Privacy policy for the use of the Swyx Service Portal

I. INFORMATION ON THE COLLECTION OF PERSONAL DATA BY THE WEBSITE OF THE SWYX SERVICE PORTAL

In the following we inform you about the collection of personal data when using the website of the Swyx Help Center, the Swyx Community or the web-based Swyx Service Portal. Personal data is all data that can be related to you personally, e.g. name, address, e-mail addresses, user behaviour.

The person responsible for the website and the web-based Swyx Service Portal in accordance with Art. 4 Para. 7 of the EU Data Protection Basic Regulation (DS-GVO) is Swyx Solutions GmbH, Emil-Figge-Str. 86, 44227 Dortmund, Germany, office@swyx.com (see also our imprint). You can reach our data protection officer at datenschutz@swyx.com or our postal address with the addition "the data protection officer".

When you contact us e.g. by e-mail or via a contact form or by logging in, the data you provide (your e-mail address, your name if applicable and your telephone number) will be stored by us in order to answer your questions. We delete the data arising in this connection after the storage is no longer necessary, or restrict the processing if there are legal storage obligations.

1. YOUR RIGHTS
You have the following rights against us with regard to your personal data:

• Right to information,
• Right to rectification or deletion,
• Right to limit the processing,
• Right to object to the processing,
• Right to data transferability.

You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us.

2. COLLECTION OF PERSONAL DATA WHEN YOU VISIT THE WEBSITE OF THE SWYX HELP CENTER
If you only use the Swyx Service Portal (https://support.swyx.net) website for information purposes, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data which is technically necessary for us to display our website to you and to guarantee stability and security (legal basis is Art. 6 Para. 1 S. 1 lit. f DS-GVO):

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Contents of the request (concrete page)
• Access status/HTTP status code
• amount of data transferred in each case
• Web page from which the request comes
• browser
• Operating system and its interface
• Language and version of the browser software.

In addition to the above data, cookies are stored on your computer when you use our Swyx Service Portal website. Cookies are small text files that are stored on your hard drive assigned to the browser you are using and through which certain information flows to the location that sets the cookie (here by us). Cookies cannot execute programs or transmit viruses to your computer. They serve to make the website more user-friendly and effective.

Use of cookies: This website uses the following types of cookies, the scope and function of which are explained below:

• Transient Cookies
• Persistent Cookies

Transient cookies are automatically deleted when you close your browser. These include in particular session cookies. They store a so-called session ID, which can be used to assign various requests from your browser to the shared session. This enables your computer to be recognised when you return to our website. The session cookies are deleted when you log out or close your browser.

Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in the security settings of your browser.

You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. We would like to point out that you may not be able to use all the functions of this website.

We use cookies to identify you for subsequent visits, for example if you have an account with us. Otherwise, you would have to log in again for each visit.

The Flash cookies used are not captured by your browser, but by your Flash plug-in. We also use HTML5 Storage Objects, which are stored on your end device. These objects store the required data regardless of the browser you are using and do not have an automatic expiration date. If you do not wish the Flash cookies to be processed, you must install an appropriate add-on for your browser. You can prevent the use of HTML5 Storage Objects by using private mode in your browser. We also recommend that you regularly delete your cookies and browser history manually.

3. OTHER FUNCTIONS AND OFFERS ON OUR WEBSITE
In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you must usually provide further personal data which we use to provide the respective service and to which the aforementioned data processing principles apply.

To some extent, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are checked regularly.

4. OBJECTION OR REVOCATION TO THE PROCESSING OF YOUR DATA
If you have given your consent to the processing of your data, you can revoke it at any time. Such a revocation influences the permissibility of the processing of your personal data after you have given it to us.

If we base the processing of your personal data on a weighing of interests, you may object to the processing. This is the case if the processing is in particular not necessary for the fulfilment of a contract with you. In the event of such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and either discontinue or adapt the data processing or point out our compelling reasons worthy of protection on the basis of which we will continue the processing.

5. USE OF GOOGLE ANALYTICS
This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. However, if IP anonymisation is activated on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA where it will be shortened. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage to the website operator.
The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and Google from processing this data by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
This website uses Google Analytics with the extension "_anonymizeIp()". This shortens the processing of IP addresses, thus excluding the possibility of personal references. If the data collected about you is related to a person, this is excluded immediately and the personal data is deleted immediately.
We use Google Analytics to analyse and regularly improve the use of our website. The statistics obtained allow us to improve our services and make them more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 Para. 1 S. 1 lit. f DS-GVO.
Third-party information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of use: https://www.google.com/analytics/terms/us.html, privacy policy overview: www.google.com/intl/de/analytics/learn/privacy.html, and privacy policy: https://policies.google.com/privacy

6. USE OF GOOGLE WEB FONTS
On the website of the Swyx ServicePortal we use external fonts, so-called Google Fonts, which are provided by Google, for the purpose of uniform display of fonts on your device. Google Fonts is a service provided by Google Inc. ("Google"), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When you access a page, your browser loads the web fonts you need into its browser cache to display text and fonts correctly. If your browser does not support web fonts, a standard font will be used by your computer.
The Web Fonts are integrated via an interface ("API") to the Google services. By integrating the web fonts, Google may collect information (including personal data) and process it in the United States. Google has submitted to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.
We do not collect any data ourselves in the context of the provision of Google Fonts.
The legal basis for the processing of personal data described here is Art. 6 para. 1 lit. f) DSGVO. Our justified interest, which is necessary for this, lies in the great benefit that a uniform representation of the fonts offers. By the possibility of a uniform representation we keep the organization expenditure smaller, than if we would have to react to font standards of different operating systems and/or Browser with own graphically adapted web pages. Google also has a legitimate interest in the (personal) data collected in order to improve its own services.
The provision of personal data is neither required by law nor by contract and is not necessary for the conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so may, however, result in your not being able to use the Partner Portal website or not being able to use it to its full extent and in a change in the presentation of the website.
You can set your browser so that the fonts are not loaded by the Google servers. If your browser does not support Google Fonts or if you block access to the Google servers, the text will be 
For more information, see :

displayed in the default font of the system.

• www.google.com/fonts
• developers.google.com/terms/
• policies.google.com/privacy

7. USING THE ZENDESK CHAT ON THE WEBSITE OF THE SWYX SERVICE PORTAL
This website uses Zendesk Chat, a live chat software provided by Zendesk Inc., 1019 Market St, San Francisco, CA 94103, USA.
Zendesk Chat tells the user if one of our employees is online to get an immediate answer to questions related to the Swyx Service Portals. You can cancel the communication at any time. It is up to you to decide what information you disclose about yourself during the chat. It is possible to enter your contact details such as name, telephone number and e-mail address to facilitate contact. Otherwise, only the IP address will be transmitted and stored.
During the chat, you communicate via an encrypted Internet connection. This prevents unauthorized third parties from accessing the contents of the chat.
Zendesk Chat uses cookies during the chat. The information generated by the cookie about the use of our website (including your anonymous IP address) is transmitted to a Zendesk Chat server in the USA and stored there. The information is only visible for the moment of the stay on a certain page and is not stored. Chats that have been carried out are logged and stored. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the website.
Further information on data processing by Zendesk can be found in Zendesk's privacy policy. You can reach Zendesk's data protection officer at: privacy@zendesk.com
By using this website, you consent to the processing of data about you by Zendesk Chat in the manner and for the purposes set out above.

8. USE OF OUR FORUM
The forum made available on the website can be read without having to register. If you wish to participate actively in the forum, you must register by entering your e-mail address, a password of your choice and your user name. There is no obligation to use a clear name, a pseudonymous use is possible. We use the so-called double opt-in procedure for registration, i.e. your registration is only complete after you have confirmed your registration by clicking on the link in a confirmation e-mail sent to you for this purpose. If your confirmation is not received within [24 hours], your registration will automatically be deleted from our database.
If you register a forum account, we will save all information you provide in the forum, such as public posts, pinboard entries, friendships, private messages, etc., until you unsubscribe in order to operate the forum. The legal basis is Art. 6 Para. 1 S. 1 lit. f DS-GVO.
If you delete your account, your public statements, in particular contributions to the forum, remain visible for all readers, but your account is no longer retrievable and marked in the forum with "guest". All other data will be deleted. If you also wish your public contributions to be deleted, please contact the person responsible using the contact data given above.

II. FUNCTIONS OF THE SWYX SERVICE PORTAL
In addition to the purely informative use, the website offers various support services within the framework of the Swyx Service Portal after successful login. In order to do this, you will usually need to provide other personal data that we use and need to provide the service and to which the above data processing principles apply.

1. INFORMATION ON THE COLLECTION AND PROCESSING OF PERSONAL DATA THROUGH THE USE OF THE SWYX SERVICE PORTAL

a.) Users of the Swyx Service Portal
The Swyx Service Portal is primarily available to Swyx contract partners and, in individual cases, to customers of our contract partners.

b.) Use of the Swyx Service Portal
(1) If you wish to use our Swyx Service Portal for extended services after concluding a corresponding contract, you must follow the link you will receive by e-mail and enter a password for the user created by the system for you. You will then be successfully verified.
(2) If you use our Swyx Service Portal, we will store your necessary data such as the login data until the final deletion. We also store the voluntary data you have provided and which you send to the portal as part of your support request for the time it takes to process your support request. The legal basis is Art. 6 Para. 1 S. 1 lit. f DS-GVO.
(3) In order to prevent unauthorised access to your personal data by third parties, the connection is encrypted using SSL.

c.) Collection and storage of personal data as well as type and purpose of their use

(1) When you use the Swyx Service Portal, we collect the following personal data:

• Contact information such as name, email address and/or telephone number
• login data
• Any other information necessary to process your support request, e.g. the partner/reseller from whom you purchased your Swyx product
• traffic data
• Any other personal data provided by the partners or users in the context of the request for assistance.

(2) We process these personal data in particular on the basis of:

• Art. 6 para. 1 lit. a) on the basis of your consent, whereby no consent is required for the conclusion of a contract or the continuation of an existing contract.
• Art. 6 para. 1 lit. b) for the establishment, performance and termination of a contractual relationship,
• Article 6(1)(c) to fulfil a legal obligation,
• Article 6(1)(f) to safeguard a legitimate interest.

(3) This data is collected for the following purposes:

• for the execution of the contract
• to the correspondence
• Customer service, in particular the provision of support services, by us or, if applicable, after passing on your request to the partner/reseller from whom you purchased your Swyx product, by this partner/reseller.
• Quality Management

(4) The legitimate interest of Swyx is also in:

• the safeguarding of our business interests
• Ensuring compliance with safety regulations, requirements, industry standards and contractual obligations,
• the assertion, exercise or defence of legal claims,
• the prevention of injury and/or liability of the company through appropriate measures.

d.) Deletion of data
The traffic data collected for these purposes will be automatically deleted after seven days if your request for assistance has been dealt with. If your support request requires further processing, the traffic data will still have to be stored. It will be deleted as soon as your support request has been completed. All other personal data will be deleted from the Swyx Service Portal after the storage is no longer required, unless Swyx is obliged to store the data for a longer period due to legal storage obligations or you have consented to storage in accordance with Art. 6 para. 1 sentence 1 lit. a DSGVO.

e.) Disclosure of data to third parties
For the purposes stated above, we transfer personal data to third parties with whom we cooperate on the basis of processing contracts. The third party may only use the transferred data for the stated purposes. If the registered office of a third party is outside the European Union or the European Economic Area, the data will be transferred to a third country. A transfer to a third country will only take place if an adequate level of data protection is guaranteed or one of the exceptions of Art. 49 DS-GVO exists. An adequate level of data protection can be guaranteed by contractually agreeing with the third parties on a data protection agreement in accordance with the legal requirements in order to establish an adequate level of data protection and by agreeing on corresponding guarantees.