Privacy Policy

This Privacy Policy describes the personal data we collect and/or process (which may include collecting, organizing, structuring, storing, using, or disclosing) to provide products and services offered directly by Instant Prospect Conversion (“IPC”), including IPC’s websites, its messaging platforms, related collaborative features, and IPC Marketplace (“IPC products and services” or “products and services”).

What Personal Data Do We Receive?

Personal data is any information from or about an identified or identifiable person, including information that IPC can associate with an individual person. We may collect, or process on behalf of our customers, the following categories of personal data when you use or interact with IPC products and services:

Account Information: Information associated with an account that licenses IPC products and services, which may include administrator name, contact information, account ID, billing and transaction information, and account plan information.
Profile and Participant Information: Information associated with the IPC profile of a user who uses IPC products and services under a licensed account or that is provided by an unlicensed participant, which may include name, display name, picture, email address, phone number, job information, stated locale, user ID, or other information provided by the user and/or their account owner.
Contact Information: Contact information added by accounts and/or their licensed end users to create contact lists on IPC products and services, which may include contact information a user integrates from a third-party app, or provided by users to process referral invitations.
Settings: Information associated with the preferences and settings on a IPC account or user profile, which may settings and configuration information.
Registration Information: Information provided when registering for a webinar or recording, which may include name and contact information, responses to registration questions, and other registration information requested by the host.
Device Information: Information about the computers, phones, and other devices used when interacting with IPC products and services, which may include information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
Content and Context from Messaging and Other Collaborative Features: Content generated in messages that are hosted on IPC products and services (“Customer Content”), which may include files, as well as related context. Customer Content may contain your voice and image, depending on the account owner’s settings, what you choose to share, your settings, and what you do on IPC products and services. As referenced below, IPC employees do not access or use Customer Content without the authorization of the hosting account owner, or as required for legal, safety, security or support reasons.
Usage Information Regarding Meetings, Webinars, Messaging, Collaborative Features and the Website: Information about how people and their devices interact with IPC products and services, such as: when participants join and leave a meeting; whether participants sent messages and who they message with; performance data; mouse movements, clicks, keystrokes or actions, edits to transcript text, where authorized by the account owner and other inputs that help IPC to understand feature usage, improve product design, and suggest features; which third-party apps are added to a meeting or other product or service and what information and actions the app is authorized to access and perform; use of third-party apps and the IPC Marketplace; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with IPC’s websites, including what pages are accessed, interaction with website features including IPC’s website’s virtual chat feature, and whether or not the person signed up for a IPC product or service. Some usage data collection is optional and may be controlled by your Diagnostic Data Preferences Setting.
Limited Information from IPC Email and Calendar Services: “IPC Email” refers to IPC’s native email service and emails sent from IPC’s native email service. IPC Email is designed to be end-to-end encrypted by IPC by default for emails sent and received directly between active IPC Email users. Support for end-to-end encryption requires IPC Email users to have added a device to their IPC Email account with the associated email address and to use a supported IPC client. When an email is end-to-end encrypted, only the users, and, depending on their settings, account owners, or designated account administrators control the encryption key and therefore access to the email content, including body text, subject line, attachments and custom labels applied to messages by users in their inboxes. Emails sent to or received from non-IPC Email users are encrypted after the email is sent or received from IPC’s servers, if the IPC Email user chooses to send them with encryption. In all cases, IPC does have access to email metadata used for basic email delivery—specifically, email addresses in the from, to, cc, and bcc fields, time, mimeID, and the number and size of attachments.
Content from Third-Party Integrations: Account owners and/or their licensed end users can access emails, calendars, files and other information from third-party services through their IPC client, if they choose to integrate them. This information is not end-to-end encrypted by IPC, but IPC employees do not access the contents of third-party-service email, calendar entries, files or other information, unless authorized to, or required for legal, safety, security or support reasons. If account owners and/or their licensed end users integrate their third-party emails, calendars, files and/or other information with products and services offered or powered by IPC, then IPC may collect or process Customer Content and email, calendar, files and other information, including content, headers, titles, and metadata, from such third-party services.
Communications with IPC: Information about, and contents of, your communications with IPC, including relating to support questions, website virtual chats, your account, feedback provided by users to IPC about IPC’s products and services (which is owned by IPC), and other inquiries.
Information from Partners: IPC obtains information about account owners and their users from third-party companies, such as market data enrichment services, including information about an account owner’s company size or industry, contact information, or activity of certain enterprise domains. IPC may also obtain information from third-party advertising partners that deliver ads displayed on IPC products and services, such as whether you clicked on an ad they showed you.

In certain jurisdictions, some of the personal data IPC receives may be considered sensitive. Please see “California & Other U.S. State Privacy Rights” for more information.

How Do We Use Personal Data?

IPC employees do not access or use Customer Content including messaging, or email content or any content generated or shared as part of other collaborative features, unless authorized by the account owner hosting the IPC product or service where the Customer Content was generated, or as required for legal, safety, security or support reasons. IPC does not use any of your audio, video, chat, screen sharing, attachments or other communications-like Customer Content to train IPC’s or its third-party artificial intelligence models.

As discussed below, and where technically feasible, IPC uses personal data to conduct the following activities:

Provide IPC Products and Services: To provide products and services to account owners, their licensed end users, and those they invite to join meetings and webinars hosted on their accounts, including to customize IPC products and services and recommendations for accounts of their users. IPC also uses personal data to determine what products and services may be available in your location, and uses personal data, including contact information, to route invitations, messages, or IPC Emails to recipients when users send or receive invitations, messages, or IPC Emails using IPC products and services. This may also include using personal data for customer support, which may include accessing audio, video, files, messages, and other content or context, including information you provide through IPC’s website’s virtual chat feature, at the direction of the account owner or their users. We also use personal data to manage our relationships and contracts with account owners and others, including billing, compliance with contractual obligations, facilitating payment to third-party developers in relation to purchases made through the IPC Marketplace, and related administration.
Product Research and Development: If authorized by any applicable settings, to develop, test, and improve IPC products and services, and to troubleshoot products and services.
IPC does not use any of your audio, video, chat, screen sharing, attachments or other communications-like Customer Content (such as poll results, whiteboard and reactions) to train IPC’s or its third-party artificial intelligence models.
Marketing and Promotions: If authorized by any applicable settings, to permit IPC and/or its third party marketing partners to market, advertise, and promote IPC products and services, including based on your product usage, information we receive from third-party partners, information you provide to process referral invitations, or if you visit our websites, information about how and when you visit, and your interactions with them. We may also use this information to provide advertisements to you relating to IPC products and services or to engage third party partners to analyze your interactions on our website or app or to deliver advertising to you. IPC does not use Customer Content for any marketing or promotions.
Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, detect, investigate, and prevent malicious conduct, fraudulent activity or unsafe experiences, address security threats, protect public safety, and secure IPC products and services. IPC uses advanced tools to automatically scan certain types of content such as virtual backgrounds, profile images, incoming emails to IPC’s native email service from someone who is not a IPC Email user, and files uploaded or exchanged through chat, for the purpose detecting and preventing violations of our terms or policies and illegal or other harmful activity.
Communicate with You: We use personal data (including contact information, and information you provide through IPC’s website’s virtual chat feature, including the content of the messages) to communicate with you about IPC products and services, including product updates, your account, and changes to our policies and terms. We also use your information to respond to you when you contact us.
Legal Reasons: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, protect you, us, and others from fraudulent, malicious, deceptive, abusive, or unlawful activities, and to enforce or investigate potential violations of our Terms of Service or policies.

How Do We Share Personal Data?

IPC provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):

Resellers: If an account owner licensed or purchased IPC products and services from a third-party reseller of IPC products and services, the reseller may be able to access personal data and content for users, including meetings, webinars, and messages hosted by the account owner.
Vendors: IPC works with third-party service providers to provide, support, and improve IPC products and services and technical infrastructure, and for business services such as payment processing, including in relation to purchases made through the IPC Marketplace. IPC may also work with third-party service providers to provide advertisements and business analytics regarding IPC products and services. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to IPC or as required by law. IPC may integrate third-party technology to provide advanced features, such as Apple’s TrueDepth technology, to process information on your device about your face or hand dimensions and gestures to provide video effects. This information is processed on your device, and such information is neither received nor stored by either the third party, or IPC.
For Legal Reasons: IPC may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers’ rights and property; and (6) resolve disputes and enforce agreements.
Marketing, Advertising, and Analytics Partners: IPC uses third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using IPC products and services, including our website; and to provide advertising and marketing for IPC products and services, including targeted advertising based on your use of our website. These third-party partners may receive information about your activities on IPC’s website through third-party cookies placed on IPC’s website. Where required by law, IPC will first obtain your consent before engaging in the marketing or advertising activities described.
Corporate Affiliates: IPC shares personal information with corporate affiliates, such as IPC Voice Communications, Inc., to provide integrated and consistent experiences across IPC products and services (such as enabling an account owner or their user to integrate a IPC Phone call into a meeting) and to detect, investigate, and prevent fraud, abuse, and threats to public safety.
Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of IPC’s business or assets, including in connection with bankruptcy or similar proceedings.
Third-Party Developers: If you purchase a third-party app or integration from the IPC Marketplace, IPC may share information about the purchase with the third-party developer, to provide the app or integration.

When you send messages or use other collaborative features on IPC, other people and organizations, including third parties outside the message, or other collaborative features, may be able to see, share, and process content and information that you share:

Account Owner: An account owner is the organization or individual that signs up for a IPC account. Typically, an account owner designates one or more people (called an “administrator”) to manage their account and can grant privileges to users on the account. Depending on their license with IPC, the account owner can authorize additional users on their account, and the account owner can create and/or access the profile information for all users on their account. The account owner and their users can invite others (including guests not on their account and unlicensed participants) to meetings or webinars hosted on their account. IPC gives account owners controls and features that they can use to determine whether certain types of content, such as recordings or IPC Team Chat messages, can be created or sent, and what third-party apps can be used, for meetings and webinars hosted on their account. Depending on their settings, account owners and the users they designate can access personal data for participants who join meetings and webinars on their account or send messages to users on their account. Account owners may also be able to determine what information IPC and others can access and use. Specifically, account owners may have access to:
Product Usage: Information about how users and their devices interact with their account, which may include who sent messages to their users in chat, email addresses, IP addresses, device information, and other information on their account, the time a message was sent, information about integrations, and other usage information and feedback metrics.
Other Collaborative Feature Content: Depending on their settings, account owners and designated account administrators can access content hosted on their account. For example, depending on their settings, account owners and designated account administrators can access email and calendar content sent to and from users on their IPC Email or IPC Calendar accounts, even if those IPC Emails are encrypted.
Intelligent Features: Users may be able to access, based on underlying permissions, customer content and context from messaging, and other collaborative features through their use of intelligent features.
Apps and Integrations:
- Account owners can choose to add IPC-developed apps and third-party apps to their account and the IPC products they use, including via use of the IPC Marketplace, and they can also control whether their users can add and use specific IPC and third-party apps.
- Account owners can also choose to integrate other content from third-party services – such as third-party email communications, calendar entries, files and other information – with apps and services that they use.
- Depending on their settings, account owners’, users’ and guests’ personal data and content may be shared with apps and integrations, including IPC-developed apps, approved by account owners, which may include all of the personal data categories listed above, such as account information, profile and contact information, registration information, participants list, settings, content, product usage, device information, or third-party emails that have been shared with the app.
- Personal information shared by account owners and users with third-party apps and integrations is collected and processed in accordance with the app developers’ terms and privacy policies, not IPC’s.

Privacy Rights and Choices

Marketing Communications

If you don’t want to learn about products and services we or our partners offer, you can opt-out of marketing communications in the communication sent to you (for example, via email or SMS). Not all of our communications are for marketing, and you’ll continue to receive messages related to your products and services, such as bills, transactional notices, or customer service. IPC will not share any mobile data originating from you through a text messaging campaign except with your consent or as necessary to provide you communications about our services or services that you requested.

Data Rights

If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California or another U.S. state with an applicable privacy law, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:

Inform you of what personal data we have about you that is under our control;
Amend or correct such personal data or any previous privacy preferences you selected, or direct you to
applicable tools; and/or
Delete such personal data or direct you to applicable tools.

Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others. As an account owner or a user under a licensed account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.

Children

IPC does not allow children under the age of 16 to sign up for a IPC account.

How to Contact Us

You can contact us by emailing our Instant Prospect Conversion Data Protection Officer via privacy at
instantprospectconversion.com.

Retention

We retain personal data for as long as required to engage in the uses described in this Privacy Policy, unless a longer retention period is required by applicable law.

The criteria used to determine our retention periods include the following:

The length of time we have an ongoing relationship with you and provide IPC products and services to you (for example, for as long as you have an account with us or keep using our products);
Whether account owners modify or their users delete information through their accounts;
Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).

European Data Protection Specific Information

Data Subjects Rights

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

If you have any other questions about our use of your personal data, please send a request to the contact details specified in the How to Contact Us section of this Privacy Policy. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when IPC processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing IPC products and services, features and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products and services;
Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. In these cases you have the right to withdraw your consent at any time;
As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the products and services (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our products and services and troubleshoot products and services; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and products and services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the products and services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.

International Data Transfers

IPC operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where IPC or its service providers have customers or facilities – including in countries where meeting participants or account owners hosting meetings or webinars that you participate in or receiving messages that you send are based.

Therefore, by using IPC products and services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.

We protect your personal data in accordance with this Privacy Policy wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws.

Under limited circumstances and after other available dispute resolution mechanisms have been exhausted, binding arbitration is available to address certain residual complaints under the DPF not resolved by other means.

California & Other U.S. States Notice at Collection

Categories of Personal Information IPC Receives: IPC may collect, or process on behalf of our customers, the following categories of personal data, as described above, in the “What Personal Data Do We Receive?” section: identifiers (such as in Account Information, Profile and Participant Information, Contact Information, and Registration Information), financial account information (such as in Account Information); commercial information (such as in Account Information); internet or other electronic network activity information (such as Device Information, Usage Information, Messages, Collaborative Features, and the Website, and Limited Information from IPC Email and Calendar Services); audio, electronic, and visual information, education information such as from university customers; inferences we derive from the preceding or other information we collect; and sensitive personal information.

Sources: We receive information from sources as described in the “What Personal Data Do We Receive?”; section, including: from you (including through your use of our products and services); from partners; from customers; and from publicly available sources.

IPC’s business and commercial purposes for use: IPC uses personal data for the following business and commercial purposes: to provide IPC Products and Services; for Product Research and Development; for Marketing and Promotions (IPC does not use messaging content, or any content generated or shared as part of other collaborative features for any marketing or promotions); Authentication, Integrity, Security, and Safety; to Communicate with You; and for Legal Reasons. Categories of third parties to whom we disclose Personal Information for business purposes are described in “How Do We Share Personal Data?”;

IPC may permit advertising and analytics services that are intended to deliver advertising to you and/or analyze your interactions, based on your interactions with our website or app which may constitute a “sale” or “sharing” of data for targeted advertising purposes under certain state privacy laws. See “California & Other U.S. State Privacy Rights” for more information regarding your right to opt-out.

Retention: IPC retains personal data for as long as required to engage in the uses described in this Privacy Policy, unless a longer retention period is required by applicable law. Additional detail on retention criteria can be found under Retention, above.

California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:

Access the categories and specific pieces of personal data IPC has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom IPC has shared personal data, and obtain the personal data in a portable and, to the extent technically feasible, readily usable format;
Delete personal data under certain circumstances;
Correct personal data under certain circumstances; and
Opt out of the “sale” of personal data or “sharing” of personal data for targeted advertising purposes. We do not sell your personal data in the conventional sense. However, like many companies, we may use advertising and analytics services that are intended to analyze your interactions with our website or app, based on information obtained from cookies or other trackers, including for delivering advertising to you (such as interest-based, targeted, or cross-context behavioral advertising). Residents of California, Colorado, Connecticut, Montana, Nebraska, New Hampshire, and Texas may also set the Global Privacy Control (GPC) to opt out of the “sale” or “sharing” of your personal information for targeted advertising for each participating browser system that you use. IPC does not have actual knowledge that it “sells” or “shares” the personal information of consumers under 16 years of age.
Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision.

IPC will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law.

Sensitive Information. IPC receives information that may be considered sensitive under some state laws, such as certain Account Information (e.g., financial information, log-in information), certain Content and Context from messaging, and other collaborative features and certain Limited Information from IPC Email and Calendar Services (e.g., messaging content in cases described in this statement) as well as voiceprints and facial geometry, if you choose to enable certain features and provide the requisite consent. IPC processes sensitive personal information to provide IPC products and services, for product research and development, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. IPC does not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require IPC to provide a right to limit under the CCPA. Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual’s information that would produce a legal or similarly significant effect. IPC does not engage in this type of profiling of individuals.

These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. To verify your identity, we may require you to log into your existing IPC account (if applicable), give a declaration as to your identity under penalty of perjury, and/or provide additional information, such as providing at least two pieces of personal information relating to your account (which will be compared to information we have, such as profile information) or as we otherwise may already have in our possession, such as your email address and phone number. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

California’s Shine the Light Law

Under California’s Shine the Light law, you may also ask companies with whom you have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Policy on our website, with a “Last Updated” date at the top so check back frequently and review it before you choose to continue using our products and services.

Privacy Policy

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