Sangoma Technologies, Inc. and its affiliated entities (collectively, “Sangoma”) take the privacy of their employees and those individuals and businesses (collectively, “You”) that interact with the Sangoma websites, products, or services (collectively, “Services”) seriously. To that end, this policy (“Policy”) is designed to clearly and concisely describe the ways in which Sangoma collects, stores, uses, shares, and releases all data You provide to, or is otherwise obtained by, Sangoma (collectively, “Information”).

Background:

As a global business-to-business communications service provider, connecting the people and processes that matter, Sangoma business is providing its customers with the best in class UC, video, chat, contact center, MSP services, and security services. Sangoma is not in the business of monetizing or in any way utilizing customer or third-party Information for any other purpose than to provide the Services.

Information Sangoma Collects:

Depending on Your relationship with Sangoma or the Services You purchase or use, Sangoma may collect some or all of the following information about You:

• Your name, email address, physical address or location, date of birth, gender, ethnicity, social security number or other government-issued identification numbers, phone number, or other personally identifiable or demographic information;
• Your employment history, educational background, references, employee files, or evaluations;
• The name and physical address of Your business;
• The name, email address, physical address, or phone number of Your employees, customers, or other third-parties that interact with You when using the Services;
• Your or Your employees’ behavioral history such as IP addresses, internet traffic information, cookies, browsing history, or history of your interactions with the Services; and
• Any content you contribute to, post on, or share when using the Services.

For more information on how Sangoma uses cookies, please refer to the Cookie Policy at www.sangoma.com/cookie-policy/.

The above list is not intended to be exhaustive but gives you a sense of the many pieces of data that constitute Information for the purposes of this Policy.

How Sangoma Collects Information:

Sangoma collects Information automatically in some instances. For example, when You access certain Services, Sangoma may gather certain metadata or details concerning the manner in which You interact with the Services. Where reasonable or required by law, Sangoma will inform You when such automatic collection occurs at the time it is collected.

Additionally, Sangoma may specifically request certain Information from You as part of its hiring or onboarding process, when You order Services or, for example, when you engage with a chatbot or any submission forms on any Sangoma website, in which case You will knowingly be providing the Information directly to Sangoma.

Finally, Sangoma may collect certain information directly as a result of how You or others choose to use the Services or certain features thereof, such as, depending on the licensing, when using the closed-captioning or recording features of Sangoma’s Sangoma Meet platform where a copy of the transcript of the relevant meeting will be collected, Sangoma’s CommUnity platform, where a copy of voicemails and transcriptions will be collected, or Sangoma’s CX platform, where a copy of recordings, transcriptions, summaries, and sentiment will be collected.

How Sangoma Stores and Protects Information:

Sangoma follows generally accepted security standards and has adopted commercially reasonable security measures appropriate to store and safeguard the Information it collects. These efforts are designed to ensure that the Information is protected against unauthorized access, alteration, disclosure, or destruction.

Why Sangoma Collects Information:

The purposes of collecting Information varies depending on the type of Information collected, but generally includes one or more of the following:

• To provide You with the Services;
• To ensure the functionality of the Services;
• To enhance Your user experience with the Services;
• To facilitate Your relationship with Sangoma; or
• To comply with applicable law.

To be clear, Sangoma does not sell or otherwise monetize Your Information for its benefit. The collection of Information is intended solely to benefit You, Sangoma, or the relationship between You and Sangoma – not unnecessary third parties.

Who Does Sangoma Share Information With:

Sangoma may share certain Information with the following types of individuals or entities:

• Service providers;
• Legal authorities;
• Those You have consented to have Your Information shared with; or
• Those Sangoma otherwise has the right or authority to share such Information.

The above individuals or entities are collectively referred to herein as “Third Parties.”

Why Sangoma Shares Information with Third-Parties:

Sangoma may share Information with Third-Parties where:

• Necessary for Sangoma to provide You with the Services;
• Necessary to ensure the functionality of the Services;
• You have requested, or otherwise consented to, Sangoma doing so; or
• Required by applicable law.

To be clear, Sangoma will use reasonable efforts to disclose to You when Information You provide is being shared with a Third-Party at the point in time that such Information is collected or shared. This may not be possible in all instances but such transparency is a priority of Sangoma.

How Long Does Sangoma Retain Information:

Sangoma retains Information for varying lengths depending on the type of Information collected and the purpose for which it is collected. At a minimum, Sangoma keeps Information for as long as (i) it is required to do so by law; or (ii) it has a legitimate business interest in doing so.

What Rights Do You Have with Respect to Your Information:

You, a data subject, have a variety of rights when it comes to Your Information collected by Sangoma which vary depending on where You reside or the laws Sangoma is subject to. These rights, set forth below for your convenience, will be honored by Sangoma in the manner and in the time required by applicable law:

• Right to obtain Information;
• Right to request personal data transfer;
• Right to correction and erasure;
• Right to restriction of processing
• Right to stop processing; and
• Right not to be subject to automated decision-making (i.e. profiling).

All of these rights can be exercised by contacting Sangoma in the manner set forth in the “How Do You Contact Sangoma” section of this Policy.

Additional Information Relevant to You and Your Information:

Sangoma may include additional context regarding the collection, storage, use, sharing, and release of Information in those contracts or agreements You enter into with Sangoma in connection with the Services. That additional information is intended to provide specific details tailored to such Services and is not intended to supplant, but rather supplement or provide further clarity to, this Policy.

This Policy will be updated from time-to-time to keep up with the ever-changing legal landscape and the developments within the Services Sangoma offers or makes available to You. The version published at https://www.sangoma.com/privacy-policy/ will always be the most current, and it will contain a date at the bottom which indicates when the last update was made public. We invite you to periodically review the Policy to stay informed of any changes that may impact Your Information.

If Sangoma makes any material changes to the Policy, we will do our best to ensure you are notified prior to those changes becoming effective so that you can be made aware and exercise any of Your rights with regard to that Information should You choose to do so. Still, Sangoma encourages You to periodically refer back to this Policy and review it for changes. It has been drafted in a way that doing so should not prove overly burdensome and You will know if you have reviewed the most recent version by referencing the “Last Updated” language below.