RingCentral^® Privacy Policy (United Kingdom)

We at RingCentral UK Ltd. (“RingCentral”), are committed to protecting the privacy of customers and users of our services and users of our website (the "Website"). We have therefore created this policy statement (the “Policy”) to explain our privacy practices and procedures, including:

1. Information we collect;
2. Our use of personal data;
3. Disclosure of personal data;
4. Security and data integrity;
5. Our use of “cookies”;
6. Our use of Web beacons;
7. Our use of banner ads;
8. Tell-a-friend credits;
9. Checking account and preferences information for accuracy;
10. Enforcement;
11. Updating of our Policy; and
12. Contacting us.

We believe that you should know what information we collect from you, as well as understand how we use, disclose, and protect that information. We believe that you should be able to communicate with us easily to limit the disclosure of any of your personal data, where practicable, and to address any questions or concerns that you may have. And we will not disclose information to unaffiliated third parties without your consent or as otherwise provided in this Policy.

This Policy applies to RingCentral’s services and its Website, which are intended for the use of persons residing in the United Kingdom, and for delivery of services within the United Kingdom.

By purchasing, subscribing to, or using RingCentral’s services or using RingCentral’s Website, you agree to the terms and conditions set forth in this Policy. For other terms and conditions that govern your use of RingCentral’s services and its WebSite, please review our Terms of Use.

1. INFORMATION WE COLLECT

We collect a variety of personal data about users of our services and visitors to our Website in order to ensure an enjoyable user experience and seamless communications. When we use the term “personal data,” we mean information that is directly associated with, or could be used to identify, a specific person. Such information includes a name, address, telephone number, e mail address, or information about activities directly linked to that person which would permit the physical or online contacting of that person.

Personal data does not include “aggregate information”—data we collect about a group or category of services or users or customers and from which individual user or customer identities have been removed. Aggregate data—for example, a report that indicates that a certain number of our customers reside in a particular region of the United Kingdom, or a report on how many of our customers visited particular pages of our Website—aids us in understanding trends and customer needs so that we can better consider new services or tailor existing services to customer preferences.

Personal data also does not include your Internet protocol (“IP”) address, unless you have registered with us in the “Preferences” section of our Website, in which case your IP address is linked to your personal data.

We collect the following types of personal data through use of our Website and telephone calls to RingCentral customer service:

• Information You Give Us: We collect information you give us—such as your name, billing address, telephone number, e-mail address, and/or credit card number—when you purchase or use a service, participate in a promotion, or register with us in the “Preferences” section on our Website. Where you receive RingCentral services via your mobile phone carrier or download the RingCentral mobile application to your mobile phone, then RingCentral will collect your mobile phone number and information about the sort of mobile device (such as mobile telephone, blackberry or PDA ) you use for the purpose of providing the services to you.
• Information We Collect Automatically: We automatically collect certain types of information whenever you interact with us. For example, when you visit RingCentral’s Website, our systems automatically provide us with your IP address to tell us what type of Web browser you use, which may be linked to personal data if you have registered with us in the “Preferences” section of our Website. When you visit RingCentral’s Website by clicking an advertisement on a third-party Website, RingCentral automatically collects information about the Website you were visiting when you clicked on RingCentral’s advertisement, including the IP address of the Website and the date and time that you clicked on RingCentral’s advertisement.
• Information We Obtain from Other Sources: We may obtain information about you from outside sources and add it to, or combine it with, your personal data, including information such as:
• Credit information, which allows us to complete transactions for the purchase of RingCentral services, and
• Commercially available demographic and marketing information from third parties, which aids us in serving you and informing you of services that may be of interest to you.

To see how we use, disclose, and protect the personal data that we collect, please review the rest of this Policy.

2. OUR USE OF PERSONAL DATA

Our Internal Use: In general, we use personal data to serve our existing and prospective customers and to enhance and extend our customer relationships. By understanding how you use our services and our Website, we are able to customize and personalize our interactions with you. More specifically:

• We use personal data for billing purposes, to provide services or complete transactions you have requested, to anticipate and resolve problems with your services, and to create and inform you of products or services from RingCentral or others that better meet your needs.
• Subject to your agreement, RingCentral uses e-mail, telemarketing, and direct mail to inform you about products or services we think will interest you. If you do not wish to receive these types of communications you can choose at any time not to continue to receive these details by clicking here and completing a form to tell us of your preferences or by responding to the unsubscribe instructions on any communication sent to you. You can also exercise the right at any time by contacting us using the contact details in the Contacting Us [insert hyperlink] section of this Policy.

While you may choose not to receive marketing information from us, you will continue to receive bills, customer service-related notifications, and other similar information from us electronically or otherwise. You will also continue to receive communications directly related to each service you purchase or subscribe to.

Our Customer Surveys: Periodically, you may be able to participate in our surveys to help us improve our services. Any personal data that we may collect from you in a survey will ONLY be used internally by RingCentral. And unless otherwise explained in the instructions for a particular customer survey, any personal data you provide to us for purposes of that survey will be used in accordance with this Policy.

Third-Party Use: To understand when and how RingCentral may disclose personal data to unaffiliated third parties, please read the Disclosure of Your Personal data section below.

3. DISCLOSURE OF PERSONAL DATA

Because information about our existing and prospective customers is one of our most important business assets, we seek to protect it and keep it confidential. We do not share personal data with unaffiliated third parties, nor do we sell it to third parties, unless permitted to do so in accordance with this Policy. We disclose personal data only as detailed below.

Your Consent: RingCentral will not disclose personal data other than in accordance with this Policy. In general, that means that you must consent to the disclosure in advance. Depending on the service, we may obtain your consent in a number of ways, including:

• In writing;
• Verbally;
• Online, by clicking on a link or button; or
• Through the use of a dialing string or buttons on a telephone handset.

Disclosure to Affiliates: We may share your personal data between our RingCentral group companies where this is necessary to support the services provided to you. In certain circumstances this may mean that the personal data you provide us may be transferred to countries outside the European Economic Area ("EEA"). By way of example, this may happen if any of our group servers or companies located in a country outside the EEA, such as RingCentral, Inc, which is located in the United States. These countries may not have similar data protection laws to the EEA. If we transfer your information outside the EEA in this way, we will take steps to ensure your privacy rights continue to be respected, however please note that certain services may be unavailable if you do not want the personal data you are asked for to be disclosed or shared.

Disclosure to British Telecoms ("BT")
For users of the BT RingCentral services, which are provided in conjunction with BT, we share your personal data, including name and contact details and information about your RingCentral package and your use of the RingCentral Services to BT. BT may use this information to monitor the RingCentral service, and market to you by email, telephone, fax and post their and their group companies services to you. By using the BT RingCentral services, you hereby agree to the sharing of such information with BT.

Disclosure to Unaffiliated Third Parties: In using the RingCentral Website, you consent to our disclosure of personal data to unaffiliated third parties as follows: We share personal data with unaffiliated third parties ONLY as necessary to complete a transaction or perform a service that you have requested, or to support the technical operation and maintenance of our services and of our Website. When the unaffiliated third party acts solely on our behalf RingCentral requires that party to follow our privacy practices. RingCentral DOES NOT SELL TO THIRD PARTIES ITS CUSTOMER LISTS OR ANY PERSONAL DATA ASSOCIATED WITH ITS CUSTOMERS.

Credit reference agencies and other checks

If at any time you apply for a credit facility from us, when you apply for such credit we will search your record at a credit reference agency or agencies. This may include details taken from the electoral register and could also be linked to, or associated with, other people's financial records. If so, you may be treated as financially associated and these records may be used when assessing your application. Even if your application goes no further the credit reference agencies will add details of this search and your application to your record. We may use automated decision making systems when assessing you for credit and for fraud prevention.

We will check your details with a fraud prevention agency or credit agencies and if you give us false or inaccurate information and we suspect fraud we will record this with them. We and other organisations may use and search these records to help make decisions about credit and related services or to consider motor, household, credit, life and other insurance policies, and to check your identity to prevent money laundering, unless you give us other satisfactory proof of identity.

Business Transfers: Information about our users and customers, including personal data, may be disclosed as part of any merger, acquisition, reorganization or sale of a RingCentral company assets and where steps have been taken to ensure that your privacy rights continue to be respected. It may also be disclosed in the unlikely event of an insolvency, bankruptcy, or receivership in which personal data would be transferred as one of the business assets of RingCentral.

999 Calls and Requests for Emergency Assistance: We will only provide the ability for you to dial 999 if and when we launch a UK VoIP services. If we do launch that service, and you take it, then if you dial 999 for emergency services, we may provide your location information (which will identify you by name) to a public safety answering point; emergency medical service provider or dispatch provider; public safety, fire service, or law enforcement official; or hospital emergency or other medical care facilityas required by law, or in an emergency situation involving risk of death or serious physical harm of any person, such as to a user's legal guardian or members of a user’s immediate family or to database management services or information providers solely to assist in delivering emergency services.

Protection of RingCentral and Others: We release personal data when we believe release is appropriate to do one of the following:

• Comply with the law (e.g., if required to do so by a lawful court order or if we believe that such action is necessary to prevent fraud or other crime or in connection with a request from OFCOM or other competent regulator);
• Enforce or apply our agreements to sell services to you;
• Bill and collect for services; or
• Protect our rights or property or the Site.

4. SECURITY AND DATA INTEGRITY

We maintain a variety of physical, electronic, and procedural safeguards to guard your personal data and CPNI. Specifically, we use commercially accepted procedures and systems to protect against unauthorized access to our systems. We restrict access to your personal data and CPNI to those employees and contractors—all of whom are covered by this Policy—who need to know that information to provide services to you or otherwise assist you. We protect the security of your personal data during transmission via the RingCentral Website by using Secure Sockets Layer (“SSL”) software, which encrypts information you input, so that no one else can read it as it is transmitted over the Internet. And we use an SSL connection to enable you to view, enter, and change the information in the “Preferences” section securely on our Website.

You can take additional steps on your own to safeguard your personal data. For example, you should be sure to sign off when finished using a shared computer. And you should always log out of any Website, including the RingCentral Website, after viewing personal account information, such as the “Preferences” section of our Website.

Please be advised that RingCentral has no control over or responsibility for the security or privacy policy or practices of other sites on the Internet you might visit, interact with, or from which you might buy products or services, even if you visit them using links from the Website, and we recommend that you check the policy of each site you visit.

5. OUR USE OF “COOKIES”

RingCentral uses “cookies” to enhance your use of our Website. “Cookies” are small text files placed on your computer’s hard drive by a Website when you visit that Website. These files identify your computer and record your preferences and other data about your visit to a Website so that when you return to that site, the site operator knows who you are and can personalize your visit. For example, cookies enable a Website shopping cart to function so that you only have to check out once. Consequently, cookies are often tied to the use of personal data while using our Website. If you choose not to accept the use of cookies, your use of our Website may be impaired.

Cookies allow us to do the following:

• Complete transactions you have requested;
• Collect information to determine which services and sections of our Website are most and least popular;
• Personalize our Website and make recommendations to you based on services you have used in the past; and
• Improve our the ease of use of our Website, sometimes in conjunction with Web beacons.

We do not use cookies to store credit card information. RingCentral does, however, use cookies to store login information (including passwords) for customers who choose the option of storing such information on their computers.

We also use a session-based cookie to maintain continuity of navigation for you when viewing our Website during a particular on-line session. After closing the browser, the session cookie simply terminates; it is not stored on your computer’s hard drive thereafter.

In conjunction with Web beacons, RingCentral may also use cookies, but these cookies are not linked to your personal data.

You can enable cookies by doing the following:

• Internet Explorer: On your task bar menu, select “Tools” and “Internet Options.” Then select the “Privacy” tab. Move the slider to any setting other than “High” or “Block All Cookies.” Then click “OK.”
• Mozilla Firefox: On your task bar menu, select “Tools” and “Options.” Select the “Privacy” tab and place a tick mark in the box for “Accept Cookies from Sites.” Then click “OK.”
• Netscape Navigator/Communicator: On your task bar menu, select “Edit” and “Preferences.” Select “Advanced” and click “Accept All Cookies.” Then click “OK.”

You can erase or block cookies from your computer if you want to (your help screen or manual should tell you how to do this), but certain RingCentral services may not work correctly if you set your browser not to accept cookies.

6. OUR USE OF WEB BEACONS

RingCentral uses Web beacons on its Website. A Web beacon (sometimes called a “Web bug” or “clear GIF”) is a tiny graphic image (usually a 1-by-1 pixel) displayed in a Web page, Web-based document, or e-mail message, but it is usually invisible, as it is usually the same color as the background of the Web page, document, or e-mail message. When the user’s Web browser reads the HTML code for the Web beacon to retrieve the image, it can along pass along the IP address of the user’s computer, the time the Web beacon was viewed and for how long, and the type of browser used. Web beacons can also be linked to a user’s cookies and any personal data that may be stored in them.

RingCentral uses Web beacons to gather aggregate information, as described above in Information We Collect. RingCentral does not use Web beacons that link to cookies or to personal data on unaffiliated third-party Websites. And it does not permit unaffiliated third parties to place such Web beacons in advertisements on RingCentral’s Website.

For its Web beacons, RingCentral uses Omniture to analyze use of RingCentral’s Website. For further information on how Omniture collects and uses information, you should refer to the Omniture Products and Services Privacy Statement at http://www.omniture.com/privacy/product.

7. OUR USE OF BANNER ADS

We may use third-party advertising companies to place advertisements about RingCentral products and services on other Websites. These advertising companies may use cookies, Web beacons, or other technologies to measure the effectiveness of our ads. The advertising companies may use anonymous information about your visits to our and other Websites in order to measure advertising effectiveness and offer selective ad content. But they use an anonymous identifiers, such as a number, to identify you. They do NOT link to or collect any personally identifying information. The use of such cookies, Web beacons, and other technologies is subject to the advertising companies’ privacy policies, not this Policy of RingCentral. If you would like more information about the advertising companies we use and their privacy practices, or would like to prevent them from sending and reading cookies on your computer, click here.

8. “TELL-A-FRIEND” CREDITS

You are invited to participate in our 'tell-a-friend' scheme to have 'tell-a-friend' credits added to your account. However, if you do so, please do not send us anyone else's personal details without first obtaining their consent

9. CHECKING ACCOUNT AND “PREFERENCES” INFORMATION FOR ACCURACY

You can review or change the information in the “Preferences” section of our Website, or by telephoning or writing to Customer Service. For Customer Service contact information, please see the Contacting Us section below. As noted in the Information We Collect About You section above, we may also use updated address information obtained from other sources to update our records.

10. ENFORCEMENT

RingCentral regularly reviews its compliance with this Policy. Please direct any questions or concerns regarding this Policy or RingCentral's treatment of personal information by contacting us. When we receive formal written complaints, it is RingCentral's policy to contact the complaining customer or user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between RingCentral and an individual.

11. UPDATING OF OUR POLICY

RingCentral will revise or update this Policy if our practices change, as we change existing services, add new services, or develop better ways to inform you of services we think will interest you, and we will post the revised version of this Policy to the Website. You should refer back to this page for the latest information and the effective date of any changes. In the event that RingCentral merges with, or is acquired by another company, a change to this Policy may result. Whenever the change to this policy is significant, we will notify you via your e-mail address on record, and place a prominent notice on our Website

12. CONTACTING US

If you have any questions, comments or concerns about this Policy, please direct them to RingCentral’s Legal Department at legal@ringcentral.com, or call us at +(650) 472-4071. Or you can write to us at: