Privacy Policy

This privacy notice for StratusTalk, Inc. (“Company,” “we,” “us,” or “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

• Visit our website at www.stratustalk.com, or any website of ours that links to this privacy notice;
• Download and use our desktop or mobile applications, or use a desk phone or other device we provision;
• Subscribe to our hosted voice, video, and messaging service, or sign in to the customer or reseller portal; or
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@stratustalk.com.

Summary of key points

This summary provides key points from our privacy notice. You can find more detail on any of these topics in the section listed after each point, or by using the table of contents below.

• What personal information do we process? When you visit, use, or navigate our Services, we process personal information depending on how you interact with StratusTalk and the Services, the choices you make, and the products and features you use. See “What information do we collect?”
• Do we process sensitive personal information? We do not seek out or process sensitive personal information for our own purposes. Where our customers use the Services in a regulated setting, protected health information and similar sensitive data may pass through our systems as their service provider. See “Regulated and sensitive data”
• Do we sell your personal information? No. We have never sold personal information, and we do not share it for cross-context behavioral advertising. See “Do California residents have specific privacy rights?”
• Do we receive information from third parties? We may receive information from public databases, marketing partners, our resellers, and underlying carriers. See “What information do we collect?”
• How do we process your information? We process your information to provide, improve, and administer our Services, to place and route your calls, to bill you, to communicate with you, for security and fraud prevention, and to comply with law. See “How do we process your information?”
• When and with whom do we share information? With service providers acting on our behalf, with the carriers and databases required to connect and port your calls and numbers, with emergency responders when a 911 call is placed, and where the law requires. See “When and with whom do we share your personal information?”
• How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. See “How do we keep your information safe?”
• What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information. See “What are your privacy rights?”
• How do you exercise your rights? Email us at support@stratustalk.com and we will consider and act upon any request in accordance with applicable data protection laws. See “How can you review, update, or delete the data we collect from you?”

Table of contents

1. What information do we collect?
2. How do we process your information?
3. When and with whom do we share your personal information?
4. Emergency (911) calling and location information
5. Customer proprietary network information (CPNI)
6. Regulated and sensitive data
7. Do we use cookies and other tracking technologies?
8. How long do we keep your information?
9. How do we keep your information safe?
10. Do we collect information from minors?
11. What are your privacy rights?
12. Controls for Do-Not-Track features
13. Do California residents have specific privacy rights?
14. Do we make updates to this notice?
15. How can you contact us about this notice?
16. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you register for an account, when you participate in activities on the Services, or otherwise when you contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:

• names;
• phone numbers;
• email addresses;
• mailing and service addresses, including the physical location where a phone or device is installed;
• company name, job title, and other business contact details;
• contact or authentication data, such as usernames and passwords;
• contact preferences;
• billing and payment details, and the contents of proposals, orders, and invoices; and
• the contents of support requests, and documents you send us to move your service — for example a letter of authorization or a copy of a bill from your prior provider.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information generally does not reveal your specific identity, but may include device and usage information. It is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. The information we collect includes:

• Log and usage data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and record in log files. Depending on how you interact with us, this may include your IP address, device information, browser type and settings, information about your activity in the Services (such as date and time stamps, pages and files viewed, searches, and features used), and device event information such as system activity, error reports, and hardware settings.
• Device data. Information about the computer, phone, tablet, desk phone, or other device you use to access the Services, which may include your IP address (or proxy server), device and application identification numbers, browser type, hardware model, MAC address, internet service provider or mobile carrier, operating system, and system configuration.
• Approximate location data. We derive a coarse location, such as country, region, or city, from your IP address in order to secure accounts, understand where our traffic comes from, and meet regulatory requirements. Our applications may also request a precise device location to support emergency calling; see “Emergency (911) calling and location information”. You can refuse or disable location access in your device settings, though some features may not work correctly if you do.

We use our own first-party analytics to measure site traffic and page performance. We do not use these measurements to build advertising profiles about you.

Information about your calls and messages

In Short: Running a phone system means we necessarily handle records about your calls and messages. We treat that data as confidential, and we never sell it.

To connect, route, troubleshoot, and bill for your communications, our network creates and stores records about them, including:

• Call detail records. The calling and called numbers, date, time, duration, direction, disposition, and the extensions, trunks, and gateways involved.
• Messaging metadata. The sending and receiving numbers, timestamps, and delivery status of SMS and MMS messages.
• Voicemail, recordings, and transcriptions. Voicemail messages left on your system, and call recordings and transcriptions where you or your organization turn those features on.
• Service quality measurements. Latency, jitter, packet loss, and registration data used to keep call quality high and to diagnose faults.

We do not monitor, listen to, read, or mine the content of your calls, messages, or recordings for advertising, marketing, or any other purpose of our own. Our personnel access this content only when you ask us to help with a specific problem, when it is necessary to protect the integrity or security of the network, or when the law requires it.

If you are an employee or end user on a system that belongs to one of our business customers, that customer controls the system and decides which features are enabled, who may listen to recordings, and how long records are kept. We process that data on their behalf and under their instructions. Please direct questions about their choices to your own organization.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, our resellers, and the carriers that help deliver your service.

In order to enhance our ability to provide relevant marketing, offers, and services to you and to update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, and data providers. This information may include mailing addresses, job titles, email addresses, phone numbers, intent data, IP addresses, social media profiles and URLs, and custom profiles.

We also receive information necessary to provide the Services from our authorized resellers, who may sign you up and manage your account, and from underlying carriers and number-porting databases, which supply routing, caller identification, and porting details for your numbers.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, to carry your calls, to communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To provide, operate, and maintain the Services. To create and administer your account, provision your phones and applications, route and deliver your calls and messages, and keep the network running.
• To bill you and collect payment. To rate usage, produce invoices, process payments, and handle disputes and collections.
• To respond to inquiries and offer support. To answer your questions and solve any potential issues you might have with the requested service.
• To request feedback. To contact you about your use of our Services and gather your input.
• To send you marketing and promotional communications, where this is in accordance with your marketing preferences. You can opt out at any time; see “What are your privacy rights?”
• To post testimonials. We post testimonials on our Services that may contain personal information. We obtain your consent before posting a testimonial that identifies you, and you may ask us to remove it at any time.
• To protect our Services. As part of our efforts to keep our Services safe and secure, including fraud monitoring, toll-fraud prevention, and abuse investigation.
• To evaluate and improve our Services, products, marketing, and your experience, including identifying usage trends and determining the effectiveness of our promotional campaigns.
• To comply with our legal obligations. To comply with law and regulation, respond to lawful requests, and exercise, establish, or defend our legal rights.

3. When and with whom do we share your personal information?

In Short: We share information only in the specific situations described in this section. We do not sell your personal information.

We may need to share your personal information in the following situations:

• Service providers. We share information with vendors, consultants, and other third parties who perform services for us — such as data center and cloud hosting, payment processing, email delivery, and ticketing — under a written contract that limits them to processing the information on our behalf and for our purposes.
• Carriers and telecommunications databases. To connect your calls and messages, present caller identification, and port your numbers to or from another provider, we exchange the necessary routing, subscriber, and authorization information with underlying carriers and industry databases.
• Emergency services. When a 911 or emergency call is placed, we transmit the registered service address or available location and callback number to emergency responders. See section 4.
• Your organization and its authorized representatives. If your service is provided through an employer, an authorized reseller, or an IT partner, we share account and usage information with the administrators and representatives they designate.
• Legal requirements and safety. We may disclose information where we are legally required to do so in order to comply with applicable law, governmental requests, a subpoena, a court order, or legal process, or where disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• With your consent. We may disclose your personal information for any other purpose with your consent.

We do not sell your personal information, and we do not share it with third parties for cross-context behavioral advertising or targeted advertising.

4. Emergency (911) calling and location information

In Short: Emergency calling requires us to know where your phones are, and to hand that information to emergency responders.

Because we provide interconnected voice service, we are required to deliver emergency calls together with information that lets responders find and call you back. To do this, we collect and maintain the registered location associated with each of your numbers and devices, and we share it, along with your callback number and name, with emergency call routing providers, public safety answering points, and the emergency personnel who respond to your call. This information may also be provided to a national emergency address database as required by law.

Keeping your registered location current is essential to your safety. If a phone or softphone is moved to a different address, update its location in the portal or contact us so that we can correct it. Our applications may ask for permission to use your device location to improve the accuracy of an emergency call. We use location collected for this purpose only for emergency calling and for the recordkeeping the law requires.

5. Customer proprietary network information (CPNI)

In Short: Federal law gives special protection to information about the phone service you buy and the calls you make, and we follow it.

Some of the information we hold is customer proprietary network information, or CPNI — information about the quantity, technical configuration, type, destination, location, and amount of use of the telecommunications service you buy from us, along with related billing information. Federal law and the rules of the Federal Communications Commission restrict how we may use and disclose CPNI.

We use CPNI to provide and bill for your service, to protect our network and our customers from fraud and unlawful use, and to respond to your requests. We do not use or disclose CPNI for marketing outside of the categories of service you already receive from us without first obtaining your approval, and we do not sell it. When you or someone claiming to act for you contacts us about call detail information, we authenticate the request before disclosing anything, and we will notify you of certain account changes and of any breach of CPNI as the rules require. You may tell us at any time that you do not want your CPNI used for marketing by writing to support@stratustalk.com; doing so will not affect the service you receive.

6. Regulated and sensitive data

In Short: We do not seek out sensitive information for our own purposes. When our customers use the Services in a regulated field, we act as their service provider.

We do not collect or process sensitive personal information — such as health data, precise financial account information beyond what is needed to bill you, biometric identifiers, or information about race, religion, or sexual orientation — for our own purposes, and we ask that you do not send it to us in support requests or web forms.

Our customers include healthcare, legal, and other organizations that handle confidential information, and communications carrying that information may pass through our platform. Where we handle protected health information on behalf of a covered entity, we do so as a business associate under a written agreement, we use and disclose that information only as that agreement and applicable law permit, and we apply the safeguards described in section 9. If your organization requires a business associate agreement, contact us at support@stratustalk.com.

7. Do we use cookies and other tracking technologies?

In Short: We use cookies and similar technologies for the essentials — keeping you signed in, keeping the site secure, and measuring traffic.

We use cookies and similar technologies to access or store information. The cookies we set are used to keep your session and sign-in secure, to remember your preferences, to protect forms against abuse, and to measure site traffic with our own analytics.

Most web browsers accept cookies by default. You can usually set your browser to remove or reject cookies, and you can clear cookies that have already been stored. If you remove or reject cookies, some features of the Services — including signing in to the portal — may not work correctly.

8. How long do we keep your information?

In Short: We keep your information for as long as necessary to provide the Services and to meet the recordkeeping obligations that apply to a telecommunications provider.

We keep your personal information for as long as your account is active, and afterwards only for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. In practice this means:

• Account, billing, and tax records are kept for the life of the account and then for the period required by tax, accounting, and telecommunications regulations.
• Call detail records and billing detail are retained for at least the period federal rules require for toll records, and are then deleted or aggregated.
• Voicemail, call recordings, and transcriptions are kept according to the retention setting your organization chooses for its system, and are deleted when that period expires or when the account is closed.
• Website and marketing enquiries that do not become accounts are kept for up to two years so we can follow up, and then deleted.
• Security and diagnostic logs are kept for a short rolling window, typically no more than twelve months.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If that is not immediately possible — for example because it is held in backup archives — we will securely store it and isolate it from any further processing until deletion is possible.

9. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These include encryption of communications between endpoints and of data in transit across our network, encryption of stored credentials and sensitive records, role-based access controls and multi-factor authentication for our staff, network segmentation and firewalling, monitoring for toll fraud and intrusion, and regular patching and backup of the systems that carry your service.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment, and you should keep your account credentials confidential.

10. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to that minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@stratustalk.com.

11. What are your privacy rights?

In Short: You may review, change, or terminate your account at any time, and you may ask us about the information we hold about you.

Depending on where you live, you may have the right to request access to the personal information we hold about you, to ask us to correct or delete it, to object to or restrict how we process it, and to receive a copy in a portable form. To make a request, email us at support@stratustalk.com. We will respond within the time applicable law allows, and we will not discriminate against you for exercising your rights.

If you are located in the EEA or the UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details at ec.europa.eu. If you are located in Switzerland, the contact details for the data protection authorities are available at edoeb.admin.ch.

Withdrawing your consent. If we are relying on your consent to process your personal information, which may be express or implied depending on the applicable law, you have the right to withdraw your consent at any time by contacting us using the details in section 15. Withdrawing consent will not affect the lawfulness of processing carried out before you withdrew it, nor will it affect processing that relies on lawful grounds other than consent.

Opting out of marketing and promotional communications. You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us using the details in section 15. You will then be removed from our marketing lists. We may still communicate with you for non-marketing purposes — for example to send service and outage notices, respond to service requests, or administer your account.

Account information. If you would like to review or change the information in your account, or terminate your account, you may sign in to the portal or contact us. On request to terminate your account, we will deactivate or delete your account and information from our active databases. We may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, or comply with applicable legal requirements.

12. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. Do California residents have specific privacy rights?

In Short: Yes. If you are a resident of California, you have specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information in section 15.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal, contact us using the information in section 15 and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems, such as backups.

CCPA privacy notice

The California Code of Regulations defines a “resident” as (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as “non-residents.” If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories where you interact with us in person, online, or by phone or mail in the context of receiving help through our customer support channels, participating in customer surveys or contests, and facilitating the delivery of our Services and responding to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice, particularly in section 2 and section 3. You may contact us by email at support@stratustalk.com, or by using the contact details at the bottom of this document.

We disclose personal information to our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf. We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered a “sale” of your personal information.

StratusTalk, Inc. has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. StratusTalk, Inc. will not sell personal information belonging to website visitors, users, and other consumers in the future.

Your rights with respect to your personal data

Right to request deletion of the data. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete it, subject to certain exceptions provided by law — such as the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed. Depending on the circumstances, you have a right to know whether we collect and use your personal information; the categories of personal information that we collect; the purposes for which the collected personal information is used; whether we sell your personal information to third parties; the categories of personal information that we sold or disclosed for a business purpose; the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information. In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request, or to re-identify individual data to verify a consumer request.

Right to non-discrimination for the exercise of a consumer's privacy rights. We will not discriminate against you if you exercise your privacy rights.

Verification process. Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match it against our records, or we may contact you through a communication method you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request, and we will delete any additional information you provide for verification as soon as we finish verifying you.

Other privacy rights. You may object to the processing of your personal information. You may request correction of your personal data if it is incorrect or no longer relevant, or ask us to restrict the processing of the information. You can designate an authorized agent to make a request on your behalf; we may deny a request from an authorized agent that does not submit proof of valid authorization to act on your behalf.

To exercise these rights, contact us by email at support@stratustalk.com, or by using the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

14. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Last updated” date, and will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at support@stratustalk.com or write to us by post at:

StratusTalk, Inc.
11921 Freedom Dr, Suite 550
Reston, VA 20190
United States

16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, to change that information, or to delete it in some circumstances. To make a request, email support@stratustalk.com with the subject line “Privacy request,” and tell us what you would like us to do. If you have an account with us, you can also review and update much of your information yourself by signing in to the portal. We will verify your request as described in section 13 and respond within the time applicable law allows.