Syniverse respects your right to privacy.

This Privacy Notice applies to personal information that we collect through our website at www.syniverse.com (the "Website") and as part of the provision of certain services, such as messaging, to our customers and their employees and end-users.

We believe you should be aware of how we treat any information about you that we might receive as a result of your visit to the Website and use of our Website (including our customer portals) or services (such as messaging services) (together "the Services"). This Privacy Notice explains how we collect, share and use personal information about you, and how you can exercise privacy rights that you may have under certain data privacy laws.

Syniverse does not disclose, give, sell or transfer any personal information about visitors to the Website or any customer employees or end-users of its Services, except as explained below or required for law enforcement or by statute.

What personal information does Syniverse collect and why?

Information that you provide voluntarily

If you choose to interact with us via the Website, including through one of our customer portals, we may ask you to provide certain information, such as:

• contact information including: name; address; phone number; email address;
• company details / employer details, industry;
• country of residence;
• the reason for your enquiry;
• other information required in order to provide you with access to a Syniverse customer portal (e.g. MySyniverse)

We will use this information in order to assist you with your enquiry. We may also use this information in order to create a better overall experience for our visitors by improving the content of the Website or other Services.

For the purposes of EEA and Brazilian visitors (see section entitled Legal basis for processing personal information (EEA and Brazilian visitors only) below), processing of your information in this manner is required for our legitimate business interests as further described below or, in the case of Syniverse customer portals, for us to perform a contract with you or for your benefit.

Information Collected and Stored Automatically

You can visit our Website without telling us who you are or revealing any information about yourself. Our web servers collect the domain names, not the e-mail addresses, of visitors. In general, we gather information about visitors to the Website in order to determine, for example, which areas visitors access more frequently and which materials visitors access the most. This information helps us to determine what is most beneficial for our visitors, and how we can continually create a better overall experience for our visitors by improving the content of the Website. For the purposes of EEA and Brazilian visitors (see section entitled Legal basis for processing personal information (EEA and Brazilian visitors only) below), processing of your information in this manner is required for our legitimate business interests. Where we process your personal information to provide access to our Syniverse customer portals, then our legal basis for processing may be to perform a contract with you or for your benefit.

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources, such as website pages you have visited or organizations (such as Syniverse customers) with whom you work, to whom we provide Services, such as messaging, or who assist us in providing our Services. We shall only accept receipt of such information where we have checked that these third parties either have your consent (where required by law) or are otherwise legally permitted or required to disclose your personal information to us.

The types of information we collect from third parties include:

• IP addresses;
• user/customer employee contact information;
• user subscriber data;
• user/customer employee identification details;
• user/customer employee account information;
• user/customer employee browsing information;
• customer employee professional experience and affiliations;
• end-user communications meta-data

We use the information we receive from these third parties to provide a better digital experience, for our own customer engagement, e-commerce, marketing and sales activities. In addition, such information may be processed for security purposes. For the purposes of EEA and Brazilian visitors, this processing is required for our legitimate business interests.

In addition, we may have a legal obligation to process certain user information or it may be required in order to fulfil our contractual obligations to our customers, such as for billing, rating or message routing purposes.

Other purposes

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, where allowed by applicable data privacy law, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes).

Who does Syniverse share my personal information with?

We may disclose your personal information for our business purposes and where required in relation to our contractual or legal obligations to the following categories of recipients:

• To our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website or to support the delivery of our Services, such as messaging, through the onward transmission of communications), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. A list of our current group companies is available upon request and a list of our current service providers and partners is available upon request.
• To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• To any other person with your consent to the disclosure.

Legal basis for processing personal information (EEA and Brazilian visitors only)

If you are a visitor from the European Economic Area or Brazil, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect or process personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. Examples where we may have a legal obligation to process your personal information include where we are required to assist law enforcement authorities with interception of certain telecommunications supported services, such as our messaging services, or where we are required to filter telecommunications, such as text messaging, for spam or other illegal content.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Website and provide our other Services, such as messaging. Our legitimate interests may also include communicating with you as necessary to provide our Services to you and when responding to your queries, improving our Services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

How does Syniverse keep my personal information secure?

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security measures in place.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website servers are located in the United States, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your data protection rights

If you are a resident of the European Economic Area or Brazil, you have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below. In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the unsubscribe or opt-out link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

California Privacy Rights Act (CPRA) information

Syniverse does not conduct business directly with consumers. Even where Syniverse is collecting personal information of California residents through the Website or our other Services, this personal information is in relation to business-to-business transactions. If you are a California resident and Syniverse (via the Website or our other Services) is collecting or disclosing your personal information for a business purpose, your rights under the CPRA are limited and do not include the right to access, the right to delete or other rights under the CPRA.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We recommend reading this Privacy Notice each time you access our Website or use our services, such as messaging, to which this Privacy Notice applies, as we may change the data that we collect from or about you when you use our Website or other services from time to time. We will not seek your consent or inform you via any other means of changes to our Privacy Notice if it would be impossible or would involve disproportionate effort for us to do so. This statement was last updated on November 18, 2020.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact our data protection officer using the following details:

Global Data Protection Officer
Syniverse Technologies
Headquarters
8125 Highwoods Palm Way
Tampa, Florida, 33647
U.S.A.
Email: dpo@syniverse.com

Data Protection Officer
Syniverse Technologies Sarl
15 Rue Edmund Reuter
L-52326 Contern
Luxembourg
dpo@syniverse.com

The data controller of your personal information is as follows:

Syniverse entity	Address and Registration No.	Lead Supervisory Authority
Syniverse Technologies Sarl	15, Rue Edmond Reuter, L-5326 Contern, Grand Duchy of Luxembourg	Commission Nationale pour la Protection des Données (“CNPD”) in Luxembourg
Syniverse Technologies Messaging ApS	c/o TMF Denmark A/S, Købmagergade 60,1. tv, 1150 København , Denmark	Commission Nationale pour la Protection des Données (“CNPD”) in Luxembourg
Syniverse Technologies GmbH and Syniverse Technologies Messaging GmbH	Königswinterer Straße 242-252, Bonn, 53227 Germany	Commission Nationale pour la Protection des Données (“CNPD”) in Luxembourg
Syniverse Technologies BV	Herikerbergweg 238, Luna Arena, 1101CM Amsterdam, Netherlands	Commission Nationale pour la Protection des Données (“CNPD”) in Luxembourg
Syniverse Technologies Solutions Limited	18 Mansell Street, London, United Kingdom E1 8AA	UK Information Commissioners' Office
Syniverse Technologies Services (India) Private Limited	9th Floor, iLabs Center, Plot No. 18, Software Units Layout Madhapur, Hyderabad 500 081 Telangana, India	Not applicable
Syniverse Technologies Network Solutions (Singapore) Pte. Ltd.	8 Marina Boulevard #05-02, Marina Bay Financial Centre, Singapore	Personal Data Protection Commission ("PDPC") in Singapore
Syniverse Technologies (China) Limited	18th Floor, AXA Tower, Landmark East,100 How Ming Street, Kwun Tong, Kowloon, Hong Kong PRC	Office of the Privacy Commissioner for Personal Data ("PCPD") in Hong Kong
Syniverse Technologies (Beijing) Limited	2002-2006, Floor 20, JinYu Mansion,No. 129 West Xuanwumen West Street, Xicheng District Beijing, China	Not applicable

Please note that in most circumstances, Syniverse processes personal information on behalf of its business customers. In these circumstances, Syniverse will not be acting as a controller, but as a processor, under terms agreed with our business customers and you should consult them for information about how your personal information may be processed. We may process other personal information on behalf of our business customers that is not described in this privacy notice.

Last Updated 11.18.2020