Effective as of May 17th 2018
INFOBIP is a pioneer in A2P messaging and the world's leading global communication platform. Our platform reaches 7BN devices through 800 telecom network connections, supported by 50+ local offices worldwide. We are dedicated to connecting the world at the intersection of internet and telco technologies. We believe that the responsible use of data supports business growth and builds strong relationships between partners, consumers and brands. As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact.
Our customers are mainly companies that integrate our Services into their business operations through their own software applications (via API), or using INFOBIP Portal, our website interface. We do not directly interact with our customers' end users, and all the information that our Customers submit is shared with us on their sole discretion in accordance with the General Service Terms and Conditions, Agreement for Services and Data Processing Agreement concluded with our Customers.
- What data we collect and how we collect it
- Why we collect your data and how we use it
- How and with whom we share your data
- Where is your personal data processed
- What are your rights in respect of your personal data
- How can you object to the processing of your personal data
- How long do we keep your personal data
- How can you contact us
The term "INFOBIP" or "us" or "we" refers to the company INFOBIP LIMITED, with its registered office at London SW1Y 6AW, 5th Floor, 86 Jermyn Street, and registration number 7085757, and its affiliated companies.
The term "you" refers to the natural person who is user of our Services or whose personal data we process during the performance of our Services.
The term "personal data" means any information about you by which you can be identified, directly or indirectly.
The term "data controller" means the natural or legal person which, alone or jointly with others, determines the purposes and means of the data processing and is responsible for processing such data in a manner consistent with the applicable European and national regulations on the personal data protection. By using our Services, with respect to processing your personal data, we will in certain situations act as a data controller. In other situations, when we processes your personal data by the means and for the purposes determined by our business partners, we will act as a data processor.
2. WHAT DATA WE COLLECT AND HOW WE COLLECT IT
We process your personal data which you provide to us directly.
INFOBIP collects and processes personal data about you as an individual in the following situations:
- JOB CANDIDATES - when you apply for a job position;
- CUSTOMERS - when you use our Services;
- SALES CONTACTS - when you visit our website, register in order to get information for a specific Service, and/or ask for communicate with us;
- MARKETING SUBJECTS - when you subscribe to our newsletters, webinars, alerts or other services from us.
We collect personal data about you when you submit a job application or a resume on our Careers web (which data will be saved in our recruitment software called SmartRecruiters), or when you enter your data directly to SmartRecruiters. Personal data we collect about you by this means is your name, last name, contact information, information about your education, about your previous work experience, location/place of residence, or any other information you choose to share with us when you submit your resume.
We collect and process this data pursuant to your consent provided to us when submitting a job application or a resume.
We collect and process personal data about you if you use our Services, e.g. if you create an INFOBIP account and become our Customer.
For that purpose, we will collect your account data, which means your personal data that relates to your relationship with INFOBIP, like your name and/or contact information (e-mail, phone number, address) and billing information (name, address, VAT number).
Collecting and processing of this data is necessary to us in order to enter into a business relationship with you or to fulfill our obligations arising from our existing business relationship with you.
We collect your personal data when you visit our website and register in order to get information for a specific Service, when you ask for more information about a certain Service, or contact us with a question or complaint. We may collect this information through our "Contact Sales" form on the web, through networking events, LinkedIn contacts or other way of communication.
For this purpose we may collect only your basic contact information (such as name, phone number, email address, your employer) as well as any other information you choose to send us, depending on a nature of your request.
We also collect your personal data when you subscribe to our newsletters, webinars, blogs or our other services through which we provide the information about our business and Services.
For this purpose, we collect data like your first and last name, your employer, country, mobile phone and email address. This type of data is necessary and relevant to our marketing department.
This data is collected through the webforms on our website. We collect and process it pursuant to your consent provided to us when submitting such webform.
In certain situations, our customers, business partners and other entities (“third parties”) may provide your personal data to us.
We use various job boards and CV databases to search for potential candidates for open positions at INFOBIP. For this purpose, we may process your personal data you have chosen to share on these platforms.
DATA PROVIDED BY CUSTOMERS
We may process personal data of the individuals on the behalf of our Customers, and for the sole purpose of providing our Services to said Customers. That can be personal data of our Customers' employees, or our Customers' end-users (customers, suppliers, clients and other end users).
That means that our Customers will provide us with contact details (like name, e-mail address, phone number or other contact details) of their employees authorized by the Customer to access Customer's INFOBIP account while using INFOBIP Services.
While using our Services, the Customer will share with us personal data of its end users, like receiver and/or sender contact data (e.g. telephone number, e-mail address), and communications content (e.g. message text, voice files, video or other media content).
If the Customer uses INFOBIP Portal, such Customer could possibly enter other personal data of its customers/ suppliers / end-users into INFOBIP Portal, for example: name, gender, address, birthday, and any other custom attributes defined, imported and controlled exclusively by the Customer. The precise personal data provided to us is determined and controlled solely by the Customer.
We process such personal data on behalf of our Customers and only for the purposes of providing our Services to our Customers, in accordance with the General Service Terms and Conditions, and/or the Agreement for the Services and Data Processing Agreement concluded with our Customers.
That means that Customer is the controller and INFOBIP is the processor regarding such personal data.
While providing our Services, we will also receive and process certain data for the purposes of transmitting, distributing or exchanging Customer communications content, e.g. data used to trace and identify the source and destination of a communication (such as individual data subjects' telephone numbers or e-mail addresses, data on the location of the device generated in the context of providing the Services, and the date, time, duration and type of the communication). Regarding this personal data, INFOBIP is the controller, as we collect and process this data for billing purposes.
3. WHY WE COLLECT YOUR DATA AND HOW WE USE IT
We collect your personal data, from you or from third parties, in order to provide our Services to you, our customers and business partners, to enable you to use our Services, as well as to improve and develop our Services.
As we are young and growing company, we are in constant need for new, talented individuals who will become a part of our team. By collecting data about people who are interested in working with us, we make sure that, when there is an open position at INFOBIP, we can reach the most quality individuals to offer them an opportunity to become a part of our team.
This data will be used only by authorized members of our team, who will use it to contact you in case there is an open position at INFOBIP, to check if you are still interested in working with us.
All the personal data collected about you as a Customer of our Services will be used only for the purpose of enabling you to access and to use our Services, to provide you with a technical support for our Services, for the purpose of improving our business relationship with you, as well as for the purpose of exercising our rights and fulfilling our obligations arising from the business relationship that we may have with you. Personal data collected for these purposes will not be used for any other purpose, unless we have another legal basis for such processing of your personal data (such as your consent).
We collect your personal data to provide you with information about our Services, to build and maintain a business relationship with you and provide you with all the necessary information to make sure our cooperation will be mutually beneficial and satisfying after you become a Customer.
We will use this information only to contact you to answer your questions or to find out if you are interested in a further cooperation with us. Any further processing of your personal data will be based on a business relationship we shall establish with you or on a consent that you have provided to us for specific purpose. If we do not establish a business relationship or obtain a consent from you, we will delete your data collected for this purpose.
Your personal data collected for the marketing purposes will be used only to deliver you our newsletters, enable you access to our webinars, blogs, events or our other marketing services, for which specific purposes we have obtained your consent.
DATA PROVIDED BY CUSTOMERS
If we receive personal data of the individuals from our Customers in order to provide our Services to said Customers, we will processes such personal data only for the purpose specified by the Customers and on their behalf.
4. HOW AND WITH WHOM WE SHARE YOUR DATA
In order to provide our Services to you or to third parties, we may share your personal data with our business partners. Some of our business partners will have access to your personal data as reasonably necessary to perform certain tasks on our behalf. Some of them will have access to your personal data as a part of the Services which we provide to you or to respective third parties. We will not share your personal data with any person or entity if we do not have a legal basis for such disclosure of your personal data. We may also need to share your personal data with certain entities pursuant to our legal obligation or when it is required to help to protect the rights and safety of you, us, or others.
OTHER CATEGORIES OF DATA SUBJECTS
If you contact us, subscribe to our newsletter, blog, alerts or other Services and/or become our Customer, we will also collect and process your personal data through internal tools, as well as Salesforce, a CRM application that is product of a company Salesforce.com inc, and Eloqua, a product of a company Oracle Corporation. If there is a problem with Salesforce and Eloqua, corresponding vendor support team may also have access to limited set of your personal data, for the purpose of resolving the problem. Details on how these companies process your personal data you can find at https://www.salesforce.com/company/privacy/ (for Salesforce) and http://www.oracle.com/us/corporate/contracts/ocloud-hosting-delivery-policies-3089853.pdf (for Oracle).
For the purposes of providing you with our Services, we use some sub-processors, who assist in providing our Services, or otherwise may have access to the data stored within our platform, and we take care to maintain an up-to date list of them here.
We are global company and we may share your personal data with our affiliated companies to complete internal procedures within our offices all over the world and to provide you with the technical support.
We are able to offer technical support for our Services by operating a 24/7 "follow the sun" support model that leverages its support engineers in countries where INFOBIP operates. This means that although INFOBIP will not move your personal data into another jurisdiction, sometimes we will provide the Customer support from outside the European Union. INFOBIP will always ensure that personal data transfer is in line with applicable data protection law, including GDPR.
Notwithstanding the foregoing, we do not share with third parties your information or information otherwise received from you through the usage of our Services, except when necessary, such as with:
- Network operators and/or other communications service providers when necessary for the set-up of proper routing and connectivity. We reach people on their smartphones through network operators as well as other global communications providers, especially OTT ones such as Telegram, Viber, Facebook and WeChat.
- Third-party service providers to the extent strictly necessary for them to perform specific actions on our behalf. We may share personal information with our trusted and verified third-party service providers for example in order to enable them to process payments for us or to prevent fraud.
- Relevant legislation. In case we are presented with a legal obligation, we will share the data from users with such third parties that are legally entitled and authorized to request the same, such as within criminal procedures or threats to the public security;
5. WHERE IS YOUR PERSONAL DATA PROCESSED
While providing our Services and unless otherwise agreed with the Customer in writing, we will make sure that personal data we have collected are stored and processed at the processing systems located in INFOBIP data centers located within European Union (Primary at our data center in Frankfurt, Germany and Zagreb, Croatia), and any transfer of personal data to the INFOBIP's data centers located outside the European Union or European Economic Area (EEA) can be made only upon such instruction of the Customer. In case when the personal data will be transferred outside the EEA area, we will take all the appropriate and necessary steps to ensure that such data is processed in accordance with the applicable laws.
Your personal data may be processed both inside and outside of the European Union by the parties specified in section 4 above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorized to process them.
6. WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
Pursuant to the applicable European and national regulations on the personal data protection, you can access or delete your personal data, as well as to exercise other rights in order to have control on how your personal data is collected, used and shared.
Where permitted by applicable law or regulation, you have the right to:
- Access your personal data that we process about you and to learn the origin of the data, the purposes of processing and the period for which your personal data will be processed, who are the controllers and processors of your personal data and to whom your data may be disclosed;
- Withdraw your consent at any time where your personal data is processed pursuant to your consent;
- Update or correct your personal data so that it is always accurate;
- Delete your personal data from our records if it is no longer needed for the purposes indicated above;
- Restrict the processing of your personal data in certain circumstances;
- Obtain your personal data in an electronic format; and
- File a complaint with us and/or the relevant data protection authority.
You may exercise these rights by contacting us by the contact information specified below providing your name, email address and purpose of your request.
7. HOW CAN YOU OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA
Where permitted by applicable law or regulation, you have the right to object to the processing of your personal data, or to tell us to stop processing your personal data (including for purposes of direct marketing). Once you have informed us of this request, we shall no longer process your personal data unless permitted by applicable laws and regulations.
You may exercise this right in the same manner as for your other rights indicated above.
8. HOW LONG DO WE KEEP YOUR PERSONAL DATA
Your personal data, collected and saved in our database pursuant to your consent, will be saved in our database for a period specified in such consent. If you wish to withdraw your consent for processing of your personal data for any purpose and to delete your data from our database, you can do that at any time by sending an email to email@example.com.
9. HOW CAN YOU CONTACT US
If you have any questions on how we use your personal data, if you wish to exercise a certain right or to resolve any complaint in respect to the processing of your personal data, you can contact us by sending an email to the following email address:
If you want to file a complaint or contact the relevant data protection authority for any other reason, you may do so by visiting the following website: