Global Privacy Statement
Effective January 24, 2022
This Privacy Statement applies to TeleVox Corporation and its affiliates (“TeleVox” “we” “us” “our”) unless the affiliate has a separately posted privacy statement. TeleVox values the privacy of our customers, users, and any individual who accesses or uses the TeleVox websites, products, and services (collectively, the “Services”). Your privacy is an important factor TeleVox considers in the development of each of our products and services. This Privacy Statement explains generally how we receive Personal Information about you, and what we do with that Personal Information once we have it.
As TeleVox is a global provider, the provision of the Services to users may require Personal Information to be shared with other TeleVox companies around the world. All TeleVox companies are bound by privacy statements, confidentiality and data transfer agreements as appropriate.
- What do we mean by “Personal Information”?
- What type of Personal Information is collected?
- How do we receive Personal Information about you?
- What do we do with your Personal Information once we have it?
- How long will we retain Personal Information?
- When do we share your Personal Information with others?
- How do we protect your Personal Information?
- How can you protect your Personal Information?
- How do you handle Information subject to the California Consumer Privacy Act?
- How do you keep my healthcare information private?
- What about cookies and other tracking technology?
- How do you handle my “Do Not Track” browser settings?
- Does TeleVox use any other tracking technology?
- How does TeleVox ensure compliance with legal obligations?
- How do you handle my Personal Information as part of the Media Database – GlobeNewswire and Notified products and services?
- Data Analytics
- What choices do you have regarding your Personal Information?
- What if we change this Privacy Statement?
- How to Contact Us?
What do we mean by “Personal Information”?
For us, “Personal Information” means information or data that relates to an identified or identifiable individual. “Sensitive Personal Information” is a subset of Personal Information and is data about children, financial information, health information (including PHI as defined by the Health Insurance Portability and Accountability Act), Social Security or other national identification number, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life, criminal convictions, and precise geolocation data.
We also want you to be aware certain information related to your account may be Customer Proprietary Network Information (“CPNI”). CPNI is information we obtain solely by providing telecommunications services or interconnected Voice over Internet Protocol (VoIP) services to you. It includes the type, technical arrangement, quantity, destination, location, and amount of services you purchased and related billing information. CPNI does not include your telephone number, name and address, or aggregate customer information or data not specific to you. The protection of your information is important to us, and you have a right, and we have a duty, under U.S federal law, to protect the confidentiality of your CPNI. We may use or disclose CPNI without your consent to (a) initiate, render, repair, maintain, bill, troubleshoot, and collect for our services; (b) protect our rights and property or to protect our subscribers or other carriers from the unlawful or fraudulent use of our services; (c) provide call location information required in connection with emergency services; (d) market services formerly known as adjunct-to-basic services; (e) market our services within the categories of services to which you already subscribe; and, (f) respond to a valid request from law enforcement, a court order, or other appropriate authority. Absent your consent, we will not access, use or disclose your CPNI to market categories of telecommunications or VoIP products and services that you do not already subscribe to or share your CPNI with unrelated third parties for their own use.
What type of Personal Information is collected?
We may collect data, including Personal Information, about you as you use our websites, services and interact with us. This information may include name, address, email address, IP address, phone number, login information (user name, password), marketing preferences, or payment card number. If we link other data with your Personal Information, we will treat that linked data as Personal Information. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.
Please understand, in addition to collecting Personal Information, TeleVox may also gather information that does not personally identify you regarding your use of the TeleVox website (“Anonymous Information”). We may use the Anonymous Information we collect regarding your use of this website to measure the effectiveness of our marketing efforts, for improving the Services we offer to you, or to improve the TeleVox website. Generally, you will not be aware when we collect such Anonymous Information. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access the TeleVox website.
How do we receive Personal Information about you?
We learn Personal Information about you when:
- you give it to us directly (e.g., when you choose to contact us, or register on the TeleVox website);
- we collect it automatically through our products and services (e.g., your use of TeleVox services);
- someone else tells us Personal Information about you (e.g., our client provides us your Personal Information in order for us to perform services for them); or
- when we try to understand more about you based on Personal Information you’ve given to us (e.g., when we use your IP address to customize language for some of our services).
Unless we receive your information through your school, or otherwise as part of our SchoolMessenger services, if you are under 13, we don’t want your Personal Information, and you must not provide it to us. If you are a parent and believe your child who is under 13 has provided us with Personal Information without your express consent, please contact us to have your child’s information removed. For SchoolMessenger services specific information, please see below
By providing your Personal Information, you opt-in and consent to its collection, use, disclosure, sharing, and transfer as described in this Privacy Statement.
What do we do with your Personal Information once we have it?
TeleVox does NOT sell your personal information.
When you give us Personal Information, we will use it in the ways for which you’ve given us permission, or ways in which our clients who provided us the Personal Information instruct. Generally, we use your Personal Information to help us provide and improve our products and services for you and our clients with which you have a business relationship. We may also use the Personal Information you provide to contact you regarding additional or new services and features offered by TeleVox, or important information regarding TeleVox.
We may use the Personal Information to enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws and prevent or detect use or abuse of our services.
Important Notice Regarding Unified Communications Services, Webcasting, and Virtual Event Services
TeleVox processes Personal Information as part of delivering the above noted services on behalf of its customers. The customer is the data controller of the information. For these services, TeleVox only collects Personal Information necessary to fulfill our contractual obligations with the customer. We may collect contact data such as name, e-mail address and company details you provide us during the registration process and during your use of the services. We may also collect product usage data, such as the date on which you viewed a webcast, the duration of your viewing and the part of the webcast you viewed.
TeleVox may also use your Personal Information to create anonymous data records or aggregations of data, to perform statistical analyses and for other purposes, by omitting or removing information that makes the data personally identifiable to you.
If you have provided Personal Information to our customer, their respective privacy statement will also apply to the processing of your data. You should familiarize yourself with their statement.
How long will we retain Personal Information?
We will retain your Personal Information only as long as needed to fulfill the purposes for which it was collected or as required by law. Your information will be deleted, anonymized or pseudonymized once it is no longer needed to comply with our business requirements, legal obligations, resolve disputes, protect our assets, or enforce our agreements.
When do we share your Personal Information with others?
We will/may share your Personal Information with others:
- When we have asked and received your permission to share it.
- When we’re required to provide it to our client from whom we received your Personal Information, or with whom you have a business relationship.
- For processing or providing products and services to you, but only if those entities receiving your Personal Information are contractually obligated to handle the data in ways approved by TeleVox. We may use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development).
- To provide aggregate Personal Information to our business partners to make our products and services better, but when we do so, we will de-identify your Personal Information and try to disclose it in a way that minimizes the risk of you being re-identified.
- To provide your Personal Information to business partners in case you purchase services of third parties from TeleVox (“Third Party Services”). Third Party Services are not directly controlled operated or maintained by TeleVox and TeleVox’s Privacy Statement does not apply to such Third Party Services. For any Third Party Services you purchase from TeleVox, we recommend you consult the respective privacy statements of the Third Party Services providers to determine how they will handle your Personal Information.
- To follow the law whenever we receive requests about you from a government entity, or related to a lawsuit. We’ll notify you or our client from whom we received your Personal Information when we’re asked to hand over your Personal Information in this way unless we’re legally prohibited from doing so. When we receive requests like this, we’ll only release your Personal Information if we have a good faith belief the law requires us to do so. Nothing in this Statement is intended to limit any legal defenses or objections you may have to a third party’s request to disclose your Personal Information.
- If we have a good faith belief it is reasonably necessary to protect the rights, property or safety of you, our other users, TeleVox or the public.
- If our organizational structure or status changes (e.g., if we undergo a restructuring, are acquired, or go bankrupt), we may pass your Personal Information to a successor or affiliate.
How do we protect your Personal Information?
We are committed to protecting your Personal Information once we have it. We implement industry standard physical, administrative and technical security measures. If, despite these efforts, we learn of a security breach involving your Personal Information, when required by law or contractual obligations, we’ll notify you or our client so appropriate protective steps can be taken. TeleVox is not responsible for unauthorized access to such Personal Information by hackers or others that obtain access through illegal measures in the absence of negligence on the part of TeleVox.
You may have access to other sites through the TeleVox websites. These sites may have different security practices and you should familiarize yourself with those practices.
How can you protect your Personal Information?
Electronic communication (e.g., email, online chat or instant messaging, etc.) you send to us may not be secure unless we advise you in advance security measures will be in place prior to you transmitting the information. For this reason, we ask you do not send Personal Information such as financial information, social security numbers or passwords to us through unsecured electronic communication. Users should also take care with how they handle and disclose their Personal Information. Please refer to the Federal Trade Commission’s Web site at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.
The TeleVox website may contain hyperlinks that can take you to websites run by third parties (“Third-Party Websites”). Any hypertext or other links to Third-Party Websites from the TeleVox website are provided solely as a convenience to you. If you use these links, you will leave the TeleVox website. TeleVox has not reviewed all of these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, TeleVox does not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Websites linked to the TeleVox website, you do this entirely at your own risk. Remember, this Privacy Statement only applies to TeleVox. When you are no longer on an TeleVox website, you may encounter different privacy and security practices and you should familiarize yourself with those practices each time you visit a new website.
Please be aware any information you choose to share on any publicly available portion of the Services or with third parties, including without limitation your personal page, chat messages, forum posts, blogs, resumes, job applications, business cards, or any other information you provide may be collected and used by third parties or other attendees without restriction.
How do you handle information subject to the California Consumer Privacy Act?
TeleVox complies with all applicable privacy laws including the California Consumer Privacy Act (CCPA). We may collect data, including Personal Information, about you as you use our websites, services and interact with us. This information may include name, address, email address, IP address, phone number, login information (user name, password), marketing preferences, or payment card number. If we link other data with your Personal Information, we will treat that linked data as Personal Information. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us. This information will only be used to provide services or information which you have requested. TeleVox does not sell your Personal Information.
We will retain your Personal Information only as long as needed to fulfill the purposes for which it was collected or as required by law. Your information will be deleted, anonymized or pseudonymized once it is no longer needed to comply with our business requirements, legal obligations, resolve disputes, protect our assets, or enforce our agreements.
TeleVox will not discriminate in any way against you for exercising any of your rights under the CCPA or any other applicable privacy law. This includes, but is not limited to denying goods or services, change in pricing, or lower quality goods or services. Please see “What choices do you have regarding your personal information?” and “How to Contact Us” sections below for how to exercise your rights under the CCPA and other applicable privacy laws.
How do you keep my healthcare information private?
TeleVox is required by law to maintain the privacy of “protected health information.” Please follow this link to TeleVox’s HIPAA Privacy Notice.
What about cookies and other tracking technology?
A cookie is a small file, typically of letters and numbers, downloaded onto a device when the user accesses certain websites. Cookies can make the web more useful by storing information about your preferences for a particular website or a service. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer.
Cookies are typically classified as either session Cookies or persistent Cookies depending on whether they expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.
- Session Cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session Cookies expire after a browser session, so would not be stored longer term. For this reason, session Cookies may sometimes be considered less privacy intrusive than persistent Cookies.
- Persistent Cookies – are stored on a user’s device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent Cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising.
Please note you may browse some TeleVox websites without accepting Cookies from TeleVox; however, you may not be able to take full advantage of the functionality of the website or the Services if you do so. Other Services, particularly those which require a login and password, require Cookies and cannot be used when you have disabled Cookies in your browser. For more general information, you can visit www.allaboutcookies.org.
How do you handle my “Do Not Track” browser settings?
TeleVox does not track the non-TeleVox website activity of any internet user with Do Not Track browser settings engaged.
Does TeleVox use any other tracking technology?
TeleVox employs a software technology called transparent images to help us better manage content on our site by informing us what content is effective. We use extremely small, transparent images with a unique identifier, similar in function to cookies, used to track the online movements of Web users. The main difference between the two is transparent images are invisible on the page and are very small, about the size of the period at the end of this sentence. In some instances, transparent images are tied to users’ personally identifiable information. In particular, we use transparent images in our HTML-based e-mails to let us know which e-mails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications. Users may opt out of these e-mails by replying to the unsubscribe link at the end of the e-mail message.
How does TeleVox ensure compliance with legal obligations?
In connection with the Services, and if applicable, you and TeleVox shall at all times ensure compliance with any privacy and data protection laws including those in the United States (including but not limited to the Gramm-Leach-Bliley Financial Services Modernization Act, the Health Insurance Portability and Accountability Act, California Consumer Privacy Act and the Fair Credit Reporting Act), in the United Kingdom (including but not limited to the Data Protection Act), in the European Union (including but not limited to relevant EU member state legislation and the General Data Protection Regulation), in the Asia-Pacific Economic Cooperation (including but not limited to Australia’s Privacy Act along with the Australian Privacy Principles, Singapore’s Personal Data Protection Act, Japan’s Act on the Protection of Personal Information and Hong Kong’s Personal Data (Privacy) Ordinance) and anywhere around the world.
We’re a global organization and our information systems are in several countries around the world. We also use service providers whose information systems may also be in various countries. This means your Personal Information might end up in one of those information systems in another country, and that country may have a different level of data protection regulation than yours. The whole or any part of your Personal Information in connection to the Services may be processed by TeleVox, its affiliates and subcontractors in the United States, United Kingdom, the European Union, Philippines, India, Canada, Mexico and the rest of the world, and may be transferred outside the country in which you provided the Personal Information. By giving us Personal Information, TeleVox may conduct such transfers of your Personal Information. TeleVox uses Standard Contractual Clauses approved by the European Commission as an international data transfer mechanism. No matter what country your Personal Information is in, we comply with applicable law and will also abide by the commitments we make in this Privacy Statement.
How do you handle my Personal Information as part of Notified’s and/or GlobeNewswire’s Media Contacts Database products and services?
Certain of our Notified and GlobeNewswire services provide detailed profiles for media contacts and news outlets to public relations, media and marketing professionals, such as yourself. If you are receiving these types of emails from Notified and/or GlobeNewswire, it is because your professional contact information is publicly available and we believe there is a legitimate interest and/or implied consent for you to be part of our media contacts database, which includes data in the public relations industry compiled by our in-house research team. If you do not wish to be part of our media contacts database, you may unsubscribe at any time by clicking unsubscribe at the bottom of an email you have received from us. We may use your Personal Information for purposes related to data analytics with our third party partners. By fully unsubscribing your Personal Information will not be used this way.
We provide business to business communication technology services and may use your Personal Information in order to enhance and deliver data analytics, which include transforming, examining, cleansing and modelling data in order to support decision making, determining useful information and informing conclusions. Specifically, data analytics are intended to include the following data sharing and recommendations across our various lines of business:
- Expand contact information;
- Aggregation of data to identify trends and benchmarks;
- Connect attendees and enhance profiles;
- Provide people and content recommendations;
- Drive recruitment to virtual and hybrid events;
- Help to understand usage, adoption and engagement;
- Increase and demonstrate return on investment of customer investments;
- Assess the physical component of hybrid events; and
- Give insight to customer analytics to develop new customers and expand existing customer relationships.
We make no representations or warranties on the accuracy and serviceability of your data in connection with data analytics. Data created or existing from data analytics is intended for your use only. Data may not be resold, reused or shared with third parties without prior written consent by TeleVox. For the avoidance of doubt, by signing up to use our Services, you have freely and voluntarily given informed, explicit and unambiguous permission for TeleVox to process your Personal Information, including your users’ Personal Information, for data analytics. You also acknowledge that providing this permission is not a condition of receiving TeleVox’s Services. You further understand that you have the right to withdraw this permission at any time by providing written notice to TeleVox.
What choices do you have regarding your Personal Information?
We are aware you have several rights in respect to how we process your Personal Information, which include but are not limited to, a right to access your Personal Information, be forgotten, restrict and/or object to processing in some circumstances and request your Personal Information be transferred to you or your nominated third party.
You may choose not to have your information disclosed to a third party (unless TeleVox is legally required to share it). You may also choose to not have your information used for a purpose materially different than the purpose for which it was originally collected or subsequently authorized by you.
We will take reasonable steps to give you the opportunity to correct inaccuracies in the Personal Information we retain concerning you and delete Personal Information concerning you upon your request, unless the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than you would be violated. We may deny a request to delete your data if we have legal obligations to retain it. Any such data will be subject to our standard retention guidelines.
You are entitled to know whether we hold personal data about you and, if we do, to have access to that personal data and require it to be corrected if it is inaccurate. In some circumstances, you may have the right to oppose the use or disclosure of your data or have your data deleted. You can do this by contacting us as directed in the “Contact Us” section below.
To correct inaccuracies in your Personal Information, limit purpose of use and disclosure, delete your Personal Information, or for any other requests or questions, please contact us as directed in the “Contact Us” section below. Once we have verified your identity, we will complete the request from you or an authorized agent you have designated. We will make all efforts to verify your identity using information we already have but may need to request additional data if we are unable to make the verification on this data alone. If you designate an agent to make requests for you, we reserve the right to ask for proof of the agency.
TeleVox will not discriminate against any individual for exercising their privacy rights outlined above. This includes, but is not limited to; denying goods or services, change in pricing or lower quality goods or services.
What if we change this Privacy Statement?
We may need to change this Statement and our notices. Unless otherwise required, the updates will be posted online. If the changes are substantive, unless otherwise required, we will announce the update through TeleVox’s websites. Unless further steps are necessary related to the changes, your continued use of the product or service after the effective date of such changes constitutes your acceptance of such changes. To make your review more convenient, we will post an effective date at the top of the page.
How to Contact Us?
If you want to make a correction to your Personal Information, or you have any questions about our privacy statement, please contact the privacy team by emailing [email protected], contacting us toll-free at 1-855-760-5025, outside of the U.S. +1-402-702-2390 or by mail, we can be contacted at:
Privacy and Legal Department
11808 Miracle Hills Drive
Omaha, NE 68154
Amended and Restated Code of Ethical Business Conduct
This Code of Ethical Business Conduct (“Code”) is intended as an overview of TeleVox’s guiding principles and not as a restatement of TeleVox’s policies and procedures. TeleVox’s reputation as an ethical company is essential to our success. Our reputation needs to be managed and developed with the same care we extend to our clients. In carrying out the business of TeleVox, we deal with investors, clients, vendors, government officials, community leaders, the press and the general public. It is essential all of our dealings be legal and above reproach, and must not, in any way, compromise TeleVox’s interests, its policies or its reputation for the highest standards of business ethics.
We believe TeleVox directors, officers and employees should disclose any activity that may have the appearance of being unethical. In so doing, not only can we take appropriate disciplinary or legal action, but we may be able to take steps to prevent the situation that gives rise to the questioned activity.
Merely operating within the law is just the beginning of the ethical conduct we expect and insist upon. This Code is a broad statement of TeleVox’s expectations regarding legal and ethical conduct. This statement is intended to be interpreted in the spirit of its intent and not literally, as it is virtually impossible to address every situation or condition that may arise.
In the event of any conflict between the Code and the certificate of incorporation or bylaws of the Company, including, without limitation, provisions related to business opportunities presented to members of the Board of Directors, the provisions set forth in the certificate of incorporation or bylaws, as applicable, shall control.
Each director and officer should be aware of the ethical practices of each of the people he or she manages. We must maintain an attitude within TeleVox unethical actions or the appearance of unethical actions are not acceptable, even though they may seem to be standard business practices in other companies. This Code cannot and is not intended to cover every applicable law or provide answers to all questions that might arise; for that we must rely on each person’s good sense of what is right, including a sense of when it is proper to seek guidance from others on the appropriate course of conduct.
Conflict of Interest:
All directors, officers and employees of TeleVox are expected to avoid any activity, investment, interest or association which interferes with or is reasonably likely to interfere with the independent exercise of his or her judgment when it is related to TeleVox’s interests. Directors, officers and employees of TeleVox have a duty of loyalty to TeleVox and must, therefore, avoid any actual or apparent conflict of interest with TeleVox.
It is impossible to cover every possible conflict of interest. At times it will not be easy to distinguish between proper and improper activity. The most common conflicts are:
- Having a financial interest, directly or indirectly, in any supplier, client or competitor of TeleVox. All interests of 1% or greater in a supplier, client or competitor should be fully disclosed to TeleVox’s General Counsel.
- Engaging in a business transaction on behalf of TeleVox with a relative by blood or marriage, or with a firm where such relative is an officer or representative, without prior full disclosure and written clearance.
- Accepting any money, gifts of other than nominal value, unusual hospitality, loans or any other preferential treatment from any supplier, client or competitor of TeleVox.
In short, we cannot be influenced by improper personal considerations which might consciously or unconsciously affect our judgment regarding the best interests of TeleVox. If a director, officer or employee becomes aware of an actual or apparent conflict of interest, he or she should discuss it with the appropriate manager and disclose it to TeleVox’s General Counsel.
No director, officer or employee of TeleVox may:
- Take for himself or herself personally any business opportunity discovered through the use of TeleVox’s property, information or position;
- Use TeleVox’s property, information or position for personal gain;
- Use confidential or non-public information of any of TeleVox’s clients for personal gain; or
- Compete with TeleVox.
Employees, officers and directors owe a duty to TeleVox to advance its legitimate interests when the opportunity to do so arises.
Information About Competitors:
As a business that competes in the marketplace, we seek economic knowledge about our competitors. However, TeleVox officers, directors and/or employees shall not engage in illegal or improper acts to acquire a competitor’s trade secrets or customer lists. In addition, we will not hire a competitor’s employees for the purpose of obtaining confidential information about the competitor.
All directors, officers and employees should maintain the confidentiality of information entrusted to them by TeleVox, its business partners, suppliers, clients or others related to TeleVox’s business. Such information must not be disclosed to others, except when disclosure is authorized by TeleVox or legally mandated. Confidential information includes all nonpublic information that might be of use to competitors, or harmful to TeleVox or its clients if disclosed. Employees should not disclose confidential information of third parties. For example, you should not disclose a former employer’s confidential information to anyone, including other TeleVox employees.
Dealing with Suppliers and Clients:
TeleVox’s overall view regarding its relations with suppliers and clients is simple. They must be treated as TeleVox expects to be treated – with fairness.
TeleVox strives to ensure it does not have or contribute to adverse human rights impacts (including modern slavery or human trafficking) within its business or through its supply chains. There is an ongoing commitment to engage only those suppliers that uphold the same principles as TeleVox. In the event suppliers fail to take steps to cease or prevent adverse human rights impacts, TeleVox will reconsider its business relationships with those suppliers.
Contributions to Political Parties, Candidates or Government Officials:
TeleVox’s policy is precise and specific. Contributions by a corporation to political parties or candidates involving federal offices in the United States are expressly forbidden by Federal law. TeleVox obeys the law. In addition, while political contributions to parties or candidates may be legal in some states and in some foreign countries, no TeleVox corporate funds may be used for such purposes without the express prior approval of TeleVox’s General Counsel. TeleVox is an active participant in the democratic process at the national, state and local levels within the parameters of the law. TeleVox also encourages all employees to participate in our political system by voting, speaking out on public issues, and becoming active in civic and political activities. It is important, however, directors, officers and employees clearly distinguish their personal views from those of TeleVox, unless specifically authorized by TeleVox to speak on TeleVox’s behalf.
Payments to Government Personnel:
The U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. It is strictly prohibited to make illegal payments to government officials of any country.
In addition, the U.S. government has a number of laws and regulations regarding business gratuities which may be accepted by U.S. government personnel. The promise, offer or delivery to an official or employee of the U.S. government of a gift, favor or other gratuity in violation of these rules would not only violate Company policy but could also be a criminal offense. State and local governments, as well as foreign governments, may have similar rules.
Accuracy of TeleVox’s Records: All official records showing the conduct of TeleVox’s business must be accurate and complete in all material respects. All those involved in the preparation of such materials should consider the accuracy of the records of critical importance and should understand TeleVox does not maintain any off-the-books funds for any purposes. It is TeleVox’s policy to fully and fairly disclose its financial condition in compliance with applicable accounting principles, laws, rules and regulations.
TeleVox keeps all books and records to fully and fairly reflect all TeleVox transactions in accordance with generally accepted accounting principles. There must be full, fair, accurate, timely and understandable disclosure in reports and documents filed with the Securities and Exchange Commission and in other public communications made by TeleVox.
Retention of Records: Disposal or destruction of TeleVox records and files should comply with company policy. In addition, when litigation or a government investigation is pending or imminent, relevant records must not knowingly be destroyed until the matter is closed. Insider Information:
Federal law and the Securities and Exchange Commission’s regulations prohibit the use of “inside” (i.e., material nonpublic) information when trading in TeleVox’s securities. The Insider Trading and Securities Fraud Enforcement Act of 1988 imposes significant criminal and civil penalties for insider trading.
Examples of such information include possible acquisitions, mergers, stock splits, dividends, earnings, new contracts, new products or discoveries, major management changes, expansion plans, data which may be proprietary, or data which has not yet been disclosed to the investment public and other important corporate developments. As a result of these regulations, TeleVox personnel should follow the TeleVox Insider Trading Policy located on TeleVox’s intranet.
Dealings with Clients:
TeleVox’s business is built upon the principle of effective, courteous management of client contacts. TeleVox treats all clients and their consumers with dignity and respect.
TeleVox’s people have been, and will continue to be, the key to our success. TeleVox strongly supports and recognizes its responsibility to provide equal employment opportunities to all qualified individuals. TeleVox places a high value on diversity. TeleVox strongly believes that all people are unique, valuable, and should be respected for their individual abilities. In support of this goal, TeleVox has established a company policy regarding discrimination or harassment on the basis of race, gender, age, color, religion, disability status, veteran status, sexual orientation, marital status or ethnic, national or any other characteristic protected by law. This policy applies to all personnel relationships, including but not limited to: promotions, transfers, training, job assignments, job stations, hours of work, rates of pay, working conditions, terminations, and all terms and conditions of employment.
Legal Conduct and Compliance with this Code: TeleVox’s policy is that all of its directors, officers and employees shall conduct business on behalf of TeleVox in full compliance with the laws of the many jurisdictions in which TeleVox may conduct business. Accordingly, the provisions of the present Code are not intended as a substitute for applicable national laws and regulations and the scope of the Code’s application shall be limited to the extent incompatible with such laws and regulations. Under the laws of certain countries in which the Company has a presence, legal conduct and compliance with this Code may require further adaptations and directors, officers and employees should refer to the appropriate country annex that addresses such matters.
Any director, officer or employee who acquires knowledge of a violation of a law or this Code, or has cause to believe that a law or this Code has been violated, must immediately report this situation to the General Counsel, the Chief Executive Officer, the Chief Financial Officer or outside legal counsel for TeleVox. If you wish to remain anonymous, you may report a violation of this Code by calling the Telephone Hotline at 800-480-9503. The Telephone Hotline is answered by an independent company and is available 24 hours a day every day. You may also report a violation by email to [email protected] or online at www.intouchwebsite.com/TeleVox. No director, officer or employee who reports such a situation, in good faith, shall be penalized for his or her reporting of any violation or suspected violation of a law or this Code. To the fullest extent possible, the identity of a person making a report will be kept confidential. If an TeleVox person believes that he or she is being treated unfairly because of reporting a violation or potential violation, this should be brought to the immediate attention of the General Counsel or a Vice President of Employee Relations of TeleVox.
Any employee who ignores or violates any of TeleVox’s ethical standards, and any manager who penalizes a subordinate for trying to follow these ethical standards, will be subject to corrective action. However, it is not the threat of discipline that should govern your actions. TeleVox expects you to share its belief that a dedicated commitment to ethical behavior is the right thing to do and is good business.
Violations of this Code will result in disciplinary action that may include termination, referral for criminal prosecution and reimbursement to TeleVox for any losses or damages resulting from the violation. As with all matters involving investigations of violations and discipline, principles of fairness and dignity will be applied pursuant to the procedures developed and used by TeleVox’s Employee Relations Department.
Any waivers of this Code for directors or executive officers must be approved by the Board of Directors of TeleVox and must be promptly disclosed in a Form 8-K within five business days with reasons for the waiver.
Foreign Hotline Numbers:
United Kingdom: 0-808-189-3366