1. Who we are
UWTelecom is the leading VoIP
switch-based telephone company in Costa Rica, Panama, Nicaragua, the United States and
Canada. Our main offices are located in Florida and Escazu, Costa Rica. Founded in 1996,
United World Telecom has quickly changed into a company with global presence by offering a
large variety of telecommunication products such as International VoIP phone lines, 800
numbers and mobile VoIP.
In the current VoIP Communications
Network marketplace, one of our greatest advantages is the sound quality provided to all of
our subscribers. Contrary to our competition that seeks to give their customers a lower cost
by sacrificing quality, UWTelecom has managed to keep track of what is important –
good quality at a good price.
Thanks to our advanced network of
new generation equipment, we are able to connect to several high-level companies such as
AT&T, Sprint, Global Crossing and Teleglobe – ensuring fast connections and the
highest quality. Our reliability, customer support and low-prices are the keys to our
We are a cloud-based communications
provider for enterprises. Our solutions include a broad range of software APIs for voice and
text functionality, as well as our own IP voice network. As used in this Privacy Notice,
“personal data” means any information that relates to, describes, could be used
to identify an individual, directly or indirectly. This does not include anonymous or
de-identified data, which does not relate to an identified or identifiable natural person or
cannot be linked to or identify an individual.
This Privacy Notice applies to
personal data collected by UWT through the uwtelecom.com, uwtelecom.net, uwlatino.com
website, and other websites which we operate and where we post a direct link to this Privacy
Notice, including digital, paper, and in-person communications. This Privacy Notice does not
cover handling of your personal data as an employee, intern, consultant, contractor or
applicant of Bandwidth and does not cover any information collected by third-party sites or
content or applications that may link to or be accessible from or on our websites. This
Privacy Notice is provided in a layered format so you can click through to the specific
areas set out below. Alternatively, you can download a pdf version of the policy here:
Please read this Privacy
Notice carefully to understand how we collect and process personal data.
2. Personal data that we collect
Identifiers, your full name, address, email, company name, company website, telephone
number, caller ID information, unique personal identifier, online identifier, Internet
Protocol (“IP”) address, proof of address and ID of end users (where there
is a regulatory requirement).
Account Payment Information, your credit/debit card number, signature, bank wire
Commercial Information, records of products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies.
Internet or Similar Network Activity, your browsing and search history, information on
your interaction with our websites and advertisements, information about the
communications delivered via our platform.
Metadata, information about the communications delivered via our platform such as
source and destination information, IP address, completion status, time and duration of
Geolocation Data, when you use our products or services, such as source and destination
information about the communications delivered, real-time location information for
emergency service via the Bandwidth products or services.
Cookies and Other Technologies, website cookies and similar technologies to distinguish
you from other visitors and compile information about the usage of our websites. For
further information, please see “Cookies and other tracking
Sensory Data, your interactions
with our sales and customer support teams may be recorded for quality assurance,
training, and analysis purposes (consent will be recorded if required by applicable
law). When you use our products or services, it may include text-to-speech
transcriptions, DTMF tones, media in your voice calls and text messages (only applicable
3. How we collect your personal data
We use different methods to collect
personal data from and about you including through:
Direct interactions. You may give us information about you by filling in forms,
engaging in chat on our website, accessing or utilizing any of our websites, opening an
account with us, requesting support, subscribing to our newsletters, requesting
information or materials (e.g. whitepapers), registering for events or webinars,
visiting our booth at a trade show or other event, participating in surveys or
evaluations, accessing or utilizing any of our websites, submitting questions or
comments, or by corresponding with us by phone, email, video, or otherwise.
Automated technologies or interactions. As you interact with our websites, we may
automatically collect technical data about your equipment, browsing actions, and
patterns as specified above. See “Cookies and other tracking
Third parties or publicly available sources. We may receive information about you if
you visit other websites employing our cookies or from third parties including, for
example, advertising networks, analytics providers, through publicly available data,
such as social media (like LinkedIn, Facebook, and others) and websites.
Indirectly. As a service
provider in the course of providing voice and messaging communications
4. How we use your personal data
We may use the personal data we
collect for one or more of the following purposes:
To fulfill or meet the reason you provided the information and to provide our products
To respond to your inquiry about our products and services, including to investigate
and address your concerns and monitor and improve our responses.
To enable our customers and end users to send and receive communications via our
platform and to bill for those services.
To inform you of additional features, expanded coverage or other products or services
offered by us.
To allow you to interact with our systems, including our websites.
To create, maintain, customize and secure your account with us.
To process your requests, purchases, transactions and payments.
To bill, collect, and remit taxes, fees and surcharges to the appropriate
To personalize your website experience and to deliver content and service information
relevant to your interests, including targeted offers, marketing communications and ads
through our websites, third-party sites and via email.
To maintain the safety, security and integrity of our website, services, databases and
other technology assets and business.
For testing, research, development, and analysis; mitigation of fraud and spam (as
applicable per specific product offering), unlawful or abusive activity, or violations
of our Acceptable Use Policies; perform quality control; gauge routing effectiveness and
deliverability and product development, including developing and improving our websites
and products and services. Specifically, with respect to MMS and SMS messaging, we
utilize industry-standard content-analysis software which utilizes electronic,
algorithmic inspection of the originating telephone number and/or content of MMS and SMS
messages for purposes of spam blocking (only applicable to US).
If you have elected to have your name, address, and telephone number published in
directories, we may share such information with directory publishers (who publish white
pages, yellow pages, and other similar directories) and directory assistance
As described to you when collecting your personal data
Law enforcement, security, and safety.
To respond to law enforcement requests and as required by applicable law, court order,
governmental regulations, or other legal process where we believe in good faith that
disclosure protects your safety or the safety of others, or where we need to protect a
legitimate business interest such as fighting against fraud that harms our
For security purposes to register visitors to our offices and to manage non-disclosure
agreements that visitors may be required to sign, to the extent such processing is
necessary for our legitimate interest in protecting our offices and our confidential
information against unauthorized access.
Asset transfer and/or M&A Activity.
evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution,
or other sale or transfer of some or all of UWTs assets, whether at UWT’s
discretion or as part of bankruptcy, liquidation, or similar proceeding, in which
personal data held by Bandwidth about you is among the assets transferred.
UWT will not use the personal data
we collected for materially different, unrelated, or incompatible purposes without providing
you notice. We may use non-personal data for any business purpose. To improve our products
and services, we commonly will de-identify/anonymize or aggregate your personal data (so
that it can no longer be associated with you), in which case we may use this information
indefinitely without further notice to you. The legal basis for collecting and using the
personal data described above will depend on the personal data concerned and the specific
context in which we collect it, including but not limited to: (a) performance of a contract;
(b) legitimate interest; (c) necessary for compliance with a legal obligation; or (d)
consent to collect and process your Personal Data.
5. How we share your personal
We may disclose your personal data
to a third party for a business purpose. UWT may share your personal data in the following
To companies that perform services on our behalf only as needed for them to perform
those services, including other communications providers in order to route
communications over the Bandwidth network.
To any member of our corporate group, which means our subsidiaries, our ultimate
holding company and its subsidiaries.
To advertising and marketing companies and networks.
To data analytic providers.
To other companies and entities, to:
Respond to emergencies or exigencies;
Comply with court orders, law, and other legal process, including responding to any
government or regulatory request;
Assist with identity verification, preventing fraud, and identity theft;
Provide directory assistance services, with your consent.
To fulfill the purpose for which you provide it.
For any other purpose that we disclose in writing when you provide the personal
With your consent.
To sell, transfer, merge, divest, restructure, reorganize, or dissolve all or a portion
of our business or assets.
To enforce our Terms and Conditions and other agreements.
protect the rights, property, or safety of our business, our employees, our customers,
6. Data subject rights
Under certain circumstances, you as
a data subject have the below rights under data protection laws in relation to your personal
Right to access. You have the right to request a copy of your personal data and
Right to rectification. You have the right to request that we correct any information
you believe is inaccurate. You also have the right to request that we complete
information you believe is incomplete.
Right to erasure. You have the right to request that we erase your personal data, under
Right to restriction of processing. You have the right to restrict the processing of
your personal data, under certain circumstances.
Right to data portability. You have the right to receive personal data you have
provided to us in a structured, commonly used and machine-readable format. You have the
right to request that we transmit this data directly to another controller.
Right to withdrawal consent. In the event our processing is based on your consent, you
may withdraw your consent at any time. The withdrawal of consent will not affect the
lawfulness of processing based on consent before its withdrawal.
to object to processing. You have the right to object to the processing of your personal
data at any time, under certain circumstances.
Data controller of our websites:
UWTelecom, Zircon Internacional S.A., San Jose, Costa Rica. Data controller for our products
and services is the entity that you contracted with. To exercise any of the above rights or
if you have any questions about this Privacy Notice, please enter them in the DATA SUBJECT
RIGHT REQUEST FORM. You may also make a complaint to a relevant data protection supervisory
authority in the USA, EU and UK. We would, however, appreciate the opportunity to address
your concerns before you do so.
Fees. 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 could refuse to comply with your
request in these circumstances.
Information we may need from you. 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 assist with our
Timing. We try to respond to all
legitimate requests within one month of receipt of the request. Occasionally, it could
take us longer than a month if your request is particularly complex or you have made a
number of requests. In this case, we will notify you and keep you updated.