Privacy

Landis Technologies Privacy Policy

Legal information

At Landis Technologies LLC (“Landis” or “we” or “us”), we care about privacy, security and transparency; these are core tenets in our company’s mission. Toward that, this privacy notice tells you what to expect when Landis collects personal information about you, including:

• How Landis collects data;

• Understanding who controls your data;

• Landis’s lawful basis for processing your data;

• Understanding Landis services;

• Information sharing and transborder flows;

• Security, compliance and certification assurance;

• Your data protection rights;

• Special information for Residents of California, USA

• Data retention;

• Our Commitment to Data Protection and

• Future changes to this Privacy notice.

Landis Technologies LLC has a registered address at 1120 Division Hwy, Ephrata, PA 17522, United States. The main website for Landis is https://landistechnologies.com/

This privacy notice is effective as of February 2024.

How Landis collects data.

One of the purposes of this Privacy notice is to explain how we collect and process personal data. The primary ways we collect information are as follows: (a) by visiting one of our websites; (b) by subscribing to our service purchased by your Employer or Business from Landis

Please be informed that this website is not intended for children, defined as age 15 and under; we absolutely do not knowingly collect data from children and will immediately delete it if discovered.

We encourage you to read this Privacy notice. It has been written to ensure you understand how we collect information, how it is safeguarded, what is collected, how it is processed, where it is processed, with whom we may share it, and your rights under the law.

Understanding who controls your data.

When you subscribe to Landis services as a Named User, we act as a Data Processor (“Processor”) under the instructions of the Data Controller. In this instance, all future requests or exercises of your rights must be made to the Controller.

When the Landis service is used in the context of US healthcare, a Business Associate Agreement between Landis and the Customer/Partner is required. We use appropriate safeguards to prevent the use or disclosure of ePHI other than as provided for in the agreement. We use administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the electronic PHI that is created, received, maintained, or transmitted via the service on behalf of the subscribed Covered Entity or Business Associate.

When you share information with us directly by visiting our website, Landis acts as a Data Controller (“Controller”) according to the definitions in Article 4 of the GDPR. This Privacy notice applies when we are acting as the Controller with respect to the personal data we process about you. In other words, where we determine the purpose and the means of the processing, we are identified as the Controller and we are responsible for controlling and safeguarding your personal data.

Toward that, we have assigned a Privacy Officer to superintend all aspects of this Privacy notice, ensuring your questions are answered and your rights are respected. Whenever you have questions, you should contact the Privacy Officer via one of the venues below:

Landis Technologies LLC

Privacy Officer

1120 Division Highway,

Ephrata, PA 17522,

United States

Email: [e-mail]

Landis’s lawful basis for processing your data.

Landis will only process your data according to the allowance permitted by law. In most instances, we will only use your data in the following situations:

• when you provide us with your consent to process your personal data which may be revoked by you at any time and for any reason;

• when it may be necessary for our legitimate interest;

• when we may need to respond to a legal requirement or regulatory action; and

• where we need to fulfill our obligation to provide services when you subscribe to our services.

In the following table, we describe ways your personal information may be used; each of these uses are tied to a legal basis for processing. Further, we have also outlined wherever we have a legitimate interest to process your data where appropriate.

Processing Data	Personal Data	Lawful Basis
Requesting information and relationship management including emails to us, requests for marketing information, enquiries about services, responding to feedback, notifying you about changes to our terms and conditions, notifying you about changes to our Privacy notice, sending you communication through our newsletters and news bulletins, asking you to update your contact information, communicating with you about our service.	Identity data, contact data, communication data, marketing preferences.	Article 6: (b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract. (c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations). (f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Subscribing to Landis services.	Name, email address, regional settings, call detail records, call participants to scheduled conferences, media streams and recordings, connection history, technical information about your device hardware and operating system, call diagnostics, last login and operating system, last active and connected date (O365), userID, time zone, administrative flags, localisation.	Article 6: (b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
Service desk support for the Landis service.	If working with our service desk to troubleshoot an issue, we may also gather information about the type of computer systems you use, including associated devices such as microphones and video cameras as these are relevant to the services offered by Landis. The information may also include your IP address, operating system, browser type, language preferences, and other relevant details to help Landis ensure your service is working correctly.	Article 6: (b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
Website analytics.	Please be informed that we use a third-party analytics service called Google Analytics to collect, analyze and tally metrics regarding website visits. Analytics help us to determine many things, including the quantity of visitors over time, the geographic location from which visitors arrive, timeframes of high and low usage, the sites most frequented, the pages most frequented, and other helpful data. The Company processes data in ways to ensure individual identity is not stored, only anonymous metrics. Furthermore, it is forbidden for Google to determine, or attempt to determine, the identity of individuals visiting our websites, and this anonymity is inherited by Landis.	Article 6: (a) Consent: the individual has given clear consent to process personal data for a specific purpose.
Recruitment process and employment in Landis.	Personal data including demographics, contact information, grades, certifications, CVs, general data, tests and other government issued identity documents.	Article 6: (a) Consent: the individual has given clear consent to process personal data for a specific purpose. (f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests

Understanding Landis services.

This section applies to users of Landis services. If you only use the Landis public website, this section does not apply to you.

Landis services are driven by an Internet-based communication platform designed to enable business users to communicate using voice calls. The person adding you for the first time to an organisation will provide certain information about you for provisioning, such as your name, company name and work email address.

Wherever possible, the media associated with all Landis originating or terminating audio communications (“calls”) is encrypted. Calls are recorded and saved using Landis’s recording services. Recordings saved using Landis’s recording services products cannot, under any circumstances, be accessed by Landis employees without your organization’s written permission. Speech-to-text conversion of Named Users alone is done by Landis for the purpose of training and quality assurance. Where you have given us your consent, we may monitor call metrics to investigate bugs and service issues. Call records will not be made available to anyone outside of Landis without the prior consent of the organisation whose Landis services account was used to originate the calls. Landis reserves the right to anonymize and save your data for any research or statistical purposes.

The Type of Personal Data we collect to provide our MS Teams related services include

· Named Users Data: Full Name, Email Address, IP Address, User Role

· Communications Data: The Call Participant Data which includes Name and Email address of the Named Users and the individuals who either receive or make calls to them. The Call Logs Data which include Microsoft Unique Identifier and call metrics. The Audit Logs generated by the Services which capture the user activities, IP address for support and tracking purposes.

· Landis Policy Call Recording for Teams: Audio streams covering both ends of the call and Speech-to-text conversion of Named Users alone (for training and quality assurance purpose)

Information sharing and transborder flows.

Landis respects your right to privacy and we do not use or share your personal information in any other way beyond what has been written in this Privacy notice. For instance, we do not sell your information to anyone, including but not limited to third parties for their own marketing use.

As a Data Processor, Landis is acting under the instructions of the Data Controller and may share your data with the Controller in support of your service.

We will inform you or your Data Controller if we are required to share your information under any of the following circumstances: (i) to the extent that we are required to do so by applicable law, by a governmental body or by a law enforcement agency, or for crime prevention purposes; (ii) in connection with any legal proceedings (including prospective legal proceedings); (iii) in order to establish or defend our legal rights; (iv) in the event that we buy or sell any business or assets, in which case we may disclose your personal data to the prospective sellers or buyer of such business or assets; or (v) if a third party acquires all (or substantially all) of our business and/or assets, we may disclose your personal information to that third party in connection with the acquisition.

A list of the external third parties are provided below:

· Microsoft Corporation

· Freshworks Inc.

· Intuit Mailchimp

The content below is applicable only for EEA, Swiss and UK Customers. If your organization is based out of other countries, then it does not apply to you.

Whenever we transfer your personal data out to third countries, we ensure a similar degree of protection is afforded to it by employing at least one (or more) of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries .

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries . In these cases, due diligence of the legal system in the third country to which personal data will be transferred is carried out; the rules for disclosure to and access by government agencies is verified as is whether the service provider is bound by these laws. The likelihood that the service provider will be disclosing personal data of Landis to the authorities in that third country is evaluated, including categories and volume of personal data transferred, purposes of the processing by the service provider, duration of data retention in the third country and any past practices of such disclosures. The service provider’s policies and procedures for:

  • notifying Landis to the extent permitted by law, if a government demand extends to the exporter’s data;

  • providing an opportunity to resist production; and

  • complying with its obligation to notify Landis that it can no longer comply with the requirements of the model contract clauses and cease processing the personal data in the event of any government demand that would not allow it in practice to comply with the contractual clauses.

Landis will confirm, on the basis of the due diligence carried out, that the model contract clauses, in conjunction with any other applicable contractual terms for the relationship, are sufficient to address any issues raised as to the protection of personal data in the third country in that context or whether the circumstances require more specific terms.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security, compliance and certification assurance.

At Landis, we have a security and compliance team actively working to keep your information protected, auditing the security posture and improving safeguards from unauthorized access, accidental loss, disclosure or destruction. Toward this, we employ physical, technical, administrative, and organisational safeguards to protect the personal information we collect and process. Administrative and organisational policies and procedures are documented in the Landis Information Security Management System (ISMS) where appropriate controls are designed to maintain an adequate level of data confidentiality, integrity and availability.

Landis is currently implementing ISO/IEC 27001:2022 and has engaged Allendevaux & Company in its endeavour to attain ISO/IEC 27001:2022 certification which is expected by Q2 2024. Also, independent technical vulnerability scanning and penetration testing are performed through Allendevaux & Company.

Your data protection rights.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), if it is shown we have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c ) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the above rights, please contact us at [e-mail].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

In exercising these rights, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within the timeframes set by applicable law and regulations.

In relation to Landis Services, we are Processor (and not Controller under GDPR) and hence all the data subject rights related to Landis Services should be directed to the Controller.

Special information for Residents of California, USA

In relation to Landis Services, we are Service Provider (and not Business under CCPA) and hence all the data subject rights related to Landis Services should be directed to the Business who would then engage us.

If you wish to exercise any of the data protection rights, please contact us at [e-mail] or write to us via postal mail to the below mentioned address:

Landis Technologies LLC

Privacy Officer

1120 Division Highway,

Ephrata, PA 17522,

United States

Data retention.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after ceasing to be a customer for taxation purposes.

In cases where we decide the means and purpose of processing and act as controller, you can ask us to delete your data and we shall address it in a timely manner, subject to legal and regulatory obligations and keep you informed of it. In other cases where we act as service provider or processor, we will route your requests to the Business or Controller for actioning your request to delete your data. We may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Our Commitment to Data Protection.

Landis is committed to the highest standards of information security, privacy and transparency. Towards this, Landis complies with data protection laws around the world where we process information and protect data subject rights. These include:

· EU Regulation 2016/679 (the GDPR)

· EU Regulation 2018/1725

· UK General Data Protection Regulation (UK GDPR)

· UK Data Protection Act 2018 (DPA 2018)

· California Consumer Privacy Act of 2018 (CCPA)

· Swiss Federal Act on Data Protection (FADP)

Future changes to this Privacy notice.

As our services evolve, this Privacy notice may change or other privacy policies may be written and posted specific to new offerings or to keep pace with data privacy laws. When changes are substantial, we will endeavour to make you aware of any forthcoming changes by attempting to contact you via our user interfaces, portals, or through your partner or reseller. If you have questions or comments on a future privacy notice, you may write us at [e-mail].

Questions for Landis.

If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please contact us by email at [e-mail].