address, telephone number, email address, call detail records, call recordings and other information sufficient to identify an individual end user.

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Indirect End User’s CPNI:

ats acts as a data processor with regard to indirect end user personal information and our Clients act as the data controller of such data. In the course of ats’ processing and protection of such data, all use will be in conformity with the data controller’s instructions.

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Direct End User’s CPNI:

ats typically collects and processes direct end user (eg: Clients, vendors, and partners) personal information for the purposes of providing Products and Services, support, conducting data analytics and managing product performance.

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Messaging, Voicemail, Video and Media Files:

ats provides Products and Services that facilitate the recording and storage of audio and video by way of features such as but not limited to voicemail, call and conference recording.  Users may elect to store or record personal information within these resources at their discretion.

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Anonymized, Non-Identifying Voice and Traffic Data ats may use anonymized, non-identifying data collected from use of our SNAPsolution, SNAPvantage and other ats Products and Services. This anonymized, non-identifying data may be used to enhance such items, but is not limited to, voice activation, improve traffic analysis algorithms and techniques, and recognition algorithms. This processing is executed under applicable terms and supports ats’ legitimate interests in tuning, maintaining and enhancing these Products and Services.

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Cookies

ats websites may use cookies to collect certain kinds of personal information about Subscribers or users. For more information on how ats uses cookies and choices available to Subscribers and users please refer to the following section.

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How We Collect Information

We collect information in various ways, including the following:

When you use one of our Products or Services, ats collects, and stores certain information that you provide directly. We also collect information about your use of the Products and Services.

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Cookies and Similar Collection Methods

ats also collects technical information about your usage of the Products and Services, and we use various technologies to collect information about cookies, IP addresses, device type and device identifiers, application state and the date and time of activity with our Products and Services, and other similar information. ats may associate this information with your user identification and/or account number for our internal use.

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Other Passive Site Tracking

Websites may also utilize Internet Protocol (IP) addresses and log files to identify network and server concerns and problems. ats also utilizes web beacons and other passive tracking mechanisms to perform standard website traffic analysis in a similar manner to how we utilize cookies.

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Credit Card Information

ats only collects credit card information in order to bill for purchased or subscribed to Products and Services. ats utilizes third-party credit card payment processing agents (where these agents are required to implement reasonable and appropriate measures to protect and secure this information from loss or misuse) solely for the purpose of processing payments for those Products and Services purchased or subscribed to. These payment processors use of your personal information is governed by their privacy policies, as well as adhering to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like American Express, Visa, Mastercard, and Discover.

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HOW DOES ats UTILIZE COOKIES

General Information about Cookies

A cookie (also known as an HTTP cookie, web cookie, or browser cookie) is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. Cookies were designed to be a reliable mechanism for websites to remember useful information (such as items in a shopping cart) or to record the user’s browsing activity (including clicking particular or specific buttons, logging in or recording which pages were visited by the user as far back as months or years ago).

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Utilization of Cookies

A visit to a page on www.affiliatedtech.com (or other ats website) may generate the following types of cookie(s):

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Anonymous Analytics Cookies

Every time a user visits a ats website, software provided by another organization (such as Google Analytics) generates an ‘anonymous analytics cookie’. These cookies can tell us whether you have visited the site before. Your browser will inform us if you have these cookies and, if you don’t, our website generates new ones. This allows ats to track how many individual users we have and how often they visit the site. Unless you are signed in to affiliatedtech.com (or any other ats website), we cannot use these cookies to identify individuals. We use these cookies to gather statistics: for example, the number of visits to a page. If you are logged in to the ats website, we will also be provided the details you gave to us for this, such as but not limited to your username and email address.

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Registration Cookies

When you register with a ats website, such as affiliatedtech.com, ats generates cookies that inform us whether you are signed in or not. Our servers use these cookies to determine which account you are signed in with and whether you are allowed access to a particular Product or Service.

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Advertising (Ad) Cookies

These cookies allow ats to know whether you’ve seen a specific ad or the type of ad, and for how long you have viewed it.  We also utilize cookies to help us direct targeted advertising.

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Other Third-Party Cookies

On some pages of our websites, other organizations may also set their own anonymous cookies. They do this to track the success of their products and/or services, or to customize the experience for you. Because of how cookies function, our websites cannot access these Third-Party cookies, nor can the other organization access the data in cookies ats uses on our websites.  For example, when you share an article or post using a social media sharing button (Facebook, LinkedIn or other social media outlets) on affiliatedtech.com, the social network that has created the button will record that you have done this.

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Changes to Our Privacy Policy

ats reserves the right to change this Privacy Policy at our discretion subject to business or legal requirements. You are advised to review and check this Privacy Policy from time to time and particularly before you provide personal information to ats. Changes to this Privacy Policy are effective when they are posted on this page. By continuing to use our Products and/or Services you are agreeing to be bound by any changes or revisions made to this privacy policy.

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Contacting Us

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please write to ats at the following address:

Affiliated Technology Solutions LLC
777 New Durham Rd

Edison, NJ 08817