The jambonz website and proprietary communications platform that lets you add voice and messaging features to your existing business software  (the “Service”) is owned and operated by Drachtio Communication Services LLC and made available to trial account users or registered account users.  Additionally, you may have end user customers that access the jambonz service, and in the course of providing these people with service we may end up collecting some information about them as well.  To keep things straight, we'll refer to you as “you” or the "Customer", and your end users as "End Users".

This Privacy Policy describes:

- Why we collect personal information
- What personal information we collect and when it is collected
- How your information is used and protected
- When and with whom your information is shared
- Your choices regarding your personal information 

We encourage you to read this Privacy Policy and our [Terms of Use](/terms) carefully. Capitalized terms used but not defined in this Privacy Policy have the meaning given them in the Terms of Use.  We will post notices of all changes that materially affect the way in which your personally identifiable information may be used or shared in updates to our Privacy Policy. 
This policy does not apply to those third-party advertising systems, networks or websites that jambonz has a relationship with or of other companies or individuals that jambonz does not own, employ, manage or control.

If you have any questions about this Privacy Policy, please feel free to contact us through our Service or write to us at Drachtio Communication Services LLC, 50 Terminal St, Suite 722 Building 2, Charlestown USA.

#### Information We Collect

We only collect from users the information we need to provide the Services.  Here are the types of information we gather: 

##### Information You Give Us

_Personal and Company-Specific Information_:  You do not need to create an account to view the free version of our Service.  If you create an account on the jambonz platform, we may ask you for certain limited personally identifiable information such as your name and email address, which we will use to contact or identify you. You can also create an account on jambonz using Google or Github as an oauth provider, and if you grant this access, we will retrieve and store your email address and name from those providers.  We may also request certain other personally identifiable information from time to time as we deem necessary to better provide the Service to you, including your company’s name, website, and a short business description.  You can choose not to provide us with any or all of the information we specify or request, but then you may not be able to register with us or to take advantage of some or all of our features.

To work with your preferred carriers and speech service providers, you will need to provide us some information about those vendors and services.  We will store this information in our database to utilize these services on your behalf.  You can change or delete this information at any time from our system, and all related information will be removed from all our systems immediately.

##### End User Data

While making calls, your End User customers may share private and confidential information over the audio connection established through jambonz -- e.g., credit card numbers, account numbers etc.  We never store audio recordings -- or transcriptions of audio recordings -- in our databases or on our servers, so this kind of information about your End User customers can never be exposed from our systems.  

While delivering calls for your End Users, we will receive information such as the phone numbers and IP addresses they are calling from, the numbers or other identifiers of the people, services, or devices they are trying to reach, along with information like the time and length of the call, etc.  This information is typically referred to as a "Call Detail Record" and unless you modify your account settings (see the next point below) we will store Call Detail Records for your end users in our database.

You can opt out of Call Detail Record reporting by disabling the feature in the self-service portal.  If you do choose to opt out, the only information we will store about your End Users will be the IP addresses of devices that they register to make/receive calls because this information is needed to successfully provide that service.  End User IP address information is only stored in our database for a period of one hour from the most successful recent device registration request.

##### Automatic Information Collected 

To perform the Service, we also collect information through cookies and other automated means. Information of this sort includes:

_Technical information about your browser and mobile device_: This information is used in the aggregate to help us optimize the Service for common browsers and devices.

_Usage information, such as the features and emails from jambonz that you interact with_: We collect and use this behavioral information and may use it in anonymized and aggregate forms to generate statistics about users and how the Services are being used and to facilitate targeted communications and advertisements but the information is not shared in any form that could be used to identify you personally.  Please see “How we use and share the information we collect,” below, for further information and choices about sharing information with third parties.

_IP address and log file information, web beacons, cookies, tokens and device identifiers_: These are alphanumeric identifiers that help us to distinguish between unique browsers and devices in order to avoid showing you the same information twice, keep you logged into jambonz, prevent duplicate actions, prevent duplicate coupon redemptions and improve your experience.  The information we collect from cookies may include your IP address, browser and device characteristics, referring URLs, and a record of your interactions with our Service. By using the Service, you are consenting to such use of cookies. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. We will respect your choices relating to on-line tracking, whether you choose to reject individual cookies or set your web browser to reject cookies and other tracking technology.  However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Service or certain areas or features of the Service.

_Crashes and error reports_: If you encounter a crash or error while using our Service, we may generate a crash report that includes technical, usage and, if you are logged in, your account information so that we can diagnose and potentially prevent the problem in the future.

**Information Collected from other Sources**. We may also periodically obtain both personal and non-personal information about you from our service providers, contractors and other third parties if you have authorized them to share it with us. 

#### How We Use and Share the Information We Collect

##### Use

We use the information we collect for things like:

- Establishing and managing your account and providing the Service 
- Conducting research and analysis of our Service
- Identifying you on our platform and communicating with you
- Operating, evaluating and improving our business model

##### Share

We will not share your personal information or user data with any third party except to perform the Services or as required by law or if we merge with another company, as described in this Privacy Policy.  

In the normal course of business jambonz may share your information with individuals (such as employees, contractors and lawyers) and companies (such as a mail delivery service) to perform tasks on our behalf and may need to share certain information, with them in order to provide improved products or services to our users. However, our agents do not have any right to use the information we share with them beyond what is necessary to assist us in providing the service to you as described in this Privacy Policy.  

Sometimes we may be required to share your information in response to a regulation, court order or subpoena or we believe necessary to comply with the law.  We may also share your information in the event of a corporate sale, merger, acquisition, dissolution or similar event.Sometimes we may be required to share your information in response to a regulation, court order or subpoena or we believe necessary to comply with the law.  We may also share your information in the event of a corporate sale, merger, acquisition, dissolution or similar event.

#### How We Store and Protect the Information We Collect

jambonz uses reasonable security measures to store and protect the information under our control and appropriately limit access to it.  However, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

We use a variety of information security measures to protect your online transactions with us. The Service uses encryption technology, such as Secure Sockets Layer (SSL), to protect your sensitive personal information during data transport. 

We want you to feel confident using the Services. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personally identifiable information, usage data or other communications will always remain secure. We will notify you by email if we have reason to believe that your personal information has been compromised due to a security breach or used in an unauthorized manner, but by using this Service, in accordance with the Terms of Use you agree to release us from any and all claims arising out of unauthorized use of your information.

#### Your Choices Regarding the Information We Collect

You may choose to:

- Update and correct your personal information
- Object to the processing of your personal information 
- Request to have your personal information or usage data deleted or restricted from our Service
- Request for portability of your personal information
- Cancel your account

To do any of these, simply notify us of this decision by one of these methods:

- Follow the unsubscribe link in any marketing email or following the directions included in any other promotional material received from jambonz.
- Send an email to us at support@jambonz.org.  Please note that when you email us with this request, we will take steps to verify that you are authorized to make the request.

#### Data Retention
We will retain your usage data for 30 days from the time it is created.  We will retain your profile information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.  If you close your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by law. Deactivating your account does not automatically delete your account or usage data from our database, but regardless of any retention policy we will make reasonable efforts to enable you to delete your profile and personally identifiable information from our database upon request.  

#### Third Party Services and Links to Other Websites 
Our website may contain links to other websites including those of our service partners and other service providers, many of which have their own privacy policies. For example, if you sign up for a paid plan we will direct you to our third-party billing partner to enter your payment details.  We do not have access to your financial or payment information and do not store it in our database or on our services.  As with any website, be sure to review the privacy policy of the site you are visiting, whether directly or through the Service. 

Additionally, we may integrate third party services in to our Service in order to personalize your experience.  This policy only covers the use of cookies by jambonz.  Cookies placed by third party services are governed by the third party terms and privacy policies applicable to those services (which we encourage you to read).

#### Children's privacy
We restrict use of the Service to individuals age 18 and above, and do not knowingly seek or collect personal information from anyone under the age of 18. 

#### Using the Services from outside the United States and a few words about GDPR
This Privacy Policy is intended to cover collection of information from residents of the United States and is not intended for users located outside the United States. If you are accessing the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Service, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

The General Data Protection Regulation (GDPR) in the European Economic Area (EEA) distinguishes between data "controllers" and "processors".  A controller decides why and how to process personal information.  A processor processes personal information on behalf of a controller based on the controller’s instructions.

jambonz is primarily a data controller; we use information included in the Customer Data such as your carrier sip trunk details and speech credentials as part of our legitimate interest of providing you with the service you expect. We have determined that our processing of your personal data is necessary to deliver such products and services to our users and that there is no less intrusive means of delivering users such products and services.  Finally, we believe that our processing of personal data will not cause unjustified harm in a way that would override our legitimate interest basis. 

When handling calls from your End Users, jambonz also acts as a data processor, in that we are processing End User data such as phone numbers and IP addresses under your instructions for routing and managing the end user's calls.

In some cases, we may use consent as our lawful basis for collecting and processing certain types of personal information.  In such cases, you have a right to withdraw the consent at any time.

#### Changes to this Privacy Policy
Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant or involve changes to the way we use personal information, we will notify you by delivering an announcement via our Service or your account email.  If you opt out of communications from jambonz, you may not receive these notifications, however they will still govern your use of the Service, and you are responsible for proactively checking for any changes. If you continue to use the Service after changes have been posted, you agree to abide by and be bound by the modified privacy policy. Each version of this Privacy Policy will be identified by its effective date found at the bottom of this page.

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this Service, or email us at support@jambonz.org.

**Last updated: May 4, 2021**

