Privacy Policy

Privacy Policy

Calero Software LLC. Privacy Policy

Calero Software LLC. (“Calero,” “our,” or “we”) respects individual privacy and values the confidence of its clients, employees, business partners, and others. Calero adheres to and complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks set forth by the U.S. Department of Commerce for the transfer of personal information from European Union member countries and Switzerland. This privacy policy outlines the practices used by Calero with regard to the collection and use of personal information. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield and to view Calero’s certification, please visit

Table of Contents

I. Definitions
II. Privacy Officer
III. Collection and Use of Personal Information
IV. Privacy Principles
V. Contact Information

I. Definitions

For purposes of this Policy, the following definitions shall apply:

“EU” (European Union) refers to those countries that are members of the European Union.

“Personal Information” means any information or set of information received by Calero that identifies or could be used to identify an individual

“CLM” means Communications Lifecycle Management

“Third Party” means any person that is not an employee or agent of Calero.

II. Privacy Officer

Calero has a designated Privacy Officer responsible for our compliance with and enforcement of this policy. Calero educates its employees that will be in possession of personal information concerning compliance with this policy and undertakes self-assessment to assure compliance. Questions or complaints regarding this policy and any privacy-related issue should be submitted by mail or email to the attention of Privacy Officer, at the address found at the end of this document.

III. Collection and Use of Personal Information

This policy applies to all personal information received by Calero in any format including electronic, paper or verbal. Calero collects and processes Personal Information from current and former employees, as well as applicants for employment, clients, and prospective clients, through its Internet websites, its Intranet site, carrier portals, electronic mail, and traditional mail.

 All personal information collected by Calero will be used for legitimate business purposes consistent with this policy. Calero will not sell or trade any of the personal information collected with Third Parties.

IV. Privacy Principles

The privacy principles in this policy are based on the EU-U.S. and Swiss-U.S. Privacy Shield principles.

1. Notice: Calero collects personal information for, among other reasons, human resource management such as payroll administration, filling employment positions, maintaining accurate benefits records, meeting governmental reporting requirements, security, and health and safety management.

Calero also receives from clients, for the purpose of providing CLM solutions, information which may be considered personal information. This information may be received directly from the customer and or through the processing of customer invoices, call detail records and from the shipping of wireless devices on behalf of customers. The type of information received may be one or more of the following; Employee Id, Name, Title, Department, Cost Center, Email Address, Phone Numbers and Addresses. This information is used solely for the purposes of providing contracted CLM services.

Calero may collect information through registration on our website, subscribing to our blog, responding to a survey or filling out a form. When ordering or registering on our site you may be asked to enter your name, e-mail address, mailing address or phone number. The information collected may be used in one or more of the following ways; personalize your experience, improve our website, improve customer service, process transactions, administer a contest, promotion or survey, or to send periodic emails.

2. Choice: Users may visit our website without providing personal information. By using our website and providing personal information, you consent to our privacy policy.

3. Accountability for Onward Transfer (Transfers to Third Parties): Calero does not sell trade or rent personal information to third parties, however Calero reserves the right to use third party contractors to supplement workforce activities. Calero will only disclose information to unaffiliated third parties if required by law or authorized individuals of respective clients. In the event Calero uses a third party or must disclose information to a third party we will have in place a data processing agreement  acknowledging that data will only be used for the intended purpose and safeguard Personal Information consistent with this Policy. Calero remains liable under the Privacy Shield Principles if its onward transfer recipients process personal data in a manner inconsistent with the Principles, unless Calero proves that it is not responsible for the event giving rise to the damage.

4. Security: Calero’s hosted solutions maintain client information on secure servers located in secure data centers. Calero will take reasonable precautions to protect client information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Client information stored on these servers is protected by firewalls restricting access and requires login ids and passwords to access the information. Calero limits access to client information and data to those persons in our organization or contractor’s organization that have a specific business purpose for maintaining and processing such information and data. Any individuals who are granted access to client information will have been made aware of their responsibilities to protect the security, confidentiality, and integrity of that information and will have been provided training and instruction on how to do so.

5. Data Integrity and Purpose Limitation: Calero will collect only information which is relevant for the purposes for which it is to be used. Calero will take reasonable steps to ensure that Personal Information is relevant, accurate, complete, and current, to its intended use. Information collected is retained for archival purposes for a period of three (3) years unless otherwise specified contractually by the client.

6. Access: Calero has no direct relationship with individuals whose personal data it processes in the course of providing CLM services. An individual who seeks access to, or who seeks to correct, amend or delete inaccurate data should direct their inquiry to Calero’s client. Employees or former employees seeking access to correct, amend or delete inaccurate data may do so by contacting Human Resources.

7. Recourse, Enforcement and Liability: Calero on a regular basis conducts audits of its security and privacy practices to verify adherence to this Policy. Any employee that we determine is in violation of this Policy will be subject to disciplinary action as appropriate.

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to Calero’s Privacy Officer. Calero will investigate and attempt to resolve complaints and disputes regarding this policy directly with the individual. For disputes involving Personal Information received by Calero from the EU or Switzerland, Calero has agreed to participate in the dispute resolution program of JAMS.  If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Calero, please visit the JAMS website at for more information and to file a complaint. If the complaint remains unresolved, under certain conditions the individual may invoke binding arbitration as outlined in the Privacy Shield Framework.

Further Calero is subject to the investigative and enforcement authority of the United States Federal Trade Commission (FTC).

V. Contact Information


Calero Software LLC.
Attn: Privacy Officer
1565 Jefferson Rd.
Ste. 120
Rochester, NY 14623

Calero may amend this privacy policy from time to time consistent with the requirements of the EU-U.S. and Swiss-U.S. Privacy Shield. We will post any revised policy on this website.