Kaleyra Privacy Policy
Foreword
We at Kaleyra are committed to protecting the information that you share with us and explaining how we collect, process, and share that information online. When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and entrust to keep it secure.
We provide you with insight into the privacy practices employed here at Kaleyra.
This Privacy Policy is meant to help you understand the following:
- What information we collect,
- How we collect,
- Why we collect it,
- How we keep it secure, and
- How you can update, manage, export, and delete your information.
Background
This Policy provides an overview of how at Kaleyra information of “data subjects” (hereinafter referred to as “You or your”) personal data are collected, how they’re handled, and how your privacy is protected. In this policy, “we”, “us” and “our” may refer to Kaleyra Inc. or its subsidiaries and affiliates.
End Users of Kaleyra’s Products and Services
Kaleyra is a market leader in providing innovative Global Communication Services. In this capacity, Kaleyra may obtain and process on behalf of its prospects, customers (collectively hereinafter referred to as “Users“) certain personal information about its Users’ employees, representatives, consultants, contractors, agents, or other end users who are authorized to use its services (“End User Data“). If you are an employee or other end user of a User, please contact your employer with any questions about how your End-User
Data is collected and processed, or to seek clarification or exercise any rights you may be offered under data protection laws in your jurisdiction.
Kaleyra, with regard to personal data, might act both as a data controller as well as a data processor or agent that processes End User Data on behalf of its User, which is the controller or owner of such data under applicable data protection laws.
As such, in the latter, Kaleyra assists its Users to address data protection inquiries from end users to the extent applicable to its services but typically does not respond directly to such inquiries from end-users.
Kaleyra is also a data controller in certain cases where there is an express agreement between Kaleyra and the client or maybe a controller in certain circumstances where there is a written consent from the client based on business necessities and exigencies. Further, Kaleyra is also a data controller to the extent of its customers’ data which it obtains and processes directly, through lead-generation platforms where the customer would have given their express consent, social media platforms where the customer could have contacted or email referrals from existing clients, tradeshows where the customer would have visited and shared their contact information with Kaleyra.
As we serve you, we want you to understand the types of information we collect.
Particular areas of the world now require different privacy disclosures, so kindly go through the entire policy to make sure you understand our practices fully. Accordingly, to be in compliance with the requirements of the General Data Protection Regulation (hereinafter “GDPR”) of the European Union (EU), we have updated our privacy policy. We would recommend you to go through our policy document, thereby ensuring transparency of our process of collecting your personally identifiable information (hereinafter “PII”).
Kaleyra has appointed a Data Protection Officer (DPO) whose appointment is mandated as a compliance of Regulation (EU) 2016/679, which obliges some organizations in EU countries to appoint a DPO, applicable as of 25 May 2018. DPO shall be the authorized controller of your data provided to us, whose primary role is to ensure that the organization legitimately processes the personal data of its staff, customers, providers, or any other individuals (also referred to as data subjects).
We build a range of services that you would find it on our website, and in order to achieve this we collect personal data from you in a number of ways including:
- Applications
- Web Forms
- Off-site services
- Others
- Contractual Commitments
We provide products and services that allow our customers and Users to capture, process, store, and transmit audial and visual content including real-time recordings of on-line and in-person communications (the “audiovisual content”). We do not determine how customers and Users operate those products and services, and the responsibility for complying with applicable laws and regulations and communicating with and obtaining consents from those whose communications are captured and processed is on the customers and Users. You should consult the privacy policies and other disclosures made by the customers and Users to see how they process and protect the audiovisual content. Our services may include storing and processing audiovisual content on behalf of customers and Users, but we only do so as necessary to operate and improve our services and only as directed by our customers and Users.
If you are located in the United States
Privacy Notice
Last modified: June 1, 2023
Introduction
Kaleyra and its subsidiaries and Affiliates (“Company” or “We”) respect your privacy and is committed to protecting it through our compliance with internal policies. Please read this notice carefully to understand our policies and practices regarding your information and how we will treat it.
This notice describes the types of information we may collect from you or that you may provide when you visit this website, mobile sites or mobile applications (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
We use your information to provide our services, contact you and provide customer service, to detect and remediate violations of our Terms of Use or other misuse of our Website, to develop and improve our products and services and for internal operational purposes.
By accessing or using our Website, you agree to our Terms or Use and other relevant policies and practices. This notice may change from time to time. Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check our Website periodically for updates.
This Privacy Notice describes the categories of personal information and/or sensitive personal information we may collect, how we collect that information, the business purposes for which we generally use such information, and which types of third-party service providers we may share that information with.
Mobile User Information
As part of Kaleyra’s services, we may receive information from wireless carriers, operators, or our clients, such as an end user’s mobile phone number. In some limited instances, additional information such as a user’s geographic location, a personal identification number (PIN), or a mailing address is also provided. Additionally, we process message content from our clients which may contain personal information on behalf of a mobile end user. Kaleyra does not create this content nor is it responsible for the content sent or received by our clients or any end user; we are simply the passive conduit through which the content is sent. Regardless, our agreements with our clients ensure that the client has the ultimate responsibility to obtain any and all required “opt-ins” or other consent(s) from end users prior to such information being sent. Any mobile user information collected pursuant to the above is governed by this Notice as well as Kaleyra’s internal policies regarding confidential and personally identifiable information. We also include specific provisions in the contracts with our clients to ensure that responsibility for compliance-related obligations and message content is within their control. If you have questions or would like more information, please contact cis-privacy@tatacommunications.com.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information:
- By which you may be personally identified, such as name, email address, telephone number, employment details, business telephone number and/or email address, and any other identifier by which you may be contacted online or offline (“Personal Information“);
- Text message content (“Sensitive Personal Information”);
- About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
- Directly from you when you provide it to us
- Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies
This information helps us improve our Website by enabling us to:
- Estimate our audience size and usage patterns,
- Speed up your searches,
- Improve our website to provide content in the most efficient and effective way,
- Recognize you when you return to our Website.
The technologies we use for this data collection may include:
Cookies (or browser cookies). You have several options to manage cookies and trackers. If you don’t want our Website to collect information using these technologies, you can change your web browser settings to reject cookies from the site. However, please note that we always seek your consent before placing cookies on your computer. Also note that cookie and tracker-based opt-outs only apply to the specific computer and browser on which the opt-out cookie is applied. If you clear cookies from your device or switch to a different browser, your opt-out will no longer be valid and you will need to opt-out again where you want your choices to apply. If you accept cookies or tracker, you can delete it at any time through your web browser. If you choose not to accept cookies or trackers used for analytics and site functionality, you will not be able to enjoy all the features available to our registered users. See additional information about Cookies in our Privacy Policy located here: https://www.kaleyra.com/privacy-policy-kaleyra/ . And our Cookie Policy located here: https://www.kaleyra.com/cookie/
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information or sensitive personal information:
- To present our Website and its contents to you
- To provide you with information, products, or services that you request from us
- To fulfill any other purpose for which you provide it
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
- To notify you about changes to our Website or any products or services we offer or provide though it
- For any other purpose with your consent
Disclosure of Your Information
We may disclose aggregated information about our users without restriction.
We may disclose personal information/sensitive personal information that we collect or you provide to us to the following:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Kaleyra’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Kaleyra about our Website users is among the assets transferred. In those cases, the new company’s use of your information will still be subject to this Notice and the privacy preferences you have expressed to us.
- To fulfill the purpose for which you provide it.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Kaleyra, our customers, or others.
Choices About How We Use and Disclose Your Information
We do not sell, license or share the personal information we collect with unaffiliated third parties for their marketing purposes. We may share personal information/sensitive personal information in the following situations:
Service Providers
We sometimes use third-party service providers to help provide our services. Our service providers may receive your name and contact information, messaging or other similar content, cookies and other device identifiers, IP address, and website browsing and interaction activity. These service providers are only allowed to use your information in connection with the specific service they provide on our behalf.
Affiliates and Subsidiaries
We may share your information among our corporate affiliates and subsidiaries for purposes described in this Notice. This allows us to seamlessly offer our various features to you.
Law Enforcement, Mergers, and Other Situations
We may be required to share your personal information and/or sensitive personal information in other, limited circumstances. For example, we may be required to share certain information to respond to a subpoena or similar judicial process, to comply with state, federal or local laws, to protect the security or integrity of our databases or website, to take precautions against liability, in the event of a corporate reorganization or, to the extent required by law, to provide information to law enforcement agencies. If necessary, we may also share information with law enforcement without a subpoena or similar judicial process if doing so may help protect the personal safety of a customer or members of the public. We reserve the right to report to the appropriate law enforcement or government agencies any information that we believe may be evidence of criminal activity or violation of any applicable law.
Accessing and Correcting Your Information
You can review and change your personal information by logging into our Website(s) and visiting your account profile page.
You may also send us an email at cis-privacy@tatacommunications.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to delete and/or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
How Long do We Retain Personal Information/Sensitive Personal Information:
Kaleyra will retain your information only for as long as is necessary for the purposes set out in this Notice, for as long as your account is active (i.e., for the lifetime of your user account), or as needed to provide our Website and associated services to you, as specified in our internal record retention policy and/or as required by applicable law.
Options to Limit the Collection and/or Use of Personal Information/Sensitive Personal Information
You have choices about how your information is collected and used. You can notify us of your preferences when you create an account with us, and if you would like to review, correct or delete your personal information on our Website(s), you can do so via your account settings or cookie settings. There may be times when we are unable to fulfill your request – for example, if providing access to your personal information would reveal confidential commercial or proprietary information or personal information about someone else (and we cannot separate your data), if we are prohibited by law from disclosing the information, or if we have a legal obligation to retain certain data. We may require additional personal information from you for the purposes of verifying your identity and rights.
Opting out of Marketing Communications
If you no longer want to receive marketing communications from us, you can unsubscribe by following instructions contained in the messages you receive or by changing your marketing preferences through your account settings. We reserve the right to send you certain communications relating to the services we provide, such as service announcements and administrative messages. We do not offer you the ability to opt-out of receiving those communications.
To exercise any of these rights please visit: https://mail.kaleyra.com/hs/manage-preferences/unsubscribe-simple?utm_source=Website-Privacy-Notice
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) credentials for access to certain parts of our Website, you are responsible for keeping these credentials confidential. We ask you not to share your credentials with anyone.
The transmission of information via the internet is not completely secure. Although we do our best to protect your personal information and/or sensitive personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information and/or sensitive personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Your State Privacy Rights
Specific states within the United States may provide their residents with additional rights regarding our use of their personal information. To learn more about consumer privacy rights in other states and how to exercise them, visit:
California: https://cppa.ca.gov/regulations
Colorado: https://leg.colorado.gov/bills/sb21-190
Connecticut: https://www.cga.ct.gov/asp/cgabillstatus/cgabillstatus.asp?selBillType=Bill&bill_num=SB00006&which_year=2022
Indiana: https://legiscan.com/IN/text/SB0005/id/2779850
Iowa: https://www.legis.iowa.gov/legislation/BillBook?ga=90&ba=SF%20262
Tennessee: https://legiscan.com/TN/text/HB1181/id/2672877
Utah: https://le.utah.gov/~2022/bills/static/SB0227.html
Virginia: https://law.lis.virginia.gov/vacodefull/title59.1/chapter53/
Your Global Privacy Rights
See additional information in our Privacy Policy here: https://www.kaleyra.com/privacy-policy-kaleyra.
Statement of Compliance with Privacy Shield
Kaleyra complies with the US-EU Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of Personal Information from you (customer, employees and prospective employees) in the European Union member countries. Kaleyra has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this Policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern.
Children Under the Age of Thirteen (13)
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to, or on, the Website. We do not knowingly collect personal information or sensitive personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, if applicable, make any purchases through the Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at cis-privacy@tatacommunications.com.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at: cis-privacy@tatacommunications.com.
or via our toll-free number: 1-877-238-3637
Notice at Collection for California Employees and Applicants
Kaleyra Inc., (“Kaleyra”) and its affiliates and/or subsidiaries collect and may use your personal information, including sensitive personal information, for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance with applicable law, and for the business purposes listed in the chart below.
Please read this Notice at Collection for California Employees and Applicants (“Notice”) to learn how we collect and process your personal information when you are employed by Kaleyra, engaged to provide services to Kaleyra or apply for a job with Kaleyra. Under the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq. and its implementing regulations (the “CCPA”), as modified by the California Privacy Rights Act (the “CPRA”), you have the right to know and understand the categories of personal information we collect about you, and the purposes for which we use such personal information. Certain terms used in this Notice have the meaning given to them in the CCPA or CPRA and their implementing regulations.
Kaleyra is committed to properly handling the personal information and/or sensitive personal information collected or processed in connection with your employment relationship with us. Kaleyra will not sell personal information, including any sensitive personal information, we collect about our employees or applicants for employment or share it with third parties for cross-context behavioral advertising.
Kaleyra uses a third-party service provider to help administer certain human resources services for us. Accordingly, please visit https://www.insperity.com/california-privacy-notice/ for more information on how your personal information and sensitive personal information is handled by such third-party service provider.
To view our full Privacy Notice visit https://www.kaleyra.com/privacy-policy-kaleyra/.
We may collect the personal information and sensitive personal information categories listed in the tables below. The tables also list, for each category, our expected collection and use purposes and whether we sell the information or share it with third parties for cross-context behavioral advertising. Kaleyra will retain your information only for as long as is necessary for the purposes set out in this Notice, as specified in our internal record retention policy and/or as required by applicable law.
|
Personal Information Category |
Business Purpose |
Sold or Shared |
|
Identifiers, such as your full name, contact information, gender, date of birth, signature, Social Security number, driver’s license or state identification numbers, and similar information for your dependents and beneficiaries. |
|
Not Sold or Shared |
|
California Customer Records employment and personal information, such as your name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, current employment, employment history, membership in professional organizations, licenses and certifications, bank account number, credit card number, debit card number, or any other financial, medical or health insurance information. |
|
Not Sold or Shared |
|
Protected classification characteristics under California or federal law, such as 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, reproductive health decision making, military and veteran status |
|
Not Sold or Shared |
|
Professional or employment-related information, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes, background check, work authorization, performance and disciplinary records, salary, bonus, commission, and other similar compensation data, benefit plan enrollment, participation, and claims information, leave of absence information including religious, military and family obligations |
|
Not Sold or Shared |
|
Non-public education information, such as education records, degrees and vocational certifications obtained, report cards, and transcripts |
|
Not Sold or Shared |
Sensitive personal information is a subtype of personal information consisting of specific information categories. While we collect information that falls within the sensitive personal information categories listed in the table below, the CPRA does not consider this information as sensitive because we do not collect or use it to infer characteristics about a person.
|
Sensitive Personal Information Category |
Business Purpose |
Sold or Shared |
|
Government identifiers, such as your Social Security number, driver’s license, state identification card, and passport and visa information, and immigration status and documentation |
|
Not Sold or Shared |
|
Complete account access credentials, such as usernames, account numbers, or card numbers combined with required access/security code or password |
|
Not Sold or Shared |
|
Racial or ethnic origin |
|
Not Sold or Shared |
|
Health information, including job restrictions and workplace illness and injury information |
|
Not Sold or Shared |
If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact cis-hr.americas@tatacommunications.com.
Effective Date: June 1, 2023
If you are located in the EU
1.1.1 What “Personal Data” do we collect from you?
In the process of rendering our services, we collect the PII, which is the information that can be used to identify you such as, but not limited to:
- Name;
- Citizenship;
- Birthdate, place of birth;
- Home and personal cell telephone numbers;
- Personal email address, mailing, and home address;
- Financial information to the extent required;
- Office location;
- Business telephone number;
- Business e-mail address;
- Other information that is releasable to the public.
Processing of Personal Data
1.1.1 How do we process your personal data?
We may process data about the use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system and other tools used for web tracking/lead generation purposes. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, services, and improve the user’s experience as well as your expressed consent where necessary.
We may also process your data (“account data”), which may include your name and email address, contact details, your qualifications, employment, and past experiences, and other related information. The source of the account data is from third-party sites, job portals, leads / connects from social media platforms like LinkedIn, Twitter, Facebook, YouTube, Instagram, Pinterest, etc., where you have given your consent to store and transmit your individual data for prospective employers and companies. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, by the performance of a contract between you and us as well as your consent where necessary.
We may also store your personal data (“profile data” ), such as your name, address, telephone number, email address, gender, date of birth, and employment details in our database, so as to contact you directly in the event of a contracting opportunity or sharing a new product portfolio or a service based on your requirements and the opportunities we intend to share with you. In the latter case the legal basis of processing, if any, is the express consent, provided by you, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Why do we process your personal information
We process your “non-sensitive” personal information for the following reasons:
- Advertising and sales activities while we would be presenting information about our services and products;
- Creating and executing contracts and agreements with you or your employer to:
- Provide services to clients and other users of these services;
- Receive goods and services from vendors;
- Control our relationship with clients, vendors, and other parties who use our services or products;
- Administering our website as per the agreement and for internal processing, including fixes of defects, data analysis, testing, investigating, and collecting statistics and surveys;
- Improving our website to provide content in the most efficient & effective way.
- Provide you with specific products and services covered under the terms of a contract with one or more of our corporate customers, including processing transactions, authenticating authorized users, and marketing our products and services;
- Perform certain benefit administration or other transactions initiated by you;
- Respond to your questions, complaints, or reviews of our product or services;
- Send you communications about online transactions, product information, ads and promotions, electronic newsletters, or other notices you requested or offers tailored to you;
- Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities;
- Help us run our business; or
- For any other everyday business purposes, such as product development and website administration.
What legal basis do we have for collecting and processing your information?
Our legal basis for each of the ways we collect information from you has been explained in the earlier sections. Please note where consent forms the basis, you can withdraw consent at any time by contacting our DPO by opting out of any email message using the “Unsubscribe” link.
Certain jurisdictions, including those in the European Union, require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information. Kaleyra relies on the following legal grounds for the collection, use, sharing, and processing of Personal Information as described in this Privacy Policy:
- Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;
- Our legitimate interests, including:
- Performance of the contract with our Users;
- Implementation and operation of a group-wide matrix structure and group-wide information sharing;
- Customer relationship management and other forms of marketing and analytics;
- Fraud prevention, misuse of company IT systems, or money laundering;
- Whistleblower scheme operations;
- Physical, IT, and network perimeter security;
- Internal investigations; and
- Intended mergers and acquisitions;
- Compliance with legal obligations and/or defense against legal claims, including those in the area of labor law, social security, and data protection, tax, and corporate compliance laws.
- Protection of the vital interests of any individual;
- Performance of a task carried out in the public interest or in the exercise of official authority vested in Kaleyra; and
- Consent, as permitted by applicable law
Location-based services
We offer to our Users the ability to use location-based tracking on certain mobile technologies as part of Kaleyra’s Services. To provide location-based services on these Kaleyra products, we and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your device. Where available and enabled within the Kaleyra product configuration, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location.
Sale of the Businesses
If we sell all or part of our business, Personal Information may be transferred to the purchaser in connection with that transaction. In that case we will inform you and use reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information consistent with the terms of this Privacy Policy.
Other Disclosures
We may otherwise disclose Personal Information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, required for legal reporting, or to protect our legal rights or enforce our Terms of Use or any applicable rules, or to protect the rights of others. We may also disclose Personal Information to our auditors, legal advisors, or to respond to a subpoena. We may also aggregate information that we gather about you (e.g., online sales, traffic patterns) and provide these statistics to others in aggregate form.
However, it is to be noted that we may not be able to withdraw the consent by virtue of contractual commitments where there was an express consent you gave for storing your information for a period mentioned in the contract, or by the law of Land under which we operate.
Providing your personal data to others
- We may disclose your profile data, usage data, account data, (collectively “your personal data”) to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found here.
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- We may also disclose your personal data to our suppliers or subcontractors or our clients, financial institutions for processing the claims and payments, identified insofar as reasonably necessary for achieving the business objectives.
Access
What if the personal information belongs to a third-party?
- If you provide Kaleyra with data of/from third parties (such as their names, email addresses, phone numbers, etc.), you guarantee that you have the right to do so and you have obtained the consent from them.
- This includes, but is not limited to, forwarding of referential for open vacancies and for lead generation.
- Third parties opt-out of future messages by clicking the corresponding link in the original message or by getting in touch with us at cis-privacy@tatacommunications.com.
- In certain cases, Kaleyra and partner third-parties can automatically collect data using browser cookies, weblogs, web beacons, and other similar applications and attachments consistently with the related policies.
- This information is used for analysis, improving the convenience and efficiency of our website, and to help us provide you with relevant and interesting material.
Who has access to the data we collect?
We process and access to the data we collect from you. However, we use third parties to assist us with processing your personal data including the following categories of recipients:
- Financial transaction processors (processing your payments)
- Customer service communication platform
- Email communication manager
- Website management services
- Website design and programming services
- Users / Sub-Contractors / Contractors to the extent necessary for our business objectives.
Preparation of Analytics and Dashboards
These third parties have a contract with us, wherein, they are prohibited from utilizing, sharing or retaining your personal data for any purpose other than we dictate.
Your rights over data
What are your rights over your PII
You have the right to control your personal data. Specifically, you have the following rights:
- Right to be informed:
We are informing you now with this policy. - Right of access:
We’ll provide you with the data we have about you. - Right to rectification:
Request we fix incorrect data about you. - Right to erasure:
Request we erase certain data about you, subject to contractual rights and terms of use - Right to restrict processing:
Ask us to restrict certain types of processing of your personal information. - Right to data portability:
Ask us to provide your personal data we have for export where applicable. - Right to object:
Object to how we use your data. - Rights of automated decision making and profiling:
While we do your profiling, we also give you the right to opt-out/ not accept. - To exercise any of these rights, please contact cis-privacy@tatacommunications.com with your request.
Your Right to Withdraw Consent
Although this is mentioned above, we want to emphasize that wherever we’ve asked for your consent to collect or process your personal data, you have the right to withdraw that consent. If you receive email messages from us, you can use the “unsubscribe” link in each message to withdraw consent and stop the mailings.
Privacy Concerns, Contacting Us, Complaints.
You can raise your request with any questions you have about these policies or your personal data.
Data Protection Officer
DPO Office, Via Marco D’Aviano, 2 – 20131 Milan, Italy – cis-dpo@tatacommunications.com
On-duty privacy representative:
Legal and Compliance Department, Via Marco D’Aviano, 2 – 20131 Milan, Italy – cis-privacy@tatacommunications.com
In General for all our valued stakeholders
What information do we collect?
We collect information from you when we/you contact each other, you place an order, subscribe to our newsletter or fill out a form.
When ordering or registering on our site, as appropriate, you may be asked to enter your: name or e-mail address and banking information for payment purposes. You may, however, visit our site anonymously.
What do we use your information for?
Any of the information we collect from you may be used in one of the following ways:
- To personalize your experience:
To better respond to your individual needs
- To improve our website:
To improve our website offerings based on the information and feedback we receive from you
- To improve customer service:
To more effectively respond to your customer service requests and support needs
- To process transactions:
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of the deliverable.
- To administer a contest, promotion, survey, or other site feature:
Thereby promoting the control over data
- To send periodic emails:
To send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related product or service information, etc.
However, if at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
How do we protect your information?
We implement a variety of security measures such as maintaining a discrete database, providing access only in case of necessity, access on a need to know basis and such other globally acceptable security measures, to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. For further help and details, please contact our ISO 27001 manager for Kaleyra IT ongoing measures/policies at cis-privacy@tatacommunications.com .
Do we use cookies?
Yes, those cookies are transferred by a site or a service provider to your computer hard drive through your web browser, which enables you to recognize your browser and capture and remember certain information. Read more in our Cookie Policy.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. The other details are discussed in Section 1.
General Information
Third-party Links
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Children’s Online Privacy Protection Act Compliance
As required by the law we are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products, and services are all directed to people who are at least 13 years old or older.
Usage of Outbound links
Kaleyra websites might include links that lead to other websites, websites that are controlled by parties we are not related or connected to. After clicking an outbound link we lose any control of collection, storage, or processing of your personal data that is transferred
The behavior of third-parties is also beyond the scope of our control, therefore is not responsible for the collection, storage, and processing of the information you share with third-parties.
How long we process your personal data
We process personal data as long as it takes to achieve the goal (goals) for which this data was originally collected. After this, your data will be deleted or transferred to an archive, except for cases when it is necessary to continue the processing of your data to abide by the legal and contractual obligations that we have or other rightful and legal purposes.
Use of social plugins as part of social media
| What Social Media do we use? | Particulars | Plugins are identified by | How does it work? |
| Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025 (“Facebook”) | Facebook logo with a “Facebook”, “Like”, or “Share” prefix. |
· When you visit our website these plugins are turned off by default. Plugins remain turned off until you click on the corresponding button. · When these plugins are turned on, you are connected to the concerned website and give it your permission to transfer data to it. · When you click one of these buttons, this information is transferred by your browser to it and remains stored there. · To receive information regarding the goal and scope of collected information, its further processing, your rights and settings you can use to protect your privacy, please read the Privacy Policy on the official website of the concerned social media. · If you would like to opt-out of the concerned website’s collection of your data when visiting our website, before visiting our website, you must log out of your profile from that social media |
|
| Youtube |
YouTube, LLC 901 Cherry Ave. San Bruno, CA 94066 USA Fax: +1 650-253-0001 |
YouTube logo | |
| YouTube logo | LinkedIn logo | ||
| Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 («Twitter») | Twitter logo with a “Tweet”, or “Share” prefix. |
How to retract your agreement of the processing of your data?
You can retract your agreement on the processing of your personal information:
- By sending us an email to cis-privacy@tatacommunications.com
- By mailing us at the address: Kaleyra Inc., Via Marco D’Aviano, 2 – 20131 Milan, Italy.
Locations and international transfers
We share your personal information and service data within the Kaleyra Group. By accessing or using our services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the domains within the United States of America, the European Economic Area (EEA) and other countries where Kaleyra operates. Such transfer is subject to a group company agreement that is based on EU Commission’s Model Contractual Clauses.
Business Transfers
We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.
Your Consent
By using our site, you consent to our Privacy Policy, Cookie Policy and the website Terms of Use.
Changes to our Privacy Policy
- If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date below.
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy
- In case of relevant changes due to legal, regulatory or business issues affecting this policy and the consent you provided us with for personal data processing, you’ll be notified and will be requested to confirm whether or not you wish to confirm your consent
- Also, any further recommendations/suggestions/concerns can be made known to us here.
Last Reviewed: June 1, 2023