VOX SOLUTIONS GROUP PRIVACY NOTICE

1. ABOUT VOX SOLUTIONS GROUP

The Vox Solutions Group respects your right to the protection of Personal Data and considers that any collection and processing of such data must be carried out responsibly and in full compliance with Applicable Law.

For the purposes of this information note, Vox Solutions Group is considered the Data Controller. Also, in the context of this Privacy Notice, Applicable Law refers to all applicable legislation on the protection of Personal Data or on the protection of individuals with regard to the processing of Personal Data.

Vox Solutions reserves the right to update, change, modify or amend this Privacy Notice in order to comply with any Applicable Law or to adapt it to our evolving business practices. Unless we are required by the Applicable Law to provide a prescribed form of notice and/or obtain consent, in which case we will do so, the latest version of this Privacy Notice will always be available on our company website.

We would also like to inform you about how we will use this data and about your rights under the legislation on the protection of Personal Data or on the protection of individuals with regard to the processing of Personal Data and how you can exercise those rights through the communication channels provided by the Vox Solutions Group.

2. CATEGORIES OF PERSONAL DATA PROCESSED

In the context of this notice, “Personal Data” refers to information that (alone or when used in combination with other information) is capable of being associated with or could reasonably be associated with an individual. Personal Data may also have specific meanings under different privacy laws. The personal data collected varies based on the circumstances of collection, particularly:

2.1 AT BUSINESS & INTERNAL EVENTS

When registering to attend or checking in at an event organized by us, it is customary for us to collect personal data. Additionally, in the course of our engagement at different business events organized by third-party entities, we may similarly collect your contact information. We may also conduct this processing for employees and internal events.

The personal data collected at events may include, but is not limited to:

A. Contact Details – this includes: your name, job title, company name, country/region, fixed and/or mobile phone number, email address, job functions.

When you are attending and event organized by us, we may collect additional information such as:.

B. Government-issued Identification – this includes: passport details, or other government issued documentation as may be needed for compliance with laws.

C. Audio and Visual Information – this includes: audio, visual, or similar information relating to your participation in the event or your interactions with us. These images may be used Vox Solutions in its promotional materials, including on its website and off-line materials (e.g. brochures, etc.) and broadcast on other media channels, including social media channels.

D. Third Party Personal Data – If you intend to provide us with Personal Data about other individuals (e.g. your colleagues), you must provide a copy of this Privacy Notice to the relevant individuals, either directly or through their employer.

2.2. ON OUR WEBSITE OR OTHER RELATED SOFTWARES, DIGITAL CHANNELS, APPS AND SOCIAL MEDIA;

We collect information from you when you interact with us, sign up to receive newsletters or the latest insights and updates from us, or otherwise provide feedback to us through social media or our other digital channels.

If you access our official social media pages, your Personal Data will be processed in accordance with this Privacy Notice, alongside the conditions of use, privacy policies and access regulations that belong to the applicable social network. We may process your Personal Data to inform you of our activities, products or services, or for other purposes that the regulations of social networks allow.

In this case, Vox Solutions processes the Personal Data provided by you, which may include but is not limited to:

A. Contact Information – this includes your name and surname, job title, employer name, country/region, fixed and/or mobile phone number, email address, your preferences in terms of channels of communication and frequency of communication and other personal data you provide to us.

B. Electronic identification data – this includes IP address, online identifiers/cookies, logs, access and connection times, where required for the purpose of delivering products or services to our company.

C. Cookies –  You may review our Cookie Policy, here.

2.3 IF YOU ENGAGE WITH US FOR MARKETING AND BUSINESS DEVELOPMENT ACTIVITIES, BUSINESS COMMUNICATIONS AND OTHER ONLINE AND OFFLINE BUSINESS INTERACTIONS;

We collect all data essential for successfully maintaining a business relationship with a customer such as information needed to conclude an agreement, create a customer account, to execute an agreement, to allow customers to use our Services, or to bill the customer accordingly.

We also utilize data for business development initiatives, including market analysis, product enhancement, and strategic partnerships. This data informs our decisions regarding investments, acquisitions, and collaborations aimed at expanding our offerings and improving our services for users worldwide.

In this case, Vox Solutions processes the Personal Data provided by you, which may include but is not limited to:

A. Contact Information – this includes name and surname, (business) address, phone number and email address, company  name and industry, and business role, as well as Customer support data (i.e. customer support communication including the content of customer support tickets).

B. Third Party Personal Data – If you intend to provide us with Personal Data about other individuals (e.g. your colleagues), you must provide a copy of this Privacy Notice to the relevant individuals, directly or through their employer.

We may obtain this Personal Data indirectly through business and professional networks and databases (such as LinkedIn) or third parties we might employ that supply us with information collected from publicly available sources and data providers. We only retain the information that will help us reach potential customers or suppliers that could benefit from our services and products, or if we are interested in their products and services.

We may also obtain this information from your employer or entity by whom you are engaged as a contractor or temporary staff member. This may happen, for instance if your employer is a Vox Solutions Group Partner or if your employer (or entity by whom you are engaged a contractor or temporary staff member) provides services to the Vox Solutions Group and you are involved in the provision of these services.

We might also obtain this information from third parties, including telecommunication publications, event’s organizers, other agencies or trusted publicly available sources (such as LinkedIn, I3 Forum, TM Forum, GSMA or ITU websites.

2.4 IF YOU ENGAGE WITH US TO PURSUE AN EMPLOYMENT / CONTRACT OPPORTUNITY WITH US

We collect and use Personal Data in order to find talented individuals who will become part of our team by enabling you to apply for a job or internship with us in order to assess whether you are a good fit for a position at Vox Solutions.

In this case, Vox Solutions processes the Personal Data provided by you which may include but is not limited to:

A. Contact Details – this includes name and surname, email address, phone number and place of residence.

B. Professional Profile – information about your education, previous work experience, and any other information you choose to share with us in your resume (CV) or application when expressing interest in joining our team.

C. Information gathered from you during the interviews and assessments – this includes, results of conducted evaluation tests, and interview notes and reviews of our colleagues who interviewed you. We may also collect information about your professional experience from your referees, if you indicated them

We collect this Personal Data directly from you when you submit your resume or application into our recruitment software or when you create an account there to receive job posting updates and during the interview and selection process.

We may also collect this Personal Data from recruitment agencies we have engaged to help us find potential candidates for open positions or from business networking sites you use such as LinkedIn.

For more detailed information on how we process Personal Data in regards to HR recruitment, please consult the Privacy Notice Regarding The Processing Of Personal Data In The Recruitment Process available on our website, here.

3. PROCESSING PURPOSES AND LEGAL PROCESSING BASIS

3.1. PROCESSING PURPOSES

We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. In particular, we process your Personal Data for the following purposes:

• implementing tasks in preparation of or to perform existing contracts;
• implementing tasks in preparation of or to perform future business contracts;
• managing our relationship with you (e.g. through our databases);
• answering your requests and provide you with efficient support;
• documenting transactions;
• providing you with adequate and updated information about our products and services;
• sending you communications regarding products or services that we promote;
• improving the quality of our services by adapting our offering to your specific needs;
• sending you surveys (e.g. to help us improve your future interactions with us);
• managing communications and interactions with you (e.g. through the operation of a database keeping records of interactions);
• tracking our activities (e.g. measuring interactions or sales, number of appointments/calls);

3.2. LEGAL PROCESSING BASIS

We will only process your Personal Data if we have a lawful justification for doing so. Therefore, we will only process your Personal Data if:

• we have obtained your prior consent;
• the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
• the processing is necessary to comply with our legal or regulatory obligations; or
• the processing is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms.

Please note that, when processing your Personal Data on this last basis, we always seek to maintain a balance between our legitimate interests and your privacy. Examples of such ‘legitimate interests’ are data processing activities performed:

• to benefit from cost-effective services (e.g. we may opt to use certain platforms offered by suppliers to process data); to offer our products and services to our customers;
• to prevent fraud or criminal activity, misuses of our products or services as well as the security of our IT systems, architecture and networks;
• to sell any part of our business or its assets or to enable the acquisition of all or part of our business or assets by a third party; and
• to meet our corporate and social responsibility objectives.

4. PERSONAL DATA SECURITY

In order to ensure the protection of Personal Data, the Vox Solutions Group has taken technical and organizational measures to prevent: unauthorized access, accidental access to data; alteration, destruction or loss of Personal Data, unauthorized transmission, unauthorized processing, or improper use of data, as well as against any other form of unlawful processing, in accordance with the provisions of the law, even after the termination of data processing.

These measures take into account:

• the state of the art of the technology;
• the costs of its implementation;
• the nature of the data; and
• the risk of the processing.

The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.

Moreover, when handling your Personal Data, we:

• only collect and process Personal Data which is adequate, relevant and not excessive, as required to meet the above purposes; and
• ensure that your Personal Data remains up to date and accurate.

For the latter, we may request you to confirm the Personal Data we hold about you. You are also invited to spontaneously inform us whenever there is a change in your personal circumstances so we can ensure your Personal Data is kept up-to-date.

5. YOUR RIGHTS

The following rights may be exercised by you under the conditions and within the limits established by Applicable Law:

• the right to access your Personal Data that we process,
• the right to rectify your data – if you believe that any of your information is incorrect, out of date or incomplete, you can ask for it to be corrected or updated;
• the right to request erasure or restriction of Personal Data for the specific categories listed above (“right to be forgotten”);
• the right to withdraw your consent at any time without affecting the lawfulness of the processing at that time;
• the right to object to processing by us or on our behalf under the conditions provided for by law.
• the right to challenge all or part of the processing of Personal Data before a competent authority;
• the right to transfer your Personal Data (e.g. your Personal Data to be transferred to an entity designated by you in a structured, electronic, standard format without limitation by us in accordance with your privacy obligations).

6. COMMUNICATION CHANNELS FOR EXERCISING YOUR RIGHTS & OPTIONS

6.1. DATA SUBJECT RIGHTS

If you have any questions or wish to exercise your right to the above or if you are not satisfied with the way we process your Personal Data, you can send an email to privacy@voxsolutions.co.  We will answer your request inside the established legal term. For recruitment or otherwise HR related privacy questions, you can send an email to HR.privacy@voxsolutions.co.

6.2 MARKETING OPTIONS WITH REGARD TO VOX SOLUTIONS GROUP COMMUNICATIONS

You can update your preferences and choices in relation to our marketing communications, including unsubscribing from newsletters, by clicking the provided unsubscribe link.

7. DATA TRANSFERS

We will not sell, share, or otherwise transfer your Personal Data to third parties other than those indicated in this Privacy Notice.

In the course of our activities and for the same purposes as those listed in this Privacy Notice, your Personal Data can be accessed by or transferred to the following categories of recipients, on a need-to-know basis to achieve such purposes:

• our personnel (including personnel, departments or other companies of the group);
• our independent agents or brokers (if any);
• our suppliers and services providers that provide services and products to us;
• our IT systems providers, cloud service providers, database providers and consultants;
• our business partners who offer products or services jointly with us or with our subsidiaries or affiliates;
• any third party to whom we assign or novate any of our rights or obligations; and
• our advisors and external lawyers in the context of the sale or transfer of any part of our business or its assets.

The above third parties are contractually obliged to protect the confidentiality and security of your Personal Data, in compliance with Applicable Law.

Your Personal Data can also be accessed by or transferred to any national and/or international regulatory, enforcement, public body or court, where we are required to do so by Applicable Law or at their request.

If we transfer your Personal Data to external companies in other jurisdictions, we will make sure to protect your Personal Data by (i) applying the level of protection required under the local data protection/privacy laws applicable to Vox Solutions, (ii) acting in accordance with our policies and standards and, (iii) for Vox Solutions located in the European Economic Area (i.e. the EU Member States plus Iceland, Liechtenstein and Norway, the “EEA“), unless otherwise specified, only transferring your Personal Data on the basis of standard contractual clauses approved by the European Commission . You may request additional information in relation to international transfers of Personal Data and obtain a copy of the adequate safeguards put in place by exercising your rights as set out in Section 6.

8. AUTOMATED DECISION-MAKING PROCESSES, INCLUDING PROFILING

Vox Solutions Group does not subject Personal Data to fully automated decision-making processes (including profiling) that produce legal effects or affect you in any similar or significant way.

9. DATA RETENTION TERMS

In general, Vox Solutions Group retains Personal Data for the duration of the customer’s business relationship with the Vox Solutions Group, where we have an ongoing legitimate business need to do so, or to abide by applicable legal provisions (for example, to comply with applicable legal, tax or accounting requirements).

Personal Data we hold in our database about you which is not related to a specific contract or legal obligation will be stored for 24 months after your last interaction with us.

For contracts, the retention period is the term of your (or your company’s) contract with us, plus the period of time until the legal claims under this contract become time-barred, unless overriding legal or regulatory schedules require a longer or shorter retention period. When this period expires, your Personal Data is removed from our active systems.

Personal Data collected and processed in the context of a dispute is deleted or archived (i) as soon as an amicable settlement has been reached, (ii) once a decision in last resort has been rendered or (iii) when the claim becomes time barred.

10. THIRD PARTIES AND THEIR PRIVACY POLICIES

Our Privacy Notice does not apply to services and products offered by other companies and individuals. We are not responsible for the privacy notices and practices of other websites, even if you access them using links or embedded content (e.g. videos, images, advertisements, articles etc) from Vox Solutions Group related websites.  Our websites and applications contain links to websites that are maintained and/or controlled by non-affiliated parties. In some instances, these websites may be co-branded and display our logos or other trademarks. You can always tell whether you are on one of our websites by checking the uniform record locator (“URL”) on the page that you are visiting.

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Thank you for taking the time to review our Privacy Notice. We understand the importance of transparency and trust in handling your Personal Data. Your privacy is paramount, and we are committed to ensuring that your data is protected and used responsibly throughout the recruitment process.