Services Privacy Notice

Tangoe likes making complicated things simple and transparent, and so we want to explain how we will use your personal data in a simple and transparent way.

Tangoe is interested in data protection laws because they govern the way we use the personal data (“data”) you give us throughout your time as a user of Tangoe’s services. This Privacy Notice explains how Tangoe uses the data we receive from you, your employer and your organization’s vendors.

Personal data is any information that could be used (directly or indirectly) to identify an individual. That may be anything from a name and address, email address, image or audio recording, IP address, telephone number or any other data that could be used to identify an individual.

We have tried to provide all the information we think you may want to know, but if you have any questions please contact us.

Tangoe believes in using your data fairly. There should be no surprises.  We will only use your data for the reason for which you or your employer gave it to us, for the delivery of agreed services or for legal or regulatory purposes.  It will not be used for other reasons.

We will not keep it longer than we need to and will only share it with people where this is required for the services or legal purposes.

Tangoe will only access data that your employer has authorized Tangoe to collect or receive. Tangoe obtains your data from different sources during the following stages of the service lifecycle;

  1. Contract signature
  2. On boarding (implementation) and in-life services

[Note: If you provided data within the sales cycle this is managed in line with Tangoe’s Marketing Privacy Notice ]

  1. Data collected throughout the contract signature process

    Certain data is passed to Tangoe to allow the contract to be executed prior to implementation of the services.  This will usually be the contact details of individuals within your legal or procurement department and the contact details for your applicable vendors.

    For a full breakdown of these data categories click here.

  2. Data collected during on boarding (implementation) and in-life services

Once the contract is signed, Tangoe’s implementation teams will initiate the design and build of the databases required to provide your services by requesting in scope data.  This data will be updated, and changes reflected based on information that continues to be provided throughout the duration of the services.  Additionally Tangoe generates personal data whilst delivering the services, such as system user ID or usage logs.

For a full breakdown of these data categories click here.

Tangoe gets your data from a variety of locations and through different media as mutually agreed during the implementation, and bespoke to your organization.

Usually HR information is provided by automated electronic means via an SFTP site. Where possible Tangoe collects your billing data from your vendor’s portal, where your vendor doesn’t offer a portal, alternative data transfer media such as SFTP, emails or CD’s may be used. Tangoe will generate additional data about individuals during the provision of services such as systems passwords, user IDs and user logs.

Depending on the services you have contracted Tangoe to provide, or your interactions with Tangoe, additional data may be collected, for example if you use our service center we would raise a ticket to track the progress of your request being actioned.

For a full breakdown of the ways Tangoe can collect data click here.

Tangoe does not require special categories of data to deliver its services.

Data protection law requires organizations to consider if using data is necessary and lawful. It is Tangoe’s clients’ obligation to ensure its employees’ data is used lawfully, with fair processing notice and to establish the lawful basis for use of Tangoe’s services.

Tangoe will only use your data for the provision, improvement and support of the contracted services; or for legal or regulatory purposes.

Tangoe understands how important confidentiality and appropriate use of your data is to a trustful working relationship. As such your data will only be shared where it is necessary to do so.

During routine service delivery this means that our employees, across all our subsidiaries, are assigned access based on their alignment with your services and their role within this. Other Tangoe employees may also see specific

 
Role Purpose (What do they do?)
Product Engineering Support trouble tickets
Customer Service Delivery of the contracted services as outlined above
IT Administrators To manage the systems and for access requests
Database Administrators Manage the database systems
Finance Team To generate invoices
Quality Team For audit purposes
Tangoe Advisory Services If contracted, for
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. Additionally, Tangoe may be obliged to disclose data for legal or regulatory purposes.  These third parties will have access to data only to the extent necessary to permit them to do their jobs which may include:
  • Tax regulator or equivalent
  • Tangoe’s external auditors
  • Supervisory Authorities, Government or Regulatory bodies
  • Your employers’ telecom vendors and third party suppliers for expense management, audit and procurement purpose
Tangoe’s third party suppliers which may include:
  • payment processing services
  • fraud monitoring and prevention
  • email, ticketing, survey or group texting platforms
  • subcontractors
  • data receipt, redirection, storage & archiving
  • data hosting centers

Tangoe may disclose data in connection with a reorganization, restructure, merger, sale, or other transfer of assets.  Tangoe reserves the right to transfer information, including data, provided that the receiving party contractually agrees to respect your data in a manner that is consistent with Tangoe’s Data Protection Policy and your organization’s data processing agreement.

Tangoe will never sell your data to a third party.

Tangoe is a global organization with a US parent and our central administration is held in the USA. For a full list of Tangoe’s locations please look here.

Your corporate contacts will be held in the USA where it can be viewed, accessed and used by Tangoe employees, and some suppliers to provide the services.

Tangoe software is hosted by specialist third party Tier 3 super sexy and secure data centres etc etc  For the hosting location of your organization’s data please refer to the data processing agreement executed between Tangoe and yourselves.

The employees, subconrt, advisors and software providers Tangoe use will vary dependent on the services that your organization has requested.  Please refer to the applicable data processing agreement for more detail on which subprocessors are used and where they are located.

In most instances your data will be accessed by our employees and/or service providers in multiple locations, including located outside the EU. Where this occurs, and EU data is in scope of the services, Tangoe enters into a contract called EU Standard Contractual Clauses with your organization to protect your data when it leaves the EU.

Tangoe’s operations are structured into departments which use your data to enable the element of the TEM service for which they are responsible. The below framework depicts a high level representation of the data required and the standard key stages in TEM delivery.
As required by your services, Tangoe will undertake the following Data Processing:
  • collect and use your data to provide the services and technical support
  • combine your HR data with your billing data to enable financial and asset management
  • store your data on the service platform/s, email exchange, shared or local drives and support systems
  • validate the data for errors and exceptions managed
  • normalise the format of the data so it can be loaded into the Tangoe software
  • link telephone numbers to ‘friendly names’, upon client’s request
  • access the data based on job roles and permissions to deliver and support the services
  • analyse the data to generate savings opportunities and identify billing errors
  • create and manages back-ups
  • generate reporting or recommendations
  • return and/or delete from our systems in accordance with your contract terms and Tangoe’s retention schedule
  • upload any patch, update, upgrade or new releases to the services
  • use data for testing and QA purposes under the same level of protection offered on production platforms (where authorised by your organization)
  • use the data for legal and regulatory purposes (e.g. audit, accounting and statutory retention terms), resolve disputes, and for the establishment, exercise or defense of legal claims
  • analyse and monitor for business planning, resources and financial management
  • collect user input regarding services and assets
  • automatically track user logins, errors, system changes, access and report generation
  • enable single sign on to Tangoe software
Where your organization uses the following Tangoe services, these data uses apply;
Type Role
Expense Management Collection of telecom vendor invoices in both electronic and paper formats, normalization of the data and load to your company’s dedicated Expense Management portal. Allocation of invoices to your company’s supplied allocation codes and production of reporting and payment files.
Inventory Management Discovery and maintenance of your company’s billing inventory (mobile and fixed lines) on telecom vendor invoices with associated reporting.
Optimisation Billing data is analysed to produce an optimization report which is provided to your organisation containing cost saving or efficiency recommendations. Where recommendations are signed off by customer, Tangoe will effect the change with the vendor.  Results, savings and management statistics are generated.
Accounts Payable (AP) File Tangoe maintains your organisational hierarchy and asset register in accordance with the information your organisation provides, generates an accounts payable (AP) file based on the structure designed for your organisation which is sent on in agreed frequency and format, if required.
Procurement & Fulfilment Tangoe receive procurement requests either through emails, telephone or directly into the ordering system.  The requests take the form of modifications, additions, changes and disconnections of devices and are all logged into the internal ordering tool for action.  The request status is monitored and communicated back to the requestor at all stages of the process. Requests go through an approval workflow, and once approved are managed by the fulfilment team who ensure the request is completed. Upon completion of the request, the service ticket is closed on our systems. Performance, management and resource statistics are generated.
Audits and Reporting Tangoe conducts an audit of the billing data, identifying billing errors and ensuring compliance with vendor contract terms.  Non-conforming items are recorded and reported.  Management, savings and statistical reporting is generated.
Audit Dispute Resolution Where Tangoe has identified erroneous charges, a dispute process is following which includes recording the identified items, raising then managing a dispute with the applicable vendor, tracking progress and communicating the outcome back to you. Results, savings and management statistics are generated.
Service Desk Service requests are received via email or telephone call from your employees to Tangoe’s service desk where they are worked through the applicable process to close. Tickets are used to record the request or issue, and its progression.  Performance and resource metrics are generated.
Tangoe Pay Payment of telecom vendor invoices by Tangoe on behalf of your company. Vendor invoices and billing data are used to create electronic payment files and verify payment of charges.
Advisory Services Aggregated usage and cost data from telecom invoices is used to develop customer benchmarks and baselines against market rates.
Automated processing of data does take place however no decisions are made that could have legal or other equally significant impact on an individual without human involvement and consideration taking place.
We hope that our organizations will have a long and happy collaboration, however if your services should end for any reason the data would be retained, returned, and deleted in accordance with the terms of your organization’s data processing agreements.
Data security is very important to Tangoe and, whilst no security controls can ever be 100% effective, Tangoe is committed to driving strong security measures to protect your data’s security, confidentiality, and integrity.

No.  Tangoe will never use the data you provide for the delivery of services for direct marketing or sales purposes.

If you have given Tangoe your data when attending a Tangoe event, via our website or similar marketing event, use of that data is covered in Tangoe’s Marketing Privacy Notice displayed on our website.

The primary contacts for our clients’ relationships will be sent information pertaining to the services and may be invited to join us at special educational or service events such as Tangoe Live.

Data protection legislation gives individuals rights. To find out more about your rights please click here.
Tangoe keep this Privacy Notice under regular review to make sure it is up to date and accurate, and so we may change this Privacy Notice from time to time. However, we will not reduce your rights under this Privacy Notice. Updated Privacy Notice’s will be displayed on the Tangoe system, the ‘last updated’ footer tells you when we last updated it.

Tangoe US, Inc. together with its’ global affiliated companies (“Tangoe”) is a leading global provider of Technology Expense Management (TEM) and Managed Mobility Services (MMS) solutions to a wide range of global enterprises.  Tangoe helps companies work smarter to drive both bottom-line improvements and top-line growth.  Our head office is 169 Lackawanna Avenue, Parsippany, NJ 07054, USA.  You can find out more about Tangoe, what we do and our organization here.

If you have any questions or concerns Tangoe welcomes the opportunity to discuss and help resolve these.  Our Data Protection Team can be contacted on

dataprotection@tangoe.com

or by post at: Data Protection at Tangoe, 10 Park Square, Milton Park, Abingdon, Oxfordshire OX14 4RR

In the EU, if you feel that Tangoe has not been able to resolve your data related concern you are entitled to make a complaint to a Supervisory Authority, such as the UK’s Information Commissioner’s Office.

This Privacy Notice last updated on March 18th, 2019.

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