Author: Mitch Edwards

Owner: Oliver Blower

Date Approved: 28/11/2022

This Privacy Notice applies to personal information processed by VoxSmart where VoxSmart is the Controller and the Data Subject is not an employee of VoxSmart.This does not apply to systems we operate on behalf of our customers to record mobile voice calls or instant messages. In this case we are not the data controller and the data controller’s policy will apply.

VoxSmart Limited is a company registered in England and Wales, registration number 05691475 and registered address 35 Luke Street, London EC2A 4LH. VoxSmart supplies cloud-based mobile surveillance solutions. We have appointed a Data Protection Officer who you can contact by writing to “Data Protection Officer” at our registered address or by emailing privacy@voxsmart.com.

We process data about you to fulfil the terms of our contracts with our customers and suppliers, who may be your employer, and to contact you about our products and services. In the first case the legal basis of the processing is our legitimate interest as a business. In the second case the legal basis is our legitimate interest combined with your consent.

We collect and process your name and contact details such as: phone number and email address, as well as your communications with us which may include recording phone calls you have with us, or emails we exchange. We also use cookies to track your usage of our website.

We collect this data directly from you through our website, from your employer under the terms of our contract with them, from our partners such as conference organisers, or from public sources.

We do not share your information with other organisations for their benefit but do engage sub-processors as our suppliers who provide data processing services to us. We only transfer data to sub-processors who are inside the EEA or in a jurisdiction judged adequate by the European Commission, including those certified in compliance with the EU-U.S. Privacy Shield Framework, or where we have contractual terms in place approved by the European Commission.

We retain personal data about you only for as long as we need it. If we are processing your personal data due to a contract, we will retain this information for as long as the contract and any terms or conditions of it that rely on the personal data are in force. We will retain your contact details for communicating with you for other purposes as long as you continue to agree we communicate with you. If you no longer want us to communicate with you, we will retain this information so we can continue to respect your decision.

The Google Play Program Policies require you to consent to having personal and sensitive user data collected by VoxSmart.

Depending on settings specified by your employer, VoxSmart may monitor and record any of your SMS messages, calls, call logs, and attempts to prevent this monitoring.

Any collected data is sent securely to VoxSmart’s cloud infrastructure, where it is made accessible to your employer.

VoxSmart also monitors your device contacts. Contact information is collected but is only used to provide correct contact information for calls.

Your rights under GDPR are summarised below. You can contact us to exercise any of these rights, apart from the right to complain to a Supervisory Authority, by writing to “Data Protection Officer” at our registered address or by emailing privacy@voxsmart.com. You will need to provide some evidence of your identity such as confirming possession of an email address or providing a copy of an identity document. We will respond to your request as quickly as we can and within one month. It may take up to three months to fulfil your request and we will inform you of any delay longer than a month. We may charge a fee or refuse to act on your request if your request is manifestly unfounded or excessive or repetitive.

This notice informs you of who we are, the purpose and legal basis of processing, what data we process and where we transfer it to. You can request more information from us if you do not understand this notice.

You can contact us as above to request us to confirm if we are processing personal data about you, to get access to this data and to receive the details of this notice at any time. We will share data about you in paper or electronic formats as appropriate. We will provide you with a single copy of the data and will charge a fee for any additional copies. We will not share data about other data subjects with you without their consent and this may affect the completeness of any information we can provide you.

We will correct personal data about you if it is incorrect or complete it if we are missing information we should have.

We will remove personal data about you provided that one oor more of the following are true:

• The personal data are no longer necessary,
• you no longer consent to us processing the data and we have no other legal reason or overriding legitimate reason to continue processing,
• we have processed the data unlawfully,
• the personal data must be erased for legal reasons.

We will not erase data on request if it is required for legal reasons. We will make reasonable efforts to remove personal data we have published and contact other data controllers who are processing public data.

You can ask us to stop processing personal data about you:

• until we have corrected any inaccuracies or omissions,
• if the processing is unlawful but you do not want us to erase the data,
• we no longer require the data but you require it for legal reasons,
• you have objected to us processing the data and we are working out whether there is any other reason we may continue to process it.

You can object to our processing of personal data about you and we will stop processing personal data about you so long as there is not an overriding reason for us to continue. If we are using personal data about you for direct marketing purposes, we will stop this immediately if you do object. You can opt-out of any direct marketing communications at any time.