Your privacy is important to us at Sorenson Communications, LLC and Captioncall, LLC and its affiliates (collectively “Sorenson,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights. This online privacy statement (the “Statement” or “Policy”) describes how we collect, use, disclose, and secure the personal information we gather about you through our website, https://sorenson.com/ (the “Site”), our applications, products, services, when you view or interact with Sorenson social media accounts or any social media accounts or content affiliated with us, and when you otherwise interact with us (collectively, the “Services”).
For purposes of this Statement, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations. It does not include data excluded or exempted from those laws and regulations, such as aggregated, anonymized, or deidentified data. Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Sorenson generally or in any specific context.
1. You Consent to This Statement
You should read this Statement carefully, so that you understand our privacy practices and our End User License Agreement. By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Statement. If you do not agree to this Statement, you may not use the Services.
This Statement and the End User License Agreement apply regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.
We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data. This Statement supplements these other notices and is not intended to override them.
If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.
2. What Types of Information Do We Collect?
We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties. The categories of personal information that we collect and the purposes for which we collect that information are described below.
The following list describes the categories of personal information we collect.
The following chart identifies the purposes for which we may collect your personal information, as well as information regarding our use and disclosure of that personal information. Please note that we may not collect each category of information about each user of our Services.
|Purpose||Categories of Personal Information||Targeted Ad / Sales||Data Shared with Third Parties||Categories of Third Parties|
|Account Management||Account Information Analytics Information Contact Information||Yes / No||Account Information Analytics Information||Analytics Providers Third Party Advertisers TRS Fund Administrator|
|Communications Services and Eligibility Verification||Analytics Information Commercial History Contact Information Payment Information||No / No||N/A||N/A|
|Providing the Services||Account Information Analytics Information Commercial History Payment Information||Yes / No||Analytics Information Commercial History Contact Information|
|Marketing and Advertising||Analytics Information Commercial History Contact Information Social Media Information||Yes / No||Analytics Information Commercial History Contact Information||Analytics Providers Third Party Advertisers|
|Analytics and Research||Account Information Analytics Information Commercial History Contact Information Responses to Surveys and Questionnaires Social Media Information||Yes / No||Analytics Information Commercial History Contact Information Social Media Information||Analytics Providers Third Party Advertisers|
|Customer Service||Account Information Analytics Information Contact Information Commercial History Chat Information Payment Information||Yes / No||Analytics Information||Analytics Providers Third Party Advertisers|
|Website Security and Maintenance||Account Information Analytics Information Commercial History||No / No||N/A||N/A|
We may also reserve the right to collect, use, or share personal information for the following purposes:
3. How Do We Use “Cookies” and Other Tracking Technologies?
We may send one or more cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services. This information allows us to understand how you use the Services.
We set some cookies ourselves and others are set by third parties. You can manage your cookies preference as described in the “Managing Your Cookies” section below.
The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers. Because the specific cookies we use may vary over time, as well as differ by the specific page you are browsing, the below chart is illustrative only.
|Types of Cookies||Purpose||Who Serves|
|Essential||These cookies are required for the operation of the Services and enable you to move around the Services and use its features. Disabling these cookies can negatively impact the performance of Services.||SorensonGoogle|
|Functionality||These cookies are used to recognize you when you return to the Services. This enables us to personalize content for you and remember your preferences. These cookies also enable your interactions with the Services such as emailing us and customer support chat.||AmazonAtlassianCalendlyComplianzDriftGoogle IntercomIAB TCFJetpopupMicrosoftVimeoWP EngineZopim|
|Analytics, Performance, and Research||These cookies, beacons, and pixels allow us to analyze activities on the Services. They can be used to improve the functioning of the Services. For example, these cookies recognize and count the number of visitors and see how they move around the Services. Analytics cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the content on the Services for those who engage with our advertising.||ElementorGoogleLinkedInMatamoMetaMicrosoftOptimizely|
|Social Networking||These cookies are used to enable you to share pages and content that you find interesting on our Services through third-party social networking and other websites. These cookies may also be used for advertising purposes.||GoogleLinkedInMetaTwitter|
|Advertising||These cookies and pixels are used to deliver relevant ads, track ad campaign performance, or track email marketing.||Google LinkedInMeta|
Some cookies operate from the time you visit the Services until the end of that particular browsing session. These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.
Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie. Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.
It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies. If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Services.
You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.
There is currently no industry agreed-upon response to a Do Not Track signal. At this time, our Site does not respond differently based on a user’s Do Not Track signal.
We recognize the Global Privacy Control (“GPC”). Your browser must be able to support the GPC for us to recognize your opt-out preference signal.
4. Colorado, Connecticut, Virginia, and Utah Users’ Rights
Colorado, Connecticut, Utah, and Virginia residents have certain rights with respect to their data. These rights are established through the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”). The chart below explains these rights and lists the states whose residents may exercise those rights. To exercise any of the following rights listed in the chart below, please email us using the information set forth in the “Contact Us” section below.
|Consumer Right||Explanation||Applies to Residents of:|
|Right to Know/Access||You have the right to confirm whether we are processing your personal data, and the right to access that data.||Colorado, Connecticut, Utah, Virginia|
|Right of Correction||You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.||Colorado, Connecticut, Virginia|
|Right of Deletion||You have the right to delete your personal data provided by you or obtained about you. *Note: If you are a Utah resident, this only applies to personal data you have provided directly to us.||Colorado, Connecticut, Utah*, Virginia|
|Right of Portability||Up to two times per calendar year, you have the right to obtain your personal data in a portable and—to the extent technically feasible—readily usable format that allows you to transmit the data to another entity without hindrance. *Note: If you are a Utah resident, this only applies to processing carried out by automated means.||Colorado, Connecticut, Utah*, Virginia|
|Right to Opt-out: Colorado, Connecticut, and Virginia||You have the right to opt-out of the processing of your personal data for the purposes of: Targeted advertising; The sale of personal data; and/orProfiling in furtherance of decisions that produce legal or similarly significant effects concerning you. To opt-out, please visit our “Your Privacy Choices” page.||Colorado, Connecticut, Virginia|
|Right to Opt-out: Utah||You have the right to opt-out of the sale of personal data or targeted advertising. To opt-out, please visit our “Your Privacy Choices” page.||Utah|
We collect Sensitive Data as deined in the CPA, CTDPA, UCPA, and VCDPA. We will not collect Sensitive Data from Colorado, Connecticut and Virginia residents without first obtaining consent. We will not collect this information from Utah residents without first presenting them with clear notice and an opportunity to opt out of the processing.
Exercising Your Rights
If you are a Colorado, Connecticut, Virginia, or Utah resident and wish to exercise one of the above rights and it applies to you, please visit our “Make a Data Privacy Request” [insert link] page or our “Your Privacy Choices” [insert link] page.
If necessary, we may request additional information reasonably necessary to authenticate you and your request.
In certain circumstances, you may make a request on behalf of another such as if you are an authorized agent or the parent or guardian of a child on behalf of whom you wish to exercise their rights.
We will respond to these consumer requests, if applicable, within 45 days of receipt of the request and without undue delay. If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay.
We will provide responses to your requests free of charge unless certain exclusions apply, depending on the state in which you reside. We may charge a fee in:
Colorado, Connecticut, and Utah, if you make more than one request in a twelve-month period; and
Connecticut and Virginia, if the request is manifestly unfounded or excessive, or repetitive in nature.
Appealing a Rights Request Decision
If you are a resident of Colorado, Connecticut, or Virginia, and we deny or fail to take action on your request to exercise your applicable consumer privacy rights, you may appeal our decision. To do this, you may email us at [email protected]. In the email appeal, please specify the right(s) you requested to exercise and the date you made such a request.
We will inform you in writing within 45 days of any action taken or not taken in response to the appeal. We will also provide a written explanation of the reasons for our decisions regarding your request(s).
5. Nevada Users’ Rights
Under Nevada law, certain Nevada consumers may opt out of the sale of certain personally identifiable information for monetary consideration to a person for that person to license or sell such information to additional persons. We do not sell personally identifiable information under Nevada law.
If you are a Nevada resident who has purchased or leased goods or services from us, you may (A) submit a request to opt out of any potential future sales, and/or (B) request changes to your Covered Information by emailing us at [email protected]. Please note we will take reasonable steps to verify your identity and the authenticity of the request.
6. European Users’ Rights
You are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.
To exercise these rights, please contact us using the information below in the“Contact Us” section or view our “Make a Data Privacy Request” page. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.
Asking us to access your personal information
You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this Policy. You also have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
Asking us to rectify your personal information
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Asking us to delete your personal information
You have the right to ask us to erase your personal information if:
However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Information Kept” section below.
If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).
Asking us to restrict our use of your personal information
You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:
The right to transfer your personal information to another service provider
You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you (i.e. data portability). This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.
The right to withdraw consent
If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.
The right to lodge a complaint with a supervisory authority
If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: EEA and EU Data Protection Authorities (DPAs); ; UK Information Commissioner’s Office (ICO).
Rights related to automated decision-making
To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.
Right to object to processing
You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us). If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the information in the “Contact Us” section below.
Legal Bases for Processing Your Personal Information
Sorenson collects your personal information to provide our products and Services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal information. The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.
Depending on the situation, we may be the controller or the processor for personal information collected from residents of the EU, EEA, UK or Switzerland. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “Contact Us” section below.
Cross-Border Transfers of Personal Information
Our Services are operated in the United States. Personal information about you provide while in the EU, an EEA member state, the UK, or Switzerland may be transferred to the United States. The United States does not have an adequacy decision or adequacy regulation. The GDPR permits such transfers when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located. If we transfer personal information from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.
To obtain a copy of the safeguard(s), please contact us using the information provided in the“Contact Us” section below.
7. Advertising and Marketing Choice
We respect your rights in how your personal information is used and shared. We may communicate you with you via email, telephone, postal mail, and/or your mobile device about our products and services. If at any time you would like to unsubscribe from receiving future emails, you can email us at [email protected] or follow the instructions at the bottom of each applicable email, and we will promptly remove you from those marketing correspondences that you choose to no longer receive. Please note, however, that we may still need to contact you regarding other matters.
8. How Long Is Your Personal Information Kept
We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.
We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation.
If you use our mobile application, you can delete your account by submitting a request to [email protected] or by deleting your account through the application itself. If you delete your account from within the application, we will delete the accompanying personal data unless we are required to retain it for legal, regulatory, contractual requirements, or other compliance purposes.
You can access and update certain personal information we hold about you at any time by logging into your account via the Services.
9. Our Commitment to Data Security
The security of your personal information is important to us. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.
However, we cannot and do not guarantee complete security, as it does not exist on the Internet.
10. Where Your Personal Information Is Held
We process personal information on our servers in the United States of America, and may do so in other countries. If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.
11. Third Party Links
Sorenson’s Services may contain links to third-party websites. When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within. It is important to note that this Statement only applies to Sorenson’s Services. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.
12. Children’s Privacy
Collection of Children’s Information. Protecting the privacy of the very young is especially important. Some of our Services are intended for children under 13 years of age. Please note that the Site is not intended for children under 13. We do not knowingly collect or otherwise process personal information from anyone under 13 without first obtaining verified permission from that child’s parent or legal guardian. This Policy, along with any additional parental consent forms provided as part of the provision of the Services to children, describes our privacy practices including the way we collect and process your child’s information.
Obtaining Your Consent. Before your child uses our Services, we will obtain your affirmative and verifiable consent. We will obtain your consent via (1) your signed consent or application form (as applicable) or (2) providing you this Policy, asking whether you consent to these practices, and having you verify your identity by showing a valid, government-issued form of identification.
Information We Collect About Children. When you apply for our Services on behalf of your child and consent to the processing of your child’s personal information, we will collect the information listed in this Policy from you about your child. We may also collect certain information from you (the parent or guardian), as required by law or regulation, and for administrative and billing purposes.
How We Use and Share Information About Children. After we receive your permission to provide Services to your child, we will collect, store, and disclose personal information necessary to provide those Services to your child. We may share information about your child and your child’s use of the Services with third parties for billing and administrative purposes and otherwise, as required or permitted by law or regulation. We may share information about your child with government agencies and private entities responsible for administering or overseeing the Telecommunications Relay Service (“TRS”) Fund and verifying eligibility for Sorenson services. For example, Sorenson may submit your and your child’s information to the TRS User Registration Database, a database administered by a government contractor, as required by Federal Communications Commission (“FCC”) regulations. Additionally, we will submit information about your and your child’s TRS usage to the Administrator of the TRS Fund and/or the FCC for billing purposes.
Sorenson may also share your child’s name, image (if your child uploads an image), and video phone number(s) with other Sorenson users in your child’s contact list. Sorenson may also share information about your child’s location with emergency services if your child calls 911 from a mobile device enabled with the Services.
Your Choices About Your Child’s Information. You have control over the ongoing collection, use, and disclosure of your child’s personal information. You may also request deletion of your child’s personal information at any time. You have the right to consent to Sorenson’s collection and use of your child’s personal information while withholding consent for disclosure of that personal information to third parties. You may review, delete, or prohibit further collection of your child’s information at any time. If you have further questions or requests related to Sorenson’s online collection of information from children, please contact [email protected].
13. Policy Changes
This Statement may change from time to time. If we need to change this Statement at some point in the future, we will post any changes on this page. If we make a significant or material change to this Statement we will notify you via email. You should check these terms when you use the Site. Your continued use of the Site constitutes acceptance of the most current version of this Statement.
14. Contact Us