alpha-CNS GmbH has adopted this Privacy Policy (Policy) to govern its collection, use and disclosure of Personally Identifiable Information. In addition, this Policy is designed to assist alpha-CNS in maintaining an adequate level of Personal Data privacy protection.
Without limiting the generality of the foregoing, this Policy applies to the processing of Personal Data that alpha-CNS obtains from individual customers located in the European Union and Switzerland.
If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

GENERAL INFORMATION

This privacy policy applies to all online services of alpha-CNS GmbH.

The controller is:

alpha-CNS GmbH
Data Privacy
Milchstr. 4
16321 Bernau bei Berlin
Germany

Phone: +49-30-24348210
Website: www.alpha-cns.com

Registration Court Frankfurt (Oder), HRB 17374 FF
CEO: Karsten Poch

Karsten Poch  is also  the data protection officer privacy (at) alpha-cns . com

HOW DO WE PROCESS PERSONAL DATA?

We save and use your personal data only to process your orders and to get in touch with you and to fulfil our hosted services contracts.

WHAT CATEGORIES OF DATA DO WE COLLECT?

Every time you visit our website, your IP address and other pieces of information are saved in anonymized form. If you register an account with us, your contact information will be stored. If you order products or services from us, your address and payment information will also be stored.

In particular, we save the following data from you.

REGISTRATION DATA

When you register an account with us, we collect and process certain personal data from you as your registration data. For example, we need your name, address information, telephone number, payment information and your email address to process your order. If you pay using a credit card, we do not collect and store any payment information such as credit card numbers or verification codes. You disclose this information only to the respective payment service provider (e.g. paypal).

SERVER LOG FILES

Whenever you visit our websites, we automatically store certain data. This includes your IP address, type and version of the browser you use, time, date, website from which you come to our site or email addresses of recipients of our Hosted VoiceMail service. Alpha-CNS does not draw any conclusions about the data subject. This information is rather needed to deliver content of our website correctly, optimize the content, provide law enforcement authorities with information required to investigate cyber-attacks or other criminal acts.
Server logs are be stored for 14 days and then deleted.

HOSTED VOICEMAIL

Hosted Voicemail provides voice mail services to customers Skype for Business deployments. For Hosted Voicemail to work, we store users SIP and email addresses in our databases. The sip address will be used to authorize and match a call to a voicebox. The email address will be only be used to send voice recordings to. The customers tenant administrator is responsible to add, change and delete voiceboxes incl. their sip address. Alpha-CNS support stuff will only access these data in case of a support request. Anonymous log data will be stored for each incoming voicemail call. The contain data like time stamp, originating server (customers Skype servers) and call length. These data are only being used for capacity monitoring and are deleted after 14 days. The legal basis for this data processing is Art. 6 (1) lit. a GDPR.

Support Portal

alpha-CNS uses Atlassians’ Jira Service Desk as there service desk and support application. For customers to be able to raise service or support tickets they would need to login to the Support Portal with user name and password. These user accounts will be created by alpha-CNS for named customer contacts. We store email addresses, contact names and a password. These data will not be used for any other purpose than for the customer to raise tickets. User accounts can be deleted on request, however the contact will then loose access to the support portal. All references to a deleted user account will also be deleted from raised tickets. The legal basis for this data processing is Art. 6 (1) lit. a GDPR.

 

WHO WE FORWARD YOUR DATA TO

External service providers may have access to your data while they assist us in providing our services. In some cases, third parties such as government authorities, external consultants, or our business partners may receive your data.

IN PARTICULAR, THIS MAY OCCUR IN THE FOLLOWING CASES:

PAYMENT VIA CREDIT CARD:

When paying via credit card (via PayPal), the payment is processed by an external service provider. For credit card payments, your information is collected directly by PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg.

DEBT COLLECTION AGENCY

If you as a customer fail to pay your invoices on time, your necessary data are passed on to an external debt collection agency.

THIRD COUNTRIES

Data is transferred to third countries in adherence to the legally regulated admissibility requirements. We will not transfer your data to a third country if it does serve the purpose of performing our contract with you; we have no consent from you; the transfer is not necessary to assert, exercise or defend legal claims; and there are no other exceptions. We will only transfer your data to a third country if there is an adequacy decision in accordance with Art. 45 GDPR or appropriate safeguards in accordance with Art. 46 GDPR. Once such adequacy decision (regarding an adequate level of protection) is the “Privacy Shield” for the USA. For transfers to a company certified under the Privacy Shield, the data privacy level is considered essentially as adequate within the meaning of Art. 45 GDPR. However, we usually do not rely on the Privacy Shield, but rather create appropriate privacy guarantees and complete the EU standard data privacy clauses issued by the European Commission with the receiving party. Together these actions establish appropriate safeguards in accordance with Art. 46 GDPR and provide an adequate level of protection.

OTHER CATEGORIES OF RECIPIENTS

State authorities and courts

WHERE DO WE PROCESS YOUR DATA?

We process your data exclusively in our data centres in Germany, Netherland, Ireland. Some hosted services (e.g. Hosted Voicemail for US customers) can be provided out of data centres in the United States. Our data centres are operated by Hetzner, 1&1, and Microsoft.

COOKIES AND THE RIGHT TO OBJECT TO DIRECT ADVERTISING

“Cookies” are small files that are stored on a user’s computer. Cookies can store different kinds of data. Cookies are primarily used to store information about users. They are stored on the users’ devices during and/or after users visit a website or online store. “Temporary cookies”, “session cookies”, or “transient cookies” are cookies that are deleted after users leave an online store and close their browsers. With such cookies, for example, the content of a shopping basket can be stored in an online shop or a login bottleneck. However, other cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, users’ login status can be saved when they visit a shop after several days. Likewise, permanent cookies can measure the “range” of a website (where the users are geographically located) or information on the users’ interests. This information is used for marketing purposes. “Third-party cookies” are cookies that are offered by the original providers (who operate the online store or website) to other parties. (If the original provider is the one using the cookies, they are often called “first-party cookies”). It is useful to know the above terms so that you understand our cookie policies and data protection agreement. If, as a alpha-CNS GmbH customer or as a visitor to our websites or interfaces, you do not wish cookies to be stored on your computer, we ask you to deactivate the corresponding option in the system settings of your browser. You can also delete stored cookies in the system settings of your browser. However, if you do these things, it will likely lead to problems when you try to use alpha-CNS GmbH websites and interfaces. If you would like to “opt out” of the use of cookies for online marketing and tracking purposes, you may be interested these two sites to help you:
1) the US site http://www.aboutads.info/choices/
2) the EU site http://www.youronlinechoices.com/.
Furthermore, you can deactivate cookies from being stored on your computer or device by changing your browser settings. However, if you do this, it will likely lead to problems when you try to use alpha-CNS GmbH websites, interfaces, and features on the interfaces.

GOOGLE UNIVERSAL ANALYTICS

On the basis of our legitimate interests (i.e. interests in analysis, optimization and commercial operation of our online offers within the meaning of Art. 6 (1) lit. f GDPR), we use Google Analytics, a web analysis service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offers by the you, the user, is usually sent to a Google server in the USA and stored there. Google is certified under the Privacy Shield agreement and thus provides a safeguard in adherence to European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Google will use this information on our behalf to assess how you use our online offers, to put together reports about activities within these online offers, and to provide other services to us in connection with the usage of these online offers and the Internet use of related services. Pseudonymized usage profiles of you can be created from the processed data. We use Google Analytics in the „Universal-Analytics“ version. “Universal Analytics” is a process of Google Analytics in which your user analysis is performed on the basis of your pseudonymized user ID, used to create a pseudonymized user profile of you with information on the use of various devices (“Cross-Device Tracking”). We use Google Analytics only with activated IP anonymization. This means that your IP address is shortened by Google within the member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Your full IP address is sent by Google to the USA and shortened there only in exceptions. The IP address sent by the your browser is not combined by Google with your other data. You can prevent the storage of cookies by making the corresponding settings in your browser; you can also refuse the collection of data generated by the cookie and related to your use of our online offers by Google and the processing of your personal data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en. Further information about data use by Google, settings, and objection options is available in Google’s data privacy policy (https://policies.google.com/technologies/ads) and Google‘s ad settings (https://adssettings.google.com/authenticated). Your personal data are deleted or anonymized after 14 months. The legal basis for this data processing is Art. 6 (1) lit. f GDPR.

YOUR RIGHTS AS A “DATA SUBJECT”

You have the right to information about your personal data that we process. If you do not make requests for information in writing, please bear in mind that we might ask you to provide proof that you who you claim to be. Furthermore, you have a right to rectification or deletion or restriction of processing, as it is applicable to you under the law. Furthermore, in accordance with legal requirements, you have the right to object to us processing your data. You also have the right of data portability.

RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint about the processing of your personal data by us to a supervisory authority for data protection.

VOLUNTARY NATURE OF DATA PROVISION

There is no statutory obligation for you to provide your data to alpha-CNS GmbH. However, you cannot use some of our services if you do not provide your data to us. Your decision to provide us with your personal data is completely voluntary.