Last Updated: June 29, 2023
(i) on www.convo.io and any other website or mobile application that links to this Policy including www.convorelay.com, https://www.convo.ca/, https://signlive.co.uk/, https://www.convoaustralia.com/, and https://www.convo.co.za/, and (collectively, the “Convo Sites”);
(ii) when you engage with us via social media;
(iii) when you purchase or engage with our products or services, including but not limited to: Video Relay Services (as defined below), Video Remote Interpreting (as defined below), and In-Person Interpreting (as defined below);
(iv) when we otherwise interact with you (by email, Short Message Services [SMS] telephone or otherwise)
(collectively, our “Services”).
By using the Services, you agree to the collection, use, and disclosure of Personal Information in accordance with this Policy.
“Cookies” are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.
“In-Person Interpreting” (also known as on-site interpreting or face-to-face interpreting) are services provided to the deaf, deafblind, and hard of hearing people to communicate with those who use spoken language through a signed language interpreter.
“Personal Information” means information about an identified or identifiable individual, and includes the personal information of our customers and Users of our Services.
“User” is the individual using our Services, including Video Relay Services, Video Remote Interpreting, and In-Person Interpreting.
“Video Relay Services” or “VRS” is a form of telecommunications relay service that enables Deaf and hard of hearing individuals who use Sign Language to communicate with voice telephone users through video equipment, rather than through typed text. Convo provides VRS in the following countries:
United States: Convo USA provides VRS through Telecommunications Relay Services (“TRS”) and is compensated through the TRS fund and regulated by the United States Federal Communications Commission (‘FCC”).
Canada: Convo Canada provides VRS to the Canadian Administrator of Video Relay Service, Inc. (“CAV”), using the CAV platform to connect to individuals and businesses who rely on telephone services.
United Kingdom: SignLive provides VRS to residents who obtain Access to Work (AtW) and Direct Payments funded by the British government.
Australia: ConvoAU offers Auslan video interpreting services to consumers with National Disability Insurance Scheme (NDIS) plans and
South Africa: Convo South Africa provides VRS in partnership with MTN under the National Relay Service program; and is regulated by the Independent Communications Authority of South Africa (ICASA).
“Video Remote Interpreting (VRI), or “Virtual Interpreting” is a service that allows people who are deaf or hard of hearing to communicate with a hearing person using an interpreter via video-communications technology such as video conferencing platforms, video equipment, and a high speed Internet connection with sufficient bandwidth.
1. Collection of Personal Information
When you use our Services, we may collect or receive Personal Information about you to provide our Services and operate our business. The types of Personal Information that we may collect about you are:
- Information You Provide to Us Directly
You may provide your Personal Information to us when you use our Services, including when you create an account through the Convo Sites (a “Convo Account”), use the Convo Sites, contact us with inquiries, or otherwise access our Services. This information may include:
- User Profile – We collect Personal Information associated with your Convo Account. This includes information such as your first and last name, email address, phone number, and billing address.
- Appointment Information – When you schedule an appointment for one of our Services, we will collect information related to the appointment. This may include information such as date and time of appointment, name of interpreter chosen, and any documents you want to share.
- Payment Details – When you use one of Services (such as In-Person Interpreting and Video Remote Interpreting) where payment is required, we collect information related to that payment. This may include information such as date and time of purchase, and total price.
- Information Received From You as Part of Your Communications
When you use our Services, complete electronic forms, communicate with us or contact us by online chat, email or phone, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; your purchase details; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction, and the action we took in response to your inquiry or request.
- Information Collected Automatically
We may receive and store certain information about you and your device(s) automatically when you access or use our Services. This information may include:
- Technical Information – We collect technical information associated with your activity on the Convo Sites and may include information related to your browser and operating system, IP address (the internet address of your computer) unique device identifiers, and other information such as your device type. We use such information for diagnostic and statistical purposes and to administer our Services.
- Site Usage Information – We collect information to better understand customer traffic patterns and Convo Sites usage. This may include the webpage that you were visiting before accessing the Convo Sites or mobile application, the pages or features of the Convo Sites you browsed to inform us which part of the Convo Sites and Services you visit and how much time you spend there. This information is used to analyze and improve the Convo Sites and to provide our customers with a better user experience
- Personal Information from Publicly Available Sources and Third Parties
We may collect or receive Personal Information about you from publicly available sources, social network providers, marketing partners, and/or third parties. This may include:
● Social Network Information – We may receive information about you from other services. For example, we receive certain information when you interact with our social media accounts.
- to make our Services function properly;
- to improve our Services;
- to recognize you when you return to the Convo Sites or the Services and to remember information you have already provided and your preferences;
- to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and
- to provide a secure browsing experience during your use of our Services.
- Online Analytics and Advertising Technologies
We and our third-party vendors may use automated technologies (including Cookie identifiers on the Convo Sites and/or the Services), along with other collected information, to tailor ads or deliver content when you are on our Services or on other devices, apps or websites.
- Interest-Based Advertising
We (or our service providers) may use the information we collect, for example, IP addresses and unique mobile device identifiers, to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content and features and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your device settings. We may also use cross-device targeting to help identify our users and serve advertising. This type of advertising is often called “interest-based” or “personalized” advertising—and when it occurs on mobile apps, “cross-app” advertising.
You can learn more about interest-based advertising and how to opt-out of receiving tailored advertising by visiting (i) the Network Advertising Initiative’s Consumer Opt-Out link or (ii) the Digital Advertising Alliance’s Consumer Opt-Out link.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.
To opt out of Twitter’s interest-based ads, you can follow their instructions posted here.
To opt out of Facebook’s interest based ads, you can follow their instructions posted here.
Please note that even if you opt-out, you may still receive advertisements from us. However, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs.
- Mobile Applications
Depending on your permissions, we may receive your Personal Information from your Internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. You can learn more about your choices for mobile devices by visiting http://www.aboutads.info/appchoices. Each operating system, (iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You should view your device or system “Settings” to determine how you can opt out of use of your device ID for “cross-app” personalized advertising. Convo’s SMS policy can be found here.
3. Use of Your Personal Information
We may use the information we collect or receive about you for various purposes.
- To Provide You With Our Services
We use your information to provide you with our Services. For example, if you utilize video remote interpreting or any of our individual payer services, we use credit card information to complete a transaction or an address to fulfill your purchase order. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable Personal Information to the third party providing the information or performing applicable Services. Your information may be available or provided to third-party service providers (such as credit card companies, and payment processing companies) and that are contractually obligated to protect your information as disclosed in this Policy.
Convo may transfer or otherwise disclose information collected from you for the following purposes: (1) to Convo’ employees, independent contractors, subsidiaries, affiliates, consultants, business associates, service providers, and suppliers, if the disclosure will enable that entity to perform a business, professional, or technical support function for Convo; (2) to employees, independent contractors, service providers, and suppliers of Convo to fulfill a product or service request; and (3) to respond to judicial process and provide information to law enforcement agencies where required, or in connection with an investigation on matters related to public safety, as permitted by law. As stated above, Convo will use, disclose or permit access to your information in strict compliance with local laws and regulations governing the use of customer proprietary network information, personally identifying information, and other sensitive information. Users of Convo’s VRI services may also have information disclosed to the Sponsors of their VRI accounts; but such information will be strictly limited to duration and amount of use, name, date and time of session, and the username of the interpreter assigned to the session.
- To Maintain, Improve, and Personalize our Services
We use your information for our everyday business operations such as auditing, administration of the Services, forum management, fulfillment, and analytics. Your information may also be used to improve the content and/or functionality of the Services. For example, it may be used to help us improve our offerings. We also use your information to personalize your experience. We may personalize the content and features you see when visiting our Services. In addition, we may personalize advertisements, marketing communications, and recommendations to make them more tailored to your interests.
- To Communicate with You
We use your information to communicate with you. We may contact you with promotional offerings or other communications that may be of interest to you. If we send you marketing emails about Services that may interest you, each email will contain instructions permitting you to “unsubscribe” from receiving future marketing or other communications within ten (10) days.
In the event you contact us, we use certain information to respond to your questions and assist you with any issues that may arise in your use of the Services.
- For Account and Network Security Purposes
We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your Personal Information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
- To Maintain Legal and Regulatory Compliance
Our Services are subject to certain laws and regulations which may require us to process your Personal Information. For example, we process your information to fulfill our business obligations, or as necessary to manage risk as required under applicable law.
- To Protect You, Others, and Our Business
- For Our Business Purposes
We may use your information for any other purpose disclosed to you at the time we collect or receive the information, or otherwise with your consent.
4. Sharing of Personal Information with Third Parties
Your Personal Information is not shared with third parties without your permission, except as described below.
- Service Providers
We may share your information with our third-party service providers for certain business purposes. This information is provided in order for them to provide us services such as payment processing, advertising services, marketing partners, web analytics, data processing, IT services, customer support and other services. These third-party service providers have access to your Personal Information solely for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.
Here is a list of some of the third-party service providers that we use:
● VTCSecure (in South Africa and Australia)
- Video Relay Services Partners
Convo’s Video Relay Services are regulated by various governing entities through a partnership including:
Convo USA provides VRS through Telecommunications Relay Services (“TRS”) and is compensated through the TRS fund and regulated by the United States Federal Communications Commission (‘FCC”). For Convo USA, in order for your VRS calls to be eligible for reimbursement from the Interstate Telecommunications Relay Services (TRS) Fund, Convo collects, at a minimum, the following information: 1) the ten-digit number you used to make your call; 2) the time the call was connected; 3) the ten-digit number you called; 4) the time the call was disconnected; and 5) the Internet Protocol (IP) address used to make the call, if applicable. Convo submits the information collected during VRS calls to the TRS Fund Administrator in order to be reimbursed for those calls. Convo does not disseminate the information to any other party. Convo USA does not keep records of the content of any conversation relayed during a VRS call.
ConvoAU offers Auslan video interpreting services to consumers with National Disability Insurance Scheme (NDIS) plans
Convo South Africa provides VRS in partnership with MTN under the National Relay Service program; and is regulated by the Independent Communications Authority of South Africa (ICASA).
SignLive provides VRS to residents who obtain Access to Work (AtW) and Direct Payments funded by the British government.
- When Required by Law
We may be required to disclose your information to third parties including law enforcement agencies when required to protect and defend our legal rights, protect the security of users of our Services, prevent fraud, comply with the law, respond to legal process, or a request for cooperation by a government entity.
- Corporate Transactions
In the event of a sale, transfer, amalgamation, merger, reorganization, dissolution, or similar event we may transfer your information to one or more third parties as part of that transaction.
- With Your Consent
We also may share or disclose your information with your consent or at your direction.
5. Security of Personal Information
We have implemented organizational, technological, and physical security controls that are designed to safeguard Personal Information. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your Personal Information is absolutely secure. Please keep this in mind when disclosing any information to us.
Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet.
We will retain your Personal Information for as long as your account is active or as needed to provide you with the Services and to maintain a record of your transactions. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain platform traffic Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
7. Your Rights
- Your Rights
This section lists the privacy-related rights (“Rights”) we extend to all of our customers. Your right to know and right to deletion are not absolute and are subject to certain exceptions. For example, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our systems.
- Right to Know – You have the right to know the Personal Information we collect, use, and disclose about you.
- Right to Deletion – You have the right to request that we delete any Personal Information we have collected from you or maintain about you. We may save Personal Information when permitted by applicable law including, without limitation, when the information is needed for a legal purpose.
You can also request that we provide you with a copy of your Personal Information in a commonly used electronic format so that you can manage and move it.
For deletion of Personal Information, if your Personal Information is part of a MasterFile Audit Trail record, it will be replaced with anonymous data so that the integrity of the audit trail remains.
Please note that we may ask you to verify your identity before responding to such requests.
- Asserting Your Rights
You may exercise your right to know or your right to deletion by contacting us as set out in Section 15. We may ask you to verify your identity if you are contacting us through online chat, email, video phone, or other video conferencing mechanisms. You may also designate an authorized agent to make a request to know or a request to delete. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf, or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf.
For Personal Information that we have collected that is not accessible through the Convo Account, you can request, in writing, that we correct an error or omission to your Personal Information or delete your Personal Information. We will respond to written requests within thirty (30) days, or alternatively, the timeframe prescribed by the relevant legislation.
8. Transfer of Personal Information
Convo has operations in various countries. Regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in other countries (such as the United States, Canada, South Africa, United Kingdom, and Australia) in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.
Jurisdiction specific processes follow as below:
United States: The transfer of personal information in the United States is regulated by a combination of federal and state laws, as well as industry-specific regulations. Unlike some other countries, the United States does not have a comprehensive federal data protection law that governs the transfer of personal information. However, there are several laws and regulations that address specific aspects of data transfers and privacy. State data protection laws: Several U.S. states have enacted their own data protection laws, such as the California Consumer Privacy Act (CCPA) and the Virginia Consumer Data Protection Act (VCDPA). These laws provide certain rights to individuals and impose obligations on organizations, including requirements related to the transfer of personal information.
Canada: The transfer of personal information in Canada is primarily governed by the federal Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA sets out rules for the collection, use, and disclosure of personal information by private sector organizations in Canada. When it comes to transferring personal information outside of Canada, PIPEDA imposes certain requirements and considerations.
United Kingdom: The transfer of personal information from the United Kingdom (UK) to another country is regulated by the UK General Data Protection Regulation (UK GDPR).
Australia: The transfer of personal information in Australia is subject to the Privacy Act 1988, which regulates how personal information is handled by Australian organizations, including the transfer of data to overseas recipients. The Australian Privacy Principles (APPs) under the Privacy Act govern the collection, use, disclosure, and storage of personal information.
South Africa: The transfer of personal information in South Africa is regulated by the Protection of Personal Information Act (POPIA), which came into effect on July 1, 2020. POPIA aims to protect the privacy rights of individuals and establishes principles and conditions for the lawful processing of personal information.
We may provide paid products and/or services within the Services. In that case, we use third-party services for payment processing (e.g., payment processors).
All payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover PCI-DSS requirements to help ensure the secure handling of payment information.
10. Third-Party Sites
Some of the functionality may be provided by third parties and the Services may link to other third-party websites that are not controlled by Convo. These third parties are not under our control and Convo is not responsible for their privacy policies or practices. If you provide any Personal Information to any third party or through any such third-party website, we recommend that you familiarize yourself with the privacy policies and practices of that third party.
11. Children’s Privacy
We do not knowingly collect personally identifiable information from anyone under the legal age of majority (a “Minor”). If you are a parent or guardian and you are aware that your Minor has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Minor without verification of parental or guardian consent, we take steps to remove that information from our servers.
For Video Relay Services, a Minor may use the Service, as long as parental or guardian consent to allow the Minor to use the Service is provided upon registration.
12. “Do Not Track” Signals
We do not support Do Not Track (“DNT”). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable DNT by visiting the Preferences or Settings page of your web browser.
13. Jurisdiction Specific Provisions:
United States - California: If you are a consumer located in California, we process your personal information in accordance with California law (e.g. the "CCPA").
As a California consumer and subject to certain limitations under the CCPA, you have rights regarding our use and disclosure of your personal information, including:
Exercising the right to know: You have a right to request additional information about the categories of personal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.
Exercising the right to opt-out from a sale: We do not sell "Personal Information" as defined by the CCPA and have not done so in the past 12 months.
Exercising the right to limit the use or sharing of Sensitive Personal Information:we do not sell or share Sensitive Personal Information as defined by the CCPA and have not done so in the past 12 months.
To submit a request to exercise any of the rights described above, please contact us using the methods described in the Contact Us section below. We will verify your request by asking you to verify your identity.
Canada: If you are a consumer located in Canada, the following definitions will apply: "applicable law" includes the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) and "Personal Data" includes "personal information" as defined under PIPEDA.
United Kingdom: If you are a consumer located in the United Kingdom, the following pertain to you. Convo has implemented the relevant policies and practices to ensure we protect any data handled by SignLive – for its employees, customers, suppliers and partners, specifically including the following: 1) Employees will be made aware of the GDPR and restrictions and obligations within it as may be relevant to them, with the adequate training provided, 2) All new employees will receive GDPR awareness training as part of our induction programme, and 3) If relevant, suppliers who process personal data on behalf of SignLive will be asked to provide details of their state of compliance with the GDPR and any new supplier will not be taken on unless we are satisfied that they comply with the new data protection regulations.
If you are a resident of the EEA and you believe our processing of your information is not in line with the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Irish Data Protection Commission. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. Where Personal Data is used for regulated financial activities in Europe, entities (defined as those who are licensed, authorized or registered by a Local Regulatory Authority) are considered joint controllers.
You may request details of personal information that we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to: SignLive Ltd. One Lochrin Square, 92 Fountainbridge, Edinburgh, EH3 9QA.
To read more about our GDPR principles and policies please review here: https://signlive.co.uk/privacy-policy/
To read more about our Fair Processing Policy, please review here: https://signlive.co.uk/fair-policy/
Australia: Any breach of conduct should be reported to the Convo Australia management team. Our team will endeavour to take appropriate corrective action to resolve the breach. Customers may make complaints by submitting written complaints to firstname.lastname@example.org or leaving videos through customer feedback on the Convo Australia app or website (in Auslan). If the customer is unsatisfied with our response, the customer may complain to the relevant authorities, using the links below which also include their complaint procedure.
If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Policy, you may wish to contact the Office of the Australian Information Commissioner.
South Africa: If you are a consumer in South Africa, the following provisions pertain to you. All concerns or complaints regarding your personal information or this Policy should be sent to email@example.com or 3rd floor 35 Ferguson, Hyde Park, Johannesburg. If you are then unsatisfied with the manner in which Convo addresses any concerns or complaints regarding Convo’s processing of personal information, you may contact the office of the regulator, the details of which are: The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001.
P.O Box 31533, Braamfontein, Johannesburg, 2017
General enquiries: firstname.lastname@example.org
We may update our Policy from time to time. We will notify you of any changes by posting the new Policy on this page.
We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the “effective date” at the top of this Policy.
You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.
15. Contact Us
- ConvoUSA: email@example.com
- Convo Canada/ConvoCA: firstname.lastname@example.org
- SignLive: email@example.com
- Convo Australia/ConvoAU: firstname.lastname@example.org
- Convo South Africa/ConvoZA: email@example.com