Altocloud

GDPR

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This topic is part of the manual Altocloud Administrator's Guide for version Current of Altocloud.

Learn how to use Altocloud in a GDPR-compliant way.

Altocloud and GDPR

For the purposes of GDPR compliance, Genesys is a data processor on behalf of customers who use the Altocloud product. You, our customers, are the data controllers of the personal data you collect from your end customers, the data subjects. This article describes how to adhere to GDPR consent requirements, should you identify consent as the most appropriate lawful basis for processing personal data. Note that there is no ‘right’ or ‘wrong’ lawful basis for processing personal data; the GDPR requires that data controllers consider the most appropriate lawful basis. A helpful link for what to consider when determining the most appropriate lawful basis can be found here.

Important
Be sure you understand the steps you need to take before you collect, process, or store your end-customers' personal data.

Altocloud collects data about visitors' activities on business websites. It uses machine learning and AI to analyze customer-generated events (page views, searches, form-fills, and chats) to determine the probability of a specific customer achieving a specific outcome. An outcome is an event the business wants to maximize or minimize. Example outcomes are making a purchase, signing up for a webinar, or filling out a complex form online. For information about how Altocloud uses cookies to track visitor activity on websites, see Cookie usage.

Businesses use end-customer data that Altocloud collects for three primary purposes:

  • Customer support - proactive or AI-driven engagement via chat and callback offers;
  • Sales engagement - proactive or AI engagement via chat, callbacks, and content offers;
  • Marketing - proactive or AI; for example, sign-up for an event or webinar via content offer.

If you are still unsure as to whether you should obtain the data subject's consent to process their personal data, you may wish to consult your legal advisor.

Important
Genesys does not pass end customer personal data processed through Altocloud to any advertising or re-targeting companies. End-customer personal data processed through Altocloud may be shared with business-integrated tools such as Salesforce and Marketo. This will happen only when one of our business customers configures that behavior for their organization.

PureCloud and GDPR

For more information on how PureCloud addresses GDPR compliance, see PureCloud and GDPR compliance.

Conditions for consent

If you have identified consent as the most appropriate lawful basis for processing end customer personal data, then the following conditions should be met when obtaining consent:

  • You must be able to demonstrate that the data subject has consented to processing of his or her personal data. That means you should maintain a record or audit trail of consent being given.
  • If the data subject's consent is given in the context of a written declaration which also concerns other matters, the request for consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language.
  • The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.
  • When assessing whether consent is freely given, utmost account shall be taken of whether, among other things, the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract.

If you have identified consent as the most appropriate lawful basis for processing end customer personal data, then you should consider what consent has been given before calling the following functions.

The ac('init',...) function starts Altocloud tracking on your website.

The ac('record',...) function allows Altocloud tracking of custom user actions on your website.

The ac('identify',...), function is used to identify end-users.

For more information about these functions and others where consent may need to be considered, see About the tracking snippet.

Important
If you require consent to be GDPR-compliant, obtain that consent before passing any personally identifiable data to Altocloud.

Make a "right to be forgotten" request

As a data controller, you can make a "right to be forgotten" request on behalf of a visitor. To do this, send an email to DataPrivacy@Genesys.com. Be sure to provide the following identifying parameters for the visitor. These parameters are the primary keys by which Altocloud recognizes unique visitors:

  • Email address
  • Phone number
  • Cookie ID
  • Business-specific ID that has been passed to Altocloud with other customer data
Important

It is your responsibility as the data controller to:

  • Confirm the visitor's identity before submitting a "right to be forgotten" request on their behalf to Genesys.
  • Provide the identifying parameters of the visitor who is requesting to be forgotten.

Notes:

  • All identities related to these parameters will be subject to deletion.
  • After Genesys deletes visitor data, it cannot be recovered.

Genesys honors "right to be forgotten" requests within 28 days. Genesys sends a confirmation to the data controller when data has been deleted.

Make a "right of access" request

As a data controller, you can make a "right of access" request. To do this, the designated representative from your organization should send an email to DataPrivacy@Genesys.com. The email should contain the identifying parameters for the visitor. These parameters are the primary keys by which Altocloud recognizes unique visitors:

  • Email address
  • Phone number
  • Cookie ID
  • Business-specific ID that has been passed to Altocloud with other customer data
Important

It is your responsibility as the data controller to:

  • Confirm the visitor's identity before submitting a "right of access" request on their behalf to Genesys.
  • Provide the identifying parameters of the visitor whose data is to be provided.

Note:

  • Genesys will provide all data related to the identities having these parameters.

Genesys honors "right of access" requests within 28 days. Genesys sends your designated representative the data in a suitable format.

Stop tracking

For information on how to stop tracking if a visitor revokes consent, see Stop tracking if a visitor revokes consent in the Web Tracking API article.

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