Policy Overview
Policy Overview
This “Privacy Policy” describes how and when Tangoe, Inc. and its subsidiaries and affiliates (“Tangoe”) collects, uses, shares and protects personal information of Tangoe’s clients, prospects, partners, consultants and website visitors.

Please note that additional terms and conditions apply to use of Tangoe’s Mobile Device Management (MDM) android application. For those terms and conditions please click here: Terms for Tangoe’s Mobile Device Management (MDM) Android Application

For purposes of this Privacy Policy, the term “personal information,” as identified below, refers to information that identifies an individual or relates to an identifiable individual. The types of personal information collected and used by Tangoe are identified below. Non-personal information is information that does not permit direct association with an individual. Tangoe may collect, use, transfer and disclose non-personal information for any purpose.

Collection and Use of Information
Clients, Prospects and Partners
Tangoe collects personal information from our clients, prospects and partners. The information may be collected by members of our marketing, sales, operations, professional services, client support and administrative teams. The type of information collected includes, but is not limited to: contact information (name, address, telephone numbers, e-mail address, company, etc.), user preferences, and event and conference participation information.
Tangoe uses the personal information it collects to respond to requests for information about our company, products and services, to manage your participation in our events, conferences, surveys and other promotions and to enable you to communication with Tangoe through its blogs, online forums, social media pages and other interactive media.

Client Employees
In order to deliver Tangoe’s services, we receive employee information from our clients that may contain one or more of the following data elements which are considered personal information: employee Id, name, title, location, corporate e-mail address, department/cost center, phone numbers, and corporate address.

We also receive billing and usage information of the assets we manage for our clients such as mobile devices, fixed lines or software subscriptions directly from the service providers or via our clients.
This data is only used for the delivery of Tangoe’s service to the client, which include the following processing;
• Create secure online databases to enable central asset and cost management & data visibility
• Align users to the corporate services they are granted access to on the central database
• Ensure vendor billing accuracy and compliance with their service contract terms
• Identify and effect cost savings and avoidance initiatives
• Ensure database is kept up to date, including access management
• Benchmarking and supplier negotiations
• Generate non personal, aggregate statistical and financial information at a client level

Further, upon explicit opt-in and only with the consent of the particular client employee, Tangoe may accept employee shipping address, credit card, and date of birth data. This information is stored for the sole purpose of requesting, approving, ordering, testing, and shipping wireless devices (I.e.: cellular telephone, pagers, calling cards, personal digital assistants, etc.), accessories and service to the client employee upon approval from the employee’s designated manager(s). This information is forwarded to the telecommunication carrier, designated carrier representative or accessory vendor selected by the employee for purposes of procurement, fulfillment and provisioning of the requested device, service, and/or accessory. Upon being notified by the telecommunications carrier or accessory vendor the order has completed, this information is purged from Tangoe’s records.

Web Visitors
Tangoe collects personal information about a visitor to our website only when the visitor chooses to provide such data. On certain pages, for example, a visitor has the opportunity to provide his/her personal information such as name, company, address, phone number, and email address. By supplying such information to Tangoe, a visitor can request details about Tangoe’s products and services.

Tangoe uses the personal information it collects to respond to requests for information about our company, products and services, register your company on our sites and identify you as a registered user, and to analyze trends and statistics regarding visitors’ use of our sites.

We may use Personal Information to operate this Site, to communicate with the users or to compile general demographic and business statistics. This information is also collected to aggregate statistical information, facilitate system administration, and improve the contents of the Site. We may also use information collected to notify Users of changes to the Site, and for any other legitimate and lawful business purposes.

Website/Cookies
Parties visiting Tangoe websites can visit sites without providing personal information; however, computers connected to the internet contain information such as IP address (Internet Protocol Address) and domain name which may identify the computer and network attempting to access our website(s). This information may be captured and stored for tracking and reporting purposes.

“Cookies” are pieces of information that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies allow the website to remember important information about a Tangoe website visitor. Like many websites, Tangoe uses cookies to improve the visitor’s on-line experience and to allow Tangoe to better provide support to its website visitors. For example, using cookies we track the total number of visitors to our site(s) on an anonymous aggregate basis. We may also employ cookies so that we remember you when you return to the site(s), to keep track of the items you have requested from Tangoe and to help us customize your web experience on return visits to the Tangoe website(s). Tangoe also keeps track of the pages you visit from our website and the content you access. We may associate personal information with a cookie file in those instances.

Some Tangoe websites use Google Analytics to help analyze how users use the site. The tool uses “cookies” which are text files placed on your computer, to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity for Tangoe’s websites.

We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personally Identifiable Information (PII) of visitors to our site. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source, unless you explicitly submit that information via a fill-in form on our website.

Disclosure of Information
Tangoe may contract with third-party vendors and suppliers to perform certain functions on Tangoe’s behalf or to enhance Tangoe’s existing product and service offerings. These third parties will have access to personal information only to the extent necessary to permit them to do their jobs. Tangoe will use reasonable efforts to obtain assurances from such third parties that they will safeguard personal information consistent with this Privacy Policy. Where Tangoe has knowledge that a third party is using or disclosing personal information in a manner contrary to this Privacy Policy, Tangoe will take reasonable steps to prevent or stop the use or disclosure.

Tangoe and its third-party vendors and suppliers may disclose or otherwise use personal information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or government request, (b) enforce the applicable contract between you and Tangoe, including investigations of potential violations thereof, (c) detect, prevent or otherwise address illegal or suspected illegal activities, security or technical issues, or (d) protect against harm to the rights, property or safety of Tangoe, its employees and customers or the public as required or permitted by law.

Tangoe may disclose personal information in connection with any reorganization, restructuring, merger or sale, or other transfer of assets, Tangoe reserves the right to transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with this Privacy Policy.

Access & Amendments
Maintaining an accurate database for our clients, using the data provided by the client, is a fundamental part of Tangoe’s routine service. Processes are established bespoke to each client’s needs and service during the implementation which ensure that Tangoe takes reasonable steps to aid users to correct, amend or delete personal information that is demonstrated to be inaccurate or incomplete.
Tangoe wants to make it easy for individuals to communicate update requests for changes to be made to their information and our staff are trained and familiar with their role in achieving this.
If a user becomes aware that personal information Tangoe maintains about that user is inaccurate, or if the user would like to update or review his or her information the user may contact Tangoe via the routes established for their organization which may include:
• Client HR department
• The Tangoe Service Manager
• Local Service Center
• Global Helpdesk
• The support section of the Tangoe software
• The advice given in the Tangoe service reference tools & documents

Tangoe will agree data change processes on a client specific basis. Most changes are provided in routine automatic data feeds by our clients. Where changes are managed by Tangoe the user will need to provide sufficient identifying information to commence the change request process. Tangoe may request additional identifying information as a security precaution.

Subject Access Requests (SAR)
Tangoe’s online services are specifically created to allow both individuals and their employees’ clear access to, and visibility of, all the billing data that is being generated against the assets they are using or providing.

Where a client has taken a service that allows end user access to their billing this allows individuals real time, unlimited access to their own data which is being held by Tangoe.

Under EU data protection law, individuals who want to know what data is being held about them and understand how it is being used, by any organization, can submit a Subject Access Request (SAR) in writing, which can be done using the “Contact Us” section of this privacy policy, below.

Security
Tangoe employs reasonable and generally accepted measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration or destruction, whether in transmission or storage. Tangoe conducts periodic internal and external audits to ensure that personal information is maintained in a manner consistent with this Privacy Policy. In addition, Tangoe conducts semi-annual SSAE 16 Type II audits from an independent auditor to ensure IT and operational security controls and policies are in place and enforced. Any employee, vendor, or supplier found to have violated this Privacy Policy will be disciplined, up to and including termination of employment or termination of service contract. Tangoe will further correct any deficiencies identified by internal and external audits to ensure continued compliance with this Privacy Policy. Please keep in mind that no security system can be guaranteed to be 100% secure. If you have any questions about the security of personal information, you can contact us via the “Contact Us” section of this Privacy Policy.

International Data Transfer
Tangoe delivers services globally and has employees in many locations, enabling us to deliver an effective local service and deliver cost savings to clients. As a standard our services may be delivered by employees based in any of our locations which include the United States, the European Union, India and China.

Tangoe will hold the primary contact details for every client on our central CRM tool and in our Client Playbooks hosted in the USA.

EU data protection legislation requires Tangoe’s clients to make a decision on their international data protection preferences and to communicate this requirement. As such the locations that a client’s data may be hosted, managed and accessed in will reflect the bespoke client contract terms agreed.

Where a client requires data to be transferred outside of the EU, Tangoe and the client sign Model Clauses to enable this to be achieved in compliance with the EU Data Protection Directive 1995 requirements of adequacy. Please visit http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm for more information on Model Clauses.

Safe Harbor
US-EU Safe Harbor was declared invalid in October 2015 however data transfer to the USA can still be achieved in compliance with EU Data Protection legislation by use of Model Contracts (see above).

Data Protection
Tangoe supports our clients in their compliance with the EU Data Protection Directive 1995, the UK Data Protection Act 1988 and will make reasonable efforts to support our clients in meeting their obligations and compliance with any relevant local data privacy laws, as they instruct Tangoe.

Tangoe is registered as a data controller with the UK Information Commissioner’s Office (ICO) at https://ico.org.uk/ESDWebPages/DoSearch .

Contact Us
Tangoe strongly encourages any complaints with regard to this Policy or Tangoe’s implementation of this policy be raised with Tangoe first using the contact information set forth below.

For suspected violations please include a description of the violation, date or timeframe in which the suspected violation occurred and your contact information. Tangoe takes any report of Privacy violation very seriously and will investigate each report to the fullest extent possible.

Subject Access Requests may also be submitted to the details below.

OfficeOfPrivacy@Tangoe.com
Tangoe, Inc.
35 Executive Blvd,
Orange CT 06477 USA
ATTN: Chief Privacy Officer

AGREEMENT TO TERMS AND CONDITIONS
Access to and use of Tangoe sites by an individual shall form an acknowledgement and acceptance by such individual of these terms and conditions and this privacy policy.

Changes to this Privacy Policy
Tangoe reserves the right to change this policy at any time and will post the Privacy Policy at https://www.tangoe.com/privacy-policy/
Last updated: February 8, 2016