Privacy Policy

Privacy Policy (version 131020262)

1. About this policy

This policy explains how Netcall collects, uses, shares, retains and protects personal data when you visit a Netcall website, communicate with us, receive business-to-business marketing, attend an event or demonstration, discuss a potential commercial relationship, or enter into or participate in the performance of a contract for Netcall solutions, goods or services.

Our websites are principally intended to promote and sell Netcall solutions, generate and respond to business enquiries, develop commercial relationships, and enable relevant Netcall group companies to enter into and perform contracts for the supply of goods and services to organisations.

In summary, Netcall uses business contact information to respond to enquiries, understand organisational requirements, develop sales opportunities, manage customer and partner relationships, provide solutions and services, and send relevant business communications. We may share information with authorised Netcall group companies and trusted service providers. You may object to direct marketing at any time by using unsubscribe options in emails or by contacting gdpr@netcall.com.

This policy concerns processing undertaken by a Netcall company as a controller. Where a Netcall company processes personal data for a customer as a processor, the customer determines the purposes and lawful basis of that processing and the applicable customer agreement, data processing terms and customer privacy information apply.

2. Who is responsible for your personal data

The principal Netcall group companies covered by this policy are:

  1. Netcall plc, company number 01812912, ICO registration ZC255046, of Suite 203, Bedford Heights, Brickhill Drive, Bedford, Bedfordshire MK41 7PH, United Kingdom.
  2. Netcall Technology Limited, company number 02831215, ICO registration Z8240037, of Suite 203, Bedford Heights, Brickhill Drive, Bedford, Bedfordshire MK41 7PH, United Kingdom.
  3. Netcall Systems Limited, company number 07157946, ICO registration ZB393921, of Suite 203, Bedford Heights, Brickhill Drive, Bedford, Bedfordshire MK41 7PH, United Kingdom.

The relevant company is the controller where that company determines why and how personal data is processed. The identity of the relevant controller may depend on the website, form, product, contract, employing entity, event, campaign or commercial relationship concerned. Where appropriate, a form, contract or other first-layer notice will identify the relevant controller.

Netcall group companies will normally act as independent controllers when they receive and use information for their own compatible enquiry-management, CRM administration, sales follow-up, marketing, customer-management, management or reporting purposes. A group company will act as another company’s processor only where it processes personal data solely on documented instructions. Where two or more group companies jointly determine the purposes and essential means of a particular activity, they may act as joint controllers and will allocate their respective responsibilities in accordance with applicable data protection law.

References to “Netcall”, “we”, “us” or “our” mean the Netcall company or companies responsible for the relevant processing.

You may contact the Data Protection Officer at gdpr@netcall.com, or by post to: Data Protection Officer, Netcall, Suite 203, Bedford Heights, Brickhill Drive, Bedford, Bedfordshire MK41 7PH, United Kingdom.

2.1 European Union representative

Where the EU GDPR applies to processing by a Netcall company that is not established in the European Union, Netcall has appointed the following representative in the European Union for the purposes of Article 27 of the EU GDPR:

Netcall Europe 
Havenlaan 86C, Box 204 
1000 Brussels 
Belgium

Individuals in the European Union may contact the representative about matters relating to the processing of their personal data. The appointment of the representative does not affect the right to contact the relevant Netcall controller or the Data Protection Officer at gdpr@netcall.com.

Applicable data protection law

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see the information on the use of cookies.

4. Personal data we collect

4.1 Business contact and professional information

  1. Name, job title, employer, department and professional responsibilities.
  2. Business address, email address and telephone number.
  3. Professional profile information, industry, areas of interest and publicly available business information.
  4. Records of your relationship, preferences and communications with Netcall.

4.2 Sales and commercial information

  1. Enquiries, product interests, meeting notes, demonstrations, events and proof-of-concept activity.
  2. Account, contact and opportunity information held in CRM and related systems.
  3. Proposals, quotations, contract negotiations, orders, licences, subscriptions, billing and account-management records.
  4. Information about your employer’s requirements, procurement process and relationship with Netcall.

4.3 Website and technical information

  1. IP address, browser, device, operating system, approximate location, and referral source.
  2. Pages viewed, links selected, dates, times, duration, form submissions, and campaign attribution.
  3. Cookie choices and information collected through permitted analytics, and similar technologies.

4.4 Communications

  1. Emails, calendar entries, messages, correspondence, and records of meetings.
  2. Telephone numbers, call details, and call recordings where recording is notified and lawful.

4.5 Information obtained from third parties

We may obtain business contact information from data and marketing providers, public registers, professional networking services, corporate websites, event organisers, partners, referrals and other lawful public or commercial sources. We may also appoint third parties to identify and contact relevant business people on our behalf, or to contact business records provided by Netcall.

Where personal data is obtained indirectly, we provide the information required by applicable law within the relevant period unless an exemption applies. This will normally be within one month, at the time of our first communication with the individual, or before the personal data is first disclosed to another recipient, whichever applies first.

4.6 Information you are required to provide

Where we ask for personal data, we will indicate if it is required by law, required to establish or administer a commercial arrangement, or optional. If required information is not provided, we may be unable to respond fully to an enquiry, arrange a demonstration, prepare a proposal, establish or administer an account, enter into or perform a contract, provide support, process a payment or meet a relevant legal obligation.

5. Why we use personal data

  1. Operate, secure, administer, and improve our websites.
  2. Respond to enquiries and provide requested information.
  3. Understand an organisation’s requirements and identify relevant Netcall solutions.
  4. Records of your relationship, preferences and communications with Netcall.
  5. Identify and develop prospective customers, partners, and commercial opportunities.
  6. Record and manage contacts, accounts, activities and opportunities in CRM, email, collaboration, and sales-management systems.
  7. Send relevant business-to-business marketing about Netcall solutions, services, events, and content.
  8. Measure and improve website and marketing effectiveness, subject to applicable cookie and e-privacy rules.
  9. Prepare proposals, quotations, procurement responses, and contractual documents.
  10. Negotiate, enter into, administer, and perform contracts for goods and services.
  11. Manage customers, partners, suppliers, licences, subscriptions, payments, support, and account relationships.
  12. Develop and improve products, services, and commercial operations.
  13. Protect our systems, personnel, customers, assets and legal rights, prevent misuse and establish, exercise or defend legal claims.
  14. Meet legal, regulatory, tax, accounting, governance, and reporting obligations.

Information submitted through Netcall forms or obtained through sales and marketing activity may be recorded in a shared CRM system and made available to authorised personnel within relevant Netcall group companies for the purposes described in this policy.

6. Our lawful bases

6.1 Legitimate interests for business-to-business sales and marketing

Netcall sells principally to organisations rather than to the individual business contacts whose data we process. Accordingly, our normal lawful basis for processing the personal data of customer and prospect employees throughout the business-to-business sales lifecycle is legitimate interests, rather than contractual necessity. This includes identifying relevant contacts, responding to and developing organisational enquiries, maintaining CRM records, communicating by business email or telephone, arranging demonstrations, preparing organisational proposals, pursuing opportunities and managing the commercial relationship with a contact’s employer.

Our legitimate interests include promoting and selling Netcall solutions and services; developing customer and prospect relationships; identifying people with relevant business responsibilities; understanding organisational requirements; maintaining accurate CRM and account records; managing opportunities; measuring and improving our websites and marketing; sharing relevant business information within the Netcall group; and protecting and improving the group’s business. We apply a purpose, necessity and balancing assessment and maintain legitimate interests assessments where appropriate.

6.2 Contract and pre-contractual steps

Where an individual is personally a party to a contract with Netcall, or asks Netcall to take steps before entering into such a contract, we may process personal data where necessary to perform the contract or take those pre-contractual steps.

6.3 Legal obligation

We process personal data where necessary to meet legal and regulatory obligations, including tax, accounting, corporate governance, sanctions, fraud prevention, litigation, regulatory enquiries, data protection and information security requirements.

6.4 Consent

We rely on consent where applicable law requires it, including for certain electronic marketing, non-essential cookies and similar technologies, and other processing for which consent is appropriate. Consent may be withdrawn at any time without affecting processing already undertaken lawfully.

6.5 Electronic communications

A lawful basis under the UK GDPR or EU GDPR does not replace separate requirements under PECR or applicable European e-privacy law. We obtain consent where those rules require it and rely on an available business-to-business rule or statutory exception where permitted. Marketing messages include a clear way to unsubscribe or change preferences.

Cookies, web analytics and Adobe Marketo Engage

Our websites use cookies and similar technologies to operate and secure the site, remember choices, understand use, measure website and campaign performance, attribute enquiries and improve content and communications.

Netcall also uses Adobe Marketo Engage, a marketing automation platform supplied by Adobe, to manage business enquiries, marketing campaigns, website forms, email communications and related engagement information. Where permitted by your cookie choices and applicable law, Adobe Marketo Engage may associate website activity, form submissions and engagement with Netcall emails with a business contact record.

Strictly necessary cookies may be used without consent where permitted. Where applicable law requires consent for analytics, advertising or other non-essential technologies, those technologies will not be activated until valid consent has been obtained. You can manage or withdraw your choices through the cookie settings on our websites. Where information collected through a permitted technology constitutes personal data, we process it under the lawful basis identified for the relevant purpose.

Information held in Adobe Marketo Engage may be used to understand an organisation’s interests, segment relevant business audiences, measure website and campaign effectiveness, notify appropriate sales personnel, assign an enquiry or contact record, manage event and content requests, select relevant business communications, and operate related sales and marketing workflows. Netcall does not use these processes to make solely automated decisions producing legal or similarly significant effects about individuals.

Full details are provided in our Cookie Policy.

We use information held about you in the following ways:

8. Marketing and your right to object

We may send business contacts information about Netcall solutions, services, events and content that we reasonably consider relevant to their professional role or organisation. We seek to keep communications proportionate and relevant, record appropriate source information, maintain preferences and suppression records, and promptly action objections and unsubscribe requests.

You have an absolute right to object at any time to processing for direct marketing. If you object, we will stop using your personal data for that purpose. You can use the link in a marketing email, our preference centre or unsubscribe page, or contact gdpr@netcall.com. We may retain limited information on a suppression list so that we continue to respect your request.

9. Sharing within the Netcall group

A relevant Netcall controller may share business contact, website, marketing, sales and commercial data with Netcall plc and other relevant Netcall group companies involved in enquiry management, CRM administration, sales follow-up, marketing, customer management, service delivery, management or reporting. Access is limited according to role and business need.

10. Sharing with service providers, partners and other third parties

We may share personal data with trusted providers of CRM, business email, marketing automation, analytics, website hosting, events, prospect data, lead generation, communications, security, professional advice, finance and other business services. These include providers supporting our CRM systems and Adobe Marketo Engage. Adobe and its relevant affiliates and subprocessors may process personal data to provide, host, support, secure and maintain Adobe Marketo Engage. Depending on our service configuration and contractual arrangements, personal data may be processed in the United States and other countries in which Adobe or its approved subprocessors operates.

Third-party marketing providers may identify relevant business contacts, verify or supplement business information, contact businesses on Netcall’s behalf, contact business records supplied by Netcall, or support events and campaigns. Where necessary for a relevant opportunity, implementation or service arrangement, we may share appropriate business contact and commercial information with an authorised reseller, referral partner, implementation partner, technology provider or professional adviser. We limit the information to what is reasonably necessary and identify the partner where required by applicable law. 

Processors may use personal data only on our documented instructions and under contractual confidentiality, security, retention, deletion, rights and transfer requirements. Separate controllers are responsible for their own lawful basis and privacy information. We do not sell personal data or provide it to unrelated third parties for their own independent marketing unless we have clearly explained this and have an appropriate lawful basis. 

We may engage Prospect Global Ltd, trading as Sopro, and similar providers to support business-to-business prospecting, contact identification, outreach and lead generation. Depending on the service, a provider may process personal data on Netcall’s documented instructions or act as an independent controller for specified activities. Information about Sopro’s handling of personal data is available here.

11. International transfers, including the United States 

Netcall uses service providers operating in several territories. Personal data may therefore be accessed from, stored in or transferred to countries outside the United Kingdom or European Economic Area, including the United States. This may include processing undertaken by Adobe and its relevant affiliates and subprocessors in connection with Adobe Marketo Engage. 

We select the safeguard applicable to the exporting controller, destination, recipient and transfer. For a UK restricted transfer to an eligible US recipient, Netcall may rely on the UK Extension to the EU-US Data Privacy Framework after verifying the recipient’s active certification and the categories of personal data covered. Where UK adequacy regulations do not apply, Netcall may use an appropriate safeguard such as the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses. For transfers governed by the EU GDPR, Netcall may rely on an applicable European Commission adequacy decision, the EU-US Data Privacy Framework for an eligible certified recipient, or European Commission Standard Contractual Clauses, as appropriate.

Where required, we carry out a transfer risk assessment or data protection test and use supplementary technical, contractual or organisational controls. Contact GDPR for information about safeguards relevant to a particular transfer. 

12. Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, alteration, disclosure or access. Measures may include access controls, multi-factor authentication, encryption, monitoring, vulnerability management, data-loss prevention, supplier due diligence, confidentiality obligations, incident response, and business-continuity arrangements. 

12. Security

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and to meet legal, regulatory, accounting, contractual and reporting requirements. Netcall maintains an internal retention schedule setting normal periods, review points and deletion or anonymisation actions for relevant record categories. We consider the purpose, relationship and sales cycle, nature and sensitivity of the data, accuracy, legal requirements, limitation periods, risk and whether anonymised information can meet the purpose.

  1. Website enquiries and prospect information are retained while the enquiry or opportunity remains active and then reviewed in accordance with Netcall’s retention schedule. They are deleted, anonymised or restricted when no longer required, unless there is a documented reason to retain them for longer.
  2. Sales and marketing records are reviewed periodically and retained only while relevant to an existing or prospective organisational relationship. They are deleted, anonymised or restricted when no longer necessary. An objection or unsubscribe request is actioned promptly, although limited suppression information may be retained to ensure the request continues to be respected.
  3. Customer, supplier, partner, procurement and contractual records are retained for the duration of the relationship and normally for up to seven years afterwards where required for contractual, tax, accounting, audit or legal purposes. 
  4. Event and demonstration records are reviewed and retained for the period specified in Netcall’s retention schedule while relevant to the associated request, relationship or business purpose.
  5. Call recordings are retained for the period notified when recording takes place or specified in the applicable retention schedule. 
  6. Security, incident and access records are retained for the periods specified in Netcall’s retention schedule, subject to any longer period required for an investigation, legal claim or regulatory obligation.
  7. Suppression information may be retained for as long as reasonably necessary to respect an objection or unsubscribe request. 

We periodically review retained information and delete, securely dispose of or anonymise personal data when it is no longer required. 

Your rights

Depending on applicable law, you may have rights to be informed; obtain access; correct inaccurate data; request deletion or restriction; object to processing based on legitimate interests; object to direct marketing; request portability of certain data; withdraw consent; and obtain information about international transfer safeguards. Rights may be subject to statutory conditions and exemptions. To exercise a right, contact gdpr@netcall.com. We may ask for information needed to verify identity and protect personal data from unauthorised disclosure. 

15. Complaints 

Please contact Netcall’s Data Protection Officer at gdpr@netcall.com if you have a concern about how Netcall has collected or used your personal data.

Netcall maintains a process for handling data protection complaints. We will acknowledge receipt within 30 days, take appropriate steps to investigate and respond without undue delay, keep you informed, and communicate the outcome without undue delay. If you remain dissatisfied after Netcall has considered your complaint, you may ask the Information Commissioner’s Office to consider the matter.

Where the EU GDPR applies, you may also have the right to lodge a complaint with the competent supervisory authority in the European Union member state where you live or work, or where you believe an infringement has occurred. 

Information Commissioner’s Office 
Wycliffe House 
Water Lane 
Wilmslow 
Cheshire SK9 5AF 
United Kingdom 
Telephone: 0303 123 1113 
Website: https://ico.org.uk 

Children

Our websites and business-to-business sales and marketing activities are not directed at children, and we do not knowingly seek to collect children’s personal data through those activities. Please contact gdpr@netcall.com if you believe such data has been supplied to us. 

17. Third-party websites 

Our websites may link to sites operated by partners, customers, suppliers or other third parties. Those sites have their own privacy practices, for which Netcall is not responsible. You should review their privacy information before providing personal data. 

Changes to this policy 

We may update this policy to reflect changes in the Netcall group, processing activities, systems, suppliers, services, security arrangements, applicable law or regulatory guidance. The current version will be published on our website with its latest update date. Where a change materially affects individuals or introduces a new use of personal data, we will take reasonable steps to bring it to their attention before the new processing begins. Relevant collection points may also provide a short first-layer notice linking to this policy and our Cookie Policy. 

19. Contact 

Data Protection Officer
Netcall
Suite 203, Bedford Heights
Brickhill Drive
Bedford
Bedfordshire MK41 7PH
United Kingdom

Email: gdpr@netcall.com
Telephone: 0330 333 6100
Website: https://www.netcall.com

European Union Representative
Netcall Europe
Havenlaan 86C, Box 204
1000 Brussels
Belgium