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DETAILS OF PROCESSING FOR LUMEN PRODUCTS AND SERVICES

Details of Processing for Lumen Products and Services

Service type, locations, quantity, configuration, features, term and similar details selected and ordered by the customer shall constitute processing instructions to Lumen to the extent required under data protection laws.  Customer self-service activity (via online portals and similar functionality), customer-directed actions such as moves/adds/changes, and similar interaction with the products and services that impact processing shall similarly constitute processing instructions to Lumen.

 

Customers determine what data is processed by their use of Lumen products and services, whether and for how long such data may be processed using such services, where processing takes place based on service locations, and whether to configure Lumen products and services or purchase additional products and services to increase security protections for customer Data.  For products and services generally, the following details apply:

A.  Subject Matter.  The subject matter of the processing is the personal data the customer elects to process via the products and services.

 

B.  Duration.  The duration of the processing undertaken by Lumen is the service term applicable to the relevant products and services as ordered, instructed, or otherwise initiated by the customer from time-to-time and as may be set forth on the applicable order forms and/or statements of work.

 

C.  Nature.  The nature of the processing undertaken by Lumen is the transmission, computing, storage or other similar information technology infrastructure services and processing activities available through the customer’s use of the applicable products and services and as further described in the agreement and relevant order forms and/or statements of work.

 

D.  Purpose.  The purpose of the processing undertaken by Lumen is the provision of the applicable products and services to the customer.

 

E.  Type of Personal Data.  The type of personal data processed by Lumen is determined by the customer and includes any type of personal data the customer elects to process through the customer’s use of the products and services. 

 

F.  Categories of Data Subjects.  The categories of data subjects whose personal data may be processed by Lumen is determined by the customer and includes any categories of data subjects the customer elects to process through the customer’s use of the products and services.  

Product and Service Specific Details of Data Processing

Lumen Products and Services Processing Only Traffic Data of Customer’s End Users

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 & 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.