1. Introduction
Pingfunnel provides a lead routing, call routing, and traffic-attribution platform through a Software as a Service model (“SaaS”). At pingfunnel, the privacy and security of our customers and consumers are of the utmost importance. Pingfunnel is committed to protecting and securing the data that you share with us. This privacy policy explains how pingfunnel processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through the use of its website and platform.
For the purpose of this policy, pingfunnel defines the term “User” as an entity with which pingfunnel has an established relationship, the term “Consumer” as any individual who calls a phone number issued or routed through pingfunnel, or whose information is submitted as a lead through the platform, and the term “Visitor” as an individual that visits our front-end website, or a website on which pingfunnel tracking tags or lead forms have been placed (for example: pingfunnel.com).
Any information stored on Pingfunnel’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. Pingfunnel implements and maintains industry standard technical, security, and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft, or disclosure.
2. Collection and Use
2.1 General
The following sections cover the specifics of the three groups from which data is collected: website Visitors, Consumers, and Users.
2.2 Website Visitors
If you are a Visitor to our website only, and not a Consumer who has called a phone number routed through pingfunnel, submitted a lead through pingfunnel, or a user of our platform, then this section is relevant for you.
By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.
Pingfunnel may collect, record and analyze information of Visitors to its website. We may record your IP address and use cookies. Pingfunnel may add information collected by way of pageview activity. Furthermore, pingfunnel may collect and process any Personal Data that you volunteer to us in our website’s forms, such as when you request a demo or sign up for information and newsletters. If you provide pingfunnel with your social media details, pingfunnel may retrieve publicly available information about you from social media.
Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in pingfunnel products, and certain information about the company you are working for (company name and address), the referring site that led you to our page or a page with pingfunnel’s tracking tags placed on it, user agent string, browser type and version, device type, operating system type and version, as well as information as to the type of relationship that exists between pingfunnel and yourself. Pingfunnel may also use your IP address to extrapolate your approximate geographic location, internet service provider, and other location based data.
Pingfunnel gathers data about visits to the website, including numbers of Visitors and visits, length of time spent on the site, pages clicked on or where Visitors have come from.
2.2.1 Purpose of Processing Personal Data
Pingfunnel uses the collected data to communicate with Visitors, to customize content for Visitors, to show ads on other websites to Visitors, and to improve its website and third-party websites that use pingfunnel tracking tags by analyzing how Visitors navigate its website.
2.2.2 Sharing Personal Data
Pingfunnel may also share such information with service vendors, clients, or contractors in order to provide a requested service or transaction or in order to analyze the Visitor behavior on its website.
2.2.3 Cookies
Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. The use of cookies is widespread and benefits the surfer.
2.2.4 Links to Other Sites
Please be aware that while visiting our site, Visitors can follow links to other sites that are beyond our sphere of influence. Pingfunnel is not responsible for the content or privacy policy of these other sites.
2.3 Consumers
Consumers should be aware that in calling phone numbers routed through pingfunnel, or in submitting their information as a lead through pingfunnel, they could be disclosing information that could make them personally identifiable to pingfunnel Users. The security and privacy protection implemented on pingfunnel’s platform does not cover this type of transfer or disclosure of personal information. Consumers calling a phone number that may be routed through pingfunnel and licensed to a pingfunnel User should be aware that they are making themselves personally identifiable by their phone number’s ‘Caller ID’ and that they are solely responsible for their actions while on the phone with whatever party they requested to speak with. For more detailed information concerning the protection of privacy when calling a number routed through pingfunnel, a Consumer may contact the entity they requested to speak with. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law.
2.3.1 Inquiries
If you wish to inquire about your Personal Data that may have been collected in a phone call or lead submission through pingfunnel, we recommend that you contact the entity that you called, spoke with, or submitted your information to. As pingfunnel is a Processor in this regard, it does not control the Personal Data used or stored from the call or lead, but processes it on behalf of its User.
2.4 Users
If you are a User of our platform only, and not just a Visitor, then this section is relevant for you.
2.4.1 General
In order to provide services to its Users, pingfunnel collects certain types of data from them. Furthermore, pingfunnel’s Users collect information from Consumers when they call a number routed through pingfunnel or submit a lead through a pingfunnel User’s campaign. This section will describe how these two types of data are collected and used by pingfunnel, as well as geographical differences that affect this policy. Data entered or transferred into pingfunnel by Users — such as campaign names, source and publisher names, destination and buyer names, workspace and sub-account information, etc. — remains the property of the User and may not be shared with a third party by pingfunnel without express consent from the User.
2.4.2 Collection of User Data
During a User’s registration and later on pingfunnel’s platform, they provide information such as name, company name, email, address, telephone, billing details, and other relevant data. Payment card details are collected and processed by our payment provider (Stripe) and are not stored in full by pingfunnel. This information is used by pingfunnel to identify the User and provide them with support, services, mailings, sales and marketing actions, billing, and to meet contractual obligations.
Pingfunnel Users can at any time access and edit, update, or delete their contact details by logging in to pingfunnel’s platform. Pingfunnel Users may create more Users with different privilege levels within their workspace or organization. It is the responsibility of the User that creates other User accounts to choose the level of access each User should have. Once these new Users log into pingfunnel, they meet the definition of User in this policy. Pingfunnel will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
2.4.3 Collection of Consumer Data
Users may issue or route phone numbers to be used on their behalf, or make them available to relevant businesses, organizations, and individuals, and may collect leads through forms and integrations. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. Pingfunnel will not process Personal Data for other purposes or by other means than instructed by its Users.
Consumer data includes data from individuals who called a phone number routed through pingfunnel, individuals who submitted a lead through pingfunnel, ‘Caller ID’ numbers from Consumers who may have called, lead form field values, and meta-data collected by pingfunnel tracking tags in some cases. Personal Data may include personal contact information such as IP address, geographic location information such as country, region, city, state, postal code, latitude, and longitude, internet service provider data, referring URLs, browser header data, user-agent strings, device type, browser type, operating system type, phone provider carrier data, and other sensitive Personal Data. Consumers may also disclose personal data inside of a call recording, should a User instruct pingfunnel to record a call. Call recordings are the property of pingfunnel Users and, should you have questions about the contents of a call recording, please contact the party you called.
The purpose of collecting Personal Data as part of a phone call or lead submission will vary depending on the User, as set up by pingfunnel’s Users. As pingfunnel provides routing and numbers to a wide group of customers and businesses, the purpose may vary greatly. For Users in the EEA or the UK, or for Users routing phone numbers or leads concerning individuals in the EEA or the UK, the User will be the “controller” as defined under the GDPR and the UK GDPR. The purpose will consequently be defined by pingfunnel’s User.
If you or your organization are required under the European Union’s General Data Protection Regulation (GDPR) or the UK GDPR to enter into a contract, or other binding legal act, with your data processors, please review and accept pingfunnel’s Data Processing Agreement, available on request from compliance@pingfunnel.com.
2.4.4 Geographical Location
Pingfunnel currently processes all User and Consumer Personal Data in the United States. Personal Data is maintained by pingfunnel and by third-party service providers that act as pingfunnel’s data processors. Where Personal Data relating to individuals in the EEA or the UK is processed in the United States, such transfers are made under appropriate safeguards, including the European Commission’s and the UK’s Standard Contractual Clauses, as described below.
2.4.4.1 Processing for Users and Consumers in the EEA and UK
For Users and Consumers located in the EEA or the UK, all processing of Personal Data is performed in accordance with the privacy rights and regulations of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”), the UK GDPR, and applicable local legislation.
2.4.4.1.1 Controller and Processor
Pingfunnel processes Personal Data both as a Processor and as a Controller, as defined in the GDPR and the UK GDPR:
- The pingfunnel entity with which you, as a User, entered into an agreement when using pingfunnel’s platform will be the Controller for User data, as outlined above in the “Collection of User Data” section.
- For Consumer data, as outlined in the “Collection of Consumer Data” section, the User will be the Controller, and pingfunnel will be the Processor.
Pingfunnel processes Personal Data in accordance with the GDPR and the UK GDPR. Transfers of Personal Data relating to individuals in the EEA or the UK to the United States are governed by a data processing agreement and Standard Contractual Clauses with our sub-processors, ensuring an adequate level of protection.
2.4.4.2 Processing in the United States
Pingfunnel processes data in data centers located in the United States. Pingfunnel has adopted reasonable physical, technical, and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use, or processing of the User’s data in pingfunnel’s possession. Pingfunnel will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.
Data collected by pingfunnel Users is stored and processed in secure hosting and service facilities provided by our sub-processors, which include Amazon Web Services and Supabase (database, authentication, and file storage), Fly.io (application runtime), Telnyx and Twilio (telephony, messaging, and call routing), and Stripe (billing and payments). Pingfunnel’s contracts with these providers ensure that all hosting and processing is performed in accordance with applicable security regulations. Pingfunnel’s policy is to protect and safeguard any personal information obtained by pingfunnel in accordance with United States state and federal laws governing the protection of personal information and data. Accordingly, pingfunnel adheres to practices and policies that aim to safeguard the data. A current list of sub-processors is available on request from compliance@pingfunnel.com.
3. Retention and Deletion
Pingfunnel will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Consumer data, pingfunnel’s Users have control of the purpose for collecting data and the duration for which the Personal Data may be kept. For Consumer data, Users with an active account will therefore have the responsibility to delete data when required. When a User’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.
4. Acceptance of these Conditions
We assume that all Visitors of our website, Consumers who call phone numbers routed through pingfunnel or submit leads through pingfunnel, and Users of pingfunnel’s platform have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our website and platform. We reserve the right to change our privacy policy as necessity dictates. Continued use of pingfunnel’s website and platform after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy. This privacy policy is an integral part of pingfunnel’s terms of use.
5. Our Legal Obligation to Disclose Personal Information
We will reveal a User’s personal information without their prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact, or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to pingfunnel or to others who could be harmed by the User’s activities, or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have a good reason to believe that this is legally required.
6. Contact
If you have any further questions regarding the data pingfunnel collects or how we use it, please feel free to contact us by email at: compliance@pingfunnel.com.