Directive 2002/58/EC of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (the ePrivacy Directive) defines traffic data as: any data processed for the purpose of the conveyance of a communication on an electronic communications network or the billing thereof.
The Lumen products and services listed below process only traffic data associated with the customer’s end users, in the course of providing service to Lumen’s customer.
Voice and Unified Communications Product
- Hosted VoIP (Voice over Internet Protocol)
- Level 3® Voice Complete®
- Voice Termination
- VoIP (Voice over Internet Protocol)
Products Where Lumen Does Not Process Personal Data of Customer’s End Users
Regulation (EU) 2016/679 of 27 April 2016, the General Data Protection Regulation (GDPR), defines personal data as: “any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.” Where Lumen cannot link an IP address or similar identifier to an individual with information reasonably available to Lumen, Lumen does not consider the IP address or similar identifier to be personal data.
In addition, for certain products, Lumen is acting as a “mere conduit” of traffic under Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 (the Directive on electronic commerce). Many Lumen products do not process Customer end user personal data in the course of providing service.