© 2021, All Right Reserved

Privacy Policy

We, Cornwall Telecom Limited, take your privacy seriously. Therefore, we have approved this Privacy Policy.

This Privacy Policy (Policy) supplements our Terms and Conditions (Terms). Any capitalized term used in this Policy has the definitions given to them in our Terms. This Policy shall apply in conjunction with the Terms, and in the event of any conflict between them, this Policy shall prevail.

We remind you that our contact address is an email address: sales@vox.do

1. About the Policy

1.1. This Privacy Policy covers how we process, use and disclose Personal Data that we collect when you access or use our Services.

1.2. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "Personally identifiable information" (PII) or "Personal information" (PI) according to the Applicable Law.

1.3. This Privacy Policy does not cover the practices of companies we do not own or control or people we do not manage.

1.4. This Policy does not apply to data that is not Personal Data, including anonymous and de-identified data created by us by deleting all information that allows such data to be associated with a specific person. We reserve the right to use such data and transmit it to third parties for our legitimate purposes and in accordance with Applicable Law, while ensuring that such data, in any case, cannot be associated with you.

2. Personal Data, Collection and Disclosure

2.1. In order to simplify this Policy, we have grouped all Personal Data we collect in the table below. If you have any questions regarding the terminology or contents of the table, please read the following provisions of the Policy.

2.2. Personal Data Table

(1)

Category of Personal Data
(2)

Type of Personal Data
(3)

Method of collecting and obligation to provide
(4)

With whom can be shared

Profile or Contact Data
Email
Phone number
Location (country and city of residence)

First and last name
Date of birth
Unique identifiers such as hashes and passwords
Provided and can be changed by user, are required for the provision of Services

Provided and can be changed by user, are not required for the provision of Services
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate
Category of Personal Data (1)
Profile or Contact Data
Type of Personal Data (2)
Email
Phone number
Location (country and city of residence)

First and last name
Date of birth
Unique identifiers such as hashes and passwords
Method of collecting and obligation to provide (3)
Provided and can be changed by user, are required for the provision of Services

Provided and can be changed by user, are not required for the provision of Services
With whom can be shared (4)
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate

Payment Data
Payment card type

Last 4 digits of payment card

Billing address, phone number, and email
Collected by us for the payment service, are required for payments
We
Service Providers (Stripe, Inc, etc.)
Category of Personal Data (1)
Payment Data
Type of Personal Data (2)
Payment card type

Last 4 digits of payment card

Billing address, phone number, and email
Method of collecting and obligation to provide (3)
Collected by us for the payment service, are required for payments
With whom can be shared (4)
We
Service Providers (Stripe, Inc, etc.)

Commercial Data and information on receiving the Services
Subscription and payment history

Data on activity and phone calls
Collected automatically after user consent, are required for the provision of Services

Collected automatically after user consent, are not required for the provision of Services
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate
Category of Personal Data (1)
Commercial Data and information on receiving the Services
Type of Personal Data (2)
Subscription and payment history

Data on activity and phone calls
Method of collecting and obligation to provide (3)
Collected automatically after user consent, are required for the provision of Services

Collected automatically after user consent, are not required for the provision of Services
With whom can be shared (4)
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate

Device data and related information
IP address
Device ID (UUID or another unique identifier)
Type of device/operating system/browser used to access the Services (fingerprint)
Domain server
Timezone
Language
Collected automatically after user consent, required for the provision of Services
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate
Category of Personal Data (1)
Device data and related information
Type of Personal Data (2)
IP address
Device ID (UUID or another unique identifier)
Type of device/operating system/browser used to access the Services (fingerprint)
Domain server
Timezone
Language
Method of collecting and obligation to provide (3)
Collected automatically after user consent, required for the provision of Services
With whom can be shared (4)
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate

Analytics of behavior on the Website
Data about your behavior on the Website:
  • time spent (session duration)
  • data about transitions (clicks, taps)
  • data on the movement of the cursor or other pointer
  • content scrolling data
  • other analytics available for collection
Collected automatically after user consent, are not required for the provision of Services
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate
Category of Personal Data (1)
Analytics of behavior on the Website
Type of Personal Data (2)
Data about your behavior on the Website:
  • time spent (session duration)
  • data about transitions (clicks, taps)
  • data on the movement of the cursor or other pointer
  • content scrolling data
  • other analytics available for collection
Method of collecting and obligation to provide (3)
Collected automatically after user consent, are not required for the provision of Services
With whom can be shared (4)
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate

Cookies
Small files that are stored in your device's memory and are designed to personalize your activity and behavior on the Website and other sites
Collected automatically after user consent, are not required for the provision of Services
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate
Category of Personal Data (1)
Cookies
Type of Personal Data (2)
Small files that are stored in your device's memory and are designed to personalize your activity and behavior on the Website and other sites
Method of collecting and obligation to provide (3)
Collected automatically after user consent, are not required for the provision of Services
With whom can be shared (4)
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate

Browser cache
Files that are stored in your device's memory and speed up Website loading times

(Transmitted in relation to the Website)
Collected automatically after the user's consent, are not required for the provision of Services
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate
Category of Personal Data (1)
Browser cache
Type of Personal Data (2)
Files that are stored in your device's memory and speed up Website loading times

(Transmitted in relation to the Website)
Method of collecting and obligation to provide (3)
Collected automatically after the user's consent, are not required for the provision of Services
With whom can be shared (4)
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate

Personal Data processing results
Profiles that accumulate data about users and their behavior
Formed on the basis of the collected Personal Data, are not required for the provision of Services
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate
Category of Personal Data (1)
Personal Data processing results
Type of Personal Data (2)
Profiles that accumulate data about users and their behavior
Method of collecting and obligation to provide (3)
Formed on the basis of the collected Personal Data, are not required for the provision of Services
With whom can be shared (4)
We
Service Providers
Advertising Partners
Business Partners
Parties You Authorize, Access or Authenticate

Other Identifying Information that You Voluntarily Choose to Provide
Other Personal Data provided by you through the Website, via email or communication media
Provided by user, are not required for the provision of the Services
Business Partners
Parties You Authorize, Access or Authenticate
Category of Personal Data (1)
Other Identifying Information that You Voluntarily Choose to Provide
Type of Personal Data (2)
Other Personal Data provided by you through the Website, via email or communication media
Method of collecting and obligation to provide (3)
Provided by user, are not required for the provision of the Services
With whom can be shared (4)
Business Partners
Parties You Authorize, Access or Authenticate

2.3. Categories of Personal Data (1) and their type (2) determined by us based on the Applicable Law and the nature of the Services provided. In case you notice the absence of a certain type of Personal Data in columns (1) or (2) of the Table, please report it to our contact address, and we will check if we are actually collecting this type of Personal Data.

2.4. The availability of Personal Data in columns (1) or (2) applies only to the possibility of collecting such data, and does not mean that we collect all your Personal Data of this type.

2.5. In all cases, when we collect data automatically (3), we are committed to properly notify you or obtain your consent.

2.6. The provision of certain Personal Data is indicated in column (3) as required, which means that if you refuse to provide such Personal Data, we will not be able to guarantee the proper operation of the Website, and, as a result, we will not be able to provide the Services properly in part or in whole.

2.7. Personal data indicated in column (3) as optional, can, however, significantly affect the nature and quality of the Services, so we recommend you to provide all requested Personal Data for optimal performance.

2.8. We disclose your Personal Data to the categories of service providers and other parties listed in (4) only. Depending on Applicable Law, some of these disclosures may constitute a "sale" of your Personal Data.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Hosting, technology and communication providers
Security, spam, and fraud prevention consultants and providers
Analytics providers
Monitoring service providers
Data management platforms
Support and customer service vendors
Product fulfillment and delivery providers
Payment processors
Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
Ad networks
Marketing partners and providers
Business Partners. These parties partner with us in offering various services. Including companies with which we have a business relationship or companies with which we do business.

Parties You Authorize, Access or Authenticate:
Third parties you access through the Services
Social media services
Other persons
Other users
2.9. All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other reorganization in which that third party assumes control of us in whole or in part. If one of these events occurs, we will use reasonable efforts to notify you before your information is shared with a third party.

3. Our Commercial Purposes for Collecting Personal Data

3.1. Provision, customization and improvement of the Services
Create and manage your account or other user profiles
Processing orders, calls, actions or other transactions; billing and payments
Operation and maintenance of the Website functions
Provision of the products, features, or information you request from the Services
Achievement of the purpose for which you provide us with your Personal Data
Providing support and assistance in the provision of the Services
Answering your inquiries
Improving the quality of the Services, including testing, research, internal analytics and product development
Ensuring and monitoring the effectiveness of the Services
Personalize the Services, the Website, and the Content based on your preferences
Remembering information so that you do not have to re-enter it the next time you visit the Website or use the Services
Monitoring aggregate metrics such as total number of visitors, traffic, usage and demographic patterns on our Website
Maintaining interaction with third party services
Performing anti-fraud, security and debugging
Diagnostics or elimination of technological problems
To fulfill other specified business purposes according to Applicable Law
3.2. Marketing and Promotion of Services:
Marketing and selling of Services
Displaying advertisements to you, including interest-based or behavioral advertisements while receiving the Services
3.3. Communication with you:
Respond to correspondence we receive from you, contact you as needed or upon request, and send you information about us and the Services
Sending emails and other messages about the latest changes or according to your preferences, as well as displaying content that we think will interest you
3.4. Compliance with the requirements of the Applicable Law:
Complying with legal obligations in accordance with Applicable Law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities
Protecting our or your rights, property or safety
Protecting our or your rights, property or safety
Resolution of disputes
3.5. We will not collect additional categories of Personal Data or use the Personal Data we collect for materially different, unrelated or incompatible purposes without notifying you.

4. Security and Retention of Personal Data

4.1. We seek to protect your Personal Data from unauthorized access. To do this, we take appropriate physical, technical, organizational and administrative measures, based on the type of Personal Data and how we are processing that data.

4.2. We ask you to assist us in protecting your Personal Data by choosing secure passwords, protecting them and other authorization mechanisms, restricting third-party access to your computer, browser or mobile device, and terminating a session and logging out of your account after receiving the Services. Also, please note you need to use safe methods of data transfer and storage on the Internet.

4.3. We retain your Personal Data until your account is deleted, or, if you ask us about it before then, until the satisfaction of your requests. In exceptional cases, we may store your Personal Data for a longer period of time if this is necessary to comply with Applicable Law or for our participation in a dispute or claim.

4.4. The storage of your Personal Data is carried out using all the necessary security measures on servers located in the European Union.

5. Personal Data of Children

5.1. As noted in the Terms, we do not knowingly collect or solicit Personal Data about children under 18 years of age. If you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data.

5.2. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible.

5.3. If you believe that a child under 18 years of age may have provided Personal Data to us, please email us at our contact address.

6. Our Cookie Policy

6.1. Websites use cookies. Cookies are small pieces of data (usually text files) placed on your computer, tablet, phone or similar device when you use that device to access our Services, which helps to manage the individual settings of the Website, collect your Personal Data and transfer it to us. We will send you a notice on your first visit to the Website.

6.2. While a cookie can identify your device, it should not personally identify you unless you are using an Account on the Website.

6.3. We use cookies to personalize your browsing experience (for example, to remember your preferences and recognize you as a repeat visitor to our website) and to track usage statistics for our Website. This allows us to better understand our users and improve the look and functionality of the Website.

6.4. In particular, we use the following cookies:
Essential cookies
Necessary for the operation of our Website. For example, cookies enable you to enter the secure area of our website using your Account
Performance/Analytical cookies
Allow us to count the number of users and see how users navigate the Website. This helps us to improve the way the Website works, for example by ensuring that users will easily find what they are looking for
Retargeting/Advertising Cookies
These cookies record your visit to the Website, the pages you visit and the links you click on. We will use this information based on your choices and preferences to make the Website and any advertisements displayed on it more relevant to your interests
Third party/shared cookies
Cookies that are set by a domain other than the one you are visiting. If you visit the Website and a separate company sets a cookie through the Website, then it is a third party cookie. In order to try to convey to you offers and advertisements that interest you, we maintain relationships with third parties, including Google, Adobe Analytics, Facebook, LinkedIn, Instagram, TikTok, Pinterest, Quora, Reddit, Snapchat, Twitter, Yandex, VK, which allow them to place cookies on our websites
6.5. These Third Party providers can:
Use third party cookies, web beacons and other technologies to collect or receive information from the Website and from other sources on the Internet
Compare the information provided by us with information collected on the Internet; and use this information to provide advertising measurement and targeting services to you
6.6. Session cookies are temporary. They allow website operators to associate the actions of a user during a browser session, the period of time between a user opening a browser window and closing it. Once closed, cookies are deleted. Persistent cookies remain on the user's device for a period of time specified in the cookie.

6.7. If you do not want to receive any cookies (other than those that are strictly necessary), you can set your browser to request or decline cookies. Please note that opting out of cookies may mean that not all functions on the Website will be available to you.

6.8. You can find more information about cookies on the websites http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are in the European Union.

7. California Resident Rights

7.1. If you are a California resident, you have the rights set forth in this section. In the event of any conflict between this section and the Policy, or between this section and the Terms and Conditions, and you at the same time are a resident of California, in relation to your subject to the application of that provision, which provides greater protection of your Personal Data. If you have any questions, please feel free to contact us at our contact email.

7.2. You have the right to receive information about the Personal Data we have collected over the past 12 months. In response to your request, we will provide you with the following information:
Type (1) and type (2) of Personal Data collected about you
Method (3) of collecting Personal Data
The commercial purposes for which such Personal Data was collected and disclosed
List of third parties by category (4) to whom your Personal Data was disclosed
Features of the Personal Data collected about you
We do not currently sell any Personal Data, and we have not done so over the past 12 months.

7.3. You have the right to request that we delete your Personal Data that we have collected. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

7.4. To exercise the rights described above, you or your Authorized Agent must send a request to our contact address that meets the following requirements:
It contains sufficient information to identify you (for example, your account details)
It contains your detailed request, which we can understand, evaluate and to which we can respond
Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

7.5. We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

7.6. You may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

7.5. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services. However, we may provide you with Services to a different extent permitted by Applicable Law and at a different Subscription price depending on the amount of Personal Data you provide.

7.6. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes. To submit such a request, please contact us at our contact address.

7.7. Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support "Do Not Track" requests at this time. To find out more about "Do Not Track," you can visit www.allaboutdnt.com.

8. European Union Data Subject Rights

8.1. If you are a resident of the European Union ("EU"), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined below.

8.2. For this section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

We are the controller of your Personal Data processed in connection with the Services.

8.3. If there are any conflicts between this section and the Policy, or between this section and Terms, and you are a resident of the jurisdictions indicated above, it will apply to you the provision that provides more protection for your personal data. If you have any questions, do not forget to contact us at our contact address.

8.4. Columns (1) and (2) of the Personal Data Table contain a list of the Personal Data we collect.

8.5. The "Our Commercial or Business Purposes for Collecting Personal Data" section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis in accordance with the Applicable Law. Such legal basis includes your consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below:

Contractual necessity: We process the following categories of Personal Data as a matter of "contractual necessity", meaning that we need to process the data to provision of Services in accordance with the Terms. In the event that we process data within the contractual necessity, your inability to provide us with the relevant Personal Data will result in your inability to use the Website in part or in whole. This may apply to the following types of Personal Data from the table:
Profile or Contact Data
Payment Data
Commercial Data and information on receiving the Services
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties
Profile and Contact Data
Device Data and related information
Web Analytics
Social Network Data
Other Identifying Information that You Voluntarily Choose to Provide
Results of processing your Personal Data
We may also de-identify or anonymize Personal Data to further our legitimate interests
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with an Applicable Law, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary to protect the public interest

8.6. Column (4) of the Tables and the following provisions of the relevant section detail how we disclose Personal Data.

8.7. As a resident of the jurisdictions mentioned in this section, you have certain rights with respect to your Personal Data, including those set forth below:
Access
You can request more information about the Personal Data we keep about you and request a copy of such Personal Data. Be aware that you can also access part of your Personal Data through your Account, Website, Application, or when receiving the Services
Rectification
If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Be aware that you can also correct some of this information directly by logging on to your account or upon receiving the Services
Erasure
You can request that we erase some or all of your Personal Data from our systems
Withdrawal of Consent
If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Be aware that after exercising such a right, we will ask for your consent in every necessary case if such processing of your Personal Data is necessary for the provision of the Services
Portability
You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible
Objection
You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes
Restriction of Processing
You can ask us to restrict further processing of your Personal Data
Right to File Complaint
You have the right to lodge a complaint about Frame.io's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

9. Changes to this Privacy Policy

9.1. We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. We reserve the right to do this unilaterally, according to the Terms.

9.2. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

9.3. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Email: sales@vox.do
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