CallMyWay Privacy and Data Protection Policy
01_CMW_25
Last updated: May 15, 2025
CallMyWay NY, SA and its group of companies, with registered office in Zapote, San Jose, Costa Rica, in front of the main entrance of the Bar Association, is a telephone service provider, developer and supplier of voice technology software products and related services among others (Services).
We appreciate your visit to our websites and use of our Services.
This Privacy Policy helps you understand how we, as data controllers, collect, use and protect your Information Provided, Collected or Generated -Information- through our website or our Services.
For you to know how our Privacy and Data Protection Policy operates and how we protect your Information, which for any reason is entered into, transferred or stored in our systems, we present our Privacy Policy:
1. Definitions
1.1 Service Contract: Refers to the Service Contract signed between CallMyWay and the User where the benefits of the Contracted Service are defined.
1.2 Cookies: Cookies are small data files that our website or Services send and store on your device to improve your experience, remember your preferences, collect information about your use of the Website or Service, and, in some cases, for advertising or analytical purposes. You can manage your use of Cookies through your browser settings. We use three types of Cookies: Functional, Statistical, and Marketing.
1.3 Information: Collectively refers to Generated Information, Collected Information and Provided Information, for CallMyWay all Information is Confidential and is treated as such under this Privacy Policy.
1.4 Generated Information: This is the information we store and that is generated by the use of our website or by the use of our Services.
1.5 Information Collected: This is information we collect through your use of our website or Services, which may be personal or otherwise.
1.6 Information Provided: This is the information that you provide to us truthfully and voluntarily, which may be personal or of any other nature.
1.7 Privacy Policy: This document includes all our Privacy policies.
1.8 Private Section: Refers to the section of our website that is accessed with credentials previously provided by CallMyWay.
1.9 Public Section: Refers to the Section of our Website that any Internet user can navigate without limitations.
1.10 Services: Refers to all current or future services provided by CallMyWay, including but not limited to: Phone Calls, DID Service, Cloud PBX, Intercom, IsMyConnect, IsMyPeers, IsMyContact, IsMyFlux CHAT or VOICE, IsMyBiometris, Pitanga Control, Call Analytics, Call Recording, IsMyPeers, 360 Omni Channel, Click2Call, Automatic Survey, SMS Service, Fax2Mail, Bitácora Corporativa, IsMyLocation or any other Service provided or contracted with CallMyWay.
1.11 Website: Refers to the website(s) of CallMyWay, its related Services or any of its affiliates.
1.12 User: Refers to the Client, Person, Company, Entity or Entity that uses the CallMyWay Website, both in its Public Section and the Private Section, as well as that uses the CallMyWay Services.
2. Application of our privacy policy
This Privacy Policy applies to the Information that the User provides or allows CallMyWay to store, with the Website, both in the Public and Private Sections, as well as with the Services.
3. Information collection
You do not need to provide any information to use the Public Section of our CallMyWay website. However, we may collect certain information, and you may provide us with certain information, which we may then associate with your computer with cookies.
To use the Services and the Private Section of the CallMyWay website, the User must first register to obtain credentials and use the Service. To obtain your credentials, you will be asked to provide certain personal information about yourself, your company, or someone you represent, such as, but not limited to name, address, email address, phone numbers; and an account password or other information specified in your CallMyWay account. You may also be asked to provide various personal or other information, such as, but not limited to, date of birth and general demographic information, among others, which will be used solely for CallMyWay internal analysis.
Finally, if you use any of our Services , Generated Information or Collected Information may be stored on our servers, such as: telephone call history, recordings, transcriptions and/or analytics of those telephone calls, information about your interactions with your CRM/ERP or ours, biometric information or activities of the computer on which the telephone calls are made or on which any of our software or applications are installed to use our Services .
3.1 Tracking your account activity
Once the User has registered and uses his or her CallMyWay account, our Services or our Website , whether public or private, information about his or her use may be recorded, processed and stored, such as, but not limited to: the frequency with which he or she uses his or her CallMyWay account, the frequency with which he or she uploads or downloads audio, video and information files, among others, the size of the content generated and other activities related to the use of the Services or the CallMyWay Website .
3.2 Computer browser
Your computer browser also provides certain information through cookies (cookies are small data files placed on your device, such as your computer, phone, tablet, etc.). You can learn more about how we use cookies in Section 6 of this policy.
3.3 Why we collect and process your Information
All information collected about you, your account, and your activity on our Services or Website is part of the Services you have contracted and that you request us to store for your use and for the purposes you deem appropriate, through your account. The portion that corresponds or does not correspond to the Services explicitly contracted and that we collect helps us improve our Services to better meet your needs. It also gives us a better opportunity to understand your demographics in detail; the use of your account and our Services, helping us with customer acquisition and marketing strategies, as well as with research and development of our products.
3.4 Personal information about third parties
If you provide us with any information about third parties, you guarantee that you are authorized to provide us with such information, to collect and use it in the same way as your information. Provided, Collected or Generated.
3.5 Accuracy of information
You should only provide us with current and accurate information. You can update this information through your CallMyWay account.
4. Use of the information or the account you use:
4.1 Information you share with us and how we use it
We may use your Information in the following situations:
- To create and manage your account.
- To communicate with you (opt-out options available).
- To modify our services to better meet your needs.
- To fulfill our Service Contract and provide you with the contracted Services.
- To develop a detailed and anonymized understanding of your demographics; as well as account use for research and development of the CallMyWay Service and applications.
- To analyze our business, customer service, advertising, and marketing strategies.
- As required by law.
Ensuring your privacy is important to us. We do not share your information or your account information with third parties except as described in this Privacy Policy. We may share your information with third parties under the following circumstances:
- You give us permission (opt-in consent).
- If we believe it is necessary to respond to legal action or an enforceable government request.
- To enforce our License Agreement or Terms of Service.
- To address technical, security, or fraud issues; or to protect the rights, property, or safety of CallMyWay, its members, its customers, its users, and the public.
- They may be provided to all our offices, subsidiaries, affiliates, or other trusted third parties contracted to provide our services or process your information. These parties must do so confidentially and securely, in accordance with this Privacy Policy.
- In connection with a corporate merger, acquisition, or other corporate reorganization.
4.2 Rental or sale of information
We do not rent, sell, or provide any of your, your partners', or your customers' information to third parties.
4.3 Opt-in consent
If we wish to use or disclose your or your account information in an anonymized or non-anonymized manner, in a manner different from that set forth in this Privacy Policy, we will request your permission in advance.
5. Content management
5.1 CallMyWay Access to Your Account and Information
Only members of our team, such as our employees, contractors, agents, and business partners who require access to conduct our business, may have limited access to your Information, your account, and content generated by you (e.g., phone call history, audio or video recordings uploaded or generated by your use of our Services, transcripts, or other specific files or information). However, all members of our team operate under strict confidentiality policies or contractual obligations.
5.2 Purpose of access to your account
We may access your account, the information and files stored therein, for the purpose of determining causes and solutions to technical problems and for the ongoing development of our processing methods.
Information Management on the premises
Your Information may be stored, processed, accessed, and handled at our facilities or at the facilities of our agents or business partners. All facilities and personnel handling Information must comply with this Privacy Policy.
5.4 Information Security
We work hard to consistently provide a high level of security to protect your Account Information and Content. This security includes limiting access to key representatives, firewalls, encryption of communications and data transmissions, and other physical security procedures in all our data centers, such as intrusion detection systems. These security measures are constantly monitored and reviewed to protect your Information and the integrity of the Service.
5.5 Specific consent to record calls and computer activity in general
Once we enable the Call Recording Service , the Corporate Logging Service, and other similar services that capture specific activity as part of the CallMyWay Services , and you, as a User, decide to use them, you must request and receive consent from all parties involved for each individual call made or each specific activity for which the activity is being captured. It is your responsibility to ensure that you receive consent in accordance with all applicable laws. It is CallMyWay responsibility to treat the Information, once collected, within this Privacy Policy.
Information Storage
information contained within your user account by written request. We assume no liability should such content be lost due to its deletion, as this is your express request. However, we state that we are unable to delete records of telephone calls to the Public Telephone Network (PSTN) for up to 5 years, in accordance with the law, and that we may not be able to continue providing you with Services after such deletion.
6. Cookies related to the website and our services
6.1 Why we use cookies
We use cookies to provide you with a better user experience on our Website and Services; and to remember your choices when using them. We also use cookies to continually improve the content and features you find on our Website and Services.
6.2 Categories of cookies
We use three categories of cookies:
- Functional cookies that are necessary for the Website or our Services to function and cannot be disabled in our systems.
- Statistics cookies that collect information about how you use our website or Services, such as the pages you visited and the links you clicked. This information is anonymous and cannot be used to identify you.
All this information is aggregated and therefore anonymized. Its sole purpose is to improve the functionality of the Website or our Services. This includes cookies from third-party analytics services, provided that the cookies are for the exclusive use of the owner of the website being visited.
- Marketing cookies (analytics and online advertising cookies) that allow us to measure the performance of our Website, our Services and social media platforms by recognizing and counting the number of visitors and identifying their tastes and preferences regarding our Services, as well as the marketing campaigns/activities with which they interact.
We also use cookies for interest-based advertising and remarketing. For this purpose, we may use services hosted by companies such as Google Ads, Facebook, Twitter, Quora, and others.
Cookies help us improve and develop the services we offer our customers and our marketing initiatives.
Cookie Consent
When you visit our website or use our Services, you are asked for your consent to place cookies on your device. You can choose to accept all cookies, or you can choose to reject statistical and/or marketing cookies, so that only functional cookies, which are necessary for the proper functioning of our website or our Services, are activated. You can withdraw your consent or modify your cookie settings at any time. If the activation of statistical or marketing cookies is necessary to use our website or our Services, we will let you know, and you can then decide whether to consent to it and continue using our website or Services or whether to desist from doing so.
7. Third party websites
We may provide links to third-party websites, products, and services. We have no control over those websites, products, or services, their privacy policies, or how they collect and handle your information. They may also place cookies or other files on your computer. It is your responsibility to read all terms of service and privacy policies associated with those third-party websites, products, and services.
8. Changes in the privacy policy
We reserve the right to change this Privacy Policy at any time and at our discretion. The new version of the Privacy Policy will be posted on www.CallMyWay.com under the Privacy Policy tab. If we make any changes to this Privacy Policy, we will post a notice on our website prior to such changes taking effect. If you do not agree with the revisions to the Privacy Policy, you have the right to cancel your CallMyWay account at any time and request, in writing, that your information be deleted.
Your continued use of the Website and/or any Services after a revised Privacy Policy has been posted will mean that you have accepted the changes.
9. Applicable law
CallMyWay undertakes to treat Information in accordance with applicable laws in Costa Rica, Mexico, and the United States of America, including but not limited to Costa Rican Law 8968, the Law on the Protection of Individuals Against the Processing of their Personal Data in Costa Rica, the Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP), along with Mexican Standard NMX-I-008-NYCE-2011 of the Federal Republic of Mexico; and the Health Insurance Portability and Accountability Act (HIPAA), the Children's Online Privacy Protection Act (COPPA), and the Gramm-Leach-Bliley Act (GLBA) of the United States of America.
10. Access to your information and your rights
If the information you have provided to us is incorrect, or if you believe that our processing of your information contradicts the protection of your privacy or the law, you have the right to access and correct your information , to request that it be blocked, corrected, supplemented, or deleted , with the exception of telephone call records, as set out in section 5.6 of this Privacy Policy ; and to lodge a complaint directly with the relevant Data Protection Authority.
information at any time, and we will provide it to you.
Additionally, you may revoke your consent for us to process or store your information at any time. However, in such a case, we may no longer be able to provide our services to you and we will not be responsible for any lost information.
11. Contact information
If you have any concerns regarding the protection of your Information, please contact us:
vía email: info@callmyway.com
Disclaimer: This is a best effort translation; the final valid version is the Spanish one
