Last updated May 23, 2018
Who we are
Hablaporinternet.com Corporation., is an Information and Communications Technology (ICT) Integrator company and provider of cloud communications. For our business and residential customers, we offer unified communications solution for the delivery of end-to-end communications via voice, video, text, mobile applications, and collaboration tools. We also deliver “Solutions As a Service” systems for Internet Service Providers (ISP), Telephony and Television service providers companies.
What information we collect
We collect your information in the following ways:
Information you provide directly to us. When you subscribe to our newsletters, register for one of our webinars, sign up for our services, request us to contact you, or through other interactions with us, we may ask you for certain personal information, such as your name, birthdate, address, e-mail address, telephone number, company name, job title, or payment information. When you request support from us, we may also collect information from you such as contact information, documentation, screenshots, or other information you or we may believe is helpful to solving the issue. When you speak with our customer service or sales representative on the phone, your calls may be recorded and/or monitored for quality assurance and training purposes. In certain circumstances, we may collect your ID or Social Security number from you for a limited purpose, such as for tax reporting relating to a payment for a customer referral or to facilitate an international money transfer.
Information we collect automatically when you visit our websites. We and our third-party partners, such as our advertising and analytics partners, collect information about your visits to our websites and your interactions with our ads or content, together with information such as your IP address, cookies, and other tracking technologies (e.g., web beacons, device identifiers, and pixels). For more information, please see our Cookies and Tracking Notice, which includes information on how to control or opt out of these cookies and tracking technologies.
Information we get from third parties. Third party sources of information include:
- Third party services and social media. If you create an account or access our services through your account with a third-party service, such as Facebook, Google, LinkedIn, GitHub or Twitter, or use a social media feature through our services, certain personal data from those third-party social media services may be shared with us, such as your interests, “likes,” and friends list. We may use this information, for example, to personalize your Hablaporinternet experiences and marketing communications, to enhance our services, and to better serve you. You can control this data sharing via options in your social media accounts. We may also collect information from third party services that are integrated with our services, such as third-party CRMs or other applications that you authorize our services to connect with.
- Credit agencies. We may obtain your credit information from third party reporting agencies in order to control our own credit risk in onboarding new customers.
- Demographic, lead, and interest data. We may obtain information from outside companies such as those that collect customer information including demographic and interest data. Examples of this information include your employment status, your job title with your current employer, and your business contact information. We use this data and combine it with other information we have about you to help us predict your preferences and to direct marketing offers that might be more relevant to you. We also obtain where permitted by law contact information and other marketing lead information from third parties, website “refer-a-friend” options or social media platforms and may combine it with information we have to contact you or direct Hablaporinternet marketing offers to you.
- Information about our customers’ users. Our customers and other third parties may also provide us with personal information about our customers’ users and others. For example, we may receive personal information and other information from our customers, message senders, mobile network operators, databases with information relevant to mobile telephone numbers submitted to our services, and other third parties. This information may include, without limitation, telephone numbers, telephone numbers’ validity, type (e.g., mobile, landline, etc.), corresponding device status (e.g., whether or not it is currently available for messaging), roaming status, carrier, country of location, and whether or not the number has been ported and is used to help us provide our services.
Information collected in connection with your use of services delivered via our platform. We and our service providers may collect information in connection with your use of communications services delivered via our platform.
- Communications usage information. This includes information about your communications delivered via our platform such as the time and duration of usage, source and destination identifiers, completion status, location, IP address, and amount of usage.
- Communications content. To enable you to send and receive communications via our platform, we need to be able to handle the content of the messages, calls, and other communications channels used by you. This also includes, for example, voicemails and call recordings recorded via our services.
Device information. Where we have provided end user equipment to you, such as an analog telephone adapter or a VoIP phone or a router, or you have installed our software on your device, we collect device-specific information from you. This includes, for example, your hardware model, operating system version, firmware, browser information, device and network configuration, device identifier, IP address, device performance, signal strength, call quality, telemetry, and mobile or wireless network information. We use the device information we collect in order to deliver and improve our services.
- Your contact lists and address book. If you use our mobile apps, we may request your permission to access and store the contact list or address book maintained on your mobile phone, tablet, or other broadband-connected device. Your contact list is considered your personal data. We may use your contact list information to facilitate certain services where selected by you such as to enable you to make calls easily and to facilitate calls, texts, and other services. We may also facilitate the delivery of messages to individuals in your contact list that you wish to invite to download our mobile apps so that you can utilize our services with these selected individuals, although it is always your choice to send invites to such individuals. We will not use your contact list information for other purposes without first notifying you of the proposed use. You do not have to allow us to access your contact list information, but if you do not, certain features of our mobile apps may not be available to you. You may at any time opt out from allowing this access via the privacy settings on your device.
- Mobile device camera, microphone and photos. If you use our mobile apps, we may request your permission to access the camera, microphone, and photos on your mobile device, to make and receive voice and video calls and messages and to send photos to others. You do not have to allow us to access these functions of your device, but if you do not, certain features of our mobile apps may not be available to you. You may at any time opt out from allowing this access via the privacy settings on your device.
- Your location information. If your mobile device is equipped with GPS or can connect with wireless access points or hot spots, or if your mobile device is also a phone that communicates with cell towers or satellites, then your mobile device is able to use these features to determine its precise geographic location. You may use the mobile app to do a one-time share of your precise geographic location through a message in a chat session by pressing the location attachment button within the mobile app (a “Location Share Event”). We will retain the Location Share Event within your chat session on the mobile app until you delete the message. Your precise geographic location, including a Location Share Event, is considered your personal data. To the extent our mobile apps collect precise geographic location, you may at any time opt out from further allowing us to have access to your mobile device’s precise location information via the mobile app’s location settings on your mobile device.
Why we collect your information and how we use it
How we use the information we collect depends on which of our services you use, how you use them, and specific preferences you may have communicated to us. We list below the specific purposes for which we collect your information.
To deliver our services. We use your information because it is necessary to perform our obligations in delivering our services to our customers. This includes delivering your communications to the intended end user, processing transactions with you (such as billing), authenticating you when you log into our platform, providing customer support, and operating and maintaining our services. We also need your information to communicate with you about the services, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, administrative messages, and other communications necessary to usage of the services.
To carry out core activities relating to our services. To effectively deliver our services to you, we use your information to engage in important supporting activities such as:
- billing and collections, including maintenance of records in the event of a subsequent billing dispute;
- preventing fraud, violations of our acceptable use policies, and unlawful activities;
- troubleshooting, quality control, and analytics; and
- monitoring the performance of our systems and platform.
For research and development. We are constantly looking for ways to improve our services, to make them more reliable, secure, and useful to you and our users generally. We use data regarding our users’ communications on our platform to understand how our services are performing and how they are being used in order to identify areas where we can do better. For instance, we may use message delivery and call connection information to gauge the effectiveness of our routing to ensure that your messages are delivered and your calls are connected. We and our service providers may use your information to assess the level of interest in, and use of, our services, our communications to our customers, and our other messaging campaigns, both on an individual basis and in the aggregate. We also use information about your use of our websites to understand how our website visitors are using our websites. Among other things, this usage information, along with tracking technologies, enables third-party analytics companies, such as Google Analytics, to generate analytics reports on the usage of our services. To opt out of your usage information being included in our Google Analytics reports, you may follow these instructions.
To comply with legal requirements. Applicable laws or regulations may require our processing of your data, such as laws mandating retention of communications data.
To protect our legitimate business interests and legal rights. Where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
According to your explicit consent. If we wish to use your information for certain purposes which require consent under applicable law, we will first seek out and obtain your consent. This may include, for example, testimonials or case studies that identify you in your individual capacity.
European Economic Area users and our “lawful bases” for using their data
European data protection law requires organizations like us to provide a lawful basis to collect and use your information. Our lawful basis to collect and use information from our EEA users include when:
- We need it in order to provide you with the services and to carry out the core activities related to our provision of the services.
- We need to comply with a legal obligation.
- We have a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests.
- You give us your consent to do so for a specific purpose.
Who we share your information with and why
We may share your information as detailed below:
Third-party service providers that help us to deliver the services and allow us to operate our businesses.
- Communications providers. As the provider of a communications platform, we share the data we collect from you with communications providers (including traditional PSTN telecommunications companies and over-the-top communications service providers) as necessary in order to provide you with the services. These are the telecommunications companies, for instance, who we need to ensure your calls, messages and other communications reach the people you want to contact.
- Business operations vendors. We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. We only work with carefully selected vendors, and we require any vendors with whom we share personal data to protect the confidentiality of such information and use it solely for the purposes for which it was shared.
- Partners. In the event that you purchase services offered by Hablaporinternet or a partner through a special marketing arrangement (for example, through a co-branded advertisement or offer, or an arrangement where we and a partner market or offer the other’s products or services), we may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.
Compliance with law enforcement requests and applicable laws; enforcement of our rights. We may disclose personal data as required by applicable law, regulation, legal process or government request; to protect Hablaporinternet, our services, our customers or the public from harm or illegal activities; and to enforce our agreements, policies and service terms.
With your explicit consent. We share information about you with third parties when you give us consent to do so. For example, we often display use cases or testimonials of satisfied customers on our public websites and require your consent to identify you in your individual capacity. If you are a business customer, and have requested this, your business name and phone number may be included in public directories.
Sharing with senders and recipients of communications. The name on your account, or a portion thereof, and/or your phone number may be displayed to people that you make calls to and to other users of the services so that they may contact you. Depending on the service you’re using, you may be able to control what’s displayed by adjusting your settings within the mobile app or your customer account, or by contacting customer care at the address provided when you signed up for the services.
Hablaporinternet affiliates; business transactions. We share your information with and among our corporate affiliates in order to operate and improve the services we provide to you; and we may share your information in