Privacy Policy

As of September 22, 2022, Dialexa has been acquired by IBM (IBM Link: https://www.ibm.com/) and integrated into the IBM organization. Dialexa, an IBM Company (“Dialexa”) is committed to protecting the privacy of visitors to the website https://dialexa.com/ (“Website”) and others who request information about Dialexa. During this integration phase, if you have any questions about Dialexa handling of your Personal Information you can contact IBM Chief Privacy Office Helpdesk.

Why and How We Collect and Use Your Personal Information

We may collect your personal information in connection with your employment relationship with IBM, when you work as a contractor for IBM, in connection with another relationship with IBM when you collaborate with IBM, get access to our systems, or work on our premises.

We may process your information for purposes of managing our relationship, for statutory obligations, for conducting our business, protecting, and defending our rights and interests and our property and safety, and that of our employees and other persons we engage with.

Information Collected through Our Services and Dialexa Websites

We usually collect information, including Personal Information, in the following ways:

Personal Information. We may collect Personal Information about users of a customer’s IT systems in order to provide our Services and as authorized by that customer. We may collect such Personal Information directly or indirectly, such as through a customer or another service provider. We may also collect Personal Information from you as a user of the Dialexa Websites or by other direct communication from you. For example, when you register for our Services or request additional information or contact from Dialexa, you may be asked to provide certain Personal Information, which may include a name, company name, job title, address, and email address. In addition, if you choose to communicate with us via a web form, email or by telephone, we may use the content of your communication together with your email address or phone number and our responses for marketing and customer service purposes. If you should enter into a customer relationship with Dialexa, you may obtain additional rights or agree to additional obligations associated with the collection, use, and disclosure of information.

Device-related Information. We may also collect device related information from the user’s device, including information such as an IP address, the date and time of use of our Services, the date and time of an event on the customer’s IT systems, system logs, and technical attributes about the device or a web browser.

Commercially Available Information. Dialexa also collects information from commercially available sources. Such information may include names, addresses, email addresses, and city and state. The information Dialexa collects from these commercial sources may be combined and cross-referenced with information collected through the Dialexa Services to tailor our interactions with you.

Cookies and Similar Technologies

A cookie is a piece of data that a website may send to your browser, which may be stored on your computer and can be used to identify your computer. Web beacons, including pixels and tags, are technologies that are used to track a user visiting a web page or if a web page was copied to another website. Web beacons may be used in email messages or newsletters to determine whether messages are read, forwarded, or links selected. Local Shared Objects can store content information displayed on the webpage visited, and preferences.

Session cookies can be used to track your progression from page to page so that you are not asked for information that you have already provided during the current session, or information that is needed to be able to complete a transaction. Session cookies are erased when the web browser is closed. Persistent cookies store user preferences for successive visits to a website, such as recording your choice of language and country location. Persistent cookies erase their data within 12 months.

You can use our Cookie Manager to learn more about the online tracking technologies we use and to review or set your preferences regarding the information that we collect about you on our websites. Our Cookie Manager is either presented as a notification window when you first visit a webpage or opened by selecting Cookie Preferences in the website footer. Our Cookie Manager does not address all types of tracking technologies (for example, web beacons). When using mobile apps, use the options on your mobile device to manage settings.

Blocking, disabling, or rejecting cookies may cause services to not function properly. Disabling cookies does not disable other online tracking technologies but prevents the other technologies from accessing any details stored in cookies.

For information on cookies and how to remove these technologies by using browser settings, see the website: https://www.allaboutcookies.org/.

How We Use Information Collected through Our Services and Dialexa Websites

To Serve Our Customers. We use the information we collect, including Personal Information, to provide our Services to the customers on whose behalf we are acting. For example, in order to provide technical support, we may contact a user of a Dialexa customer’s IT system using any contact information provided to us.

To Serve You. We use the information we collect, including Personal Information, to respond to any request or query directed to us, to provide you with our products and Services and to manage our relationship with you. For example, we may respond to a job application, address any enquiries or complaints you may have, endeavor to improve the Services we provide, or provide you with information about other products and services we offer that we think you may be interested in.

For Internal and Service-Related Purposes. We may use any information we collect through the Services for internal and service-related purposes, including providing it to third parties as necessary to allow us to facilitate provision of the Dialexa Services.

Marketing

Subject to your marketing preferences, we may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

We may also engage with advertising partners, such as publishers and social media platforms, to deliver targeted advertisements on their websites, aggregate information for analysis, and track engagement with those advertisements on our behalf. These advertising partners may also track your interactions with us on our websites.

How We May Disclose Information Collected through Our Services and Dialexa Websites

Dialexa does not share your anonymized data with any outside organizations for any reason. We do not sell or rent any voluntarily submitted Personal Information, including names and email addresses. However, we may disclose this information to our professional partners if requested by you.

Internally, as necessary in connection with our business operations and the provision of the Dialexa Services, we share Personal Information amongst Dialexa affiliates on a need-to-know basis and subject to appropriate intercompany agreements.

With Our Third-Party Vendors and Service Providers. As appropriate, we may share Personal Information with our Business Partners, vendors and service providers retained in connection with the provision of the Dialexa Services. These third parties have access to Personal Information to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any information is provided to them, and they are restricted from using the information for other purposes.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose information, including Personal Information, if we believe doing so is required or appropriate: to comply with national security or law enforcement requests and legal process, such as a court order or subpoena; to respond to your requests; to prevent or address fraud, security, or technical issues; or to protect our property or other legal rights or the rights or property of others.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, information collected through the Services or Dialexa Websites (or both) may be sold or transferred as part of such a transaction, as permitted by law and/or contract. We cannot control how any other party to the transaction, or any future entity created by the transaction may use or disclose such information however we will only disclose the information if the party acquiring the information agrees to be bound by the terms of this Privacy Policy.

Other than as stated in this Privacy Policy, we will not release Personal Information to unaffiliated third parties, and we will not cross-reference Personal Information collected through one customer’s use of our Services with that of any other customer or entity.

Facilitating International Transfers

Your information, including Personal Information, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there.

Where it is necessary, we implement Contractual Clauses, such as those approved by the EU Commission and accepted in several other countries, as safeguards. You can request a copy of the EU Standard Contractual Clauses (EU SCCs) by contacting IT@dialexa.com.

Legal Basis

In some jurisdictions, the lawful handling of Personal Information is subject to a justification, sometimes referred to as legal basis. The legal bases that we rely on for the lawful handling of your Personal Information vary depending on the purpose and applicable law. The different legal bases that we use are:

Necessary for the performance of a contract with you

We rely on this legal basis when we need to process certain Personal Information, such as your contact details, payment details, and shipment details, to perform our obligations or to manage our contractual relationship with you. Examples:

If you intend to purchase a product or service, we require your business contact information to enter into a contract with you or you may need to create an account to access a purchased product online.
When fulfilling a contract, you may need to receive support services, for which we will need to collect your contact information.

Necessary for the purposes of Dialexa or a third party’s legitimate interest

Legitimate interests relate to being able to conduct and organize business, which includes the marketing of our offerings, protecting our legal interests, securing our IT environment, or meeting client requirements. Examples:

We capture your use of, and interaction with our websites to improve them.
We process your account information to manage access authorization of our services.
Where we have a contractual relationship with the organization that you are working for, we have a legitimate interest to process your Personal Information used to manage this contract.
We process your business contact information in combination with other business-relevant information to tailor our interactions with you and promote our products and services.
We have to keep our general business operations functional. To this end we may, for example, processes the login information of our IT systems and networks, or CCTV footage at Dialexa locations for security and safety purposes.
We may also process Personal Information where it is necessary to defend our rights in judicial, administrative, or arbitral proceedings. This also falls under the legal basis of legitimate interest in countries where they are not a separate legal basis.

Legal obligation

Where we need to process certain Personal Information based on our legal obligation. Example:

We may be obliged to ask for a government-issued ID for certain transactions, such as for a financing transaction (see Contractual Relationship).

Your Rights

You have certain rights when it comes to the handling of your Personal Information. You can contact IT@dialexa.com to:

request access to the Personal Information that we have on you, or have it updated. Depending on the applicable law, you may have additional rights concerning your Personal Information.
ask questions related to this Privacy Policy and privacy practices. Your message is forwarded to the appropriate member of the data privacy team.
submit a complaint if you are not satisfied with how Dialexa is processing your Personal Information.

California Consumer Privacy Act of 2018 (CCPA – US):

If you are a California resident, you have rights under the California Consumer Privacy Act of 2018 (CCPA). The information below provides instructions on how to exercise the rights granted by the CCPA. There may be cases where we present you with an additional privacy notice that includes information specific to an activity or offering.

Know your Personal Information
You can request specific pieces of Personal Information, or information about the categories of Personal Information that Dialexa holds about you by submitting a request to IT@dialexa.com or by calling (toll free) 1-800-IBM-4YOU (1-800-426-4968).

Request Deletion of your Personal Information
You can request the deletion of the Personal Information that Dialexa holds about you by submitting a request to IT@dialexa.com or by calling (toll free) 1-800-IBM-4YOU (1-800-426-4968).

Opt-Out of the Sale of Personal Information
When you use Dialexa websites, Dialexa authorized advertising partners may collect cookies and similar technologies and use this data for their own purposes. This activity may qualify as a “sale” under the CCPA. You can make choices to allow or prevent such uses. Depending on your choices, during the past twelve months, we may have “sold” to authorized advertising partners information within the following categories defined by the CCPA:

Identifiers like IP address and cookies
Internet activity information relating to your interactions with IBM websites
Inferences about your consumer preferences

To opt-out of Dialexa making information relating to cookies, and similar technologies, available to third parties for their own purposes, click here .

If you are accessing our websites while located outside of California, you can opt-out by going to “Cookie preferences” in the footer and setting your cookie preferences to “Required”.

Non-Discrimination
If you choose to exercise any of these rights, we will not deny goods or services to you or provide different quality of services.

Authorized Agent
You may use an authorized agent to submit a request about your Personal Information via IT@dialexa.com. To use an authorized agent, you must provide the agent with written authorization. In addition, you may be required to verify your own identity with Dialexa.

General Data Protection Regulation (European Economic Area and United Kingdom)

If the processing of your Personal Information is subject to the EU General Data Protection Regulation (“GDPR”) or UK General Data Protection Regulation (“UK GDPR”), and your Personal Information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR and UK GDPR you may also have the right to request to have your Personal Information deleted or restricted, ask for portability of your Personal Information, and not be subject to a decision based solely on automated processing. Where the processing of your Personal Information is based on consent, you have the right to withdraw this consent at any time. This does not affect the lawfulness of the processing based on consent before your withdrawal.

When providing Services, we collect information at the direction of our customers and generally do not have a direct relationship with the individual users of their IT systems whose information we may process. To request access to, correction, amendment, or deletion of Personal Information, a user of a Dialexa customer’s IT system should direct their query to that company.

We include an “unsubscribe” hyperlink in Dialexa marketing emails for those users who wish to stop receiving email communication from Dialexa. The hyperlink will connect to one of our websites, which will confirm the email address that has been automatically unsubscribed and will no longer receive emails from Dialexa.

Information Security and Retention

To protect your Personal Information from unauthorized access, use, and disclosure, we implement reasonable physical, administrative, and technical safeguards. These safeguards include role-based access controls and encryption to keep Personal Information private while in transit. We also require our Business Partners, suppliers, and third parties to implement appropriate safeguards, such as contract terms and access restrictions, to protect information from unauthorized access, use, and disclosure.

We only retain Personal Information as long as necessary to fulfill the purposes for which it is processed, or to comply with legal and regulatory retention requirements. Legal and regulatory retention requirements may include retaining information for:

audit and accounting purposes,
statutory retention terms,
the handling of disputes,
and the establishment, exercise, or defense of legal claims in the countries where we do business.

We retain any contractual relationship information for administrative purposes, legal and regulatory retention requirements, defending our rights, and to manage our relationship with you.

When Personal Information is no longer needed, we have processes in place to securely delete it, for example by erasing electronic files and shredding physical records.

Children’s Privacy

This web site is not directed at children under the age of sixteen and we do not knowingly collect personal information from children under the age of sixteen on the site.

Do Not Track

The Dialexa Websites currently do not respond to “Do Not Track” (DNT) signals, and operate as described in this Privacy Policy whether or not a DNT signal is received.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices from time to time. If we decide to change this Privacy Policy, we will post the changes on this page so visitors to the Dialexa Website and our customers and the users of their IT systems are aware of our practices, and we will change the “Last Updated” date above. If we make a material change to our information practices, such as to how we use Personal Information, we will make reasonable efforts to provide notice on our website and/or through our customers.

Complaints and How to Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our information practices, please email us at IT@dialexa.com.

Where IBM Corp. or a subsidiary it controls is required to appoint a legal representative, the following representatives have been appointed.

European Economic Area (EEA)
IBM International Group B.V.,
Johan Huizingalaan 765,
1066 VH Amsterdam,
The Netherlands

United Kingdom (UK)
IBM United Kingdom Limited,
PO Box 41, North Harbour,
Portsmouth, Hampshire, PO6 3AU,
United Kingdom

In compliance with the Data Protection Principles under GDPR, we are committed to resolving complaints about your privacy and our collection or use of your Personal Information. You may also have the right to complain to the competent supervisory authority. Contact details of Data Protection Authorities in the European Economic Area can be found here, and in the UK here.