Mitel Application Privacy Policy

Mitel Networks Corporation (and/or one if its affiliates) ("we"/"us") has made this application or plug-in available for use with the Mitel cloud-based communications services ("communications services".) and/or Mitel on-premise communication products (“communication products”) we provide to the company or organization you work for (or are otherwise engaged with) ("your organization"). Communication services include cloud-based communications services used to augment communication products (e.g., Mitel CloudLink) (“hybrid services”).  Plug-ins may require authentication to third-party services and certain permissions therein (e.g., such access to contacts). Third party credentials are solely used to obtain access to information stored in your third-party account for the purpose of setting up or tearing down VoIP calls using your organizations’ communication product or service from your devices or presenting you with information about your calls (e.g., inbound caller information.), Plugins may read and write notes you enter about your calls and contacts into your third-party accounts. Plug-ins never share third party service passwords with us. 

Communication Services:

Your organization gives us any data we need to provision the application or plug-in and associated communications services for you which may include your company directory. When you use the communications services, we and our service providers may process data about you and people you communicate with (“personal data”) as required to provide the communication services (associated training and maintenance services, if any). For example, we and our service provider may process the following types of information about you and those individuals you communicate with:

(a) User ID, first name, last name, language preference, phone number, job title, address, email address, photo, geographic location, username and password;

(b) inbound and outbound call logs (or CPNI information), email and text message communications, phone calls, video calls, recorded calls, inbound and outbound faxes, voicemails, meeting information, chat histories, calendar data, personal contacts, birthdate, user-saved or stored content shared among users;

(c) IP addresses, service set-up information, service configurations and settings; and

(d) your emergency call location;

Where personal data is processed, it is only done on behalf of your organization and under the terms of our contract with your organization (“your organizations’ contract”).  Additional information about our processing of emergency call location in the United States is found in the 911 calling section below which takes effect on the day Mitel’s Dynamic e911 services become available on your communication service.

For example, we may process personal data:

• to track your session login and logout;
• to address any outbound communications or identify any inbound communications;
• to maintain logs about inbound and outbound calls and messages;
• in text messages or instant messages to the extent required to send and receive those messages;
• in files to the extent required to facilitate file sharing and collaboration between application users;
• in a phone or video call, voice mail or conference to the extent required to facilitate those calls, voicemail facilities or conferences;
• in respect of any other communications services, we may provide to your organization (e.g. call recording services);
• as required to contact you and/or your organization;
• as required provide technical support to you and your organization;
• as required to bill your organization;
• as required by a lawful access request or court order; and
• where your organization has a contact center, to provide your organization with agent statistics such as: total number of calls made or received, average call handle time, total number of webchat or email handled, average handle time for those interactions

We will only disclose personal data to third parties (e.g., service providers) as set out in your organizations’ contract. Personal data is retained and deleted as set out in your organizations’ contract. We will not review the content of messages, calls, voice mails, conferences or communications unless required to do so by your organization, by applicable law or other extenuating circumstances. We treat personal and non-personal data found in communications content in the same manner. 

Our systems and software used to host personal data are protected by appropriate security controls including, but not limited to, firewalls, access controls and unique user ids and passwords. User account creation and deletion procedures for granting and revoking access to systems and networks are based on a “need-to-know” basis and use the least privilege approach. Ongoing security testing is performed on all of our systems which contain personal data. We monitor and track ongoing reported security vulnerabilities.

If you are using a plug-in with a communication service, we will process the following information necessary to authenticate you and provide you communication services: third party email, device number, contact name, call type, phone type, phone number, third party service contact ID and name, call duration, company name.

Communication Products:

Communication products are operated by your organization or their service provider(s). Except where we provide your organization with hybrid services, we do not have access to your application, plugin, organization’s communication products, nor the communications they facilitate, and as such, we do not process personal information associated with your communications. You should be aware that if your organization has purchased any third-party product add-ons, this application may send any necessary data to such third party. Please contact your organization or such third party for details.

Location Data:

The MiCollab for Mobile App (“MiCollab Mobile”) presents an availability status to your colleagues telling them your current "status" which may include settings like "in the office " or "working from home". You can configure your calls to be routed based on your availability status (for example to your cell phone or your desktop). If you would like MiCollab Mobile to automatically update your status when you move physical locations, you can enable dynamic location services.

If enabled, MiCollab Mobile will use location information services available on your phone (e.g., GPS or other) to determine whether you are at a location you have previously registered in MiCollab Mobile and update your availability status. For example, MiCollab Mobile can determine when you are “at home” and update your status to “working from home” (and change your call settings to your “working from home” configuration). Once enabled, dynamic location services operates when MiCollab Mobile is in use, in the background when other applications are in use and when your phone is locked.

MiCollab Mobile does not store your location information as you move around. MiCollab Mobile only store locations you register. These locations are stored locally within the application. Location information covered under this section is not transmitted to Mitel.

Locations registered for dynamic location services are distinct from911 emergency address information.

Analytics Data:

Regardless of whether our applications are used with our communication services or our communication products, our applications may transmit to us: application identifier, log data, crash data, information about the features used within the application including date, time and frequency of usage, sequence of features and clicks, and screens viewed, and the type and identifier(s) of the mobile device used to run the application. We use the foregoing information to improve and maintain our applications, products, and services.

911 Calling (United States only)

Collection of Emergency Address

On-Campus. When you use a Mitel soft or hard phone within your organization’s campus environment (“Campus”), your Mitel phone can use available network information (e.g., wireless BSSID, Private & Public IP address, and MAC Address of their default gateway, and LLDP switch and port information) (“Network Information”) along with information about your Campus which your organization has provided to us to determine your emergency location within your Campus. Emergency location information is only collected if and when 911 is dialed. 

Off-Campus. NETWORK INFORMATION DOES NOT PROVIDE MITEL WITH PHYSICAL LOCATION INFORMATION. INSTEAD, IT ALLOWS US TO RECOGNIZE LOCATIONS ON COMPUTER NETWORKS WHICH HAVE BEEN REGISTERED WITH US. When you use a Mitel soft or hard phone outside of your Campus, your Mitel phone will use available Network Information, if any, to determine whether your phone is located at an emergency address which you (or your organization) have registered with us.  If we detect that you are not at a registered address, you will be prompted to provide your current address for emergency registration.  Unless you indicate you do not wish Mitel to retain your emergency address, each emergency address that you provide to us will be retained within our cloud for the period set out in the user documentation or by your administrator, where such function is available.

Use/Disclosure of Emergency Address

Emergency address information is only used to route 911 calls to the appropriate public safety answering point (“PSAP”). Emergency address information is disclosed to the PSAP (and other third party involved in routing 911 calls).

We may disclose location information if necessary to comply with law including subpoenas, court orders, or other requests (including criminal and civil matters). 

We may also disclose your information to emergency service providers for the purposes of emergency planning and/or response.

Call Records

For each 911 call, we generate a call record including date and time of call, the phone number from which it was made, the location of the caller. These records will be retained in accordance with the communications services’ Call Detail Record data retention policy.

Central Notice

When 911 is dialed an alert is sent out to a pre-defined set of people selected by your organization. This notice includes the caller’s phone number and the location from which the 911 call was placed.

General:

You can find out more about us at www.mitel.com/legal. Our DPO and legal department can be reached at [email protected]. 

If you have specific questions about your organizations’ communication services or communication products, you should address them to your organization.

Last Modified:  03/11/2022