ActiveCalls Privacy Statement
1. Who We Are
1.1 This Privacy Statement explains how Intergo Telecom Ltd, a limited liability company incorporated in the Republic of Cyprus with registration number HE 352115, having its registered office at Tepeleniou 17, Office 102-103, 8010 Paphos, Cyprus, telephone +357 26 913001 (“Intergo Telecom”, “ActiveCalls”, “we”, “us” or “our”), processes personal data in connection with the activecalls.com website (the “Website”), the ActiveCalls portal and applications, and the ActiveCalls cloud contact-centre and voice services (the “Services”).
1.2 We process personal data in accordance with Regulation (EU) 2016/679 (the “GDPR”), the Cyprus Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data, Law 125(I)/2018, and, as a provider of electronic communications services, the rules on privacy in electronic communications under Directive 2002/58/EC as transposed into Cypriot law by Law 112(I)/2004, as amended.
2. Our Role: Controller and Processor
2.1 We act as controller for the personal data described in this Privacy Statement, namely data relating to: visitors to the Website; prospective customers and persons who contact us; our customers’ account owners, administrators and billing contacts; End Users of the Services in relation to their account, login and usage data; and traffic data that we process for billing, fraud prevention, network security and compliance with our legal and regulatory obligations as an electronic communications provider.
2.2 We act as processor on behalf of our business customers when we process the content of their communications and related data through the Services, such as call recordings, voicemails, transcripts, call analytics, contact lists and the data of persons who call or are called by our customers. In that case, the customer is the controller and determines how and why that data is processed. If you have called, or been called by, a business that uses ActiveCalls, please refer to that business’s privacy notice and address any request to it. Our processing as a processor is governed by the ActiveCalls Data Processing Agreement.
3. Data Protection Officer
3.1 We have appointed a Data Protection Officer (“DPO”). You may contact our DPO about any matter relating to the processing of your personal data or the exercise of your rights at: Intergo Telecom Ltd, Attn: Data Protection Officer, Tepeleniou 17, Office 102-103, 8010 Paphos, Cyprus; email: dpo@intergotelecom.com
4. Personal Data We Collect
| Category | Examples | Source |
|---|---|---|
| Contact and enquiry data | Name, company, job title, email, telephone number, country, message content | You, through contact, sales, trial or newsletter forms, email or calls |
| Account data | Name, email, telephone number, username, password (hashed), role, company details, account settings | You or your organisation’s administrator |
| Identification and verification data | Company registration documents, identity documents and proof of address, where required for number allocation or “know your customer” checks | You or your organisation, as required by numbering and regulatory rules |
| Billing and transaction data | Billing address, VAT number, invoices, payment history, plan and usage; payment card details are processed by our payment provider and are not stored by us | You, our payment provider |
| Traffic data | Calling and called numbers, date, time, duration and routing of calls, Numbers assigned, IP addresses used to connect to the Services | Generated by the Services |
| Usage and device data | Log-in records, IP address, device and browser type, app version, crash reports, feature usage | Generated by the Website, portal and applications |
| Communications with us | Support tickets, emails, chat messages and, where you are informed in advance, recordings of calls with our support or sales teams | You |
| Marketing preferences | Newsletter and SMS consents, opt-outs, interactions with our emails | You, our email tools |
| Cookie data | Cookie identifiers and online identifiers | The Website, see our Cookie Policy |
4.1 We do not intentionally collect special categories of personal data. Please do not provide such data to us unless necessary.
5. Purposes and Legal Bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Responding to enquiries, providing quotes, arranging demos and trials | Steps at your request prior to entering into a contract (Art. 6(1)(b)); legitimate interests in responding to business enquiries (Art. 6(1)(f)) |
| Creating and administering accounts, providing the Services and technical support | Performance of a contract (Art. 6(1)(b)); for End Users of a business customer, our legitimate interest in providing the Services to that customer (Art. 6(1)(f)) |
| Allocating telephone Numbers and carrying out identity and “know your customer” checks | Compliance with legal obligations (Art. 6(1)(c)); performance of a contract (Art. 6(1)(b)) |
| Billing, invoicing, payment collection and accounting | Performance of a contract (Art. 6(1)(b)); compliance with tax and accounting obligations (Art. 6(1)(c)) |
| Processing traffic data for billing, interconnection, fraud prevention (including toll fraud) and network security | Compliance with legal obligations (Art. 6(1)(c)); legitimate interests in protecting our network and customers (Art. 6(1)(f)); as permitted by Law 112(I)/2004 |
| Responding to lawful requests of competent authorities | Compliance with legal obligations (Art. 6(1)(c)) |
| Information security, incident detection and compliance with NIS2 requirements | Compliance with legal obligations (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f)) |
| Improving the Website, portal and applications, and service analytics | Legitimate interests (Art. 6(1)(f)); consent where required for non-essential cookies (Art. 6(1)(a)) |
| Sending newsletters and marketing communications | Consent (Art. 6(1)(a)); for existing customers, legitimate interests in marketing similar services, subject to your right to opt out at any time |
| Recording calls with our support or sales teams for quality and training | Legitimate interests (Art. 6(1)(f)); |
| Establishing, exercising or defending legal claims | Legitimate interests (Art. 6(1)(f)) |
6. Applications and Device Permissions
6.1 The ActiveCalls softphone and mobile applications request access to certain device functions only where needed for the features you use: the microphone, to make and receive calls; notifications, to alert you of incoming calls and messages; and, where you choose, contacts, to display and dial your contacts. You can manage these permissions in your device settings at any time; some features may not work without them.
7. Cookies
7.1 The Website uses cookies and similar technologies. Non-essential cookies are used only with your consent, which you can withdraw at any time through the cookie settings. Further details are set out in our Cookie Policy.
8. Recipients of Personal Data
8.1 We disclose personal data only where necessary and to the following categories of recipients:
- companies of the Intergo Telecom group, where necessary for the provision of the Services and internal administration;
- hosting, cloud infrastructure, software, transcription and support providers acting as our processors under written agreements;
- telecommunications carriers and interconnection partners that originate, transit or terminate calls and port Numbers, which act as electronic communications providers in their own right;
- payment service providers and banks;
- national regulators and numbering authorities, where required for the allocation and use of Numbers;
- external auditors, legal and tax advisors and insurers, under duties of confidentiality;
- law enforcement, judicial and other public authorities, where required by law and after assessing the lawfulness of the request; and
- a purchaser or successor in the event of a merger, acquisition or sale of all or part of our business.
8.2 We do not sell personal data. Mobile numbers and SMS opt-in data are not shared with third parties or affiliates for their marketing or promotional purposes.
9. International Transfers
9.1 Some of our service providers and carrier partners are located outside the European Economic Area. Where we transfer personal data to a country that has not been recognised by the European Commission as ensuring an adequate level of protection, we use appropriate safeguards under Article 46 GDPR, in particular the Standard Contractual Clauses adopted by the European Commission, supplemented where necessary by additional measures following a transfer impact assessment. Where a recipient in the United States is certified under the EU–US Data Privacy Framework, we may rely on that framework.
9.2 International calls are, by their nature, routed through carriers in the destination country. Such transfers are necessary for the performance of the contract and the routing of the communication.
9.3 You may obtain a copy of the relevant safeguards by contacting our DPO.
10. Retention
10.1 We keep personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, tax and accounting requirements:
| Data | Retention period |
|---|---|
| Account data | Duration of the customer relationship plus 3 years |
| Billing and accounting records | 7 years from the end of the relevant tax year, as required by Cyprus tax law |
| Traffic data | As long as necessary for billing and dispute resolution, and as required by applicable telecommunications and data retention law |
| Identification and verification documents | Duration of the Number allocation plus 5 years, or as required by the relevant regulator |
| Enquiries from prospects who do not become customers | 24 months from the last contact |
| Support tickets and recordings of support calls | 12 months |
| Marketing consents and opt-outs | Until consent is withdrawn; records of opt-outs are kept to honour your choice |
11. Security
11.1 We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, including encryption in transit and at rest, access controls, multi-factor authentication for administrative access, network monitoring and fraud controls, and staff confidentiality obligations. As an entity subject to Directive (EU) 2022/2555 (NIS2), we also apply the cybersecurity risk-management measures it requires.
12. Automated Decision-Making and AI Features
12.1 We do not take decisions about you based solely on automated processing, including profiling, that produce legal or similarly significant effects. Automated fraud-detection controls may temporarily block suspicious calls, in which case you may contact us to obtain human review.
12.2 Where our business customers enable transcription, call summarisation or other AI-assisted features, these features are processed on behalf of and under the instructions of the customer, as described in clause 2.2.
13. Your Rights
13.1 Subject to the conditions and exceptions of applicable law, you have the right to:
- access your personal data and receive a copy of it;
- have inaccurate or incomplete personal data rectified;
- have your personal data erased;
- restrict the processing of your personal data;
- receive your personal data in a structured, commonly used and machine-readable format and transmit it to another controller (data portability);
- object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests, and to object at any time to processing for direct marketing purposes, in which case we will stop such processing;
- withdraw your consent at any time, without affecting the lawfulness of processing carried out before its withdrawal.
13.2 To exercise your rights, contact our DPO at dpo@intergotelecom.com. We will respond within one month of receipt, which may be extended by two further months where necessary given the complexity and number of requests. We may need to verify your identity before responding.
13.3 You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement. Our lead supervisory authority is the Commissioner for Personal Data Protection, Kypranoros 15, 1061 Nicosia, Cyprus (postal address: P.O. Box 23378, 1682 Nicosia), telephone +357 22 818456, email commissioner@dataprotection.gov.cy, website www.dataprotection.gov.cy.
14. Marketing and Text Messages
14.1 You may unsubscribe from our marketing emails at any time by using the unsubscribe link in each email, and from our text messages by replying “STOP”. We will continue to send you service-related communications that are necessary for the administration of your account.
15. Children
15.1 The Website and the Services are intended for businesses and are not directed at children under the age of 18. We do not knowingly collect personal data from children.
16. Additional Information for Certain Jurisdictions
16.1 United Kingdom. Where the UK GDPR and the Data Protection Act 2018 apply, references to the GDPR include the UK GDPR, transfers are safeguarded by the UK International Data Transfer Addendum, and you may lodge a complaint with the Information Commissioner’s Office (ico.org.uk).
16.2 United States. We do not sell or share personal information for cross-context behavioural advertising. Residents of US states with comprehensive privacy laws, including California, may exercise their rights to know, access, correct and delete their personal information, and will not be discriminated against for doing so, by contacting our DPO.
17. Third-Party Websites
17.1 The Website may contain links to third-party websites and integrations. We are not responsible for their privacy practices, and we encourage you to read their privacy notices.
18. Changes to this Privacy Statement
18.1 We may update this Privacy Statement from time to time. The date at the top shows when it was last updated. Where changes are material, we will notify customers by email or through the portal before they take effect.
19. Contact
19.1 For any questions about this Privacy Statement, please contact our DPO at dpo@intergotelecom.com or write to Intergo Telecom Ltd, Attn: Data Protection Officer, Tepeleniou 17, Office 102-103, 8010 Paphos, Cyprus.
