CTM Privacy

Last Updated
February 12, 2025

Protecting your privacy and maintaining your trust is important to us.

This Privacy Notice is designed to help you understand CTM LLC and any affiliate, subsidiary, parent company, or our employees (collectively “CTM’s” “our” “we” or “us”) current global privacy practices, including how we collect, use, and share personal information about customers (“you”) who access our CTM account portal, visit our website, use our products and services (“Services”), and to assist you in exercising privacy rights available to you by law. There are two sections to this Privacy Notice because we process personal information differently based on the direct relationship we have with you, our customer, and the indirect relationship we have with your end users:

1. Privacy Policy. The Privacy Policy addresses the personal information we, as a data controller, collect from you based on how you use and interact with our Services and how we operate our business. As a data controller, we determine the purpose and means of personal data processing and are ultimately responsible for the correct handling of your data, in accordance with applicable law.
2. Platform Policy. The Platform Privacy Policy addresses the personal information we may collect and process about your end users who use or interact with your account or application that uses CTM services, like those you communicate with based on your instructions. This category contains your Customer Usage Information (e.g., communications metadata) and your Customer Content (e.g., the contents of communications).

Please carefully review these policies before you submit any information on or through CTM’s website (“Site”) or account portal or Services. You acknowledge and understand that you are subject to our Privacy Notices by using any part of the CTM’s Site or Services. You further understand and agree to our use of cookies, session replay technologies (e.g., tracking your online session), and similar tracking technologies to collect data automatically about your use of our website or for advertising, as discussed in the cookie policy here.

Please note that some CTM customers may have special agreements with us that specify the collection, use, and sharing of their information. If those special agreements conflict with this notice, the special agreements will apply.

I. Privacy Policy

This Privacy Policy applies to personal information handled or otherwise processed by us in our business, including on our websites, our platforms, and other products or applications CTM offers or uses (collectively, the “Services”). This Privacy Policy applies to you whether you use and access the Services for personal or business purposes. Our processing of personal information and personal data, such as your name, address, e-mail address, or telephone number, will be undertaken consistent with the requirements of applicable global privacy laws, each as may be supplemented, modified, and/or amended from time to time.

This Privacy Policy does not apply to third-party websites, services, or applications, even if they are accessible through our Services. By continuing to use our Services, you agree to this Privacy Policy and the Terms and Conditions and consent to CTM’s collection, maintenance, use, and disclosure of your information, data, and other information in accordance with this policy.

A. Personal Information We Collect

1. Information you provide to us

The information we collect from you depends on how you interact with us or the Services you use under our Terms of Service. We may collect the following types of information.

• Account and contact information. If you create an account, request information about us, or use our Services, we may collect certain information that can be used to identify you, including your full name, billing address, postal address, email address, password, telephone numbers where you can be reached, date of birth, voice recordings or other biometric identifiers, driver’s license number or Social Security Number, and any referral information.
• Financial information. In connection with a financial transaction via the Services, our payment processor, acting on our behalf, may collect your credit or debit card information or other financial and payment information. We may directly collect, or store payment card or financial information entered through our Services, including the last four digits of your payment card. We may receive other information associated with your payment card information (e.g., your billing details).
• How you use our Services and your devices. Depending on your Services, this may include call or messaging logs, traffic routing information, and the content of communications sent through or integrated with our services, such as audio recordings, message bodies, and call recording transcriptions.
• Information you give us directly on our website (e.g., surveys, newsletters, or events). On some site pages, you can fill in a web form to share your information with us directly, such as on our “Contact Sales” page or our “Contact Support” page. We collect the information you provide in response to those web forms. Occasionally, we may also offer opportunities for you to share your information with us, such as through a survey, to sign up for a newsletter, or to register for or receive details about an event we are hosting. If you participate in those surveys, sign up for a newsletter, or register for an event, we will collect the information you provide to us in doing so.
• Job applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, resume, and/or cover letter, we will collect and use the personal information you provide.
• Security and Fraud Protection. We assign your Account ID (and Agency ID if you are on a plan with an umbrella Agency ID), which acts as a username, and a password. If using our API, you will also be assigned keys and an authentication token that you will need to use to make requests to our APIs. We keep a record of these credentials so that when you log in to your account, or your application requests our API using these credentials, we know that you are making the requests. We use your Account ID and API authentication token to authenticate that your application is making requests to our APIs. If two-factor authentication is set up for your account, we’ll ask you to enter a telephone number, and we will communicate verification codes to verify that you are logging into your account.

2. Information collected automatically or from third parties

• Cookies and other Tracking Technologies (“Technologies”). When you visit the Site, we and our service providers acting on our behalf automatically collect specific data using tracking technologies, like cookies. We use this to understand how visitors to the Site are using it and which pages and features of the Site are most popular. This helps us know how we can improve our Site and track the performance of our advertisements. In addition, tracking technologies are used to help improve the navigation experience on the Site and to determine propensity-to-purchase calculations (i.e., an analysis of how likely a website user is to purchase our services based on an analysis of their browsing behavior).
• Analytics. We may use website analytics and other third-party tools to provide you with the best possible experience with our platforms, Site, and offerings. We will use this data to manage customer interactions, manage the success of campaigns, engage in a session replay analytics service that allows us to record and replay an individual’s interaction with the Services, and understand how users interact with our Site.
• Social Media Widgets. Our website includes social media features, such as the Facebook Like button, and widgets, such as the Share This button, which are interactive mini-programs that run on our site. These features may collect your IP address and which page you are visiting on our site, and they may set a cookie to enable the feature to function correctly. Social Media Features and Widgets are hosted by a third party or hosted directly on our Site. The company’s privacy policy governs your interactions with these Features.
• Chatbot. The chatbot technologies on our Site are operated by third parties, which may collect certain information, including, but not limited to, IP address or information provided by you during your interaction, such as your name, email address, location, and other personal and non-personal data. This information is collected and/or processed solely by the chatbot technology’s third party to improve user experience and provide personalized content delivery. It is not shared with us except to inform us about the total usage of the chatbot function. By using this chatbot, you consent to the collection and use of data as described herein.

3. Collection and Use of Sensitive Information

We have collected the following categories of sensitive personal information (as defined under specific US state privacy laws) from consumers within the last twelve months:

• Government identifiers: Social Security Number, driver’s license, government-issued identification card, or passport number
• Complete account credentials
• Mail, email, or text message contents

B. Why and how we use your information

We use your information for various business purposes, including providing our Services, administrative purposes, and marketing products and services that may interest you, whether from CTM or nonaffiliated third parties, as described below. We retain personal information about you for as long as necessary to provide you with the Services. Sometimes, we keep personal information longer if required to comply with our legal obligations or as permitted by applicable law. Afterward, we retain some information in a de-identified and/or aggregated form but not in a way that would identify you personally.

When we process your personal information, we do so when we are satisfied that we have an appropriate legal basis to do this because (i) needed to perform our responsibilities in connection with our obligations to you, (ii) our use of your personal information is in our legitimate interest as a commercial organization (for example, communicating with you to resolve a complaint or query or tracking your use of the CTM Site using cookies to improve and tailor your browsing experience) – in these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights; (iii) our use of your personal information is necessary to comply with a relevant legal or regulatory obligation, for example, where we must disclose data to a government body, law enforcement agency, or regulator, or (iv) you have provided consent to us using your personal information; for example, you have opted-in to receiving marketing communications from us.

C. Other Purposes

• Automated decision-making. We may engage in automated decision-making by analyzing your online behavior and interests to recommend specific products or services, including in connection with AI and ML models. The processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have a proper legal basis, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision-making, please get in touch with us as outlined in “Contact Us” below.
• Consent. We may use personal information for other purposes disclosed to you when you provide personal information or with your consent.
• Using de-identified and aggregated information. Aggregated or de-identified data: We might also share information collected from you from the CTM Site with a third party if that information has been de-identified or aggregated in a way that does not directly identify you.

D. Share content with friends or colleagues

Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

E. Disclosing your Information to Third Parties

We disclose your information to third parties for various business purposes, including to provide our Services, to protect us or others, or in the event of a significant business transaction such as a merger, sale, or asset transfer, as described below. We do not share your information (including, but not limited to, the personal information of your end users) with third parties for their direct marketing purposes unless you consent.

1. Disclosures to Provide Services

The categories of third parties we may share your information with are described below.

• Advertising Partners. We may share information collected from you on the CTM Site with third-party service providers or consultants who need access to the data to perform their work on CTM’s behalf, such as a website analytics company or our third-party advertising partners. These third-party service providers are limited to accessing or using this data only to provide services to us. They must provide reasonable assurances that they will appropriately safeguard the information.
• Affiliates. We may share information collected from you from the CTM Site with our affiliates. Our affiliates will use the information for the same purposes as CTM, as described in this policy.
• Business Partners. We may share your personal information with business partners to provide you with a product or service that may interest you. We may also share your personal information with business partners with whom we offer products or services jointly. These partners may also use our information to customize offers and services for you or their own marketing purposes.
• Service providers and other partners. We may share your personal information with our vendors, third-party service providers, and partners who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.

2. Disclosures to Protect Others

We may disclose your information to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or a government request (including to meet national security or law enforcement requirements), (ii) to obtain legal advice, (iii) to enforce our agreements and policies, (iv) to protect the security or integrity of the CTM Site or our services and products, (v) to protect ourselves, our other customers, or the public from harm or illegal activities, or (vi) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing a death or serious bodily injury. If CTM is required by law to disclose any of the information that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement unless we are prohibited from doing so by statute, subpoena, or court or administrative order. Further, we object to requests that we do not believe were issued properly.

3. Disclosure in the event of merger, sale, or other asset transfers

If we go through a corporate sale, merger, reorganization, receivership, dissolution, purchase or sale of assets, financing, or similar event, your personal information may be part of the assets sold, transferred, or shared in connection with due diligence for any such transaction as permitted by law and/or contract. Any acquirer or successor of CTM may continue to use the information we collect from you through our website as described in this policy.

F. Information from Children

We do not knowingly collect any personal information directly from children under 16. If we discover we have received any personal information from a child under 16 in violation of this Privacy Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under 16, please get in touch with us at privacy@CTM.com.

G. Security of Your Information

We use appropriate security measures to protect the security of your information, both online and offline. These measures vary based on the sensitivity of the information we collect, process, and store and the current state of technology. Please note that no website or internet transmission is completely secure, so while we strive to protect your information, we cannot guarantee that unauthorized access, hacking, data loss, or a data breach will never occur.

H. Data Retention

As explained in this notice, we will store your personal information for as long as it is reasonably necessary for the purposes for which it was collected. In some circumstances, we may store your personal information for more extended periods, for instance, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements.

In specific circumstances, we may store your personal information for extended periods to have an accurate record of your dealings with us in case of any complaints or challenges or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

I. Your Privacy Choices and Rights

1. Your Privacy Choices

• Cookies and tracking technologies. How you choose cookies and other tracking technologies depends on the type of cookie or tracking technology being used. We partner with third-party ad networks to either display advertising on our Site or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect non-personal information about your activities on this website and other websites to provide targeted advertising based on your interests. If you wish not to have this information used to serve targeted ads, you may opt-out by clicking here: http://optout.networkadvertising.org/ or here: http://www.youronlinechoices.com. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
• Promotional communications. If you are receiving promotional emails from us, you can choose to stop receiving those by following the unsubscribe/opt-out instructions in those emails. You can also opt-out by contacting customer support at info@calltrackingmetrics.com. Please note that even if you opt out of promotional communications, we may still send you non-promotional messages relating to updates to our terms of service or privacy notices, security alerts, and other notices relating to your access to or use of our products and services. We will respond to your request within a reasonable timeframe and notify you of our action.
• Online Advertising Industry Options. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data and other advertising partners participating in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. To make separate choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices, you may use your device’s platform controls in your settings to exercise your choice. Please see https://www.networkadvertising.org/mobile-choice/ for more information on how to opt out on mobile devices. Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising.

2. Your Privacy Rights

To the extent required by applicable law, you may have the right to:

• Access to/know/port information about you, including (i) confirming whether we are processing your personal information; (ii) the specific pieces and categories of your personal information collected; (iii) the categories of sources from where your data is collected; (iv) the purpose for collecting your personal information; (v) the categories of third parties with whom we have shared your personal information; (vi) obtaining access to or a copy of your personal information in a structured, commonly used, and machine-readable format; and (vii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (the “right of data portability”).
• Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or refer you to the controller who can correct your personal information.
• Request deletion of your personal information, subject to certain exceptions prescribed by law.
• Request restriction of or object to processing your personal information, including sensitive personal information.
• Withdraw your consent to our processing of your personal information.
• Restrict the use of sensitive personal information or opt out of the sale of personal data, but please note that we do not currently sell personal information.
• Access information on automated decision-making, or opt out of our use of automated decision-making related to your personal information.
• Object to direct marketing and any use of your personal information based on a ‘legitimate interest’ justification.
• Obtain a copy of the personal information safeguards used for transfers outside your jurisdiction and complain to your local supervisory authority if you are in the EU.

To request deletion of access to or to make changes to the information we’ve collected from you via the CTM Site, email us at privacy@calltrackingmetrics.com. Please note that even if you request that we delete the information we’ve collected from you, we may still retain your information in an aggregated or anonymized form that does not identify you. We also will not delete your information if we are legally required to maintain it.

We may ask you for additional information to confirm your identity and for security purposes before taking any action regarding your information. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. Where state law permits, consumers can make the following requests twice every 12 months.

3. Exercising Your Rights

If you want to exercise your rights, you can contact us at 1-800-577-1872 (toll-free) or email us at privacy@calltrackingmetrics.com. We will respond to verifiable requests received as required by law. Account holders may also submit requests in their account by going to the Help menu and using any of our customer support channels. We may also ask you for additional information to verify or process your request. We may also check with third-party identity verification services to verify your identity before taking any action regarding your personal information. We will respond substantively to your verifiable requests within the periods required by law, which is most likely within 45 days unless additional time (up to 45 extra days) is needed, in which case we will let you know.

4. International Transfers

CTM is based in the United States of America, and you understand that browsing the CTM Site will store your information on servers in that country, which has different data protection standards.

In addition, we use service providers located around the world. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law to protect your privacy rights and interests. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information is disclosed.

5. Supervisory authority

If you are located in the European Economic Area, Switzerland, Singapore, Canada, or the United Kingdom, you have the right to complain in writing to our Data Protection Officer (whose contact details are set out below) or with the applicable supervisory authority if you believe our processing of your personal information violates applicable law or believe we have not complied with this Privacy Policy. You should include as much detail as possible about the personal information affected and the circumstances that you believe amount to a breach of this Privacy Policy or the applicable privacy or data protection law or regulation.

J. Incentives and discrimination

We will not discriminate against you for exercising your privacy rights. We may offer you specific financial incentives as permitted by law, which may have different prices, rates, or quality levels. Any permitted financial incentive offer will reasonably relate to the value of your personal information and contain written terms describing the program’s material aspects. Participation in an economic incentive program requires prior opt-in consent, which you may revoke at any time.

K. How to resolve disputes relating to our privacy practices

If you have a dispute about our privacy practices, please email us at privacy@calltrackingmetrics.com. If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time, but no later than 90 days from the date of our decision. To submit an appeal request, you can exercise this right by contacting us at privacy@calltrackingmetrics.com with the subject line “Appeal a Decision” and providing us with your name and the email address associated with your account. If you believe your rights have been violated and cannot resolve the issue directly with us, you may file a complaint with your state attorney general’s office.

L. Third-party websites

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content. Please remember that when you use a link from the CTM Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those with a link or advertisement on our website, are subject to that third party’s rules and policies.

M. Changes to our Privacy Policy

We may change our Privacy Policy from time to time. If we make changes, we’ll revise the “Last Updated” date at the top of this policy, and we will notify you of those changes through other reasonable means of communication, such as email. We will comply with applicable law concerning any changes we make to this policy.

N. How you can contact us

You can email us at privacy@calltrackingmetrics.com or write to us at the address listed below.

CallTrackingMetrics
231 Najoles Road Suite #500
Millersville, MD 21108

II. CallTrackingMetrics Platform Privacy Policy

A. Scope and Overview

This Platform Privacy Policy summarizes our practices regarding information collected and processed on your behalf from your end users. CTM is a contact management company. Our customers are generally marketing agencies or businesses. Our customers typically use CTM products and services to track the performance of their marketing campaigns, sales teams, and contact centers. Our customers often have their customers or users of the reporting they are compiling and the communication campaigns they are developing using CTM products and services. To avoid confusion, we’ll call the individuals who use our customers’ applications the “end users.”

CTM generally does not interact directly with our customers’ end users. Instead, end users interact with our customers’ websites or contact our customers (or their customers) via phone, text, or form, which in turn interacts with our products and services. So, if you’re an end user of a website that has CTM code running on it or calling a phone number that a CTM customer manages, you should check out that customer’s terms of service and privacy policy to find out how they collect, use, store and share your information. We are not responsible for our customers’ privacy policies or privacy practices.

1. What information do we collect, how do we collect it, and why

• Customer Usage Information. Customer Usage Information includes operational information like call or messaging logs, origination and termination points (i.e., to/from numbers), traffic routing information, API requests, or usage information.
• Customer Content. Customer Content consists of the communications sent through CTM products and services, like the body of a text message or phone call.
  • Your use of our products and services. We may collect customer content about your use of our products or services. For example, if you use our messaging services, we collect the messages being sent and received to convey those messages to and from the carrier networks and surface the content in your account portal and our API. Similarly, to transmit voice calls to and from the telecommunications carrier networks, we must collect the voice communications being sent and received to route them appropriately, then surface that information in our portal and our API. You can also use our products and services to record voice communications or have them transcribed, in which case, we will also collect those voice recordings or transcriptions.
  • Information about the visitors to your website. If you are using our tracking code on your website, we also collect on your behalf the information about the visitors to your website, such as their IP address, their landing page, referring URL, and the online ads that led them to your website. The tracking code uses cookies to identify the visitors to your websites so that the tracking code can display the correct tracking number to your end users and associate phone, form, or text activity to the correct website visit.
  • Caller ID Services. Suppose you are using caller ID services that we offer through a sub-processor. In that case, we will collect information about your end users, such as the caller’s name, phone number, and the city where the phone number is registered (not available in all countries or for all phone numbers). In addition, customers can enable our premium caller ID service, which uses one of our subprocessors to collect addresses and other demographic information about an end user, such as marital status and occupation.

As stated above, Customers have control over which information they want to collect and what they do with it. We provide the tools to collect the information. So, if you are an end-user of one of our Customers and believe they are collecting your information, you should check out their terms of service and privacy policy to find out how they collect, use, store, and share your information. We are not responsible for our customers’ privacy policies or practices.

NOTE ABOUT PHI: You should not use CTM products or services to receive, send, or otherwise process Personal Health Information (“PHI”) as defined by the Health Insurance Portability and Accountability Act of 1996 as amended (HIPAA), unless you have a Business Associate Agreement (“BAA”) with CTM or your use case for CTM products and services does not require a BAA. CTM disclaims all liability for PHI sent, received, or processed through CTM products or services without a Business Associate Agreement. Please contact our sales team to discuss HIPAA-compliant uses of CTM products and services.

2. How we use your information

Generally, we use all the information that you provide to us or that we collect to provide our products and services to you, to deliver your communications to their intended destination, to provide reporting on your communication programs in your account portal, to analyze our customers’ use of our products and services, to improve our products and services, and to detect fraudulent or unlawful activity in connection with CTM accounts.

Below are additional details regarding how we use the categories of information we collect.

• Customer Usage Information. When you use our products and services, we collect Customer Usage Information. This may include information like what commands your application has communicated to CTM through the API, what configurations you have made in your account portal, your IP addresses, how many times you used a CTM product or service when you or your end users used the product or service, the number of website visits, calls, messages, or form entries that occurred, the length of calls or messages, where those calls or messages originated or terminated, how those calls or messages were routed, and whether or not the connection was successful or failed. We collect Customer Usage Information so that you can view it in the account portal and you can manage your use of our products and services. We also collect it so that we can properly bill you for your use of our products and services, appropriately manage and route customer traffic, analyze and improve our products and services, and identify and solve problems that arise. We also use certain usage information to support regulatory requirements, such as calculating and reporting tax or similar obligations.
• Customer Content. We use Customer Content to include it in your reporting in your account portal or through the API, convey it to and from telecommunications carrier networks, or record and transcribe it per your instruction. We may also use Customer Content stored on our systems to troubleshoot call quality concerns.
• Promotional emails. We will use your email address to send you information about other CTM products, services, or events you might be interested in. You can choose not to receive marketing emails from CTM at any time. If you wish to stop receiving CTM marketing emails, you may click on the unsubscribe link at the bottom of any CTM marketing emails, or you can contact customer support.
• Publicly available customer account information. We will use publicly available Customer Account Information about your company, such as your industry, size, and website URL, to help us better understand our customer base and tailor the information we send you about other CTM products, services, or events.
• Address information. If you provide us with a physical address to obtain a number for which CTM is required to have your physical address on file, we’ll use that address to confirm we can allow you to have that number. We may also check the physical address you provide and/or your billing address, as well as other information you provide or that we obtained from your use of our service about your identity, such as your name, email address, and IP address, with our fraud prevention and identity validation providers (to confirm you have provided us with accurate details). We may also use your address information to calculate taxes. We may also have to share these addresses with the telecommunications provider from whom CTM obtained the phone number or local authorities upon their request. Unless prohibited by law, we’ll let you know if we have to share your address information like this.
• Payment Information. We use your payment information to bill you and be paid for using our products and services.

3. Who we may share your information with

Unless you give us your permission, we won’t share your Customer Content, Customer Account Information, or Customer Usage Information with third parties, except as described below:

• Cloud Communication Providers and Telephony Operators. We provide information as necessary for proper routing and connectivity. Customer Content and certain Customer Usage Information are shared with and received from communication providers and telephony operators to the extent required to route and connect those communications from the sender to the intended recipient. How those providers and telephony operators handle your Customer Content and Customer Usage Data is generally determined by those operators’ policies and local regulations.
• Third-party service providers or consultants. We may share your information stored on our systems with third-party service providers or consultants who need access to the information to perform their work on CTM’s behalf, like sharing relevant Customer Account Information with our payment processor so it can process payments on our behalf or our storage provider for storing your information on our behalf. These third-party service providers are limited to only accessing or using this information to provide services to us. They must provide reasonable assurances that they will appropriately safeguard the information.
• Compliance with laws. We may disclose your information stored on our systems to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or government request (including to meet national security or law enforcement requirements), (ii) to obtain legal advice; (iii) to enforce our agreements and policies, (iv) to protect the security or integrity of the CTM Site or our services and products, (v) to protect ourselves, our other customers, or the public from harm or illegal activities, or (vi) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If CTM is required by law to disclose any of the information that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement unless we are prohibited from doing so by statute, subpoena, or court or administrative order. Further, we object to requests that we do not believe were issued properly.
• Business transfers. If we go through a corporate sale, merger, reorganization, dissolution, or similar event, customer information we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction. Any acquirer or successor of CTM may continue using your information as this notice sets forth. We do not share your information (including, but not limited to, the personal information of your end users) with third parties for their direct marketing purposes unless you consent.
• International operations and transfers out of the EEA and Switzerland. Please note that when you use our account portal or other products and services, your Customer Content, Customer Account Data, or Customer Usage Information may be sent to the United States and possibly other countries. Some, but not all, may be connected with routing your communications that are sent via our products and services most efficiently. We store customer information on servers located in the United States, and we may also store this information on servers and equipment in other countries. We take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and that transfers are limited to countries that are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end, where appropriate (e.g., because our customer is established in the EU), we enter into appropriate data transfer agreements incorporating the EU Commission-approved standard contractual clauses or rely on other mechanisms provided by data protection law. You have a right to ask our customers for more information about the safeguards they have in place to ensure the adequate protection of transferred information.

a. How we tell you about changes to our privacy practices

We may change our Platform Privacy Notice from time to time. If we make changes, we’ll revise the “Last Updated” at the top of this notice, and we will provide additional notice, such as on the CTM website homepage, account portal sign-in page, or via the email address we have on file for you. We will comply with applicable law concerning any changes we make to this notice.

b. Your Choices About Your Information

Through the account portal, you may access and change certain parts of your Customer Account Information. You can also access Customer Content stored on our systems and various types of Customer Usage Data.

c. Account Deletion

To request deletion of your CTM account, email us at privacy@CTM.com. You should know that the deletion of your CTM account will result in you permanently losing access to your account and all customer information to which you previously had access through your account. Certain information associated with that account may remain on CTM servers in an aggregated or anonymized form that does not specifically identify you. Similarly, information associated with your account that we are lawfully required to maintain will also not be deleted.

If you are an end user of a customer that uses CTM services, you should direct requests for access and deletion of your information, or other rights that may be available to you under applicable data protection laws, to the relevant customer by their privacy policy.

B. Cookies and tracking technologies

How you choose cookies and other tracking technologies depends on the type of cookie or tracking technology being used. Please check out our Cookie Notice for details on managing your preferences for cookies and tracking technologies.

C. Information from children

We do not knowingly collect personal information directly from children under 16. If we discover we have received personal information from a child under 16 who is violating this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under 16, please contact us at privacy@calltrackingmetrics.com.

D. How we secure your information

We use appropriate security measures to protect the security of your customer information both online and offline. These measures vary based on the sensitivity of the information we collect, process, and store and the current state of technology. Please note, though, that no service is completely secure. So, while we strive to protect your information, we cannot guarantee that unauthorized access, hacking, information loss, or an information breach will ever occur.

You may access your account through our portal using the email address and password you provided when you signed up for CTM’s products and services. To protect the confidentiality of your customer information and from unauthorized use of your account, you must keep your password confidential and not disclose it to anyone else. Please let us know immediately if you think your password or API Auth Token was compromised or misused.

For additional information regarding CTM’s security practices, click here.