SUMMARY OF LASTEST CHANGES

This policy was last updated on February 16, 2022. The February 16th update: (i) explains Mitel’s email tracking policy, (ii) provides additional details on Mitel’s data retention policies, and (iii) provides miscellaneous clarifications throughout including (a) that Mitel may market both its own products and services, as well as those of its partners, including RingCentral, (b) that when analyzing your personal data for marketing and business purposes, Mitel may combine various sources of personal data to extrapolate the likelihood that you and/or your organization will be interested in our products and services and/or those of our partners, such as RingCentral and (c) that Mitel may use a third service provider to confirm the accuracy of your contact information.

MITEL PRIVACY POLICY

Mitel Networks Corporation and its affiliates, subsidiaries and entities that Mitel Networks Corporation operates (collectively, “Mitel”, “we”, “our”, or “us”) is committed to protecting the security and privacy of your personal data and ensuring that we conduct our business in compliance with laws on privacy, data protection and data security.

This is the Privacy Policy ("Policy") for Mitel’s worldwide websites, which includes our online store, our affiliated websites and any websites or marketing applications operated by or on behalf of Mitel (collectively “our Sites”). This Policy also applies to our direct mail, telemarketing, email campaigns and other similar marketing activities as well as any contact information used for an administrative or operational purpose which is contained in a purchase or service order submitted to Mitel, or added into a Mitel product or service portal, by you or another person at your organization. We encourage you to read this Policy so that you understand Mitel’s commitment to your privacy, and how you can contribute to that commitment.

For the purposes of EU/EEA General Data Protection Regulation (“GDPR”), Mitel Europe Limited is the data co

ntroller. Our contact details are set out at the end of this Policy.

This Policy describes our general privacy policy and practices in relation to the personal data that we collect and process. In addition, the Policy and the documents referred to within the Policy set out:

This Policy does not extend to the practices of other websites that we may link to, companies that we do not own or control, or to people that we do not employ or manage.

Information we collect about you

When you use our Sites or otherwise communicate with us including through our sales or support teams, or apply for a job, through our Sites or otherwise, we may collect the following types of personal data:

The categories of personal data we collect have not changed for the past twelve months.

From Third Parties

We may also collect the following types of personal data about you from (a) our customers or another person at your organization, including by way of a purchase or service order submitted to Mitel, or a Mitel product or service portal, and (b) prospects or third parties we work with, such as business partners, sub-contractors, advertising networks, lead providers, analytics providers, search information providers, social media providers or media companies:

How we use your information

We use your personal data to support our business functions, such as fraud prevention, marketing, and legal functions. Examples of how we use your personal data include:

Cookies and Other Technologies

Cookie Policy

Email Tracking.

Emails we send you may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that automatically provide us information about how you interact with our email, if at all. For example, the web beacon tells us when you receive our email, when you open the email, how many times, and if you click on the call to action. We may also track if you click any other link in the email including those to social media. This allows us to gauge the effectiveness of our communications and marketing campaigns and your interest in same.

Summary of legal basis and purpose of processing

Data protection laws (including the GDPR) set out a number of different reasons for which we may collect and process your personal data in certain circumstances. Where data protection Laws apply, the legal bases we rely upon include:

Who we give your information to

We may share your personal data with:

The categories of personal data we have disclosed over the last twelve months has not changed.

Other Disclosures We May Make

Where your information is stored

Personal data collected by us may be stored and processed in your region, in Canada, and in any other country where Mitel or its service providers operate. We maintain major data centers in the following countries: the United Kingdom, France, Canada and the United States. Where your information is stored by Mitel itself, typically, the primary storage location is in your region.

If you are a EU citizen, personal data that we process in relation to you may be transferred and stored at, a destination outside the EEA that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers. The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

Where your information is transferred outside the EEA, we take steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as where applicable relying on a recognised legal adequacy mechanism and contracts, to help ensure your rights and protections travel with your data and that your personal data is treated securely and in accordance with this Policy.

Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.

How long we keep your information

Where we process personal data about you on behalf of our clients that use our products and services, the period for which we keep your data is determined by our client or by legal or regulatory requirements.

Where we process personal data about you in conjunction with the supply of our products or services (e.g., contact data for technical or billing purposes), we retain that personal data for as long as necessary to provide the products and fulfill the transactions our clients have requested, or for other purposes such as complying with our legal or regulatory requirements, resolving disputes and enforcing our agreements. The criteria used to determine the retention periods include whether your personal data is still needed to provide, maintain or improve the performance of our products and services, you requested that your personal data be deleted, we have determined a specific retention period for certain types of data, you have provided your consent (where applicable), and have not withdrawn your consent.

We keep your contact information, and our extrapolation of your organization’s procurements cycle and the likelihood that you and/or your organization will be interested in our products and services and/or those of any of our partners, until you ask to us delete it or unsubscribe to our marketing list. For clarity, even where you ask us to delete your contact information or opt-out of future marketing, we will keep your email and phone number on our email and phone opt-out lists.

Your rights

You, or a verifiably authorized person acting on your behalf, have the right under certain circumstances to be provided with a copy of your personal data held by us.

Depending upon the data protection law applicable to you, you may have some or all of the following rights under certain circumstances:

Prior to processing any of the aforementioned requests Mitel will require proof of identity acceptable to Mitel.

Your right to withdraw consent:

Where the processing of your personal data by us is based on consent (provided either directly to us or to a third party from whom we obtained your personal data), you have the right to withdraw that consent without detriment at any time by contacting us using the contact details at the end of this Policy. You can also change your Marketing Preferences at any time.

How to exercise your rights

You can exercise the rights listed above at any time by contacting our Privacy Service Team at [email protected] It is important to Mitel that the information we have is accurate and complete. To update your personal data, please contact our Privacy Service Team at [email protected]

If you have any further questions, comments or concerns about our privacy policies or practises, please contact our Privacy Service Team at [email protected] Mitel Networks Corporation is committed to resolving any concerns you may have regarding this Policy quickly and efficiently.

If you are an EU citizen, and if your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Changes to this policy

Any changes we make to this Policy in the future will be posted on our websites and all related websites for additional languages and regions. This Policy was last updated on: February 16, 2022

Contact us

Mitel Legal Department
[email protected]

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