The controller for the processing of personal data in connection with the INGOS Phone product is INGOS GmbH, Mimminger Str. 37B, 94491 Hengersberg, Germany. The authorised representatives are listed in the legal notice.

Contact for data protection matters: privacy@ingos.com. A company data protection officer has been appointed and can be reached at the same address.

This privacy policy applies to the INGOS Phone product: the telephone system operated by INGOS, the customer portal my.ingos.com and the INGOS Phone apps for mobile devices and desktop. It supplements the general privacy policy of the ingos.com website, which also describes the cookies used there.

What applies to your company: For the content of communication (voice, video, voice messages, chat, call notes, recordings, phone books) the customer company is the controller within the meaning of the GDPR. INGOS processes this data on the customer's behalf and instructions as a processor (Art. 28 GDPR). The customer company ensures the legal basis towards its employees and call partners and informs its employees about the use of INGOS Phone.

What applies to you as a user: For inventory and traffic data that INGOS needs to provide, bill, secure and troubleshoot the telecommunications service (accounts, extensions, call details, logs), INGOS is the controller. For questions about communication content please contact your company; in all other cases contact INGOS.

INGOS protects the secrecy of telecommunications under Section 3 of the German Telecommunications Digital Services Data Protection Act (TDDDG). Content and circumstances of telecommunications are processed only as far as necessary to provide the service.

Depending on how the service is used, the following categories of personal data are processed:

• Account and master data: name, business e-mail address, extension, role and permissions, credentials in protected form. This information is required to set up an account; without it, access cannot be provided.
• Traffic data (call details): calling and called number, start, ringing and answer time, end and duration of a call and its outcome. Numbers of call partners arise when a connection is set up.
• Content data: voice and video calls while in transit, voice messages (personal and company voicemail), chat messages with attachments, call notes and call recordings where the customer company has enabled that feature.
• Contact data: personal and shared phone books; imported from the device address book at the user's request.
• Presence and usage data: availability status, processing status of voice messages, activity counters (counts only, no content).
• Device and connection data: IP address, device type and software version, the hardware address of desk phones, the device's push identifier, login times.
• Log data: change log of the portal (who changed what and when), log of support access with IP address and device identifier, settings for AI features including their history.
• Diagnostic data: app error reports that are only created at the user's request and transmitted to INGOS in encrypted form.

Fax features are not part of INGOS Phone.

INGOS does not carry out automated decision-making, including profiling, with legal effect.

Processing takes place for the following purposes and on the following legal bases:

• Provision of the service (connecting and routing calls, voice messages, chat, phone books, apps, portal): towards the customer company, performance of the contract, Art. 6(1)(b) GDPR; for communication content, processing on behalf under Art. 28 GDPR.
• Billing and evidence of the services rendered based on call details: Art. 6(1)(b) and (c) GDPR in conjunction with commercial and tax retention obligations.
• Security and troubleshooting (logs, device and connection data, diagnostic data): legitimate interest in secure and reliable operation, Art. 6(1)(f) GDPR.
• Call recording: only at the instruction of the customer company. The customer company ensures the legal basis towards the call participants, in particular informing them and, where required, obtaining their consent (Section 201 of the German Criminal Code).
• AI-assisted features (transcription and summary): on behalf of the customer company, which ensures the legal basis towards the participants. The user's setting in the app (always, never, ask) is an additional technical block: without release, no processing takes place.
• Support access to a user account: performance of the contract with the customer company and legitimate interest in troubleshooting, Art. 6(1)(b) and (f) GDPR, in conjunction with Art. 28 GDPR. Release by the data subject is an additional technical safeguard.
• Storing and reading information on end devices (credentials, push identifier, optionally the address book): necessary to provide the service explicitly requested, Section 25(2) TDDDG; the address book is accessed only with the permission you grant in the system settings.

The INGOS Phone apps are available for iOS, Android and desktop systems. They connect exclusively to the telephone system of the user's own company.

The apps request only the permissions needed for the respective feature: microphone for calls, camera for video calls, notifications for incoming calls and messages, and optionally access to the address book to show contacts in the phone book. Address book access can be revoked in the system settings at any time.

To signal incoming calls while the app is closed, the mobile apps use the push services of Apple (iOS) and Google (Android). A device identifier, an account identifier and the information needed to signal the call, such as the caller's number, are transmitted. Call content is not transmitted via push services. A device's push binding (the link between device and account for notifications) becomes invalid after 365 days without use and is no longer used.

Error reports are only created at the user's request, transmitted to INGOS in encrypted form and decrypted solely by INGOS for error analysis.

The telephone system, the customer portal and the servers for AI features are operated by INGOS on its own hardware in data centres in Germany. INGOS operates the servers, network and virtualisation itself; the data does not leave the data centre. No external cloud providers are used to store or analyse call, message or contact data. This does not affect push signalling to mobile devices and the delivery of notifications by e-mail to the mailboxes designated by the customer company.

Connections between apps, desk phones, portal and telephone system are encrypted in transit.

Personal data is only disclosed where necessary for the service:

• Telecommunications carriers for routing and delivering calls to the public telephone network. They receive the phone numbers and connection data required for the connection. For calls abroad, carriers in the destination country may also receive this data.
• Push services of Apple and Google for signalling to mobile devices (see the Softphone Apps section).
• E-mail delivery of notifications, such as company voicemail messages, via INGOS's own mail servers to the mailboxes designated by the customer company and their mail servers.
• Data centre operators that provide premises, power and network connectivity for INGOS hardware, without access to the data.
• Authorities, where INGOS is legally obliged to do so.

Personal data is not shared for advertising purposes.

Personal data is not sold.

Call, message and contact data is processed in Germany. Transfers to countries outside the European Union may occur for push signalling to mobile devices via Apple and Google and for calls with participants abroad. Apple and Google are certified under the EU-US Data Privacy Framework or bound by the European Commission's standard contractual clauses.

Call recording is switched off by default. It can only be enabled by an administrator of the customer company per extension or call queue. The customer company is responsible for informing call participants before recording; INGOS provides an announcement feature for this purpose. Recordings are accessible only to authorised persons of the customer company.

Voice messages are stored in the telephone system and, depending on the settings, additionally delivered by e-mail. Chat messages and attachments are stored on the service's messaging server for as long as the chat or the customer account exists.

INGOS Phone can transcribe and summarise voice messages and calls. This processing takes place exclusively on servers in Germany using language models operated by INGOS itself. No data is transmitted to external providers of AI services.

The features are only active if the respective user has allowed them in the settings (always, never, or ask each time). The setting and its history are stored as evidence; no call content is stored there. For transcription, a copy of the audio is held in memory only and discarded after processing; the original file stored by the customer company is not affected. Only duration, language and processing time are logged.

INGOS staff can view a user account only after release by the data subject and only for the released extension. In the support view certain actions are technically prevented, including changing the settings for AI features.

Every access is logged with time, IP address and device identifier and is visible to the data subject under “Activities”. Internal access to the portal is bound to hardware security keys. Exports of connection data are logged separately.

Data is stored only for as long as necessary for the respective purpose or as required by statutory retention obligations. The following default periods apply to the telephone system; the customer company can adjust them within the legal limits:

Billing-relevant data is retained for up to ten years in accordance with commercial and tax law.

INGOS implements technical and organisational measures in accordance with Art. 32 GDPR, in particular encryption of all connections in transit, separated tenants in the telephone system (each customer company in its own instance), role-based permissions, hardware security keys for internal access, complete logging of changes and access, encrypted transmission of diagnostic data, and regular updates of the systems.

Under the GDPR, data subjects have the following rights:

• access to the data processed (Art. 15),
• rectification of inaccurate data (Art. 16),
• erasure (Art. 17) and restriction of processing (Art. 18),
• data portability (Art. 20),
• withdrawal of consent with effect for the future (Art. 7(3)).

Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is based on legitimate interests (Art. 21 GDPR). INGOS will then no longer process the data unless there are compelling legitimate grounds that override your interests, or the processing serves to establish, exercise or defend legal claims.

Right to lodge a complaint: You may lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the Member State of your residence, your place of work or the place of the alleged infringement. The authority responsible for INGOS is the Bavarian State Office for Data Protection Supervision.

Where INGOS processes data on behalf of a customer company, please address requests concerning communication content to that company; INGOS supports it in responding. INGOS does not individually inform call partners whose numbers arise when a connection is set up, as this would involve a disproportionate effort (Art. 14(5)(b) GDPR); this privacy policy is publicly available. In all other cases a message to privacy@ingos.com is sufficient.

INGOS updates this privacy policy when the service or legal requirements change. The current version is available at this address; the publication date and the date of the last change are shown at the end of the page.