POSH VIRTUAL RECEPTIONISTS UK LTD
PRIVACY POLICY

Last Updated: September 2023

POSH VIRTUAL RECEPTIONISTS UK LTD. (“Company” “we” and “ours”) takes the privacy of our customers, our customers’ end users, and our website visitors (“User”, “you” and “yours”) very seriously. This Privacy Policy outlines our policies on the privacy of Personal Information (as defined herein) that we collect via the Internet and/or delivery of our Services (as defined in our Service Terms and Conditions located at (“Terms”). Capitalized terms used herein but not defined will have the meaning given them in our Terms. If you have any questions on the use of information collected on our Site or used for the delivery of our Services, please feel free to contact us at uksupport@posh.com.

As used in this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, such as:

  • Identifiers (e.g., name, address, telephone number, email address, username);
  • Sensitive Personal Information (e.g., government identification number; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient);
  • Protected classification information (e.g., race, citizenship, marital status, medical condition, sex, sexual orientation, veteran or military status);
  • Biometric information (e.g., voice, keystrokes, behavioral or biological characteristics);
  • Internet or other similar activity (e.g., browsing history, content interactions);
  • Employment-related information (e.g., current or past employment);
  • Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); and
  • Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.

Personal Information does not include (i) publicly available information; (ii) aggregate information, meaning data about a group or category of Services or Users from which individual identities and other Personal Information has been removed; or (iii) deidentified information that cannot be easily linked back to the individual. We collect your Personal Information (a) with your consent; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. Personal Information as used herein includes Personal Data as defined by applicable law. We collect Personal Information from these sources:

Consumers. We interact with consumers (“Consumers”) who call, text, message, or communicate with us as a service provider to you and our other customers (“Customers”):

  • We collect and use Personal Information from Consumers via phone, text, chat, text-to-chat, email, SMS, MMS, or other channels as needed to provide our Services to our Customers.
  • If you are a Consumer contacting one of our Customers, we may collect your contact information or other identifiers, as well as Personal Information like the contents of your message to our Customer you are contacting. We collect this information to support our Customers in their efforts to assist you.

Customers. We collect and use Personal Information from our Customers with your consent and according to your instructions, as follows:

  • When you sign up as a Customer, we will collect information about your company such as name, email, phone, and other identifiers for yourself or your employees.
  • You as a Customer may provide us with your employee’s identifiers or employment-related information to include the employee in your list of potential call recipients, grant the employee access to our software or other Services or include your employee in our marketing communications. You and any of your employees may opt-out of receiving marketing communications from us at any time. If you opt-out of marketing communications, we may continue to send you product and support messages to keep you updated on the Services you receive.
  • We collect any information you submit via the mobile application, Customer self-service portal, or other software, such as account profile information and any Personal Information included in communications with us related to your subscription and/or our Services.
  • If you collect technical information about your Consumers’ online activities, you may share that information with us. We may combine this information with other data to gather feedback about our software and to run reports on your behalf. We only use the information you provide to us in our capacity as a service provider as permitted by our Agreement with you or as permitted by law. You may use this information for your own purposes according to your own privacy practices.

Note that you are solely responsible for ensuring you are authorized to share Personal Information with us for any purpose. We reserve the right to refuse your instructions to collect or process Personal Information about another individual without their consent or in a manner or for a purpose that we determine violates others’ privacy or publicity rights or otherwise violates our Terms, and such instructions may result in termination of Services at our option. We are not responsible for the privacy practices of any of our Customers or any third party.

Your Inquiries. If you contact us as a potential new Customer, Site visitor, or for any other reason, we will collect Personal Information from you to respond to your inquiry:

  • If you request information about our Services, through an online form, via chat, by text, email, or by phone, we will collect your name, email address, and other contact information as needed to provide you with the information you request. We collect this information with your consent, and we use it for the purposes stated at the time of collection, to provide you with our Services, and to communicate with you or send you direct marketing communications.
  • Where state law allows, if you participate in a phone call with a member of our team, we may record the call. We engage in call recording for quality monitoring, and training, to improve our Services, and for other internal business purposes. If you are in a state that requires notification, you will be notified if your call is being recorded. By staying on the line after receiving the notification, you consent to the call recording. If you do not consent to call recording, you may end the call or ask not to be recorded.

SECURITY
Our Site takes every precaution to protect our Users’ information. When you submit sensitive information via our Site, your information is protected both online and off-line. If we ask you to enter information, such as a credit card number and/or a social security number, that information is encrypted using SSL. While on a secure page, the lock icon on the bottom of Web browsers such as Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when you are just “surfing.”

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect your information off-line. All of your information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing staff or a customer service representative) are granted access to Personal Information. Our employees are kept up-to-date on our security and privacy practices.

COOKIES
A cookie is a piece of data stored on your hard drive containing information about you. The usage of a cookie is not linked to any Personal Information while on our Site. Once you close your browser, the cookie simply terminates. For instance, by setting a cookie on our Site, you would not have to log in with a password more than once, thereby saving time while on our Site. If you reject the cookie, you may still use our Site. Cookies can also enable us to track and target your interests to enhance the experience on our Site.

WEB SERVER LOG FILES
We use IP addresses to analyze trends, administer our Site, track Users’ movements, and gather broad demographic information for aggregate use. IP addresses are not linked to Personal Information.

SHARING
We may disclose Personal Information for a business purpose to:

  • Affiliates. We work closely with our affiliated companies (“Affiliates”) to identify mutual or shared Customers and offer enhanced, integrated, or co-branded Services. If you use an integrated Affiliate service with our Services, we may disclose Personal Information collected about or on your behalf to one another to provide the integrated Services. For example, we share Personal Information for customer support purposes, marketing, or technical operations.
  • Professional Associations. If a Customer is a member of a professional association with which we have a referral or affinity agreement, we may pay a referral fee to your professional association and, if requested by the association, disclose your name and contact information and the type or amount of our Services used by you as an association member.
  • Service Providers. Vendors that provide us with services (“Service Providers”) may receive Personal Information to perform their contractual obligations. Our Service Providers include but are not limited to telecom providers, marketing companies, IT service providers, billing processors, and email and data hosting providers. For example, we may share identifiers to register your phone number or SMS campaign with our telecom provider, subject to their terms and conditions. We prohibit our Service Providers from selling or disclosing the Personal Information we provide, and we require all Service Providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information. The type of information that we provide to a Service Provider will depend on the service that they provide to us. To learn more about our Service Providers, read our Data Processing Agreement.
  • Advertisers. We may disclose Personal Information to Service Providers we use for advertising purposes (collectively, “Advertisers”) to serve targeted advertisements. We may directly share Customer names with the Advertiser or allow the Advertiser to collect and analyze cookie data from your use of our Site (see our Cookie Notice) to assist us with behavioral advertising.
  • Law Enforcement and Other Governmental Agencies. Additionally, if, in our sole discretion, we perceive that you are an imminent threat to your own physical safety or the physical safety of another person then we may disclose your Personal Information to law enforcement.
  • Other Third Parties. As permitted by applicable law. We may disclose Personal Information collected to other third parties, for example: (i) if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); (ii) to comply with a legal requirement or a court order; (iii) when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; (iv) to exercise or defend our legal claims; or (v) for any other reason with your consent.
  • Aggregated and Deidentified Information. We reserve the right to share aggregated, anonymized, or deidentified information for marketing, advertising, research or other purposes, without restriction.

LINKS
Areas of this Site may contain links to other websites. Please be aware that we are not responsible for the privacy practices of other such websites. We encourage our Users to be aware when they leave our Site to read the privacy statements of each and every website that collects Personal Information.

NOTIFICATION OF CHANGES
If we decide to change our Privacy Policy, we will post those changes on our Site so Users are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

QUESTIONS
If you have any questions or concerns or would like more information on this Privacy Policy please email uksupport@posh.com.

Individual Rights

  • Right to Know About Personal Information Collected, Disclosed, Shared, or Sold

You have the right to request that we disclose the personal information we collect, use, and disclose about you to third parties. There are two types of Rights to Know requests that you can make:

  • 1. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
    • a. Categories of personal information collected, sold, or shared;
    • b. Categories of sources from which personal information is collected;
    • c. Categories of third parties to whom the information is sold, shared or disclosed;
    • d. Business or commercial purpose for collecting, sharing, or selling personal information;
    • e. Categories of personal information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.
  • 2. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
  • Specific pieces of personal information collected about you.

This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

  • Right of Deletion

You have the right to request that we and our service providers delete any personal information about your which we have collected from you upon receipt of a verifiable request. This right is subject to certain exceptions. We will state in our response if an exception applies.

  • Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your personal information by a business subject to certain laws and regulations.

We recognize the Global Privacy Control. Your browser must be able to support the Global Privacy Control (“GPC”) for us to recognize your opt-out preference signal.

Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.

  • Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by UK and EU law. We will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

  • Right of Correction

If we maintain inaccurate personal information about you, then you have the right to request that we correct the inaccurate personal information upon receipt of a verifiable request. Taking into account the nature of the personal information and purposes of processing the personal information, you have the right to request that we correct inaccurate personal information about you, if applicable.

  • Right to Limit Use and Disclosure of Sensitive Personal Information

If we process Sensitive Personal Information, we will only do so for the purposes specifically authorised by UK and EU law and in a manner that is necessary and proportionate for those purposes. As such, we do not perform any processing for which a Right to Limit request is available.

Where we process your personal data on the basis of your consent, you may withdraw your consent at any time without any prejudice to you by contacting us using the contact details below. This will not affect the processing of your data based on your consent previous to the point at which you withdraw consent.

Please note that some of these rights are limited by applicable Data Protection Law and we have the right to collect, process and hold your Personal Data to perform our legal obligations. We may require you to provide additional information necessary to confirm your identity before we comply with any request made by you.

  • Submitting Requests

You can submit your request by emailing us at uksupport@posh.com or by phone at +44(0) 20 3376 6020

  • Verifying Requests

To ensure the protection of your personal information, we must verify that the individual submitting a request to know, request to delete, or request to correct is the Consumer to whom the request relates prior to processing the request. To verify a Consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury from the Consumer whose personal information is the subject of the request.

Making a verifiable Consumer request does not require you to create an account with us.

We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of Consumers where we have reason to believe a request is fraudulent.

  • Authorized Agents

You may choose a person or a business registered within the UK or EU that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in Posh Virtual Receptionists UK Ltd denying your request.

  • Contact Us

If you have any questions about this Privacy Policy, please contact us by email at uksupport@posh.com, via phone +44(0)20 3376 6020 or at:

Posh Virtual Receptionists UK Ltd,
Suite A, 3 Forbury Place,
Reading
Berkshire,
RG1 3YA

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