So-e Privacy Statement

Your privacy is important to So-e. Therefore, So-e is committed to respecting Your privacy and the confidentiality of Your personal data, traffic data and communications content. This Privacy Statement is designed to assist You in understanding how So-e uses and safeguards the information You provide in using So-e’s peer-to-peer VoIP software and/or VoIP Service.
So-e collects and processes, or has third party service providers who collect and process on So-e’s behalf, personal data relating to You, as permitted to (1) provide the VoIP Service, in particular to convey the communications You make by means of the So-e Software and/or the VoIP Service, (2) invoice to You Your use of the VoIP Service and (3) carry out So-e marketing activities.
In this Privacy Statement the following capitalized definitions are being used, singular as well as plural.
Communications Content: any information that is communicated by users of So-e Software and/or VoIP Service such as calls or instant messages.
Feedback Information: any information that is reported to So-e by filling in the feedback forms on the Website.
Passive Information: Information that is necessary in order to provide You with the desired functionality of the So-e Software, such as a session ID token, source and destination addressing information, and the version of the software You are using.
Personal Data: any information that So-e possesses relating to an identified or identifiable user of So-e Software and/or VoIP Service.
PSTN: Public Switched Telephone Network.
Register Information: any information provided when voluntarily registering at the Website, including, but not limited to, username and password.
So-e: means under this Privacy Statement the So-e Software S.A., a company incorporated under the laws of Luxembourg.
So-e Software: Peer-to-peer software that allows You to communicate with any other So-e user through voice communication, Instant Message (IM) and/or other forms of communication, through the Internet.
Subscriber Information: Information that is necessary in order to verify Your identity and to provide VoIP Service, such as Your name, billing information and e-mail address on the Website.
Traffic Data: any data processed for the purpose of the conveyance of communication or the billing thereof, including, but not limited to, the duration of a call and the (IP) numbers of the called party and the calling party.
User Profile: any information about the user, filled in by the user on the Website, that is meant to be shared with other users of the So-e Software, that can be searched for by other So-e users and/or, only after the user’s approval, can be added to another user’s “friend’s list”, including the user’s own “friend’s list”.
VoIP Service: means the payable services provided by So-e and/or So-e’s partners, including but not limited to, the Making Call service, Follow Me service, Calling Card service, Virtual PBX and Voicemail service and other services which may be extended or changed from time to time;
Website: the website located at www.So-e.com.
You: You, the user of the So-e Software and the VoIP Service, also used in the form “Your” where applicable.
Contents

• What is So-e and what services does it offer?
• What information does So-e collect?
• How does So-e use this information and for what purpose?
• To whom does So-e transfer Your personal information?
• What are cookies and how does So-e use them?
• How far does So-e’s responsibility extend?
• How does So-e protect Your personal information?
• Can this Privacy Statement be modified?
• What rights do You have and how can You contact So-e?

1. What is So-e and what services does it offer?
So-e is a company established under the laws of Luxembourg. Through the Website, So-e Software S.A. offers you the So-e Software and So-e Communications S.A. offers the VoIP Service, which may be extended or changed from time to time.
2. What information does So-e collect?
In order to provide the So-e Software, So-e gathers and processes the following information.

• Register Information
• User Profile
• Personal Data of friends
• Feedback Information
• Passive Information
• E-mail addresses

In order to provide You with VoIP Service, So-e shall, in addition to the above mentioned information, collect and process the following information.

• Subscriber Information
• Traffic Data

3. How does So-e use this information and for what purpose?
Our primary purpose in collecting information is to provide You with a safe, smooth, efficient, and customized experience. We may use the information defined in this Privacy Statement to: provide the services and customer support You request; resolve disputes, collect fees, and troubleshoot problems; enforce our Terms of Service; customize, measure, and improve So-e Software, VoIP Service and Website content and layout; inform You about targeted marketing, service updates, and promotional offers unless You opt out; compare information for accuracy, and verify Your identity; provide other services for You as described when we collect the information. Additionally we may use Your information as described below.

• Register Information
  You do not need to register to use the So-e Software, but Register Information may be needed if You want to use particular services of So-e.

• User Profile
  So-e does not store the User Profile centrally on a server. In the event You choose to make the User Profile available, this information is temporarily transmitted to computers of other users in the peer-to-peer network. You can access Your User Profile from the “File” menu in the So-e Software in order to view, correct, complete or remove information. Since the User Profile is not stored centrally, So-e cannot guarantee that this information will always be available and will not disappear.

• Personal Data of friends
  You may be interested in inviting Your friends to join So-e. In the event You wish to use So-e’s referral service, You will be directed to a webpage and will have the possibility of adding one or more e-mail addresses in an online form. The information entered in this form, will only be used for the purposes of automatically generating an e-mail message to these potential So-e users and will thereafter immediately be deleted.

• Feedback Information
  Any and all information which is voluntarily submitted in feedback forms on the Website, is used for the purposes of reviewing this feedback and improving the So-e Software, VoIP Service and Website. So-e reserves the right to utilize anonymous information for marketing purposes, for instance by displaying selected comments on the Website or in other communications. Further, So-e may from time to time ask you to provide information on your experiences which will be used to measure and improve quality. You are at no time in any obligation to provide any of such data. So-e will never use any personally identifiable (feedback) information without Your explicit permission thereto.

• Passive Information
  Passive Information is automatically generated and is not stored centrally. So-e will only use this Passive Information, on an aggregated level, to provide You with better service or for statistical information.

• E-mail addresses
  So-e respects the privacy of personal e-mail accounts and stores Your e-mail addresses just as securely as other Personal Data. So-e will not send You unwanted e-mail messages or junk mail, and Your details will not be passed to third parties for their marketing purposes without Your explicit permission. However, So-e will use e-mail to send You messages about faults and service issues. So-e may also use e-mail to keep You up to date with news about the So-e Software and VoIP services. If You do not want to be kept informed in this way by e-mail, please contact So-e at delete@So-e.com. Further, So-e reserves the right to use e-mail to notify You of any eventual claims related to Your use of So-e Software and/or VoIP services, including without limitation claims of violation of third party rights.

• Subscriber Information
  So-e asks for Subscriber Information in order to verify Your identity and to provide VoIP Service. We use third party banking organizations and other providers of payment services to bill You for VoIP Service and we will, therefore, provide this billing provider with the necessary billing data.
  Please note that Your billing data is sensitive information, which can be used to find out information about Your use of VoIP Service. Please be sure to keep this information safe and do not share it with others.

• Traffic Data
  In order to transmit the calls through the PSTN and to bill the calls, So-e collects Traffic Data. So-e will erase Traffic Data, or make Traffic Data anonymous, as soon as it is no longer needed for the purpose of the transmission of the communication or for billing purposes, unless applicable law permit otherwise.

4. To whom does So-e transfer Your personal information?
Except as provided below, So-e shall not sell, rent, trade or otherwise transfer any Personal and/or Traffic Data or Communications Content to any third party without Your explicit permission, unless it is obliged to do so under applicable laws or by order of the competent authorities.
So-e may share your information with its Affiliates (as defined in the End User License Agreement).
In order to provide You with VoIP Services or other services You have requested, So-e may sometimes, if necessary, share Your Personal and Traffic Data with carriers, partner service providers and/or agents, for example the PSTN-VoIP gateway provider, distributor of So-e Software and/or VoIP Service and/or the third party banking organization or other providers of payment services. So-e will always require these third parties to take appropriate organizational and technical measures to protect Your Personal Data and Traffic Data and to observe the relevant legislation. Please be informed that, notwithstanding the abovementioned, in the event of a designated competent authority requesting So-e or So-e’s local partner responsible towards such authority, to retain and provide Personal and/or Traffic Data, or to install wiretapping equipment in order to intercept communications, So-e and/or its local partner will provide all necessary assistance and information to fulfill this request.
Information collected on the Website may be stored and processed in any country in which So-e and its affiliates maintain facilities, including outside of the EU. In this regard, or for purposes of sharing or disclosing data in accordance with this article 4, So-e reserves the right to transfer information outside of Your country. By using So-e Software or VoIP Service You consent to any such transfer of information outside of Your country. As So-e continues to develop its business, So-e might sell or buy subsidiaries or business units. In such transactions as well as in the event So-e or substantially all of its assets are acquired by a third party, personal information of So-e users will generally be one of the transferred business assets. We reserve the right to include Your personal information, collected as an asset, in any such transfer to a third party. 
Third Party Advertising
The adverts appearing on So-e’s website are delivered to you by DoubleClick, our web advertising partner. Information about your visits to this site, such as number of times you have viewed an advert (but not your name, address, or other per-sonal information), is used to serve adverts to you. For more information about DoubleClick, cookies, and how to "opt-out", click here.
5. What are cookies and how does So-e use them?
Cookies are pieces of information that So-e will transfer to Your computer’s hard drive through Your browser to enable So-e′s systems to recognize Your browser. Cookies also enable So-e to gain information about the use of its Website and to enhance the Website accordingly to the preferences of the users.
The Help option on the toolbar of most browsers will tell You how to prevent Your browser from accepting new cookies, how to have the browser notify You when You receive a new cookie, or how to disable cookies altogether. So-e’s cookies do not contain any identifying information. Please bear in mind that some personalized services may not be available if You choose to disable cookies.
Third Party Cookies
In the course of serving advertisements to this site, our third party advertiser may place or recognize a unique cookie on your browser.
6. How far does So-e’s responsibility extend?
The Website may contain links that will let You leave the Website and access another website. Linked websites are not under the control of So-e and it is possible that these websites have a different privacy policy. The Privacy Statement applies solely to personal information that is acquired on the Website, so So-e urges You to be careful when You enter any personal information online. So-e accepts no responsibility or liability for these other websites.
7. How does So-e protect Your personal information?
So-e shall take appropriate organizational and technical measures to protect the Personal Data and Traffic Data provided to it or collected by it, and shall not retain it any longer than permitted in order to perform its services or as required under relevant legislation. Your Personal and Traffic Data can only be accessed by authorized employees of So-e who need to have access to these data in order to be able to fulfill their given duties.
So-e shall take appropriate technical measures to protect the confidentiality of the Communications Content via its So-e Software and VoIP Services, with due observance of the applicable obligations and exceptions under the relevant legislation.
8. Can this Privacy Statement be modified?
So-e reserves the right to modify the provisions of this Privacy Statement if deemed necessary. We will inform You of these changes by publishing the revised Privacy Statement at www.So-e.com/ privacy. The revised Privacy Statement shall become effective within thirty (30) days of such publishing, unless You expressly accept the revised statement earlier by clicking on the accept button. You agree that the express acceptance by You, or Your continued use of the So-e Software or VoIP Service after the notice period of thirty (30) days, shall constitute Your acceptance of the Privacy Statement.
9. What rights do You have and how can You contact So-e?
If You would like to exercise your right to view, correct, complete or remove Your Personal Data, please contact So-e at delete@So-e.com. Within a reasonable period of time and upon verification of Your identity, So-e will fulfill Your request, provided So-e will not act contrary to applicable legislation by fulfilling Your request.
10. How long is Your Personal Data kept by So-e?
So-e will retain Your information for as long as is necessary to: (1) perform the VoIP Service; (2) invoice to You Your use of the VoIP Service and to maintain records until invoicing for the VoIP Service cannot be lawfully challenged and legal proceedings may no longer be pursued; (3) carry out So-e marketing activities; (4) comply with applicable legislation, regulatory requests and relevant orders from competent courts; (5) enforce our Terms of Service; or (6) fulfill any of the other purposes detailed in this Privacy Statement.