Privacy Policy

We have developed this policy because you are entitled to feel confident about the privacy and security of your Personal Information. We have appropriate technical and operational measures in place to prevent loss, misuse, unauthorized access and alteration of all data (including Personal Information) under our control. Our security arrangements and policies are regularly reviewed and access to our records is restricted to authorized personnel.

When we refer to Personal Information in this privacy policy, we mean any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one of more factors specific to his physical, physiological, mental, economic, cultural or social identity (“Personal Information”). Accordingly, we may hold and use Personal Information about you in your capacity as a business customer, as an individual acting on behalf of a business customer, or in any other capacity, for example as a visitor to our Websites.

If you access our Website from the European Economic Area (EEA) please also see additional information on our use of your Personal Information and your privacy rights at the end of this privacy policy.

Scope of Privacy Policy

This privacy policy sets out the basis on which any Personal Information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Information and how we treat it.

This privacy policy does not cover information, communication or material you submit to the Websites that does not meet the definition of Personal Information. Any information that is not Personal Information, that you provide in any manner and for any reason, will not be deemed confidential or proprietary and may be used by IPC at any time, for any reason, and without prior or subsequent notice to you. In addition, we may reproduce, transmit, publish, broadcast, modify, revise or otherwise use such information, communication or material without your permission and without financial or other liability to you.

This privacy policy also does not apply to any other company’s websites, even if you access them through IPC. If you disclose Personal Information to other companies your information will be dealt with according to their privacy practices.

Collection of Personal Information

Informational use of the website

If you visit our website without using any service offered by us and without providing us with Personal Information, we may automatically collect the following information about you. This information may include Personal Information. Your browser automatically sends the following information to us:

  • Browser type and browser version,
  • Operating system used,
  • Referrer URL,
  • Host name of the accessing computer,
  • Time of service request, and
  • IP address.

We need this information to enable the use of our website, for example by adapting the website to the needs of your device.

Competitions and promotions

If you enter into any of our competitions or promotions, we may ask for information about you, which will be made clear at the time you enter. We will also inform you of the purposes for which the information you provide may be used.

Registration with the IPC Xchange Portal

You may be required to register in order to use the IPC Portal and certain other areas within the Websites, and in the course of the registration process, you may provide your name, address, email address, phone number, account number and other voluntary Personal Information. We will use this information to provide the account, newsletters and other information you have requested, and to help us better target our other marketing activities.

Contacting us

You can always contact us via email, e.g. to send inquiries about our services. In this context, we will process your name, contact details, content of the message and other Personal Information you provide to us. Purpose of the processing is to process your inquiry.

Location of Data

The data that we collect from you (including Personal Information) may be transferred to, and stored at, a destination in the United States of America. It may be processed outside the European Economic Area (“EEA”). Information may also be transferred to our other offices or processed by third parties acting on our behalf and such locations may be outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Via the technical and organization measures referred to above, IPC will do its best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website and any transmission is at your own risk.

Sharing of Data

We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

Retention Periods

The time period for which we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep Personal Information for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.

Use of the Personal Information

We may use the Personal Information in the following ways:

  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchase, enquired or viewed on the Websites;
  • to answer questions or queries you have submitted to us via the Websites;
  • to ensure that content from our site is presented in the most effective manner for you and for your computer;
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that the content is presented in the most effective manner for you and for your computer;

Cookies

A “cookie” is a text file, which is allocated by our server to your personal computer (PC) when you visit areas of the Websites. If you want to know more about, cookies please go to www.aboutcookies.org which explains how cookies work and how you can manage their use. We use “cookies” to collect information from visitors to the Websites and registered customers.

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 it to improve our site and to target our marketing activities. For example, we may collect information about the pages you visit on our Websites, the time of your visit, and the amount of time you spend on each page and what collateral material you have downloaded. We may also collect information about your computer, including for example the name and version of your web browser and computer operating system, screen colors, screen resolution and other software you may be using. Further, we may collect information about your network, connection speed, IP address, geographic location and other similar data, as well as information about the website (URL) from which you came to our Websites and any search engine query you might have used to find us.

Our servers use two different types of cookies. The first type is known as a “session-based” cookie and is allocated to your PC only for the duration of your visit to the Websites. It helps you to move around the Website faster. This cookie automatically expires when you close down your browser. The second type of cookie known as a “persistent” cookie allocated to your PC, where we can oversee all the activities that you have carried out on our Websites and will remain on your PC for a period of time.

We do not store information regarding your telephone number, account or payment details in the cookie, and this information cannot be accessed using it. IPC´s cookies do not collect any information regarding the use of your PC or your Internet browsing in any way.

Please note that as the cookie is based on your PC, we will not find it if you visit the Websites using a different PC to the one you registered on.

All types of cookies can be removed from your PC, but you may not be able to use the full functionality of the Websites and there may be some deterioration in the service you receive (for example, you may receive many pop up boxes containing the same advertisements or you may not be able to access a page you earlier personalized).

The Websites use Google Analytics, a web analytics service provided by We transmit information we collect from you and about your visit to the Websites to these partner services. They use the information we collect for the purpose of evaluating our visitors’ use of the Websites, compiling reports for us, and providing other services relating to use of our Websites.

Google Analytics

Google Analytics uses so-called cookies (see above). The information generated by the cookie about your use of this website is generally transmitted to a Google server in the United States and stored there. The corresponding evaluation of your surfing behavior is made available to us in anonymized form. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google has committed that it will not associate your IP address with any other data held by Google.

You can prevent the use of Google Analytics at any time, either by installing a Google Browser Plugin that will set an opt-out cookie, or through appropriate settings in your browser. For more information, visit https://tools.google.com/dlpage/gaoptout?hl=de and https://www.google.com/analytics/terms/de.htm.

For more information on the handling of Personal Information by Google, see https://support.google.com/analytics/answer/6004245?hl=de.

Marketo

Marketo collects your IP address and uses cookies (see above) to track and analyze the use of the website in order to provide information specifically tailored to the interests of the user. The information generated by the cookies is transferred to a Marketo server and stored there. On our behalf, Marketo uses this information to evaluate the use of the website by registered persons and to compile reports on website activities.

You can prevent the use of Marketo at any time through appropriate settings in your browser.

For more information on the handling of Personal Information by Marketo, see http://eu.marketo.com/trust/privacy.php.

Access to Personal Information

Certain privacy laws entitle you to access the Personal Information we hold about you and to have any inaccuracies rectified. Where you are entitled to do so, any request for access to Personal Information may be subject to the payment of a fee up to the relevant statutory limit.

Additional information if you access our website from a country in the European Economic Area (EEA):

The following information only apply to you if you access our Website from the EEA.

Legal bases for the processing of Personal Information

As outlined above, we process your Personal Information for different purposes. Below you may find the legal bases that justify these processing activities. This also includes the sharing of

  • Informational use of the website: The legal basis for the processing is Article 6 (1) (1) (b) GDPR. The Personal Information is necessary for the provision of our Website.
  • Troubleshooting, data analysis, testing, research, statistical and survey purposes: The legal basis for the processing is Article 6 (1) (1) (f) GDPR. We have a legitimate interest in ensuring the security and effective use of our Website as well as adaption of our Website to your device. We assume that the problem-free use of the website is also in your interest.
  • Registration with the IPC Xchange Portal: The legal basis for the processing is Article 6 (1) (1) (b) GDPR as the Personal Information is necessary to provide the user account. This may also include information (including our newsletter) you requested from us.
  • Contacting us: The legal basis for the processing is Article 6 (1) (1) (b) GDPR where the processing is necessary to perform an existing contract or as part of contract initiation. Further, we may rely on Article 6 (1) (1) (f) GDPR. We have a legitimate interest in properly processing and responding to your requests.
  • Cookies: The legal basis for the processing of Personal Information through the use the cookies by Google and Marketo is Article 6 (1) (1) (f) GDPR. We have a legitimate interest using the analytics data to assess the use of our Website and improve our services accordingly.

Sharing of Personal Information

In the course of the engagement, Google and Marketo act as data processors. This means that they process Personal Information exclusively on our behalf. The Personal Information transfer is privileged under Art. 28 GDPR. Where Google and/or Marketo process Personal Information in the US, the transfer is safeguarded under the EU US and Swiss US Privacy Shields, which the vendors are subject to.

Your rights

You may be entitled to exercise some or all of the following rights:

 

  • require (i) information whether your Personal Information is retained and (ii) access to and/or duplicates of your Personal Information retained, including the purposes of the processing, the categories of Personal Information concerned, and the recipients of Personal Information as well as potential retention periods;
  • request rectification, removal or restriction of your Personal Information, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;
  • refuse to provide and – without impact to processing activities regarding Personal Information that have taken place before such withdrawal – withdraw your consent to processing of your Personal Information at any time;
  • object, on grounds relating to your particular situation, to processing of your Personal Information, in case such processing is either based on our or a third party’s legitimate interests or on a performance of a task carried out in the public interest. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your Personal Information or present you our compelling legitimate grounds for an ongoing processing; and/or
  • take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data protection regulators.
  • require (i) to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those Personal Information to another controller without hindrance from our side; where technically feasible you shall have the right to have the Personal Information transmitted directly from us to another controller;

 

You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us under the contact details set out above.

Contact:

IPC Systems, Inc.

3 2nd St, Jersey City, NJ 07302, United States

IPCLEGAL@ipc.com

Privacy Shield certification

We comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the EU and Switzerland to the United States. IPC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles available under https://www.privacyshield.gov/article?id=Requirements-of-Participation (“Privacy Shield Principles”). If there is any conflict between the terms in our Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall prevail. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

The Privacy Shield Frameworks cover Personal Information we receive from customers located in the EU and Switzerland. We process this Personal Information exclusively on the instructions of these customers that act as data controller. Our customers are part of the financial community. We offer these customers different types of services, including the use of our converged-access platform to deliver critical applications to counterparties and throughout an enterprise, solutions for information exchange and collaboration in the financial markets, a cloud-based platform to power communications-enabling apps.

For processing of Personal Information under the Privacy Shield Frameworks, the following applies:

Choice and means for limiting the use of your Personal Information

You may be entitled to limit the use of your Personal Information. This may include cases where your Personal Information is disclosed to a third party that is not acting as an agent or data processor on behalf of the controller, or it is used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by you. As indicated above, we process Personal Information received from controllers in the EU and Switzerland exclusively on the instructions of these controllers. Therefore, please contact the respective controller directly if you would like to exercise possible choices. In case of doubt, please contact us and we will try helping you to put you in contact with the respective controller.

Access

You have the right to access the Personal Information processed about you. As indicated above, we process Personal Information received from controllers in the EU and Switzerland exclusively on the instructions of these controllers. If you would like to exercise your access right, please contact the respective controller directly. In case of doubt, please contact us and we will try helping you to put you in contact with the respective controller

Sharing of your Personal Information (Onward Transfers)

IPC may engage third party service providers to assist us in providing our services to our customers. In transferring such information to a third party, IPC will obtain assurances from such third party that it subscribes to the Privacy Shield Principles or otherwise safeguards your Personal Information consistently with the same level of privacy protection as is required by the Privacy Shield Principles. In the context of an onward transfer, IPC has responsibility for the processing of Personal Information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. IPC shall remain liable under the Privacy Shield Principles if its agent processes such Personal Information in a manner inconsistent with the Privacy Shield Principles, unless IPC proves that it is not responsible for the event giving rise to the damage.

In addition, we may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Complaints and recourse mechanism

In compliance with the Privacy Shield Principles, IPC commits to resolve complaints about our collection or use of your Personal Information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact IPC at:

IPC Systems, Inc.
3 2nd St, Jersey City, NJ 07302, United States
IPCLEGAL@ipc.com

IPC has further committed to refer unresolved Privacy Shield complaints to American Arbitration Association. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit American Arbitration Association for more information or to file a complaint.

FTC Jurisdiction

The Federal Trade Commission (FTC) has investigatory and enforcement power over IPC and its compliance with the Privacy Shield.

Invocation of binding arbitration

Under certain conditions, you have the possibility to invoke binding arbitration in order to determine whether IPC has violated its obligations under the Privacy Shield Principles as to you, and whether such any such violation remains fully or partially unremedied. You must take following steps prior to initiating an arbitration claim:

  1. raise the claimed violation directly with IPC and allow us an opportunity to resolve the issue within 45 days of receiving your complaint;
  2. make use of the independent dispute resolution mechanism, which is at no cost to you; and
  3. raise the issue through your Data Protection Authority to the Department of Commerce and afford the Department of Commerce an opportunity to use best efforts to resolve the issue, at no cost to for you.

This arbitration option may not be invoked if your same claimed violation of the Principles (1) has previously been subject to binding arbitration; (2) was the subject of a final judgment entered in a court action to which you were a party; or (3) was previously settled by the parties.

Please check https://www.privacyshield.gov/article?id=C-Pre-Arbitration-Requirements for further information.

 

Last updated: 27th May 2020