Privacy Policy

Introduction

Gaglers Inc, a Delaware corporation (“CallHub”, “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Important information and who we are

This privacy policy aims to give you information on how CallHub collects and processes your personal data through your use of this website, including any data you may provide through this website when you use our services relating to making and receiving calls or sending and receiving messages. This website is not intended for children, and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Controller

CallHub is the data controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at [email protected] You have the right to make a complaint at any time to the supervisory authority for data protection and may do so in the country of your residence, where applicable. We would, however, appreciate the chance to deal with your concerns before you make a formal complaint with such authority, so please contact us in the first instance.

Please find our GDPR Representative for the respective regions:

Europe (EU)

Rickert Rechtsanwaltsgesellschaft mbH
-Gaglers Inc.-
Colmantstr. 15
53115 Bonn
Germany
Email – [email protected]

United Kingdon (UK)

Rickert Services Ltd UK
-Gaglers Inc.-
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
Email- [email protected]

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 16th May 2024.

The personal data we hold about you must be accurate and current. Please keep us informed by emailing us at [email protected] if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier

Contact Data includes billing address, delivery address, email address, website address, and telephone numbers

Financial Data includes bank account and payment card details.

Professional Data includes your company name, company size, business type, your customer information.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your account registration data, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, and any other information you provide us.

Usage Data includes information about how you use our website, products and services, such as the phone number placing and receiving calls, the date of the call, duration of the call, other call related meta-data, text message data, the phone number sending and receiving the message, the date of the message and the content of the message.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences and any account information from add-ons and other third-party services you use in conjunction with our services.

We also collect and use Identity, Contact and Profile data about other individuals that you submit to us to use the services. YOU SHOULD ALWAYS OBTAIN THE CONSENT OF SUCH INDIVIDUALS BEFORE PROVIDING US WITH SUCH INFORMATION. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by mail, phone, email, or otherwise. This includes personal data you provide when you:
use our products or services including making telephone calls and sending text messages; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion, or survey; or give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:

  1. analytics providers;
  2. advertising networks; and
  3. search information providers.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Identity and Contact Data from data brokers or aggregators.

Identity and Contact Data from publicly availably sources.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email, phone call or text message. You have the right to withdraw consent to marketing at any time by contacting us at [email protected]

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer and to allow you to maintain and customize your customer account/profile

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order for services including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us, purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. We reserve the right to use the name and/or logo of the company you work for in publicity material, advertising or marketing collateral, unless you specifically tell us otherwise.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the CallHub group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time. You may opt-out of receiving our newsletters by clicking on the opt-out link included in every email newsletter we send, or by contacting [email protected]. CallHub service offerings include acting as a service provider for our clients’ in providing an “opt-out” platform for their recipients [end users]. At any time, recipients [end users] may discontinue receiving SMS offers by sending the SMS message “STOP” to the applicable shortcode, or by following other instructions provided by that Client. If at any time recipients [end users] forget what keywords are supported, they can text “HELP” to 33339 . CallHub will then respond with instructions on how to use the service as well as how to unsubscribe. Opting out from a particular Client’s offers will not apply to any communications from other Clients. All information provided to CallHub’s clients is owned by said client and subject to their privacy statement. We are not responsible for their privacy practices during our role as the clients’ service provider.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above. Internal Third Parties as set out in the Glossary. External Third Parties as set out in the Glossary. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We share your personal data within the CallHub Group. This will involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Data Privacy framework which requires them to provide similar protection to personal data shared between Europe and the US. [Refer: EU-US Data Privacy Framework for more details].

Compliance with Applicable Laws and the EU-U.S. Data Privacy Framework (EU-U.S. DPF)

CallHub strives to be in compliance with all applicable data protection laws. Additionally, CallHub adheres to the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework (reference to these frameworks as “DPF”) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries, the UK (and Gibraltar) transferred to the United States pursuant to DPF. CallHub strives to certify that it adheres to the Principles of the DPF with respect to such personal data. If there is any conflict between the policies in this privacy policy and data subject rights under the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view our certification page, please visit https://www.dataprivacyframework.gov/s/.

The Federal Trade Commission has jurisdiction over CallHub’s compliance with the DPF. CallHub is subject to the investigatory and enforcement powers of the FTC (Federal Trade Commission). CallHub may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the DPF, CallHub commits to resolve complaints about our collection or use of your personal data transferred to the U.S. pursuant to the DPF. EU and UK individuals with inquiries or complaints should first contact [email protected]. CallHub commits to cooperate with EU Data Protection Authorities (DPAs) and the UK Information Commissioner’s Office (ICO), as well as to comply with the advice given by such authorities with regard to non-human resources data transferred from the EU and the UK.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found in Annex I of the DPF: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Pursuant to the DPF, EU, and UK individuals have the right to obtain our confirmation of whether we maintain Personal Information relating to You in the United States. Upon request, we will provide You with access to the Personal Data that we hold about You. You may also correct, amend, or delete the Personal Data we hold about You. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the DPF, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.

Further, You have the right to restrict your personal data from being processed in the event that you contest the accuracy of the personal data, contest the means of processing, or find us having no legitimate claim to do so.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of Your Personal Information, please submit a written request to [email protected].

CallHub’s accountability for personal data that it receives in the United States under the DPF and subsequently transfers to a third party is described in the DPF Principles. In particular, CallHub remains responsible and liable under the DPF Principles if third-party agents that it engages process personal data on its behalf and do so in a manner inconsistent with the principles unless CallHub proves that it is not responsible for the event giving rise to the damage.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Read our security policy.

Data retention – How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law, we may also have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes. In some circumstances, you can ask us to delete your data. In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us

No fee is usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract

Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Below are the different scenarios under which we may share your data with third parties. Telephony operators as necessary for proper routing and connectivity. Communications-related data is shared with and received from telephony operators, such as Twilio and Plivo as necessary to route and connect those communications from the sender to the intended recipient. How those telephony operators handle this data is generally determined by those operators’ own policies and local regulations. Third-party service providers or consultants. CallHub engages certain third-party service providers to carry out certain data processing functions on our behalf. These providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances they will appropriately safeguard the data. In addition, CallHub uses Maxmind as a service provider to help us detect potentially fraudulent or malicious accounts or customer activity. These service providers use machine learning as part of its service and certain Customer Account Data CallHub shares with them may be used in building machine learning models to help detect potential fraud or malicious activity that not only benefits CallHub but other customers as well. Sub-processors. We may share Customer Content with sub-processors who assist in providing the CallHub services, like our infrastructure provider, or as necessary to provide optional functionality like transcriptions. An up-to-date list of our sub-processors is located in the section “SUB PROCESSORS”. Integration Partners.

SUB PROCESSORS

CallHub uses certain sub-processors to assist in providing CallHub’s services. A sub-processor is a third-party data processor engaged by CallHub who agrees to receive personal data from CallHub intended for processing activities to be carried out (i) on behalf of CallHub customers; (ii) in accordance with customer instructions as communicated by CallHub; and (iii) in accordance with the terms of a written contract between CallHub and the sub-processor. CallHub maintains an up-to-date list of the names and locations of all sub-processors. This list is below, or you can obtain a copy by contacting [email protected]

Find all the Sub-processors here:

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us

Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have to override legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.