Last Updated February 15, 2021
I. Your Consent
II. Rights and Choices of Website Visitors from California
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 877-320-0040
- Emailing us at firstname.lastname@example.org
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Consumers have a right to not receive discriminatory treatment based upon exercising their CCPA rights.
For Website Visitors Located in the EEA, Switzerland or the United Kingdom
Our Company provides adequate protection for the personal data of our customers and contacts in the EEA, United Kingdom, and Switzerland under the General Data Protection Regulation (GDPR), the Swiss data protection law, and the U.K. Data Protection Act. Our Company honors the data protection rights of these data subjects who send us their personal data via this Website or other means of communications with us, namely:
The right to access their personal data – You have the right to request Our Company for copies of your personal data. to the extent permitted by the law. Your first request for data is free of charge. Any subsequent requests based on complexity may be charged a fee.
The right to rectification of their personal data – You have the right to request that Our Company correct any information you believe is inaccurate, to the extent permitted by the law. You also have the right to request Our Company to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions to the extent permitted by the law.
The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions to the extent permitted by the law.
The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions to the extent permitted by the law.
The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions to the extent permitted by the law.
Your personal data will be processed for the purposes and the time periods set forth in Section III below. Section VI also describes how we share your Personal Data with third parties.
If you are one of the mentioned data subjects and want to exert any of these rights, please contact us via regular mail (Attn: Privacy Officer, Spok, Inc.6850 Versar Center, Suite 420 Springfield, VA 22151 or via email email@example.com. If you have any unresolved issue, you have the right to contact your data protection agency.
For Residents of California
Our Company would like to make sure you are fully aware of all of your data protection rights. Users who are residents of California are entitled to the above rights for individuals of the EU and following:
The right to notice – You have the right to be informed at or before the point of collection what categories of personal information will be collected and the purpose for which these categories will be used.
The right to opt-out – You have the right to request at any time that Our Company stop the sale of your information.
III. Summary of Our Services and Site
Spok, Inc. (“we,” “us” or “our”) connects people to each other and to the data they need. Through the Website, our clients can learn about Spok software, hardware, and other products that enable seamless, critical communication across platforms and devices. In addition to reading about our products, visitors to the Website can contact us to learn more about mission-critical communication, chat live with a solutions advisor, and request demos of our services.
As with any service, you should be mindful of your privacy and security when communicating via our Website.
IV. What Do We Collect on the Website?
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|Category and Source Category of Personal Information||Examples||Purposes for Collecting||Collected|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||To help generate new traffic, leads, and sales for our business by reaching people looking for our products and services.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, and account name|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||To help generate new traffic, leads, and sales for our business by reaching people looking for our products and services.||A name, address, telephone number,|
|C. Protected classification characteristics under California or federal law.||Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||N/A||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||N/A||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||N/A||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||To help generate new traffic, leads, and sales for our business by reaching people looking for our products and services.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|G. Geolocation data.||Physical location or movements.||To deliver a location-specific website to Asia-Pacific visitors in order to help generate new traffic, leads, and sales for our business by reaching people looking for our products and services.||Physical location|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||N/A||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||N/A||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||N/A||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||N/A||NO|
- User Provided Public Content
Website users may be able to post publicly available content (“Public Content”) to certain areas of the Website, such as the Spok Blog. This content is meant for public consumption and we may collect and display it on the Website.
- Information you provide in forms you complete, i.e., to communicate your interest in learning more about our products and services
We collect and store the information you provide about yourself when completing and submitting online forms where you are invited to request additional information about our products and services or register for additional interactive services (“Online Form Data”). These forms typically ask you to provide your first name, last name, a valid e-mail address, title, phone number, company, and address, as well as any specific questions or comments you may have.
To register for interactive services such as the Partner Portal, eStore, or Spok Directions User Group, you may be asked to provide additional information to create a username and password.
- Web Access and Usage Information
When you access or interact with our Website, we may collect certain information automatically and store it in log files or pseudonymized user profiles.
This information can be combined with the information you have generated and transmitted to or through us, which will enable us to analyze and better customize use of our Website.
Under Age 13. We do not knowingly collect any Personal Information from children under the age of thirteen (13) without parental consent, unless permitted by law. If we learn that a child under the age of thirteen (13) has provided us with Personal Information, we will delete it in accordance with applicable law.
Under Age 18. Our registered services are available only to individuals 18 or older. Minors under 18 years of age may have the Personal Information that they have provided to Spok while using the Website deleted by sending an email to firstname.lastname@example.org requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your Personal Information does not ensure complete and comprehensive removal of that data from all systems.
V. How We Use Your Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products, or services that you request from us.
- To provide you with email alerts, event registrations, and other notices concerning our products or services, or events, or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis, and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
- We will use your Personal Information, including Online Form Data, for all purposes necessary to communicate with you about your interest in our Website, products and services; to inform you about events; to invite you to participate in new initiatives or feature and product upgrades; to perform quality control activities; and to conduct research and development.
- We use third-party analytics services to help Spok understand how visitors engage with our Website. These analytics services allow us to analyze all types of data received from users and businesses to generate reports about aggregate user behavior on our Website and help us to measure and research its effectiveness. The specific tools utilized may change from time to time, however the underlying objectives remain the same. To learn more about these services, contact email@example.com.
VI. Ability of User to Opt-Out
Should you later wish not to receive any e-mails related to the Personal Information you submitted, you can ask to be removed from our mailing list by emailing us at firstname.lastname@example.org or selecting the opt-out link, if provided.
VII. How We Share Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
VIII. Retention of Personal Information
IX. Third-Party Sites and Services
- Payment information
Spok does not currently support payment services via the www.spok.com website.
- Live Chat
- Third Party Sites
X. Do-Not-Track Signals and Similar Mechanisms
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates, although web browsers incorporate and activate this functionality in different ways, and it is not always clear whether users intend for these signals to be transmitted. There currently is disagreement, including among participants in the leading Internet standards-setting organization, concerning what, if anything, websites should do when they receive such signals. Spok currently does not take action in response to these signals, but, if and when a standard is established and accepted, we may reassess how to respond to these signals.
XII. Security of Your Information
Spok is very concerned about safeguarding the confidentiality of your information. We follow generally accepted industry standards to protect the Personal Information submitted to us from unauthorized access, both during transmission and once we receive it. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through our Website, we cannot and do not guarantee the security of any information you transmit on or through the Website, and you do so at your own risk.
XIII. Correcting, Updating or Deleting Information
The Website gives users the option to correct, update, or delete Personal Information previously provided to us by the user; however, we will maintain copies of user information to the extent retained as part of the Website’s standard backup/archive process or required by law or regulatory requirements and subject to our legal obligations.
To make changes to your contact information or other Personal Information, please contact us as described above in the “How to Contact Us” section. Visitors from the EEA, Switzerland and the United Kingdom: Please note our specific data protection statement in Section II above.
XIV. Site Visitors From Outside of the United States
The Website and the servers upon which the Website is hosted are located in the United States. Any personal data that users outside of the United States provide via the Website will be transferred to the United States, and by visiting the Website or submitting personal data, you authorize this transfer. Visitors from the EEA, Switzerland and the United Kingdom: Please note our specific data protection statement in Section II above.
XV. Business Transfers
XVI. How to Contact Us
Questions about this Privacy Statement, or generally about Spok’s processing of your Personal Information may be emailed to email@example.com or sent to:
Attn: Privacy Officer
6850 Versar Center, Suite 420
Springfield, VA 22151