Non-User Privacy Policy

1. Scope and Purpose

1.1 This Policy explains our handling of personal information relating to people who did not personally submit their information to us, including:

• A contact person named in a Partner application who did not submit the form themselves;
• A person named in a contact-form message addressed to a Partner (for example, a colleague the sender refers to);
• An end user of a Tenant whose call metadata, voicemail, recording or extension configuration passes through the Platform as part of the Tenant’s ordinary operation;
• A person whose business card or signature block is attached to correspondence sent to WPPBX.

1.2 Where you are a registered user of the Site or Reseller Portal, the Privacy Policy applies in preference to this Policy.

2. Categories of Data We May Hold About You

2.1 Depending on how your information reached us, we may hold:

• Your name, business title and contact details (email, phone, organisation, country);
• The context in which you were named (for example, the body of a contact-form message or an extension list in a Tenant);
• Call metadata generated when you place or receive a call through a Tenant (calling or called number, duration, disposition, timestamps);
• Voicemail or call-recording audio and any resulting transcription, where the Tenant has those features enabled;
• Technical data (IP address, user-agent) when you interact with a Tenant through a browser-based interface.

3. How We Receive Your Information

3.1 We receive information about you from:

• The person or organisation who named you in a communication to us;
• The Partner or Customer whose Tenant you interact with, as part of that Tenant’s configuration or ordinary operation;
• Our subprocessors, in the limited context of service delivery; and
• Automatically, when your device or browser connects to a system operated by or for us.

4. Why We Process Your Information

4.1 We process information about you, as a processor of a Partner or Customer in most cases, for the purposes of:

• Operating the Platform on behalf of the Partner or Customer whose Tenant you interact with;
• Routing communications you send or receive through that Tenant;
• Keeping the Platform secure and anti-abusive;
• Responding to lawful requests from supervisory or law-enforcement authorities; and
• Exercising our legal rights and responding to complaints and claims.

4.2 Where WPPBX itself is the controller, we rely on our legitimate interest in communicating with organisations that reach out to us, balanced against your rights and freedoms.

5. Controllers and Processors

5.1 For data processed in the operation of a Tenant, the Partner or the Customer is the data controller and WPPBX is a processor acting on their instructions. Questions about the lawful basis, scope, or retention of that data should be addressed to the Partner or Customer operating the Tenant.

5.2 WPPBX will refer non-user rights requests to the relevant Partner or Customer where that party is the controller, unless we are required by law to respond directly.

6. With Whom We Share It

6.1 We share information about non-users with:

• The Partner or Customer whose Tenant you interact with;
• Our subprocessors, as identified in the Privacy Policy, strictly for service delivery;
• Competent authorities under lawful request or binding order.

6.2 We do not sell personal information about non-users and do not use it for advertising.

7. International Transfers

7.1 Our primary hosting is located in the European Union. Certain subprocessors receive data outside the European Economic Area under the safeguards described in the Privacy Policy, including the European Commission’s Standard Contractual Clauses where required.

8. Retention

8.1 We retain information about non-users only as long as is necessary for the purpose for which it was received, or to comply with a legal obligation. Where WPPBX is acting as a processor, retention is determined by the Partner or Customer’s configuration of the Tenant and is not under WPPBX’s independent control.

9. Your Rights

9.1 Subject to applicable law you have the same data-protection rights as any data subject, including access, rectification, deletion where applicable, objection and complaint. To exercise these rights in respect of data held by WPPBX as controller, email [email protected] and reference that you are a non-user of the Site.

9.2 For data held on a Tenant as processor, please contact the Partner or Customer operating the Tenant in the first instance. WPPBX will support the Partner or Customer in giving effect to your request where the Platform’s assistance is required.

9.3 You have the right to lodge a complaint with a supervisory authority: in South Africa, the Information Regulator; in the EU, the Data Protection Authority in your country of residence.

10. Contact

Questions or requests can be directed to [email protected].