Your privacy is very important to us. We are committed to ensuring that when you use our services or engage with us, you know what personal information or data (Personal Data) we collect about you and how we use your Personal Data. This data privacy notice (Privacy Notice) is a statement that describes how we will use your Personal Data. Please take the time to read and understand our Privacy Notice.
It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Notice supplements the other notices and is not intended to override them.
Data protection and privacy laws in certain jurisdictions, like the European Economic Area (EEA) and in the UK, differentiate between “controllers” and “processors” of personal information. A controller determines the purposes and means of the processing of Personal Data. A processor processes personal information on behalf of a controller based on the controller’s instructions. We are mainly a processor of Personal Data but in some instances act as a controller as well. This privacy notices explains how we process Personal Data as a controller.
Dubber is a global group which provides call recording and audio asset management in the cloud, headquartered in Australia with offices also in the United States of America and the United Kingdom.
In this Privacy Notice, you or your means an individual who is the subject of Personal Data we process as a data controller, which would: (i) typically be the representatives, and end users of our corporate customers (which could be either communication operators or other corporate customers) that interact with us and manage and use our call recording and transcription facilities or our other corporate services; and (ii) the data subjects of a small number of recordings and audios we spot check for quality and product development purposes only – we do not otherwise control stored audios or recordings.
If you are a European Union (EU) data subject the General Data Protection Regulation 2016/679 (the GDPR) applies. If you are in the UK, the Data Protection Act 2018 applies along with the GDPR (until the GDPR ceases to apply in the UK). Dubber, we, our or us refers to Dubber Limited, reg. no 10093254 of 49 Greek Street, London W1D 4EG, UK, otherwise each of those terms refers to Dubber Pty Ltd ACN 150 843 164 of Level 5, 2 Russell Street, Melbourne Vic. 3000, Australia.
If you are an EU or a UK data subject, the controller of your Personal Data is Dubber Limited.
For any other data subjects, Dubber Pty Ltd is the controller and the applicable data protection laws will apply to the processing of their Personal Data.
This Privacy Notice (together with our Terms of Service, which you can find at www.dubber.net/terms and any other documents referred to in it) sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. This Privacy Notice also sets out how you can instruct us if you prefer to limit the use of that Personal Data, as well as the procedures that we have in place to safeguard your privacy.
Dubber may collect your Personal Data when:
We may collect, use, store and transfer different categories of Personal Data about you which we have grouped together as follows:
We will only collect information from third parties where:
We may process your Personal Data for one or more lawful bases of processing (Lawful Basis) depending on the specific purpose for which we are using your data (see below).
For example, in accordance with this Privacy Notice Dubber may use your Personal Data in order to:
Your information may, for the purposes set out in this Privacy Notice, be disclosed for processing to:
Dubber serves customers globally. Accordingly, the information we collect from you may also be transferred to, and stored at, a destination anywhere in the world, including outside the EEA or the UK. It may also be processed by staff operating outside the EEA or the UK who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Notice.
For EU and UK data subjects, we may implement one of the following safeguards, namely:
Where possible and practical, you will have the option to deal with Dubber on an anonymous basis or by using a pseudonym. However, in some circumstances, if we are unable to collect Personal Data from or about you, or if the Personal Data provided is incomplete or inaccurate, Dubber may not be able to do business with you, including providing the products or services you are seeking or provide support or assist you with your queries.
The Internet is not a secure medium. However, we have put in place a range of security procedures, as set out in this Privacy Notice. Where you have been allocated an account, this area is protected by your username and password, which you should never divulge to anyone else.
Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered. This is the nature of the World Wide Web/Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
We will use reasonable endeavours to implement appropriate policies, rules and technical measures to protect the Personal Data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
We will ensure that your information will not be disclosed to government institutions or authorities except if required by law (e.g. when requested by regulatory bodies or law enforcement organisations in accordance with applicable legislation).
Certain services may include social networking, chat room or forum features. When using these features please ensure that you do not submit any Personal Data that you do not want to be seen, collected or used by other users.
We will take all reasonable steps to ensure that all information we collect, use or disclose is accurate, complete and up-to-date. Please contact us if your details change or if you believe the information we have about you is not accurate or complete.
EU and UK data subjects also have the following rights:
What we may require from you to exercise the rights above.
We may need to request specific information from you to help us confirm your identity. We may also contact you to ask for further information in relation to your request.
Time limit to respond to EU and UK data subject requests.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer that a month if your request is particularly complex, or you have made several requests. In this case, we will notify you and keep you updated.
No fee usually required to deal with EU and UK data subject requests.
All communication and all actions taken by Dubber regarding your rights described above are provided free of charge. Dubber reserves the right, in the case of clearly unfounded or unreasonable requests, to either take out a reasonable fee covering the administrative costs of providing the information or taking the requested action or refusing to fulfil the requested action.
We will only retain your Personal Data for as long as you have consented to it or when is necessary to us to provide you with our services or fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements. For instance, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) typically for six years after they cease being customers for tax purposes.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your Personal Data.
In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you believe that the privacy of your Personal Data has been compromised, you are entitled to complain and we will endeavour to satisfactorily resolve the issue.
You can raise your concerns by contacting Dubber by email at firstname.lastname@example.org or by contacting us in writing at one of the following addresses:
Our worldwide headquarters: Level 5, 2 Russell Street Melbourne Vic. 3000 Australia
Our UK and EU offices 41 Corsham Street London N1 6DR United Kingdom
Our US offices 1920 McKinney Avenue Dallas, TX 75201 United States of America
Australian residents can lodge a complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) regarding Dubber’s information handling practices or a breach of the Privacy Notice.
EU and UK data subjects have additional rights to make a complaint to a competent data protection authority or commence proceedings in a court of competent jurisdiction in accordance with applicable data protection laws, including with the Information Commissioner’s Office of the United Kingdom (ico.org.uk).
We reserve the right to amend or edit this Privacy Notice from time to time at our discretion, such as to reflect changes in Dubber’s business or practices. We may change the Privacy Notice at any time by posting the changed Privacy Notice on our Websites, including posting a notice on the homepage of one or more our Websites indicating a change has been made.
This Privacy Notice was last updated on 24 March 2020.
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