Privacy Policy
Belthrough Privacy Policy
Effective Date: March 15, 2024
Welcome, and thank you for your interest in Belthrough Inc., a Delaware corporation doing business as (dba) Belthrough (together with its affiliates and subsidiaries, “Belthrough”, “we”, or “us”), our websites including https://belthrough.com (“Site”), and all related web sites, downloadable software, mobile applications (including tablet applications), and other services provided by us and on which a link to this Privacy Policy is displayed, and all other communications with individuals though written or oral means, such as email or phone (collectively, together with the Site, our “Service” or “Services”).
This Privacy Policy (“Policy”) describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information. By visiting the Site, or by purchasing or using the Service, you accept the privacy practices described in this Policy.
This Policy is incorporated into, and is subject to, the Belthrough Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Belthrough Terms of Service.
Data Processing Addendum available via link shall be agreed and signed by Client if required to enter into a data processing agreement on behalf of itself. If and to the extent Belthrough processes Personal Data for which Client’s authorized affiliates qualify as the Controller, Data Processing Addendum shall be executed in the name and on behalf of Client’s authorized affiliates.
**Explanation of Service**
We provide a SaaS-based telecommunications platform which enables you to (i) create, and (ii) allow your End Users to utilize, voice and video calls through an internet browser (including related services). Through our Service, you and your End Users can communicate with others through voice, video and/or other forms of communication.
**Privacy Shield Commitment**
Belthrough complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Belthrough has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
As described in the Privacy Shield Principles, Belthrough is accountable for Personal Data that it receives and subsequently transfers to third parties. If third parties that process Personal Data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
**Definitions**
“Client” means a customer of Belthrough.
“Client Data” means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
“End User” means a Client’s customers and end users (including, without limitation, those authorized by Client) of the Service.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“User” means an employee, agent, or representative of a Client, who primarily uses the Restricted Areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the Public Area, but has no access to the restricted areas of the Site or Service.
**What Information Do We Process and How Do We Use it?**
Belthrough collects personal data about individuals in several contexts:
When visiting our website (see below, Passive Collection of Information);
When interacting with us as a business customer;
Or, if you communicate via one of our customers’ platforms.
We use collected information only for the purpose for which you provide it, including client services, email marketing and corporate communications, customer service and feedback or to provide requested information and services.
Depending on the context we may process the following categories of Personal Data — not all categories will be collected about every individual:
– Name,
– Organization name,
– Email address,
– Phone number,
– Billing address,
– Mailing address,
– Credit card and payment details,
– SIP and Skype information (see below for more information),
– Number of calls to and from a provided number,
– Call length to and from a provided number,
– Numbers calling or called by a provided number,
– Call content and usage information,
– Contact information associated with a corporate Client account,
– Usage data (see below for more information).
**Personal Data**
Personal Data includes information collected, received, accessed, used and disclosed (both online and offline) that allows us to identify you. Examples of this kind of information include, as applicable, your name, organization name, email address, login and password, phone number, billing address, mailing address, credit card and payment details, data required for registration, and other similar kinds of information that may be used for the same purpose. We may also request photo identification and/or proof of address information for account verification, telephone number verification, and legal compliance purposes.
**Usage Information**
Usage Information, under some circumstances may be a type of Personal Data, and consists of information provided passively or generated automatically during your use of Belthrough’s Service including the number of calls, call length, called numbers and call content. Usage Information may include Call Detail Record information (“CDR”) and other call records of Clients and End Users. CDR records may include Personal Data including (i) the identity of an End User who initiates a voice or video call, and (ii) the identity of the person which receives such voice or video call. Unless required under applicable law, we don’t provide information on calls, call length, called numbers or call content to any third party.
**SIP & Skype Account Information**
SIP account information consists of SIP requisites you enter in order to redirect calls using the Belthrough Services. Skype account information consists of Skype ID that you enter in order to redirect calls using the Belthrough Services. Unless required by applicable law, this information is not provided to any third party.
**Integrated Services**
You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google or Facebook account, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store information that the Integrated Service makes available to us (including, without limitation, your name, email address(es), date of birth, gender, current city, profile picture and URL), and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service may make available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.
**Tracking of Website Visitors**
As is customary for most websites, we automatically collect certain information and store it in log files. This data may encompass internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, or clickstream data. We may merge this automatically collected log information with other data we gather about you. This amalgamation aids in enhancing marketing strategies, analytics, and site functionality. The collected information may consist of Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data for analyzing trends collectively and managing the site efficiently.
**Tracking Technologies**
When you engage with Belthrough.com, we employ technologies like cookies, beacons, tags, and scripts to gather information about you. These technologies assist in analyzing trends, managing the site, tracking users’ movements on the site, and compiling demographic information about you and our user base overall. Reports generated from the use of these technologies may be on an individual basis as well as aggregated.
We utilize cookies for various functions, including user authentication, our shopping cart, and personalizing the user experience. Users retain control over cookie usage at the individual browser level. If cookies are declined, browsing our site remains possible, but access to most features or areas of our websites may be restricted. More information about our Cookie Policy is available here.
**Social Media**
When interacting with us on social media platforms such as Facebook and Instagram, we may gather information concerning your interactions with us (such as items you have ‘liked’) and profile details you have opted to disclose publicly. Should you wish to limit access to your social media profiles, you can adjust your settings on the respective social media provider’s website.
Personal Data & Non-Personal Data
Personal Data:
Belthrough will not lease or sell your Personal Data to third parties. We may store Personal Data in locations beyond the immediate control of Belthrough (for example, on servers or databases situated alongside hosting providers including, but not limited to, Amazon Web Services, Servers.com, Google Cloud, and Liquid Web (‘Hosting Providers’). Hosting Providers for Belthrough may have servers physically positioned anywhere globally (including outside the European Union). Any Personal Data you choose to make publicly available on our Site or through the Service, such as posting comments on a blog page, will be accessible to others. Should you remove publicly available information from our Site or the Belthrough Service, copies may persist in cached and archived pages of our Site or the Belthrough Service, or if other users have copied or saved that information. Registration may be required to post a comment on our blog.
Non-Personal Data:
We may collect and share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, IP address, browser and platform types, referring/exit pages, operating system, number of clicks, etc.) with interested third parties to aid in comprehending usage patterns for specific Belthrough Services and those of our partners.
Use of Information
We utilize the information we gather in various ways to provide the Service and operate our business, including operations, enhancements, and communications. Such uses include facilitating the operation of our business and Site, adhering to applicable laws, delivering products and services, or as otherwise appropriate in connection with a legitimate business necessity, including, but not limited to:
(1) enabling, providing, and improving the efficacy of Belthrough’s Site, products, or services (including the Service and for any additional purposes delineated in agreements between Belthrough and its Clients, including acting as a data processor on behalf of its Clients which act as data controllers);
(2) conducting customer service activities (including via email and telephone), such as administering an account, processing/fulfilling/confirming orders, billing, providing technical support, responding to requests, providing updates, and customizing, enhancing, upgrading, and improving the Site and offerings;
(3) executing sales, marketing, and promotional activities (including sales tracking and administering contests), as well as managing customer relationships (including newsletters, notices, and sending requested product or service information); and
(4) handling internal business processes and management, analysis (including usage trends and preferences), crime/fraud detection and prevention, security, safeguarding Belthrough’s legal rights, and compliance with governmental, legislative, and regulatory requirements.
You possess the option to opt-out of receiving promotional communications as detailed below under ‘Your Choices.’
Belthrough may divulge Personal Data to business partners and subcontractors as necessary for providing Belthrough’s Services, including performing mandatory processes for identifying and verifying the client’s identity, or as otherwise suitable in connection with a legitimate business necessity. These companies are authorized to utilize Personal Data only as needed to provide such services to Belthrough.
Credit card details are handled securely to ensure confidentiality, and 128-bit SSL encryption is employed to protect sensitive data during transmission over the internet.
The Site also features a blog where public access to your feedback is available, as well as access by the Belthrough team.
Feedback sent via Belthrough email is accessible solely by the Belthrough team.
We retain the right to use Personal Data and Non-Personal Data for marketing purposes (such as displaying selected comments on our website or in other communications) and to comply with applicable laws (including, but not limited to, providing data to our telecommunications providers, including Voxbone, headquartered in Belgium).
Periodically, we may send you surveys or solicit your feedback. Surveys aid in gauging user interest in new products and premiums we may offer. Feedback may also be requested concerning site features. The information gathered is used to enhance our Site and provide a more meaningful experience to Clients and End Users. Additionally, the information may be used to notify you about offers and products in which you have expressed interest.
In the event that we (and/or our business lines, subsidiaries, or affiliates) are ever sold, acquired, merged, liquidated, reorganized, or otherwise transferred, we reserve the right to transfer our user databases (together with any Personal Data or Non-Persona Data contained therein) to a third-party acquiring our assets. If such an event occurs, a prominent notice of the sale will be displayed on the homepage of our corporate website, along with links providing information on how to modify your privacy preferences.
**Storage and Processing**
As elaborated above, but subject to appropriate safeguards: (i) your information collected through the Belthrough Service may be stored and processed anywhere globally (including, but not limited to, the United States, Europe, or any other country where Belthrough or its subsidiaries, affiliates, or service providers maintain facilities), and (ii) Belthrough may transfer information collected about you, including Personal Data, to affiliated entities or other third parties across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.
Should you opt to store and process Personal Data within a specific territory provided by Belthrough (e.g., the European Union, USA, etc.), we strive to process Personal Data solely on servers located within such a territory. However, our customers may access Personal Data from locations beyond such a territory, and our customer support team may also access Personal Data from outside the chosen territory.”
**How we Protect Your Information**
Belthrough is committed to safeguarding your privacy and data. However, we cannot guarantee the security of any information you transmit to Belthrough, nor can we assure that your information on the Belthrough Service will remain inaccessible, undisclosed, unaltered, or secure against breaches of our industry-standard physical, technical, or managerial safeguards. When you input confidential information (such as login credentials) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). Nevertheless, no method of transmission over the Internet or electronic storage is entirely secure. Hence, we cannot ensure absolute security.
If you have inquiries regarding security on our Site, feel free to reach out to us at support@belthrough.com. We may engage an external assistance platform and a credit card processing company to bill you for Services purchased. However, these entities do not retain, share, store, or utilize Personal Data for any other purposes. No specific software installation is required to use Belthrough Services, and our Site pages do not install any software onto your system.
**Federal Trade Commission**
Belthrough is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). We may be obligated to disclose Personal Data handled under the Privacy Shield in response to lawful requests by public authorities, including those related to national security or law enforcement requirements.
**Data Rights for those in the European Economic Area (EEA), United Kingdom (UK), and Switzerland**
For individuals residing in the EEA, the UK, or Switzerland, our use of your personal information adheres to the European Union’s General Data Protection Regulation (GDPR) or applicable EEA, UK, or Swiss national laws. These regulations grant you specific rights concerning your personal information, including the right to modify, rectify, receive, or delete personal information stored by Belthrough at any time, subject to our business interests and legal requirements.
Moreover, individuals in the EEA, UK, or Switzerland have the right to lodge complaints with a data protection authority regarding our processing of your personal information. For further details, please contact your local data protection authority. We respond to all requests from individuals seeking to exercise their data protection rights under applicable laws. To uphold your privacy and security, we may need to verify your identity before addressing your request.
To exercise any of these rights, you can contact us at support@belthrough.com. If we are unable to resolve your complaint, you may contact your country’s data protection authority.
**Cross-Border Transfers**
Belthrough is headquartered in the United States. Consequently, your personal data may be processed and stored in the U.S., either by us or by our vendors or customers. Depending on the location of our vendors or customers, your information may be transferred to other jurisdictions, including the U.S., which may not offer the same level of data protection as your home jurisdiction.
We endeavor to process EU personal data only on servers located within the EU. However, our customers may access personal data from locations outside the EU, and our customer support may access your personal data from outside the EU. Whenever we transfer your personal data to countries outside the EEA, UK, or Switzerland, we ensure adequate safeguards are in place to protect your data, such as approved transfer mechanisms by the European Commission or specific contractual arrangements.
We utilize supplementary measures, such as TLS1.2 encryption or IPsec tunnels with AES-128 ciphers, to mitigate the risk of mass surveillance during the transit of Personal Data.
**How you can access, update or delete your data**
Ensuring the accuracy and currency of the information we hold about you is crucial. You can update or correct your personal information at any time by contacting us at support@belthrough.com. If you request deletion of your personal data, we will honor it to the extent that it is no longer necessary for the Services purchased or required for our legitimate business purposes, legal, or contractual obligations.
Your California Data Rights
If you reside in California, our use of your information is governed by California law, including the California Privacy Protection Act (CCPA). This section applies only to California residents.
**Personal Information Collected and Purposes of Use**
We collect and utilize information that identifies, relates to, describes, or could reasonably be linked to you or your devices. This includes information collected when you visit our Websites, provide personal information, or have a contractual or business relationship with us or any of our customers.
We collect this information for the purposes outlined in the section above titled “What Information Do You Provide to us and How Do We Use it?”.
**Your Privacy Rights under California Law**
Californians have rights concerning the collection and use of their personal information. You have the right to request information about the personal information we have collected, sold, or disclosed about you. Additionally, you have the right to opt-out of sharing, disclosure, or sale of your Personal Information. You also have the right to request deletion of your personal information, subject to certain exceptions outlined in California law.
You can exercise these rights by contacting us at support@belthrough.com. We will respond to your verified request within the timeframe prescribed by law.
**Your Nevada Data Rights**
If you reside in Nevada, our use of your information is governed by Nevada law. This section applies only to Nevada residents.
**Personal Information Collection and Purposes of Use**
We collect certain personal information of Nevada consumers as identified in the section above titled “What Information Do You Provide to us and How Do We Use it?”.
We collect this personal information for the purposes identified in the same section.
**Your Privacy Rights**
Nevada residents have the right to access, correct, or opt-out of the sale of their personal information. You can exercise these rights by submitting a request to support@belthrough.com. We will respond to your verified request within the timeframe prescribed by law.
**How Do We Protect Your Data, Information, and Resources?**
We employ security technology as supplementary measures to protect the information you provide us. Passive data and data in transit are safeguarded by either TLS1.2 encryption or IPsec tunnels with AES-128 ciphers.
**Your Choices – Access, Correction & Deletion**
We respect your privacy rights and provide you with reasonable access to the Personal Data you have provided through the use of our Services. You can update, correct, or delete your account information and preferences at any time by accessing your Profile page within our site. Please note that while we will promptly reflect any changes you make, we may retain certain information for specific reasons outlined in our Privacy Policy or as required by law.
If you believe your privacy rights have been infringed upon, please contact Belthrough’s Data Protection Officer at support@belthrough.com. You also have the right to lodge a complaint with data protection authorities.
**Data Retention**
We retain Personal Data collected from you only for as long as necessary to fulfill the purposes for which it was collected, unless required by law to retain it for a longer period. We will use and retain information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you need further assistance regarding your privacy rights or our data practices, please contact us at support@belthrough.com. We are committed to ensuring the protection of your privacy and data in accordance with applicable laws and regulations.
**Data Retention**
We only retain the Personal Data collected from you for as long as your account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
• the contents of closed accounts are deleted within twelve (12) months of the date of closure;
• backups are kept for twelve (12) months;
• billing information is retained for a period of seven (7) years as of their provision to Belthrough in accordance with applicable accounting and taxation laws;
• information on legal transactions between Client and Belthrough is retained for a period of seven (7) years as of their provision to Belthrough in accordance with the general limitation period set for civil claims in applicable law.
If you remove information that you have made public on the Belthrough Service or Site, copies may remain viewable in cached and archived pages of the Belthrough Service or Site, or if other users have copied or saved that information. Non-Personal Data may be stored indefinitely.
**Data Controller and Data Processor**
Belthrough does not own, control or direct the use of any of the Client Data stored or processed by a Client, User or End User within the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. Belthrough is largely unaware of what Client Data is actually being stored or made available by a Client or End User to or through the Service and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client, Users and End Users.
Because Belthrough does not collect or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, Belthrough is not acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”), and does not have the associated responsibilities under the GDPR, with respect to Personal Data contained in any Client Data. Belthrough should be considered only as a processor on behalf of its Clients, Users and End Users as to any Client Data containing Personal Data that is subject to the requirements of the GDPR. Except as provided in this Privacy Policy, Belthrough does not independently cause Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties, except to third-party subcontractors who may process such data on behalf of Belthrough in connection with Belthrough’s provision of Services to Clients, User and End Users. Such actions are performed or authorized only by the applicable Client or End User.
The Client or End User is the data controller under the Regulation for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of Personal Data contained within any Personal Data.
Belthrough is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client, Users or End Users, nor is Belthrough responsible for the manner in which the Client, Users or End Users collect, handle disclosure, distribute or otherwise process such information.
**Dispute Resolution**
If you believe your Personal Data has been used in a way that is not consistent with this Privacy Policy, we invite you to contact us first at support@belthrough.com. We will make all efforts to resolve your complaints timely and accurately. Further, we have committed to cooperate with EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC), and to comply with the information and advice provided by such authorities with regard to data transferred from the EU and Switzerland.
Under certain conditions, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
**Modification of Privacy Policy**
We reserve the right to modify the provisions of this Privacy Policy if deemed necessary. We will inform you of these changes on our website.”
Contact Information
You can contact us by writing or email us at the address below:
Belthrough.com, Inc.
Attn: Data Protection
noahdaniel@belthrough.com
brisa@belthrough.com
sales@belthrough.com