1. Who we are
Orílé Networks is a customer experience, technical support and contact-center consultancy business operated by Coxama LLC, a limited liability company organized under the laws of the State of Georgia, United States (“Coxama”, “Orílé Networks”, “we”, “us” or “our”). Coxama LLC is responsible for the personal information described in this Privacy Policy.
You can contact us about privacy at contact@orilenetworks.com or by post at 1349 W Peachtree Street NW, Suite 1910, #796, Atlanta, GA 30309, United States.
2. Scope of this policy
This policy applies to personal information we collect:
- through our websites, including the pages on which this policy is posted (the “Site”);
- when you request a proposal, call back or consultation, use our team-size estimator or health check, or otherwise contact us;
- when you register interest in working with us or apply for a role;
- in the course of our business relationships with clients, prospective clients, suppliers and partners, including their representatives.
It does not govern personal information about our clients’ own customers or employees that we process on a client’s behalf while delivering services. That processing is governed by our contract with the client and the client’s own privacy notice. See section 6.
3. Information we collect
Information you give us
- Contact and business details: name, work email address, phone number, company, job title.
- Inquiry details: your sector, contact volumes, services, channels and languages you need, start date, current platform, team size, challenges and any notes you add.
- Tool inputs: answers you enter in the team-size estimator or contact-center health check when you choose to send them with a request.
- Careers information: name, email, years of experience, languages, and anything else you choose to send us in an application.
- Communications: the content of emails, calls, video meetings and messages you exchange with us. Calls and meetings may be recorded where you are told in advance and, where required, you consent.
Please do not send us sensitive information (such as health, financial-account or government ID details) through the Site’s forms.
Information collected automatically
- Technical data: IP address, browser and device type, operating system, referring page, pages viewed and the date and time of your visit, collected through server logs and the services that host and deliver the Site.
- Website analytics: aggregated information about visits, such as pages viewed, referring sites, approximate country, device type and page performance, collected through Cloudflare Web Analytics. It does not use cookies or build a profile of you across other websites.
- Security checks: when you submit a form, Cloudflare Turnstile may check signals from your browser and device to tell people from automated bots.
- Cookies and similar technologies: as described in section 8.
Information from other sources
We may receive business contact information from your colleagues who refer you, from public professional sources (such as company websites and professional networks), from event organizers and from our service providers. We combine it with information you give us only for the purposes in this policy.
4. How we use information
- to respond to inquiries, arrange discovery calls and prepare proposals and estimates;
- to provide, manage and invoice our services, and to administer our contracts;
- to assess job applicants and manage recruitment;
- to send service communications and, where permitted, information about our services (see section 14);
- to operate, secure, maintain and improve the Site, including detecting and preventing fraud, abuse and security incidents;
- to understand how the Site is used, in aggregated or de-identified form;
- to comply with legal, regulatory, tax and accounting obligations, and to respond to lawful requests from authorities;
- to establish, exercise or defend legal claims and to enforce our agreements;
- in connection with a merger, acquisition, financing, reorganization or sale of all or part of our business.
We do not use personal information collected through the Site to make decisions that produce legal or similarly significant effects about you based solely on automated processing.
5. Legal bases (EEA, UK and similar laws)
Where the EU or UK General Data Protection Regulation, Nigeria’s Data Protection Act 2023, the Philippines Data Privacy Act of 2012 or a similar law applies, we rely on these legal bases:
- Contract: to take steps at your request before entering into a contract, and to perform our contracts.
- Legitimate interests: to run and grow our business, respond to business inquiries, keep the Site secure and defend our rights, where those interests are not overridden by your rights.
- Consent: for optional cookies, certain marketing and call recording where consent is required. You can withdraw consent at any time; this does not affect processing that already took place.
- Legal obligation: where we must process information to comply with the law.
6. Client customer data we handle for clients
When we deliver customer service, technical support or related services, we handle information about our clients’ customers and users (for example names, contact details, account information, call recordings, chat transcripts and support tickets) on behalf of and under the instructions of our client. In this role we act as a “processor” or “service provider” and the client is the “controller” or “business”.
- We process that information only to provide the services, as set out in our agreement and data processing terms with the client.
- The client is responsible for providing notice to, and obtaining any consent required from, its customers, and for the lawfulness of its instructions.
- If you are a customer of one of our clients and want to exercise privacy rights, please contact that company directly. If you contact us, we will pass your request to the relevant client where we are able to identify it.
7. How we share information
We do not sell personal information, and we do not share it for cross-context behavioral advertising. We share personal information only as follows:
- Service providers who act for us under contract, such as website hosting, analytics and form security (Cloudflare), form delivery (we use FormSubmit to deliver website form submissions to our inbox), meeting scheduling (if you book a call through a scheduling link), CRM tools, email, messaging, video-conferencing, contact-center platforms, background-check providers (for applicants, where lawful), payroll, IT, security and professional advisers. They may use the information only to provide services to us.
- Our clients, where you are a client’s customer or user and the information was collected while delivering services to that client.
- Affiliates of Coxama LLC, for the purposes in this policy.
- Legal and safety: where we believe disclosure is required by law, regulation, legal process or a governmental request, or is necessary to protect the rights, property or safety of Coxama LLC, our clients, our people or others, or to detect and prevent fraud or security issues.
- Business transfers: to a buyer, investor, successor or other party in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy or sale of assets, subject to standard confidentiality protections.
- With your direction or consent.
We may share aggregated or de-identified information that cannot reasonably identify you.
8. Cookies and similar technologies
The Site uses only the technologies needed to display, measure and secure it. Our fonts and images are hosted with the Site itself, so loading a page does not send your information to font or advertising providers. We use Cloudflare Web Analytics, which measures visits without setting cookies, and Cloudflare Turnstile, which helps protect our forms from spam and may use browser storage or similar technologies strictly for that security purpose. The Site sets no advertising cookies.
If we add analytics, advertising or other non-essential cookies in future, we will update this policy and, where the law requires, ask for your consent first through a cookie banner. You can also block or delete cookies in your browser settings; the Site may not work fully without essential technologies.
Global Privacy Control and Do Not Track: where required by law, we treat a Global Privacy Control signal as a valid request to opt out of the sale or sharing of personal information for that browser. Because there is no agreed standard for “Do Not Track” signals, we do not respond to them.
9. International transfers
We are a fully remote business. Our people and service providers may be located in the United States and in other countries, so your information may be transferred to and processed in countries whose data protection laws differ from those where you live. Where the law requires, we protect such transfers with appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or other lawful mechanisms. You can ask us for more information about these safeguards.
10. How long we keep information
We keep personal information only for as long as needed for the purposes in this policy, including to meet legal, accounting and reporting requirements and to resolve disputes. As a guide:
| Information | Typical retention |
|---|---|
| Inquiries that do not lead to a contract | Up to 24 months after our last contact |
| Client relationship and contract records | The contract term plus up to 7 years |
| Applicant and careers-interest information | Up to 12 months after the role is filled or your last contact, unless you agree to a longer period or we hire you |
| Server and security logs | Up to 12 months |
| Client customer data processed for clients | As set out in the client agreement |
When information is no longer needed, we delete it or de-identify it. Backups are overwritten on a rolling schedule.
11. How we protect information
We use administrative, technical and physical safeguards that we consider appropriate to the nature of the information, such as encrypted devices, multi-factor authentication, role-based access, secure remote access, confidentiality agreements and security training. Our practices are described further on our Security & Trust page. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach that affects your personal information, we will notify you and the authorities where the law requires.
12. Your rights and choices
Depending on where you live, you may have the right to:
- know whether we process your personal information and access a copy of it;
- correct inaccurate information;
- delete your information;
- receive your information in a portable format;
- object to or restrict certain processing, including processing based on legitimate interests and direct marketing;
- withdraw consent at any time where we rely on consent;
- opt out of the sale or sharing of personal information, targeted advertising and certain profiling (we do not do these);
- not be discriminated against for exercising your rights;
- lodge a complaint with your data protection authority (for example, an EU supervisory authority, the UK Information Commissioner’s Office, the Nigeria Data Protection Commission or the Philippines National Privacy Commission).
How to make a request: email contact@orilenetworks.com with the subject “Privacy request”. We will verify your identity before acting, which may require you to confirm information we already hold. You may use an authorized agent where the law allows; we may ask for proof of the agent’s authority and confirm your identity directly. We respond within the time required by applicable law (generally 30 to 45 days). If we decline your request, you may appeal by replying to our decision with the subject “Privacy appeal”.
These rights are subject to legal exceptions, for example where we must keep information to comply with the law or to establish or defend legal claims.
13. United States state privacy rights
Residents of California and other US states with consumer privacy laws (including Colorado, Connecticut, Virginia, Texas and others) have the rights described in section 12, to the extent those laws apply to us. In the past 12 months we have collected the following categories of personal information, for the purposes in section 4, from the sources in section 3, and disclosed them for business purposes to the recipients in section 7:
- identifiers (name, email, phone, IP address);
- professional or employment-related information (company, job title, work experience);
- internet or other electronic network activity (Site usage and technical data);
- audio or electronic information (call or meeting recordings, where applicable);
- inferences limited to understanding your service needs.
We do not sell or share personal information as those terms are defined under California law, and we have no actual knowledge of selling or sharing personal information of consumers under 16. We do not use or disclose sensitive personal information for purposes that require a right to limit. California residents may also ask about disclosures to third parties for direct marketing purposes; we make none.
14. Marketing, calls and messages
We send marketing emails to business contacts only where permitted by law. Every marketing email includes an unsubscribe link, and you can opt out at any time by contacting us. We will still send messages about your inquiries, contracts and our services.
By providing a phone number and asking us to contact you, you agree that we may call or message you about your request. We do not send automated marketing calls or text messages without the prior express written consent required by law, and consent is never a condition of buying our services. Reply STOP to any text message to opt out.
If you choose WhatsApp as your preferred contact method, we will contact you through WhatsApp. Messages sent through WhatsApp are also subject to WhatsApp’s own terms and privacy policy.
15. Job applicants
We use applicant information to assess your suitability, communicate with you, verify your information and, where lawful and with notice, run background checks. We are an equal opportunity employer and do not discriminate based on any characteristic protected by law. If you are hired, your information will be handled under our employee privacy notice.
16. Children
The Site and our services are intended for businesses and adults. They are not directed to children under 16, and we do not knowingly collect personal information from them. If you believe a child has given us personal information, contact us and we will delete it.
17. Third-party sites and services
The Site may link to websites and services we do not control. Their privacy practices are governed by their own policies, and we are not responsible for them.
18. Changes to this policy
We may update this policy from time to time. We will post the updated version with a new “last updated” date and, where changes are material, give additional notice as required by law. Your continued use of the Site after the update means you have been informed of the updated policy.
19. Contact us
Coxama LLC (Orílé Networks)
1349 W Peachtree Street NW, Suite 1910, #796
Atlanta, GA 30309, United States
Email: contact@orilenetworks.com
Where the law requires us to appoint a representative in the EU or UK, or a data protection officer, we will list their details here.