Global Data Privacy Notice for RingCentral Personnel

Issued: December 23, 2020
 
1.       Introduction
This Global Data Privacy Notice (“Notice”) describes how RingCentral, Inc., and its subsidiaries (collectively “RingCentral”) handles personal information processed about our employees, contractors, interns, temporary employees, consultants, professional advisors and job applicants (collectively referred to as "you" or “personnel”).
 
We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This Notice outlines the personal information that we collect and process about you, the purposes for the processing and the rights that you have in connection with our data gathering, processing and retention.
 
If you have any comments or questions about this Notice, please contact the RingCentral Privacy team at privacy@ringcentral.com.
 
2.       Categories of Personal Information We Collect
RingCentral may process personal information about you and your dependents, beneficiaries and other individuals whose personal information has been provided to us.
The categories of personal information we may process may include:
  • Identification information – such as your name, gender, photograph, date of birth, staff member IDs, a copy of your signature, and a physical description.
  • Contact details – such as home and business address, telephone/email addresses, emergency contact details.
  • Employment details – such as job title/position, office location, employment contract, performance and disciplinary records, grievance procedures, sickness/holiday records, performance results, and materials or information that you work on in connection with the performance of your job that are identified or identifiable to you.
  • Background information – such as academic/professional qualifications, education, CV/résumé, and information provided by third parties, such as background check data (where such checks are permitted by law) or information from professional references, financial information, visa/immigration related documents, address history.
  • National identifiers – such as national ID/passport, immigration/visa status, social security numbers.
  • Spouse & dependents – Identification Information (see above),   National Identifiers (see above), marital status.
  • Financial information – such as banking details, tax information, withholdings, salary, benefits (including insurance), expenses, company allowances, stock, and equity grants.
  • IT information – information required to provide access to company IT systems and networks such as IP addresses, log files and login information, as well as information about your use of RingCentral systems and equipment. This may include information about your precise location when you use RingCentral systems, software and equipment; it may also include audio and visual recordings of you, such as recordings of RingCentral personnel and customers during customer service calls. For further information on how IT information is processed, please see the Employee Monitoring Notice. Click here to view policy.
  • Where required to fulfill our legal obligations or related to a legitimate business interest and authorized by applicable law, information that reveals your racial or ethnic origin, your sexual orientation, or your religious, political or philosophical beliefs; health or genetic data, including information about your temperature, other vital signs and disease symptoms where reasonably related to assuring workplace and personnel safety; biometric data for the purposes of unique identification; or union membership information. We treat these types of personal information as “Sensitive Personal Information.”
  • Voluntarily provided information – Personal information you voluntarily provide to Ring Central.
  • Other information upon notice –  Other categories of personal information where RingCentral provides you with advance notice of the collection, information about how the personal information will be processed, and the lawful grounds for processing (where required by applicable law).
3.       Processing of Sensitive Information
As a general rule, we try not to collect or process any Sensitive Personal Information about you, unless authorized by law or where necessary to comply with applicable laws. However, in some circumstances, we may collect, or request on a voluntary disclosure basis, some Sensitive Personal Information, which we will use only for legitimate recruitment, employment, or work-related purposes, unless we obtain your affirmative consent to use it for other purposes. For example, RingCentral may collect information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to provide work-related accommodations, health and insurance benefits to you and your dependents, or to manage absences from work.
 
4.       Purposes and Bases for Processing Personal Information
(i)      Information Collected through Recruitment
 
If you are applying for a role at RingCentral, then we may collect and use personal information to determine and evaluate your qualifications for employment and to help us reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role or roles, verifying information you voluntarily provide, carrying out reference and background checks (where permitted, and, where legally required, with your express consent), and to manage the hiring process and communicate with you about it.
 
The categories of personal information processed for recruitment purposes are identification information, contact details, employment details, background information, national identifiers, voluntarily provided information, Sensitive Personal Information (subject to the limits described above), and other information upon notice. If you are offered and accept a role with RingCentral, the information collected during the recruitment process will become a part of your employment record and personnel file.
 
By providing us with personal information in connection with your application, you consent to RingCentral using that information for recruitment purposes. We will also process application and recruitment information in connection with the performance of your employment agreement or other contract with RingCentral, should you ultimately enter into one; in connection with RingCentral’s legitimate business interest; as necessary in an emergency; as required by law; or in connection with furthering the public interest.
 
(ii)     Information Collected through Employment or Work-related Activities
 
RingCentral may collect and use personal information to manage our employment or working relationship with you. Some examples of the way we use this information are as follows: your employment records and contact information are used to manage our employment relationship with you, your bank account and salary details are used so we can pay you, your equity grants are used for stock plans administration, and details about your spouse and dependents are used for emergency contact and benefits purposes. All of the categories of personal information that we collect are processed for employment and work-related purposes.  Our processing of Sensitive Personal Information for employment or work-related purposes are subject to the limits described above.
 
We process information collected through your employment or provision of services to RingCentral: as necessary and in connection with the performance of your employment agreement or other contract with RingCentral; in connection with RingCentral’s legitimate business interest; as necessary in an emergency; as required by law; or in connection with furthering the public interest.
 
(iii)   Information Collected through Other Means
 
We may also collect and use personal information through other means when it is necessary for other legitimate purposes (such as to help us conduct our business more effectively and efficiently). For example: for HR resourcing on a global level, IT security/management, accounting purposes, or financial planning. We may also process your personal information to evaluate compliance with law and RingCentral policies. RingCentral may also collect additional personal information we collect where we consider it necessary for complying with laws and regulations, including collecting and disclosing your personal information as required by law (e.g. for tax, health and safety, anti-discrimination laws), under judicial authorization, or to exercise or defend the legal rights of the company.
 
We may process any of the categories of personal information that we collect in connection with pursuing RingCentral’s legitimate business interests and as required by law. Our processing of Sensitive Personal Information for employment or work-related purposes are subject to the limits described above.
 
5.       Other RingCentral Personnel’s Access to Your Personal Information
We maintain a global directory which may contain your professional contact details (such as your name, location, photo, job title and contact details). This information will be available to everyone in the company to facilitate global cooperation, communication, and teamwork.  You may opt out of having your photo included in the directory at any time by contacting People Operations or Employee Experience teams.  RingCentral’s collection and inclusion of all other professional contact details in its global directory is necessary for the performance of your employment agreement or other agreement to provide services for RingCentral.
 
For US: You may not opt out of having your photo included on the company badge used to get into US offices.
 
For EEA: You may opt out of having your photo included on the company badge used to get into EEA offices.
 
Select RingCentral personnel may also have access to any other category of personal information where the personnel member requires access to such information in connection with performing job-related duties and tasks.
 
6.       Disclosures Outside of RingCentral Inc.
RingCentral relies on third party service providers and RingCentral subsidiaries and affiliates around the world in order to administer human resources, staff member compensation and benefits at an international level, as well as for other legitimate business purposes such as IT services/security, tax and accounting, and general business management.  For example, RingCentral may process your personal information using global employee success systems ("HR System"), which are tools that help us administer your compensation and benefits and which may allow you to manage some of your own personal information. RingCentral may host HR System servers ourselves or may utilize third-party servers; in either case, RingCentral will be responsible for the security of and access to your personal information that is stored on our employee success systems.
 
We provide service providers with access to personal information only in connection with performing services to RingCentral and in accordance with applicable data privacy law. For example, some personal information will be available to our stock and benefit plans service providers and third- party companies who provide us with payroll support services such as relocation, tax and travel management services, such as Workday, ADP, E*Trade, AWS, Google, Concur, BCD Travels, and others.
We may also disclose personal information to other third parties on other lawful grounds, including but not limited to:
  • Disclosing your name and contact information to RingCentral customers, potential customers, vendors, and partners in connection with the performance of your job duties;
  • Complying with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
  • In response to lawful requests by public authorities (including for national security or law enforcement purposes);
  • As necessary to establish, exercise or defend against potential, threatened or actual litigation;
  • Where necessary to protect the vital interests of another person or RingCentral;
  • In connection with the sale, assignment or other transfer of all or part of our business; and
  • With your consent.
Whenever we permit a third party to access personal information, we will implement appropriate measures designed to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.  Any category of personal information we collect may be disclosed to RingCentral subsidiaries and affiliates and to third policies in accordance with this section.
 
7.       Transfer of Personal Information Abroad
RingCentral may need to transfer your personal information to countries other than the ones in which the information was originally collected. We will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer personal information from the European Economic Area or United Kingdom to the United States we will implement an appropriate data export solution such as entering into EU standard contractual clauses with the data importer or taking other measures to provide an adequate level of data protection under EU law.
 
8.       Data Retention Periods
Personal information will be stored in accordance with applicable laws and kept as long as reasonably needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally, and with the exception of IT data and personal information contained in business documents, this means your personal information will be retained until the end or your application period or work relationship with RingCentral plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters (such as judicial or disciplinary actions), to document the proper termination of your employment or work relationship (e.g. to tax authorities), or to provide you with ongoing pensions or other benefits.
 
9.       Your Data Privacy Rights
You may request access to, correction or update of your personal information at any time by visiting our data subject request portal.  Depending on the nature of your request, we may need to verify your identity and any updated information before completing your request. We may also limit our response to your request after providing you with notice, where doing so complies with applicable law.
 
You may request deletion of your personal information at any time by visiting our data subject request portal.  Depending on the nature of your request and your country of residence, RingCentral may be legally entitled to retain some or all of your personal information and reserves the right to do so in appropriate circumstances, subject to its sole discretion.  Nevertheless, RingCentral endeavors to comply with reasonable deletion requests from employees.
 
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, United Kingdom, Switzerland and certain non-European countries are available here.)
 
Depending on your location, you may have additional legal rights related to your personal information.  You may exercise these rights by contacting the RingCentral Privacy Team at privacy@ringcentral.com or the RingCentral People Operations Team at peopleops@ringcentral.com. For example, if you are a resident of the European Union or United Kingdom:
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • If we have collected and processed your personal information with your consent, then you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
 
You may have the right to refuse consent to our collection and processing of some or all of your personal information under applicable law. If you decline to provide required information, we may be unable to fully evaluate your qualifications for employment and reach a hiring decision, provide employment benefits you may be entitled to, comply with our legal obligations, or to continue your employment or service arrangement with RingCentral.
 
10.   Data Protection Officer
RingCentral has appointed a data protection officer (“DPO”) who you may contact if you have any questions about RingCentral’s privacy policies or practices.  You can email our DPO at privacy@ringcentral.com, or write to us at:
RingCentral, Inc.
Attn: Data Protection Officer
20 Davis Drive,
Belmont, California
 
11.   Updates to this Notice
This Notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, we will inform you via company-wide emails and indicate at the top of the Notice when it was most recently updated. We encourage you to review this website periodically to ensure you have the most recent version of this Notice.
QUICK LINKS
We recommend that you read this Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Notice, then you can click on the relevant link below to jump to that section.
 
 
How We Gather Personal Information
We may collect personal information from or about you in a variety of ways. 
  • We collect your personal information when you actively provide it to us.  For example, users directly give us personal information when signing up for an account, communicating with RingCentral, responding to surveys, participating in events or promotions, or modifying an account profile.  
  • We may also collect personal information about you when another user actively provides it to us.  For example, if an account holder invites you to a meeting using our Apps and Services, RingCentral would collect your email address.
  • We may automatically collect personal information from you as you use our Apps and Services, or visit our Websites.
  • We may receive personal information about you from a business or commercial partner.  For example, we may receive personal information from third-party service providers that you have linked to your use of our Services (including social media accounts, single-sign-on services, and scheduling applications), publicly available sources, data enrichment vendors, payment and delivery service vendors, advertising networks, analytics providers, and our business partners.  
 
YOUR PRIVACY RIGHTS
Update and access to your information
Where we process personal information collected via our Website or Apps or via our Services for our own account management, billing or marketing purposes and where required by applicable law, we provide individuals with the opportunity to access, review, modify, and delete any such personal information that we process.
 
Requests from End Users
If you believe RingCentral may have collected or stored personal information about you on behalf of a RingCentral customer, please contact the RingCentral customer with any requests related to your personal information.
 
Your Privacy Rights as a data subject protected by EEA/UK law or as a California Resident
If you are a person located in the EEA/UK or if you are a California resident, you may have broader rights to access and delete your personal information, to object to or restrict processing of your personal information, to correct your personal information, or request portability of your personal information. 
 
If you are an End User whose personal data we collected on behalf of a RingCentral customer, please contact the relevant RingCentral customer directly to make such requests.
 
In general, when processing the content of communications such as voicemails, faxes, recordings etc. in connection with  our Services, we do so on behalf of our EEA/UK  Customers and in accordance with their instructions. This means that if you wish to access, review, modify or delete any content of your communications, under applicable EEA/UK law or otherwise, you should contact that Customer with your request. We will then help them to fulfill that request in accordance with their instructions.
 
In other circumstances, you can submit a request through our online portal. We will consider and handle all requests in accordance with applicable laws.
 
Additional Privacy Rights as a California Resident
If you are a California resident and receive RingCentral Services or visit our Website or Apps solely as a private individual—in other words, not as the member or representative of a company or other organization—you may have the right to receive a free, yearly accounting of:
 
  • Information identifying each third-party company to whom we may have disclosed, within the past year, personal information pertaining to you for our own direct marketing purposes; and
  • A description of the categories of personal information disclosed.
You may have the right to know more about personal information that we have collected, disclosed, or sold, including:
 
  • The categories of personal information that we have collected or shared about you in the preceding 12 months,
  • The categories of sources from which we have collected that information in the preceding 12 months
  • The commercial or business reason(s) we have collected or shared that information, 
  • The categories of third parties with whom we have shared or to whom we have sold that information in the preceding 12 months, and
  • Pursuant to a verifiable request, the specific pieces of information that we have collected about you. 
Depending on the nature of your request, we may need additional information to verify your identity. 
 
To make a request, please submit a ticket through our online portal, or contact our Privacy Team at privacy@ringcentral.com
 
Unsubscribe from our mailing list
We give you the choice of receiving a variety of information related to our Apps and Services. You can manage your communication preferences through the following methods:
 
These choices do not apply to service notifications or other required communications that are considered part of certain Apps/Services, which you may receive periodically unless you stop using or cancel the App/Service in accordance with its terms and conditions.
 
THIRD-PARTY SITES  
This Notice does not apply to, nor are we responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website links including but not limited to social media sites. The inclusion of a link on the Website does not imply our endorsement of the linked site or service. You should check the privacy notices of those sites before providing your personal information to them.
 
For RingCentral Meetings Product only: RingCentral Meetings product is based on the Zoom platform. Our RingCentral Privacy Notice covers how RingCentral collects, uses and discloses personal information in connection with the use of the Zoom platform. However, this Notice does not otherwise apply to Zoom’s practices.
 
 
BLOGS AND FORUMS
Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blog or community forum, you can submit a request through our online portal. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all users to exercise caution when providing personal information in blogs and community forums.
 
 
SECURITY
Keeping your information secure is important to us. Like all businesses, we cannot guarantee the security of the personal information we collect and process in connection with our Websites, Apps and Services. We have, however, taken certain steps designed to reduce the risk that your personal information will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction. RingCentral has no control over or responsibility for the security or privacy policies 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 our Website.
 
 
DATA RETENTION
We will retain your personal information for no longer than is necessary to fulfill the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.
 
Where we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.
 
 
INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. Specifically, information collected outside the United States, including in the European Economic Area ("EEA") and the UK, may be transferred to and stored on our servers in the United States, Switzerland, and Netherlands, and potentially in other countries where our group companies and third-party service providers and partners operate. These countries may have data protection laws that are different to the laws in your country (and in some cases, may not be as protective).
 
However, RingCentral complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the UK, and Switzerland, including the onward transfer liability provisions. We have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice and applicable laws. For example, in respect of personal information originating from the EU and Switzerland, RingCentral has self-certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. Please click here to view our Privacy Shield Notice.
 
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
 
With respect to personal data received or transferred pursuant to these Privacy Shield Frameworks, RingCentral is subject to the regulatory enforcement powers of the US Federal Trade Commission.
 
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
 
In certain cases, RingCentral will transfer personal data from the EU in accordance with the European Commission-approved Standard Contractual Clauses.
 
 
CHILDREN'S PRIVACY
RingCentral does not knowingly provide products or services directly to children under the age of 16, or knowingly collect or solicit personal information from or about children under the age of 16 outside of the school offering. If you believe that a child under the age of 16 has disclosed personal information to RingCentral outside of the school offering, please contact privacy@ringcentral.com
 
 
UPDATES TO THIS NOTICE
We may update this Notice from time to time in response to changing legal, technical, or business developments. If we make nonmaterial changes to our Notice, we will post those changes on this page in addition to updating the "Last Updated" or effective date at the top of this webpage. If we make material changes, we will notify you more directly, for example by emailing you prior to such material changes taking effect. We encourage you to review this Notice regularly to stay informed of the latest modifications.
 


CONTACT US
If you have any questions, comments or concerns about this Notice, please e-mail our data protection officer at privacy@ringcentral.com. Or, you can write to us at:
 
RingCentral, Inc.
Attn: RingCentral Privacy Team
20 Davis Drive,
Belmont, California 94002
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