As part of Two Circles’ commitment to its data protection obligations, this privacy notice covers the processing of personal data (any reference to ‘personal data’ includes ‘personal information’ as defined by the CCPA) when we’re using Gong to record meetings.
What personal data is being collected
When we organise a call with you, we collect your name, email address, employer organisations, video and audio recording where your camera is enabled, call analytics, user-generated data through the discussion, data submitted using the instant messaging functions, and technical data (IP address, user agent, operating system, etc).
Why do we use your data and what is our legal basis for it?
We use the personal data we capture in recordings in our communications and recordings which use Gong as part of facilitating efficient business administration, for the training and development for our employees, quality control and to help improve our service. The lawful basis for processing your personal data will be under Article 6(1)(f) of the UK and/or EU GDPR (as applicable), as the processing of personal data is justified for Two Circle’s legitimate interests.
Who has access to this data?
In the first instance, only approved Gong users within Two Circles can access the recording. These can be shared with others within the business and externally but only where appropriate, necessary and lawful to do so.
Who do we share your information with?
We share the personal data we handle with the following organisations:
- Microsoft Ireland Limited (Ireland);
- Gong.io, Inc (USA);
- Chili Piper, Inc (USA)
- Two Circles group companies (Global);
- Our clients and partners (your employer, upon request); and
- Others organisations where required to do so by law.
Transferring your data to other countries
Where your applicable data protection or privacy law has specific rules around transfers to other countries, we will ensure that the data is only transferred where it will continue to have the necessary measures to ensure the security of the data.
How long do we keep your data for
Recording and associated data are kept for 3 years before being automatically deleted.
If you don’t want to be recorded
Let the Two Circler who arranged the meeting know that you don’t wish to be recorded and they will ensure that your objection is captured and any recording is stopped (which will automatically delete the recording so far too).
More information
If you want to see more information about your rights, please see our main privacy notice. If you wish to exercise any of your rights in relation to your personal information or if you have any queries about how we use your personal information, please let us know by contacting our DPO at Two Circles at the following address: dpo@twocircles.com.
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