Toly Digital Networks
Privacy Policy
Effective: July 15, 2024
Introduction
Toly Digital Networks, Inc, and its subsidiaries and affiliates (“Toly Digital Networks”) are committed to protecting the privacy rights of all individuals. 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 Toly Digital Networks sponsored events or other events in which Toly Digital Networks participates, you agree to be bound to the terms and conditions of this Privacy Policy.
The obligations and responsibilities set out in this Privacy Policy are applicable to Toly Digital Networks and its personnel and will be made available on Toly Digital Networks’ website (www.tolydigital.net). The obligations and responsibilities set out in the Privacy Policy are in addition to any other applicable policies or agreements entered into with Toly Digital Networks and any applicable laws and/or regulations.
General Statement
Toly Digital Networks 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.
Toly Digital Networks’ 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.
Scope
At Toly Digital Networks, privacy matters. Toly Digital Networks respects the privacy of its Clients and other individuals with whom Toly Digital Networks has business interactions
This policy is global, applying to all Toly Digital Networks 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 Toly Digital Networks. The concepts enumerated in this policy will guide Toly Digital Networks’ selection and expectations of its Clients, partners, agents and/or contractors to whom Toly Digital Networks transfers and relies on for processing of personal information.
Toly Digital Networks 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. Toly Digital Networks processes personal information that is controlled by or originated from other companies, such as our Clients or other business partners. Toly Digital Networks also processes personal information in the course of providing support for Toly Digital Networks communications products. Toly Digital Networks 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, Toly Digital Networks relies on guidance and direction of the Client (as the data controller), who determines the purposes of processing such personal information. In some cases, Toly Digital Networks may collect and process personal information for our own business purposes and shall comply with the applicable privacy laws concerning Toly Digital Networks processing.
While Toly Digital Networks 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. Toly Digital Networks only processes such personal information in order to provide and invoice for purchased and/or subscribed Products and Services.
Data Processor
Toly Digital Networks 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. Toly Digital Networks processes personal information that is controlled by or originated from other companies, such as our Clients or other business partners. Toly Digital Networks also processes personal information in the course of providing support for Toly Digital Networks communications products.
Toly Digital Networks 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, Toly Digital Networks relies on guidance and direction of the Client (as the data controller), who determines the purposes of processing such personal information. In some cases, Toly Digital Networks may collect and process personal information for our own business purposes and shall comply with the applicable privacy laws concerning Toly Digital Networks processing.
While Toly Digital Networks 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. Toly Digital Networks only processes such personal information in order to provide and invoice for purchased and/or subscribed Products and Services.
What Information We Collect or Process
Toly Digital Networks processes and in certain situations collects personal information as needed to deliver its Products and Services and manage its business. When collecting personal information, Toly Digital Networks does so in a reasonable and lawful manner.
The types of information and the purposes for which Toly Digital Networks collects or processes personal information may include:
Privacy Policy for Toly Digital/VoIPiTalk Android and iOS Apps
- Information Collection and Use:
- Contact List Name and Phone Numbers: Our app accesses the contact list on your device, specifically the names and phone numbers, only when you have enabled this feature via system permission. This data is used to display personal contacts within the application.
- Contact List Email Addresses: Our app uses Gravatar to retrieve avatar images linked to the MD5 hash of your contact’s email address, but only when enabled via Settings and UIConfigs.
- Data Handling and Sharing:
- Phone Contacts:
- When you send an SMS message or initiate a call to one of your phone contacts, the phone number is sent securely through Toly Digital Networks’ API to our server to complete the call.
- We do not store phone numbers with any other personal identifiable information (PII), and these numbers cannot be directly or indirectly attributed to any person or persons.
- We store only the phone number and pertinent metadata (Call Data Record) to comply with applicable state and federal laws.
- We do not share this data with any advertisers or third parties under any circumstances.
- Gravatar:
- When Gravatar use is enabled, we hash each contact’s email address and send the MD5 hash to Gravatar to retrieve an avatar image.
- MD5 hashes cannot be directly or indirectly attributed to any person or persons, and we never send the email address in plain text.
- Phone Contacts:
- User Rights and Control:
- Revoking Access:
- You can revoke phone contact access on your mobile device at any time, and your app experience will not be hindered or interrupted.
- Similarly, you can revoke Gravatar access at any time in Settings or via UIConfig, and your app experience will remain unaffected.
- Revoking Access:
- Transparency and Compliance:
- Data Processing Role:
- Toly Digital Networks acts as a data processor with regard to indirect end user personal identifiable information, while our Clients act as the data controller of such data.
- All data processing and protection by Toly Digital Networks will conform to the data controller’s instructions.
- Policy Changes:
- We may update this privacy policy from time to time. Users will be notified of any significant changes through appropriate channels.
- Data Processing Role:
Clients
Toly Digital Networks uses such personal information only for relevant, appropriate, and customary purposes. Toly Digital Networks 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 Toly Digital Networks may process.
Business Contact Information:
Toly Digital Networks may collect and use personal information about individual contacts of Clients and others who access Toly Digital Networks 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 Toly Digital Networks and/or requesting information about Toly Digital Networks. 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 Toly Digital Networks Products and Services.
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.
Toly Digital Networks provides Products and Services that are primarily for the benefit of Clients and Subscribers in that Toly Digital Networks transmits, routes, switches or caches information. These Products and Services merely act as a conduit for data transmitted by third parties and Subscribers. Toly Digital Networks 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 Toly Digital Networks is merely providing a conduit for transmission, the subscribed services are of such a nature that, in most instances, Toly Digital Networks 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 Toly Digital Networks that is not subject to the control of others, Toly Digital Networks shall obtain consent from the user for the processing of this data.
Toly Digital Networks collects end-user CPNI in the course of providing Product support. This data may pertain to Clients of Toly Digital Networks or Subscribers (eg: end users of Toly Digital Networks’ 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.
Indirect End User’s CPNI:
Toly Digital Networks 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 Toly Digital Networks’ processing and protection of such data, all use will be in conformity with the data controller’s instructions.
Direct End User’s CPNI:
Toly Digital Networks 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.
Messaging, Voicemail, Video and Media Files:
Toly Digital Networks 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.
Anonymized, Non-Identifying Voice and Traffic Data
Toly Digital Networks may use anonymized, non-identifying data collected from use of our Toly Digital Networks 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 Toly Digital Networks’ legitimate interests in tuning, maintaining and enhancing these Products and Services.
Cookies
Toly Digital Networks websites may use cookies to collect certain kinds of personal information about Subscribers or users. For more information on how Toly Digital Networks uses cookies and choices available to Subscribers and users please refer to the following section.
How We Collect Information
When you use one of our Products or Services, Toly Digital Networks collects, and stores certain information that you provide directly. We also collect information about your use of the Products and Services.
We collect information in various ways, including the following:
Cookies and Similar Collection Methods
Toly Digital Networks 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. Toly Digital Networks may associate this information with your user identification and/or account number for our internal use.
Other Passive Site Tracking
Websites may also utilize Internet Protocol (IP) addresses and log files to identify network and server concerns and problems. Toly Digital Networks also utilizes web beacons and other passive tracking mechanisms to perform standard website traffic analysis in a similar manner to how we utilize cookies.
Credit Card Information
Toly Digital Networks does not directly collect or store credit card information. Toly Digital Networks 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.
How Does Toly Digital Networks 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).
Utilization of Cookies
A visit to a page on www.tolydigital.net (or other Toly Digital Networks website) may generate the following types of cookie(s):
Anonymous Analytics Cookies
Every time a user visits a Toly Digital Networks 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 Toly Digital Networks to track how many individual users we have and how often they visit the site. Unless you are signed in to www.tolydigital.net (or any other Toly Digital Networks 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 Toly Digital Networks 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.
Registration Cookies
When you register with a Toly Digital Networks website, such as www.tolydigital.net, Toly Digital Networks 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.
Advertising (Ad) Cookies
When utilized, these cookies allow Toly Digital Networks to know whether you’ve seen a specific ad or the type of ad, and for how long you have viewed it. These cookies also help us direct targeted advertising.
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 Toly Digital Networks 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 www.tolydigital.net, the social network that has created the button will record that you have done this.
How Do I Turn Cookies Off
It is usually possible to stop your browser accepting cookies, or to stop it accepting cookies from a specific website. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘options’ or ‘preferences’ menu of your browser. To understand these settings, you can use the ‘Help’ option in your browser for more details. It is solely your responsibility to stop cookies in your browser.
Note: If you block the use of cookies, then this will limit the service that we are able to provide to you and may affect your visitor/user experience.
VENDORS, SUPPLIERS AND SUBCONTRACTORS
Toly Digital Networks may collect personal information about individuals who are employed by our suppliers and vendors. This business contact and payment information are strictly used to administer existing and future business arrangements.
OTHERS
Additional personal information may be collected, processed and disclosed for the purposes for which it was collected and for legal compliance purposes, including regulatory reporting, investigation of allegations of wrongdoing, and the management and defense of legal claims and actions, and compliance with subpoenas, court orders, and other legal obligations. For example, we may collect information about individuals that visit our office or other facilities. When we do collect data, such collection shall be relevant, proportionate and limited to the purposes for which they are processed.
International Cross-Border Personal Information Transfers
Toly Digital Networks is a U.S.-based company. If you are visiting our Website(s) from the EEA or other regions with laws governing data collection and use, please note that by providing this personal information you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which Toly Digital Networks operates in accordance with this Privacy Policy.
How We Use the Information We Collect
We use your information primarily and as necessary to provide you with the various Toly Digital Networks Products and Services, including but not limited to one or more of the following ways: to create your accounts and allow use of our Products, to provide technical support and respond to Client inquiries, to prevent fraud or potentially illegal activities, enforce our other agreements with you, to notify Clients of application updates, and to inform Clients about new products or promotional offers.
SENSITIVE INFORMATION
Toly Digital Networks recognizes that for some sensitive information, affirmative express consent from individuals is required and must be obtained if such information is to be (i) disclosed to a third party or (ii) processed for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice. In addition, Toly Digital Networks shall treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.
Sharing Your Information
We may disclose or report information that individually identifies Clients, Subscribers or devices in certain circumstances, such as:
(i) if we have a good faith belief that we are required to disclose the information in response to a valid legal process (for example, a court order, search warrant or subpoena, or to defend or respond to legal actions, and as otherwise authorized by law, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements); (ii) to satisfy applicable laws, (iii) if we believe that the Products and Services are being used in an unauthorized, unlawful or abusive manner, such as to commit a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction, (iv) if we have a good faith belief that there is an emergency that poses a threat to the health or safety of a person or the general public, (v) in order to protect the rights or property of Toly Digital Networks, including enforcement of our Intellectual Property Rights and terms of the Agreement(s), and (vi) for all other purposes with your consent. We may also provide your information to third party companies to perform services on our behalf, including but not limited to payment processing, data analysis, message delivery, hosting services, customer service, and marketing.
If Toly Digital Networks enters into a merger, acquisition or sale of all or a portion of its assets or business, Client and Subscriber information, including personal information, will also be transferred as part of or in connection with the transaction as per applicable law.
INFORMATION DISCLOSURE
Internal Disclosure
In general, personal information may be shared within Toly Digital Networks, where legally permitted for reasonable and appropriate corporate purposes. However, even within Toly Digital Networks, we restrict access to personal information to those employees, agents, or contractors who need access to carry out their assigned functions.
External Disclosure
Toly Digital Networks uses vendors and partners for a variety of business purposes, such as to help us develop, deploy and invoice for the various Products and Services we provide. We share information with those vendors and partners when it is necessary for them to perform work on our behalf. Toly Digital Networks requires that these vendors and partners protect the customer information we provide to them and limit their use of such information to their respective processing activity. Toly Digital Networks will only transfer or provide direct access to personal information covered by this policy to third parties that have made a commitment to respect the privacy rights of the data subject; limit processing of personal information to comply with data controller instructions; and provided Toly Digital Networks contractual assurances that they will provide at least the same level of privacy protection as is required by applicable privacy laws.
Security of Your Information
We implement security measures we believe are reasonable to protect your information. It is important that you protect and maintain the security of your account and you need to immediately notify us of any unauthorized use of your account. Remember, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot and do not guarantee its absolute security.
Protecting Personal Information
To help protect the confidentiality of personal information, Toly Digital Networks employs security safeguards appropriate to the sensitivity of the information and in accordance with this Privacy Policy. These safeguards include reasonable administrative, technical and physical measures to safeguard the confidentiality and security of personal information against anticipated threats and unauthorized access to personal information. No transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. Additionally, we convey safeguard obligations to our agents who receive personal information from or on behalf of Toly Digital Networks in the course of their relationship with our organization as described above in the section titled External Disclosure.
Transfer of Data
Your information, including personal information, may be transferred to, and maintained on, computers, servers or other data storage located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you reside outside the United States and choose to provide information to Toly Digital Networks, please note that we transfer the data, including personal information, to the United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Retention of Data
Personal information collected by Toly Digital Networks will be retained for as long as necessary and legally permitted for the purposes for which it was collected, to provide you with Products and Services, enforce our legal agreements and policies and to conduct our legitimate business interests or where otherwise required by law.
Data Integrity
Toly Digital Networks employs reasonable means to keep personal information accurate, complete, and current, as needed for the purposes for which it was collected.
How to Access and Update Your Information
We generally provide individuals with an opportunity to examine their own personal information, confirm the accuracy and completeness of their personal information, and have their personal information updated, if appropriate.
The ability of an individual to access his or her personal information is not unlimited, however. An individual’s ability to access personal information may be limited, for example, where (i) the burden or expense of providing access would be unreasonable or disproportionate to the risks to the individual’s privacy, (ii) the information should not be disclosed due to legal or security reasons or to protect confidential commercial information; or (iii) providing access would compromise the privacy of another person.
If you have created a user profile on a portal, you may also access and revise the personal information in your user profile when you log into your account.
Individuals who wish to access or update their personal information not accessible via a portal should direct such communications to Toly Digital Networks Support at:
Third-Party Websites, Plugins or Widgets
Toly Digital Networks websites, Products and/or Services may include social network or other third-party plugins and widgets not operated by us. Accessing these links to other sites is done at your own option and is not part of any Toly Digital Networks’ offerings. Toly Digital Networks has no control over and assumes no responsibility for the content, privacy policies or practices of any third-party sites or services. We strongly advise you to review each privacy policy provided at the respective site.
Health Insurance Portability and Accountability Act
Our products and services are not designed to comply with HIPAA requirements unless explicitly stated. Clients are responsible for ensuring HIPAA compliance when using our products.
California Privacy Rights
California residents can request details on PI disclosed to third parties for marketing purposes and request the removal of publicly posted information.
Changes to Our Privacy Policy
Toly Digital Networks 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 Toly Digital Networks. 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.
Contacting Us
For questions or concerns about our Privacy Policy, email support@voipitalk.com or write to us at:
Toly Digital Networks, Inc.
1005 W Indiantown Rd, Suite 201,
Jupiter, FL 33458
