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Privacy Notice: WEM
Last Updated: 15th January 2019
Version 2.5
Tangoe Inc.
169 Lackawanna Avenue
Parsippany, NJ 07054
www.tangoe.com
Copyright Notice
© 2019 Tangoe US., Inc..All rights reserved
No part of this publication may be reproduced, transmitted,
transcribed, stored in a retrieval system, or translated into any
language in any form by any means without the prior written permission
of Tangoe .
Revision History
2.2
14.12.2018
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Page(s)
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Section
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Change Description
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Initials
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Date
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Notice Ownership
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Name
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Title
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Role
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Last Review Date
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Matt Biddle
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Senior Manager, Service Excellence
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Notice Owner
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Laura Wilkie
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Global Data Protection & Privacy
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Data Protection Sponsor
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Keri King
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Global Compliance
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Compliance Sponsor
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Chris Walls
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General Counsel
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Executive Sponsor
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Contents
Copyright Notice
Revision History
Notice Ownership
1) Introduction
2) How will Tangoe use your data?
3) What data is collected?
4) Where is your data is collected?
5)
Special categories
of data
6)
How does Tangoe ensure there is a lawful reason to
use your data?
7)
Who
will Tangoe share your data with?
8)
Where
will your data be stored and used?
9) How is your data used to manage your TEM
service?
10)
Is there any automated decision making?
11) What happens if we stop using Tangoe's
services?
12)
How long
will Tangoe keep your data?
13) How will Tangoe protect my data?
14)
Will my data be used for direct marketing?
15)
What are your rights?
16) Changes to this Privacy Notice
17)
How to contact Tangoe?
Privacy Notice: WEM
1) Introduction
Tangoe likes making complicated things simple and transparent, and so
we want to explain how we will use your personal data in a simple and
transparent way.
Tangoe is interested in data protection laws because they govern the
way we use the personal data ("data") you give us throughout your time
as a user of Tangoe's services. This Privacy Notice explains how Tangoe
uses the data we receive from you, your employer and your employer's
other vendors.
Personal data is any information that could be used (directly or
indirectly) to identify an individual. That may be anything from a name
and address, email address, image or audio recording, IP address,
telephone number or any other data that could be used to identify an
individual.
We have tried to provide all the information we think you may want to
know, but if you have any questions please contact us. [Note: Click highlighted
words for more detail or for definitions.]
2) How
will Tangoe use your data?
Tangoe believes in using your data fairly. There should be no
surprises. We will only use your data for the reason for which you or
your employer gave it to us, for the delivery of agreed services or for
legal or regulatory purposes. It will not be used for other reasons.
We will not keep it longer than it is required and will only share it with people where this is
required for the services or legal purposes.
3) What data is collected?
Tangoe will only access data that your employer has authorized Tangoe
to collect or receive, in order to enable delivery of your services.
Tangoe obtains your data from different sources during the following
stages of the service lifecycle;
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Contract signature
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On boarding (implementation)
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In-life services
[Note: If you provided data within the sales cycle this is managed in
line with Tangoe's Marketing Privacy Notice]
a) Data collected throughout the contract signature process
The table below shows the list of data which is passed to Tangoe to
allow the contract to be executed prior to implementation of the
services:
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Data Category
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Data Type
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Data Source
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Employees' data
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Name
(s) of the employees required for contract
signature.
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Your organisation or third party supplier
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Employees' data
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Email address
(es) of the employees required for contract
signature.
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Your organisation or third party supplier
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Employees' data
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Phone number
(s) of the employees required for contract
signature.
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Your organisation or third party supplier
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Employees' data
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Job title
of the employees required for contract signature.
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Your organisation or third party supplier
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Telecom vendor & other third party information
(account listing)
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Name
(s) of the third parties' employees required for
contract signature.
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Email address
(es) of the third parties' employees required for
contract signature.
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Phone Number
(s) of the third parties' employees required for
contract signature.
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Job title
of the third parties' employees required for contract
signature.
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Your organisation or the vendor/ third party supplier
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In some instances a) and b) will happen in parallel.
b) Data collected during on boarding (implementation)
Once the contract is signed, Tangoe's implementation teams will
initiate the design and build of the databases required to provide your
services by requesting and will obtain additional data:
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Data Category
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Data Type
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Data Source/s
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Employees' data
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Name of your current employees
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Your organisation or vendor
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Employees' data
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Title of your current employees
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Your organisation or vendor
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Employees' data
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Email address of your current employees
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Your organisation or vendor
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Employees' data
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Phone numbers (landline) of your current employees
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Your organisation or vendor
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Employees' data
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Phone numbers (mobile) of your current employees
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Your organisation or vendor
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Employees' data
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Job title of your current employees
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Your organisation
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Employees' data
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Organisational charts and reporting structures of your current employees
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Your organisation
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Employees' data
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Employee number of your current employees
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Your organisation
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Employees' data
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Work location of your current employees
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Your organisation
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Employees' data
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Line managers of your current employees
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Your organisation
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Employees' data
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Tangoe platform login, password
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Your organisation
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Employees' data
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Employee employment status
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Your organisation
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Telecom vendor & other third party information
(account listing)
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Company name
of your telecom vendors
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Name
of your telecom vendor contacts (Account managers)
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Phone number
of your telecom vendor contacts (Account managers)
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Email address
of your telecom vendor contacts (Account managers)
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Telecom vendor invoice remittance information
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Vendor billing data
including summary, invoice and call detail records
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Vendor account statements and payment
ledgers
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Your organisation or the vendor/ third party supplier
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Your office(s) information
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Address
of your current offices
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Your organisation
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(real estate file)
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Your cost centres
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Your organisation
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Your office(s) information
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Your cost centre hierarchy
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Your organisation
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c) Data collected during in-life services
(post-implementation).
Your data will continue to be collected for the ongoing provision of
services. Tangoe's service delivery teams will ensure the data
collected during the b) implementation stage is maintained in
accordance with the applicable service contract. In order to deliver
the services the data categories listed above continue to be collected,
in addition to the following:
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Data Category
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Data Type
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Data Source
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Employees' data
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Name of new employees or changes to the name of current
employees
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Your organisation or vendor
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Employees' data
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Email address of new employees or changes to the email
of current employees
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Your organisation or vendor
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Employees' data
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Changes to phone numbers (landline) of your employees
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Your organisation or vendor
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Employees' data
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Changes to phone numbers (mobile) of your employees
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Your organisation or vendor
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Employees' data
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Changes to job title of your employees
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Your organisation
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Employees' data
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Changes to organisational charts and reporting
structures of your employees
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Your organisation
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Employees' data
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Changes to employee number of your employees
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Your organisation
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Employees' data
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Changes to work location of your employees
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Your organisation
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Employees' data
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Changes to line manager of employees
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Your organisation
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Employees' data
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Changes to employee status of employees
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Your organisation
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Employees' data
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System usage logs
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Directly from your employee's usage of Tangoe's systems
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Employees' data
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IP Addresses
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Directly from your employee's usage of Tangoe's systems
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Employees' data
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Alternate user login names
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Directly from your employee
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Employees' data
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Aggregate management and statistical data
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From Tangoe's systems
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Employees' data
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User satisfaction surveys (post implementation &
ongoing)
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Directly from your employee
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Employees' data
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Mobile policy acceptance
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Directly from your employee
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Employees' data
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Shipping address
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Directly from your employee
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Employees' data
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Approver level
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Directly from your employee
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Office(s) information
(real estate file)
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Changes to the address of your offices
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Your organisation
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Office(s) information
(real estate file)
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Changes to cost centres
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Your organisation
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Telecom vendor & other third party information
(account listing)
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Changes to the list of your telecom vendors or third party
suppliers
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Changes to the name of your telecom
vendor or third party contacts (Account managers)
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Changes to phone numbers of your
telecom vendor or third party contacts (account
managers)
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Changes to the email address of your
telecom vendor or third party contacts (account
managers)
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Your organisation or the vendor/ third party supplier
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Telecom vendor & other third party information
(account listing)
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Changes to telecom vendor or third party invoice remittance information
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Your organisation or the vendor/ third party supplier
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Service Dependant:
Employees' data
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Audio recording of a service desk phone call
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Directly from your employee
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Service Dependant:
Employees' data
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Service desk requests or complaints
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Directly from your employee
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Service Dependant:
Employees' data
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Credit card details, employee home address
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Directly from your employee
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4) Where is your data is collected?
a) Employee data
Tangoe gets your employee data from a variety of locations and through
different media as mutually agreed during the implementation, which may
include those outlined in the table below:
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Portals and Applications
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Secure File Transfer Protocol (SFTP)
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Emails and Other Media
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Directly from your vendor's portal
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Shared on your Secure File Transfer
Protocol (SFTP) site(s)
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Emailed by you (your employees)
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Directly through Tangoe's system(s): WEM and Command
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Shared on your Vendor's Secure File
Transfer Protocol (SFTP) site(s)
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Emailed by your vendor(s) or other third party
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Tangoe's supplier system(s)
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Shared on through Tangoe's Secure File
Transfer Protocol (SFTP) site(s)
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Compact Discs (CD) from you
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Compact Discs (CD) from your vendor(s)
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Through telephone discussions with your employees and
your vendor(s)
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Through interactions with your other third party
suppliers
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b) Billing data
Where possible Tangoe collects your billing data from your vendor's
portal, where your vendor doesn't offer a portal, alternative data
transfer media such as SFTP, emails or CD's may be used:
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Portals and Applications
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Secure File Transfer Protocol (SFTP)
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Emails and Other Media
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Directly from your vendor's portal
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Shared on your Secure File Transfer
Protocol (SFTP) site(s)
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Emailed by you (your employees)
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Directly through Tangoe's system(s): WEM and Command
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Shared on your Vendor's Secure File
Transfer Protocol (SFTP) site(s)
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Emailed by your vendor(s)
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Shared on through Tangoe's Secure File
Transfer Protocol (SFTP) site(s)
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CD or DVD from you
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CD or DVD from your vendor(s)
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Through telephone discussions with your employees and
your vendor(s)
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Through interactions with your other third party
suppliers
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c) Other data collection
Depending on the services you have contracted Tangoe to provide, or
your interactions with Tangoe, additional data may be collected:
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Service/ Interaction
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Data Collected
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Where
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Tangoe's service center
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Telephone call records
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Through telephone discussions with your employees and
your vendor(s)
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Tangoe's service center
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Ticket entries: support questions & complaints
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Through telephone discussions with your employees and
your vendor(s)
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Procurement and fulfilment
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Credit card details, employee home address
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Through telephone discussions with your employees and
your vendor(s)
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Tangoe office visits
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Security CCTV
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Third party office management provider or Tangoe
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Tangoe office visits
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Employee names and signature for check-in and out
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Tangoe reception team
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Tangoe system usage
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System usage logs & IP Addresses
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Directly through Tangoe's system(s): WEM and Command
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Survey or information collection
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User opinions & feedback
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Asset management
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Through SurveyMonkey.com or Tangoe system/s directly
from your employees
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Mobile policy acceptance
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Tick acknowledgment
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Directly through Tangoe's system(s): WEM and Command
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5)
Special categories
of data
Tangoe does not require special categories of data to deliver its
services.
6)
How does Tangoe ensure there is a lawful reason to
use your data?
Data protection law requires organizations to consider if using data is
necessary and lawful. It is Tangoe's clients' obligation to ensure its
employees' data is used lawfully, with fair processing notice and to
establish the lawful basis for use of a TEM service.
Tangoe will only use your data for the provision, improvement and
support of the services; or for legal or regulatory purposes.
7)
Who
will Tangoe share your data with?
Tangoe understands how important confidentiality and appropriate use of
your data is to a trustful working relationship. As such your data will
only be shared where it is necessary to do so. Within Tangoe service
teams this means that our employees are assigned access based on their
alignment with your services and their role within this. Other Tangoe
employees may see specific sections of your data where it is required
which will include:
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Finance to generate invoices
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IT Management for access requests
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Quality manager for audit purposes
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Tangoe advisory services, if contracted
Tangoe may contract with third-party vendors and suppliers to perform
certain functions on Tangoe's behalf or to enhance Tangoe's existing
product and service offerings. Additionally, Tangoe may be obliged to
disclose data for legal or regulatory purposes. These third parties will
have access to data only to the extent necessary to permit them to do their
jobs which may include:
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HMRC or equivalent
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Tangoe's external auditors
-
Supervisory Authorities, Government or Regulatory bodies
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Your employers' telecom vendors and third party suppliers for expense
management, audit and procurement purpose
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Tangoe's third party suppliers which may include payment processing
services, fraud monitoring and prevention, email, ticketing, survey or
group texting platforms, service providers, and data hosting centres.
Tangoe may disclose data in connection with a reorganization,
restructure, merger, sale, or other transfer of assets. Tangoe reserves
the right to transfer information, including data, provided that the
receiving party contractually agrees to respect your data in a manner
that is consistent with Tangoe's Data Protection Policy and your data
processing agreement.
Tangoe will never sell your data to a third party.
8) Where
will your data be stored and used?
Tangoe software (WEM Application) is dual hosted in the UK and Ireland, EU. Whilst, some
Clients have made provisions in their DPA to contain their data in the EU,
in most instances your data will be accessed by our employees and/or
service providers located outside the EU
. Where this occurs, Tangoe enters into a contract called EU Standard
Contractual Clauses with your employer to protect your data when it leaves
the EU. Please refer to the applicable data processing agreement for more
details.
Tangoe is a global organization with a US parent and our central
administration is held in the USA. As such your corporate contacts will be
held in the USA where it can be viewed, accessed and used by Tangoe
employees, and some suppliers, out with the EU. This would include contract
signatories, key relationship or procurement contacts.
In addition, where required to provide your service, your data may be used
in the following locations;
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Type
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Role
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Location
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Billing mapping tool
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Normalisation of billing data to load into Tangoe software
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Ireland, USA
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Email hosting
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Storage for tangoe.com emails
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Ireland, USA
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Bulk SMS service
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Send bulk emails to customer employees in accordance with
service obligations
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England
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Additional data center
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Procurement service users only
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USA
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9) How
is your data used to manage your TEM service?
Tangoe's operations are structured into departments which use your data to
enable the element of the TEM service for which they are responsible. The
below framework depicts a high level representation of the data required
and the standard key stages in TEM delivery.
Framework 1 - General Data flow.
As required by your services, Tangoe will:
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collect
and use your data to provide the services and technical support
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combine
your HR data with your billing data to enable financial and asset
management
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store
your data on the service platform/s, email exchange, shared or local
drives and support systems
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validate
the data for errors and exceptions managed
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normalise
the format of the data so it can be loaded into the Tangoe software
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link
telephone numbers to 'friendly names', upon client's request
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access
the data based on job roles and permissions to deliver and support the
services
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analyse
the data to generate savings opportunities and identify billing errors
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create and manages back-ups
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generate reporting or recommendations
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return and/or delete
from our systems in accordance with your contract terms and Tangoe's
retention schedule
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upload
any patch, update, upgrade or new releases to the services
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use data for testing and QA purposes under the same
level of protection offered on production platforms (where authorised
by your organization)
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use the data for legal and regulatory purposes (e.g.
audit, accounting and statutory retention terms), resolve disputes, and
for the establishment, exercise or defense of legal claims
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analyse and monitor
for business planning, resources and financial management
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collect
user input regarding services and assets
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automatically track
user logins, errors, system changes, access and report generation
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enable single sign on
to Tangoe software
Where your organisation uses the following Tangoe services, these data uses
would also apply;
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Type
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Role
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Package/Connection Optimisation
|
Billing data is analysed to produce an optimization report
which is provided to your organisation containing cost
saving or efficiency recommendations. Where recommendations
are signed off by customer, Tangoe will effect the change
with the vendor. Results, savings and management statistics
are generated.
|
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Accounts Payable (AP) File
|
Tangoe maintains your organisational hierarchy and asset
register in accordance with the information your
organisation provides, generates an accounts payable (AP)
file based on the structure designed for your organisation
which is sent on in agreed frequency and format, if
required.
|
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Procurement & Fulfilment
|
Tangoe receive procurement requests either through emails,
telephone or directly into the ordering system. The
requests take the form of modifications, additions, changes
and disconnections of devices and are all logged into the
internal ordering tool for action. The request status is
monitored and communicated back to the requestor at all
stages of the process. Requests go through an approval
workflow, and once approved are managed by the fulfilment
team who ensure the request is completed. Upon completion
of the request, the service ticket is closed on our
systems. Performance, management and
resource statistics are generated.
|
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Audits and Reporting
|
Tangoe conducts an audit of the billing data, identifying
billing errors and ensuring compliance with vendor contract
terms. Non-conforming items are recorded and reported.
Management, savings and statistical reporting is generated.
|
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Audit Dispute Resolution
|
Where Tangoe has identified erroneous charges, a dispute
process is following which includes recording the
identified items, raising then managing a dispute with the
applicable vendor, tracking progress and communicating the
outcome back to you. Results, savings and management
statistics are generated.
|
|
Service Desk
|
Service requests are received via email or telephone call
from your employees to Tangoe's service desk where they are
worked through the applicable process to close. Tickets are
used to record the request or issue, and its progression.
Performance and resource metrics are generated.
|
10)
Is there any automated decision making?
Automated processing of data does take place however no decisions are made
that could have legal or other equally significant impact on your employees
without human involvement and consideration taking place.
11) What happens if we stop using Tangoe's services?
We hope that our organizations will have a long and happy collaboration,
however if your services should end for any reason the data would be
retained, returned, and deleted in accordance with the terms of your
organization's data processing agreements.
12)
How long
will Tangoe keep your data?
Tangoe will retain your data only for as long as is required for the
services, or other valid reasons such as to comply with our legal and
regulatory obligations (e.g. audit, accounting and statutory retention
terms), resolve disputes, and for the establishment, exercise or defense of
legal claims in the countries where we do business. These retention terms
may vary at a service or client level; refer to your organization's
processing agreement which will provide more detailed information on
applicable retention terms.
13) How will Tangoe protect my data?
Data security is very important to Tangoe and, whilst no security controls
can ever be 100% effective, Tangoe is committed to driving strong security
measures to protect your data's security, confidentiality, and integrity.
14)
Will my data be used for direct marketing?
No. Tangoe will never use the data you provide for the delivery of services
for direct marketing or sales purposes.
If you have given Tangoe your data when attending a Tangoe event, via our
website or similar marketing event, use of that data is covered in Tangoe's
Marketing Privacy Notice displayed on our website.
The primary contacts for our clients' relationships will be sent
information pertaining to the services and may be invited to join us at
special educative events such as Tangoe Live.
15)
What are your rights?
Data protection legislation gives individuals rights. To find out more
about your rights please click here.
16) Changes
to this Privacy Notice
Tangoe keep this Privacy Notice under regular review to make sure it is up
to date and accurate, and so we may change this Privacy Notice from time to
time. However, we will not reduce your rights under this Privacy Notice.
Updated Privacy Notice's will be displayed on the Tangoe system, the 'last
updated' footer tells you when we last updated it.
17)
How to contact Tangoe?
Tangoe US, Inc. together with its' global affiliated companies
("Tangoe") is a leading global provider of Technology Expense
Management (TEM) and Managed Mobility Services (MMS) solutions to a
wide range of global enterprises. Tangoe helps companies work smarter
to drive both bottom-line improvements and top-line growth.
Our head office is 169 Lackawanna Avenue, Parsippany, NJ 07054, USA. You can
find out more about Tangoe, what we do and our organisation here.
If you have any questions or concerns Tangoe welcomes the opportunity to
discuss and help resolve these. Our Data Protection Team can be contacted
on dataprotection@tangoe.com
or by post at: Data Protection at Tangoe, 10 Park Square, Milton Park,
Abingdon, Oxfordshire OX14 4RR
In the EU, if you feel that Tangoe has not been able to resolve your data
related concern you are entitled to make a complaint to a Supervisory
Authority, such as the UK's Information Commissioner's Office.