- conduitglobal.com (the Website) is operated by Conduit Global, which is the trading name of Conduit Global, Inc. (Company No: 5371866; Office address: 3400 Bath pike, Suite 312, Bethlehem, PA 18017 (Conduit Global or we, us or our). We are part of the kgb group of companies, which includes 118 118, The Number and 118 118 Money, all together the Group.
- If you wish to contact our Data Protection Office, please contact them via email@example.com. Other ways to get in touch with us are set out in the Contacting us section below.
- Protecting your personal information:
- The aim of this Policy is to tell you how we will collect, use and retain any personal information you provide to us, or which is provided to us by our customers.
- What the law says:
While there is no national data protection law in the United States, personal data is protected by law in other geographies in which we operate (such as General Data Protection Regulation and the Data Protection Act 2018), and these laws require that we only use your personal information if we have a lawful reason to do so. Therefore, under this policy, our aim is to have one or more of the following lawful reasons:
- We have your consent;
ü We are entering into or are performing a contract with you;
- It is in our legitimate interests;
- When we are under a legal duty.
When we rely on your consent, we will either gain your consent directly, or we will act on our customer’s behalf and rely on the consent that you provided to them. We will not collect or use any of your personal information that we receive from our customers without first confirming that our customers properly gained your consent.
When we rely on our legitimate interests we mean our:
- pursuit of our commercial activities and objectives, or those of a third party;
- compliance with applicable legal and regulatory obligations and any codes of conduct;
- improvement and development of our business operations and service offering, or those of a third party; or
- protection of our business, shareholders, employees and customers, or those of a third party.
- What is personal information?
Personal information is information about you and other individuals. It is information which identifies you such as your name, address and email address. The personal information which we collect about you may include:
- personal information provided to our customers that we are asked to process on their behalf;
- personal information included in communications between us (including telephone calls and e-mails);
- contact information you provide to us via our website or otherwise,
- recordings of calls between us; and
- telephone numbers.
We also collect (automatically) some information about your device when you visit the Website. For example, we will collect session data, including your IP address, Web browser software, and referring website. We may also collect information about your online activity such as content viewed and pages visited. To the extent that this information constitutes personal information, its use by us will be covered by this Policy.
Who is responsible for the personal information we collect?
Conduit Global, or any Group company processing your data on Conduit Global, Inc.’s or a customer’s behalf, is the data controller for the purposes of the GDPR. This is because we dictate the purpose for which your personal information is used and any personal information you give us about other individuals.
How we collect and use your personal information:
- You do not have to give us any personal information in order to use our Website.
- In some circumstances we may need to collect your personal information for example, by law or to perform a contract with you. If you decide not to give us your personal information, we may not be able to fulfil our obligations.
- References to you in this Policy mean the person who is using our Website or whose information is provided to us by our customers included.
- We have set out our reasons for using your personal information in the table below under the heading Legal Basis. Where we rely on our legitimate interests, we have set out those interests in the table below.
- You have the right to object to our use of your personal information at any time. A summary of your right to object and details of who to contact if you want to exercise this right can be found at the Contacting us section below.
- For further information on your rights please see the Your Rights section below.
|To communicate with you and other individuals:
Ø In emails, SMS and telephone calls (which we may record and/or monitor for quality checks and staff training);
Ø Please note that these recordings may also be used to help us combat fraud, when registering for our products and services, in customer surveys, when you participate in competitions and promotions, through our Group company websites, resolve complaints, provide refunds and collect customer opt-in consent;
Ø To tell you about other products or services we, other members of our Group or our partners can offer you which may be of interest to you; and
Ø administer offers, competitions, rewards and promotions.
|Consent, performance of a contract we have with you and/or legitimate interests: we require your personal information in order for you to receive our products and services.
|To manage your relationship with us (including to keep a record of the products and services you order from us).||Performance of a contract we have with you and/or Legitimate interests: we require your personal information in order for you to receive our products and services.|
|To improve the quality of our service including:
Ø To train our personnel;
Ø To assess the quality of our products and services;
Ø To measure interest in and improve our products, services and the Website;
Ø To help us to understand the interests of our users and customise your user experience (for example using information we collect automatically); and
Ø Recording our telephone calls with you for training and quality control purposes.
|Legitimate interests: we require your personal information in order for you to receive our products and services.|
|To perform services as a subcontractor on behalf of our customers with whom we have a contractual relationship in place.||Consent.|
|To enable us to publish your reviews, ratings and other content to the Website.||Legitimate interests: we require your personal information in order for you to receive our products and services.|
|To comply with legal and regulatory obligations and to prevent potentially prohibited or illegal activities.
Ø Administer, update, consolidate, improve and manage the accuracy of our records and our business including meeting legal, regulatory and compliance requirements and operating rules (such as anti-money laundering, regulatory reporting requirements and record maintenance); and
Ø Monitor and analyse the use of the Website to detect, prevent, investigate, prosecute and/or report fraud, terrorism, misrepresentation, security incidents or crime.
|Necessary for compliance with a legal obligation to which we are subject.|
|To investigate and respond to any complaints, refund requests, feedback and queries and handle/resolve disputes.||Legitimate interests: to enable us to deal with any issues you may have in relation to our products and services.|
|If you download our mobile application(s) or use our Website, we may collect information about your use of them including, where available:
Ø your IP address;
Ø operating system and browser type; and
Ø the type of device(s) you use (we use this information for system administration, fraud prevention and product development).
|Performance of a contract we have with you and our legitimate interests to enable you to receive our products and services in certain formats.|
- Your personal information will be held securely so that we and any other companies in our Group that you have dealings with, either now or in the future, can manage your relationship with us. This will include personal information you provide when you complete forms on our Website, and any additional personal information provided by you or others.
- Who do we share your personal information with?
- Our Group companies
- By sharing your personal information it enables us, and other companies within our Group, and our service providers and agents to better understand your needs. We will always treat your personal information as private and confidential.
Our other service providers and agents
We will share your personal information with:
- third parties who carry out hosting, maintenance, call centre operation, or provide other services in relation to the Website;
- our suppliers of telecommunication services;
- business process outsourcing providers;
- third parties where we are required to do so by law or by our regulatory bodies or if we require or are required by others to investigate or prevent crime (this may include foreign authorities to help them in their fight against crime and terrorism); and
- third parties who may be connected with you.
We will also share your personal information:
- with any person to whom we sell, merge or transfer (or enter into negotiations to sell, merge or transfer) our business or part or all of our business or assets or enter into a merger with it;
- to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction;
- if the transaction goes ahead, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this Policy.
- We will always ensure your information remains safe and secure.
- Why we may process special categories/sensitive personal information about you:
- Some personal information under data protection law has special protection. This information is known as special categories of personal information but it may also be called sensitive personal information. This type of personal information includes information which relates to your racial or ethnic origin, political opinions, religious beliefs or philosophical beliefs, trade union membership, genetic or biometric data or data concerning your health, sex life or sexual orientation.
- If we collect this type of personal information, we will only do so to provide the product or service you require or help to manage your products and services.
- If we need to obtain special categories of personal information, we will ask for your explicit consent first.
- Where will we transfer your personal information?
- There will be times when we share your personal information within our Group and with our third party providers who are located in countries outside of the United States.
- Your personal information may be transferred to countries outside the United States and the European Economic Area (EEA) (such as the Philippines). When we transfer your personal information outside the United States or the EEA, we will take reasonable steps to ensure that your personal information is protected. To do this we use a set of standard data protection clauses which have been approved by the European Commission.
- The above approach is compliant with data protection law established in the EEA (being Article 46.2 of the GDPR). For further information about these transfers and the safeguards in place, please get in touch via the Contacting us section below.
Retention of your personal information
- How long we keep your information for depends on the basis for which it was provided.
- Generally, however, we will keep the information that is necessary to enable us to provide you with the relevant products or services you have requested for as long as it takes us to provide that product or service, or, in the event we receive your personal information from our customer in the performance of a contract, as otherwise requested by our customer.
- If you have asked that we do not use your details for marketing purposes, we may still need to keep them to ensure our systems reflect your preferences.
- We will keep records of any transactions you enter into on this Website for a minimum of 6 years from the end of our relationship with you. This is so that we can respond to any complaints or disputes that arise in that period.
- If you would like to know more about how long we hold your personal information please get in touch using the Contacting Us section below.
- You have certain rights with respect to your personal information. The rights will only apply in certain circumstances and are subject to certain exemptions.
- Please see the table below for a summary of your rights and who to contact to exercise them.
|Your rights||What this means||Who to contact|
|Right of access to your personal information||You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.||Write to us at:
The Data Protection Office 3400 Bath Pike, Suite 312, Bethlehem, PA 18017
|Right to rectify your personal information||You have the right to ask us to correct your personal information that we hold where it is incorrect or firstname.lastname@example.org|
|Right to erasure of your personal information||You have the right to ask that your personal information be deleted in certain circumstances. For example:
Ø where your personal information is no longer necessary for the purpose(s) it was collected or otherwise used;
Ø if you withdraw your consent and there is no other legal reason to permit us to continue to use your personal information;
Ø if you object to the use of your personal information (see below);
Ø if we have used your personal information unlawfully; or
Ø if your personal information needs to be erased to comply with a legal obligation.
|Right to restrict the use of your personal information||You have the right to suspend our use of your personal information in certain circumstances. For example:
Ø where you think your personal information is inaccurate;
Ø the use of your personal information is unlawful but you don’t want us to delete it;
Ø we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or
Ø you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.
|Right to data portability||You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible.
This right only applies:
Ø to personal information you have provided to us;
Ø where the use of your personal information is based on your consent or for the performance of a contract; and
Ø when the use of your personal information is carried out by automated (i.e. electronic) means.
|Right to object to the use of your personal information (including to object to direct marketing, automated profiling and decision making)||You have the right to object to the use of your personal information in certain circumstances. For example:
Ø where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party);
Ø if you object to the use of your personal information for direct marketing purposes; and
Ø where we use your personal information to take a decision based solely on automated processing where that decision produces a legal effect or otherwise significantly affects you.
|Write to us at:
The Data Protection Office
3400 Bath Pike, Suite 312, Bethlehem, PA 18017
|Right to withdraw consent||You have the right to withdraw your consent at any time where we rely on consent to use your personal information.||Write to us at:
The Data Protection Officer The 118 3400 Bath Pike, Suite 312, Bethlehem, PA 18017
Links to third party websites:
- The Website may contain links to other websites over which we have no control.
- We are not responsible for privacy policies or practices of other websites to which you choose to link from the Website. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.
- From time to time, we may wish with your agreement to contact you by e-mail, SMS, post or phone with information about other products or services which may be of interest to you. These communications may be from us or other members of our Group or it may be from other organisations whose products or services we think may be of interest to you. We will only transfer your personal data to third parties for marketing purposes with your express opt-in consent to do so. You may opt-out by Contacting us as set out at the end of this Policy.
- Use by Minors:
- This Website is not directed to individuals under the age of eighteen (18) and we request that these individuals do not provide personal information about themselves or others through the Website.
California Do Not Track (DNT) Act:
Conduit Global does not respond to “do not track” signals or similar mechanisms.
- Where appropriate we will give you reasonable notice of any changes.
- Contacting us:
- If you have any questions about this Policy or your personal information and/or if you wish to see what information we hold about you, please contact the Data Protection Office on email@example.com.
- If you no longer wish to receive any marketing communications or wish us to stop using your personal information, please contact us:
- By phone: 212 909 8282.
- By mail: 3400 Bath Pike, Suite 312, Bethlehem, PA 18017
- By email: firstname.lastname@example.org
- How to complain:
- We are committed to resolving any privacy concerns that you may have. If you have any concerns or complaints about the way we have handled your personal information, please contact us at: email@example.com. Should you have a complaint, we will try to resolve that complaint directly with you; however, if we are unable to resolve your dispute and you reside in the US, Conduit Global has selected the International Dispute Resolution Center as the independent recourse mechanism to resolve the dispute via arbitration. For more information on the International Dispute Resolution Center, please visit https://www.idrc.co.uk/ . Additionally, Conduit Global is subject to the jurisdiction of the U.S. Federal Trade Commission. Individuals who are unable to resolve a complaint through the aforementioned complaint process may contact the Federal Trade Commission at:
- Federal Trade Commission
- Attn: Consumer Response Center
- 600 Pennsylvania Avenue NW
- Washington, DC 20580
- mailto: firstname.lastname@example.org
Modern Slavery Statement:
INTRODUCTION FROM THE GENERAL COUNSEL
We are proud of the steps we have taken to combat slavery and human trafficking and Conduit Global is not only committed to supporting the prevention of slavery and human trafficking wherever possible, but we will also continue to take measures aimed at ensuring the same.
Conduit Global is part of the kgb family of companies with its headquarters in New York, New York. We have over 4,000 employees worldwide and operate in 6 countries.
Conduit Global is a cloud-based, fully integrated business process outsourcing (BPO) company providing multi-channel contact center, back office and professional managed services, as well as thought leadership.
OUR SUPPLY CHAINS
Although we are a service-based company, our supply chains include providers of technology, software and other infrastructure required to support our business, as well as the resources to support and maintain such infrastructure.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any aspect of our business. We are committed to acting ethically and with integrity in all of our business relationships and to implementing and enforcing effective systems and controls designed to ensure slavery and human trafficking are not taking place anywhere in out supply chains. We will develop and implement any policies and processes needed to support the same.
DUE DILIGENCE AND SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
Conduit Global does not tolerate slavery or human trafficking in any form. To ensure those in our supply chain comply with our values, we mandate and require each supplier to adhere to all relevant laws, including the Modern Slavery Act 2015.
Conduit Global also has a team dedicated to identifying and mitigating any risks across all aspects of our business, which consists of the following departments:
• Risk and Compliance
• Human Resources
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
Conduit Global will monitor the effectiveness of our efforts at combating modern slavery and human trafficking in our supply chains on a continuing basis and will take any/all necessary steps to mitigate any identified risks. To the extent needed, we will also provide training to our relevant staff to ensure they understand the risks of modern slavery and human trafficking in our supply chains and our business.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2017. Conduit Global reserves the right to update this statement from time to time in its sole discretion, so please refer back to this page for future updates.
Please identify yourself via e-mail