Instavox privacy policy

Instavox is a service provided by Telbee Group Ltd, a private company incorporated and registered in England & Wales with company number 11538541 (“Telbee”, "we", "us").  This Privacy Policy applies to personal data processed by Telbee in our business when delivering the Instavox services, including on our websites, application software (“App”) and other online or offline offerings (a “Service” or collectively, the “Services”). 

Telbee gives visitors to the Instavox website, the Instavox App and users of the Instavox Services (each referred to in this Privacy Policy as “you” or “your”), the power to be in control of their personal data. We also provide controls that allow you to have control over the privacy of personal data that is captured by our Services. This Privacy Policy provides information about how Telbee processes and protects this data.

Telbee considers data protection and data security to be of paramount importance. We will never sell your personal data and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation (“GDPR”), as well as the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) as the same applies in England and Wales (“Data Protection Legislation”).

If you are a user of a website, app or any social media platform providing access to Instavox Services provided by Telbee (“Service Enabled Site”), you are referred to as an “End User” in this Privacy Policy and the additional provisions at heading “Specific Terms for End Users” will apply to you.

For the purpose of this Privacy Policy, personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, economic, cultural or social identity of that natural person (the “Personal Data”).

Responsibility for Processing Personal Data

Telbee is a data controller (as defined in the Data Protection Legislation) regarding the information processed for our own purposes, which is the Personal Data collected from you via our website or App or to provide you with our Services. Telbee is a data processor (as defined in the Data Protection Legislation) on your behalf for the Personal Data captured to provide the Services. 

What kind of Personal Data is processed?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifiers, title, voice, video, image, avatar, date of birth, gender, and information that could contribute to identification included in voice, video or text messages.
  • Contact Data includes billing address, delivery address, social media usernames, email addresses and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use.
  • Profile Data includes your username and password, images provided to represent you, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, App, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Cookies

Telbee uses cookies to process information including standard internet log information and details of the visitor’s behavioural patterns upon visiting our website or App. This is done to provide you with a better experience, and to facilitate the use of certain functions. Cookies are small data files transferred onto computers or devices by sites for record-keeping purposes and to enhance functionality on our site. 

We may use the following types of cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website or App. They include, for example, cookies that enable you to log into secure areas of our website or App.

Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website or App when they are using it. This helps us to improve the way our website or App works.

Functionality cookies. These are used to recognise you when you return to our website or App. This enables us to personalise our content for you, greet you by name and remember your preferences.

Please note that third parties whose technology is used by Instavox may also use cookies over which we have no control. 
If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website or App.

Contact with us

On our site and App you have the opportunity to contact us to ask us questions. We ask you for your contact information (e.g. name, email address etc.) and use this data solely in connection with answering the queries we receive.

Instavox Account

If you sign up for and open an Instavox account with Telbee, we may ask you to provide us with information such as your name, email address, phone number and details about your organization. As otherwise detailed in this Privacy Policy, we will solely process this information to provide you with the service you signed up for. 

You can deactivate your Instavox account from us at any time by contacting us and submitting a deactivation request. Following termination of your account, we may retain your personal data (in part or in whole) in order to meet any regulatory and reporting requirements for the timeframes stipulated by law and in order to be able to address customer service issues. 

Third Party Access

Telbee does not sell and has not sold Personal Data at any time. Except as provided below, we also do not share or disclose your Personal Data.

We use a select number of trusted external service providers for certain technical data analysis, processing or storage offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services offered, as defined on our Subprocessors page, which they may also use to improve their services. 

In addition to the services providers mentioned on our Subprocessors page, other categories of third parties may include:

  • In relation to our Services. We may share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services.

  • Disclosure to our contractors. We may share information with contractors who work for us. They are all working for Telbee under strict confidentiality obligations.

  • Vendors/public institutions. To the extent that this is necessary in order to make use of certain services requiring special expertise (such as legal, accounting or auditing services) we may share your personal data with vendors of such services or public institutions that offer them (courts). The legal basis of this data processing is Art.  6(1)(f)GDPR.

  • Disclosures to protect us or others.  We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity; depending on the concrete issue, the legal basis for such processing may be Art. 6(1)(b), (c) or (f) GDPR.

  • Disclosure in the event of merger, sale, or other asset transfers.  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be transferred as part of such a transaction, as permitted by law and/or contract. The legal basis for such processing would be Art. 6(1)(f) GDPR as such processes are in the legitimate interest of Telbee.

Other than the cases mentioned above, we will only pass your data on to third parties without your express consent if we are obliged to do so by statutory law or an instruction by a public authority or court. 

Notice regarding Third-Party Websites

The Instavox Services may contain links to other websites, social media platforms and applications, and other websites, social media platforms and applications may reference or link to our website or the Instavox Services. These other websites, platforms and applications are not controlled by Telbee. We encourage you to read the privacy policies of each website, platform and application with which the Instavox Services interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites, platforms or applications. Visiting these other websites, platforms or applications is at your own risk.

Communications

We may occasionally send you notification emails about updates to our product, legal documents, offer customer support or marketing emails. Except for cases where we are required to do so by law (e.g. notifying you of a data breach), you shall have the opportunity to unsubscribe from receiving these messages free of charge. 

Public disclosure

If you write feedback or questions to us, we may display it publicly on our website, App or otherwise. Feedback or questions might display the name and avatar associated with your Instavox login and any additional Personal Data you may include in the message. 

Your Data Protection Rights

If you have an Instavox account, you have a right to be informed of any Personal Data processed by Telbee in connection with your account, a right to rectification/correction, erasure and restriction of processing. You also have the right to receive from Telbee a structured, common and machine-readable format of any Personal Data that you have provided to us. 

We will identify you via your email address and/or phone number (or another proof of identity), and we can only adhere to your request and provide information if we have Personal Data about you through you having made contact with us directly and/or you using our site and/or services. 

Please note that we cannot provide, rectify or delete any data that we store on behalf of other users (e.g. where you are an End User of an Instavox Account owned or controlled by another party). In these circumstances, we are collecting your Personal Data on behalf of our customers who are Data Controllers. We will transmit your request to the relevant Data Controller, where possible. However, the final decision related to the access, deletion or rectification of your information belongs to them. We will make reasonable efforts to satisfy your request, but we cannot make the final decision regarding your Personal Data. 

To exercise any of the rights mentioned in this Privacy Policy and/or in the event of questions or comments relating to the use of Personal Data you may contact Telbee’s support team: support[at]instavox.io.

Where you have provided consent to us, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of the Instavox Site and/or Services. You further agree that Telbee shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent. 

Where Personal Data is processed for the above purposes on the basis of Telbee’s legitimate interests, under the GDPR, you may object to such processing at any time by contacting us at support[at]instavox.io or by sending us a Vox at instavox.io/support

In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.

Duration of Processing

We store personal information for only as long as we or our Customers who control the data have a legitimate reason to keep it. We aim to make it as simple as possible for you to control the personal information that we store. We may also retain information as required by law.  

Purposes for which we will use your Personal Data

We will only use your Personal Data for legitimate interests. We have set out, below, a description of the ways we may use your Personal Data and the bases we rely on to do so.  

Purpose/Activity

To register you as a new customer

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

Purpose/Activity

To process, deliver and support the Instavox Services

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Technical

(e) Usage

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate business interests 

Purpose/Activity

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms, the App or any Services

(b) Asking you to leave a review or take a survey

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Usage

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

Purpose/Activity

To administer and protect our business, our website and our App (including troubleshooting, data analysis, testing, system maintenance)

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Technical

(e) Usage

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests 

Purpose/Activity

To deliver content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity

To use data analytics to improve our website, App, marketing, customer relationships and experiences

Type of data

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of customers for our services, to keep our website and App updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity

To improve our services and for research development

Type of data

(a) Technical

(b) Usage

(c) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our services and grow our business)

International Transfers of Personal Data

Instavox customer information may be accessed from, or other data (e.g., Instavox content) may be transferred to, the United States or other countries which may have data protection laws that are different from the laws where you live. Telbee has taken appropriate safeguards to require that your Personal Data will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.

Children’s Information

Children under 13 (or other age as required by local law) should only use the Instavox Services under the authority of the holder of their parental responsibility or any other legal representative of the children. The Services are not aimed for children under 13 to use independently. 

Specific Terms for End Users

If you are a visitor to a Service Enabled Site, this section applies to you.

The data that Telbee processes for Service Enabled Sites is processed by us on behalf of our Customers, and our privacy practices are also governed by the contracts that we have in place with our Customers. 

Please see below the specific privacy terms for the use of the Instavox Service 

To provide our Instavox Service, we may collect any of the types of data set out above at “What kind of Personal Data is processed”. 

Additionally, we may use third party services to collect information regarding visitor behaviour and visitor demographics on our Instavox Service. 

Sending a Vox via Instavox is similar in nature to leaving a comment on a public social media profile. The contents of your Vox and your profile information may be publicly visible and may be reused or reshared by us or our customers.

We acknowledge that all intellectual property rights in your Voxes including any voice recordings, images and videos shall be owned by you. By using our Services, you shall grant us an irrevocable, royalty-free, transferable, sub licensable, worldwide perpetual licence to reuse, reshare, copy, perform or display the content in your Voxes for use in our business including for the purposes of product development and market research. We may sub-licence the right to use the content in the Voxes that you send to our customers who may reuse, reshare, copy, perform or display your content.

Any personal data submitted by you as an End User may be processed by our customers in accordance with their own privacy policies.  We encourage you to read those policies before providing any personal data via the Instavox Service.

We may also process, use and store your Personal Data for the purposes set out above in this Privacy Policy.

Revisions to this Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of this Privacy Policy will govern our practices for collecting, processing, and disclosing personal data. We will use our best endeavours to provide you with advanced notice of any modifications via email. 

Your use of the website, App and/or Services following the effective date of any modifications to this Privacy Policy will constitute your acceptance of the Privacy Policy, as modified. All changes to this Privacy Policy automatically take effect on the sooner of the day you use the site and/or services, or 14 calendar days after they are initially posted on our site. Your use of the site and/or services following the effective date of any modifications to this Privacy Policy will constitute your acceptance of the Privacy Policy, as modified.

Contact Details

InstaVox, Telbee Group Ltd.
20 Exhibition House Addison Bridge Place, London, England support[at]instavox.io

Privacy Policy last updated: June 2023