Privacy Policy

(Last modified on May 27th, 2014)

Pear Comms is committed to the confidentiality and security of any personal information that you provide us with. When accessing our website, services and/or products, you may be required to give us certain information. This privacy statement describes the conduct and practices of Pear Comms as it applies to all our clients and visitors.

  1. User Information
    • Pear Comms collects User Information when you use Pear Comms solutions, products and/or services, when you visit our web pages or micro site web pages.
    • ”User Information” means any information that may be used to identify an individual or entity, including, but not limited to:
      • Identification data (for example, first and last name, email address, home, postal or other physical address, e-mail address, mobile phone number, telephone number, other contact information, title, birth date, gender, personal interests, other information needed to provide a service you requested;
      • Electronic identification data (for example, IP addresses, cookies phone information, country information and network information;
      • Payment related information;
      • Survey results;
      • Information about your usage of and interaction with Pear Comms’ website, solutions, products and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our websites;
      • Solutions, products and/or services ordered and delivered;
      • List of your contacts;
      • Your user profile including your username and password;
      • If you give us your username and password for other email accounts where you have provided this to us and requested us to search for your friends on Pear Comms (Please note that Pear Comms does not retain this information or use it for any other purpose);
      • Correspondence between you and Pear Comms
      • Traffic data (data processed for the purpose of the conveyance of communications or the billing thereof, including, but not limited to, the duration of the call, the number calling and the number called);
      • Transaction data including without limitation, data relating to the consumption, top-up, expiry and transfer of credits;
      • Business financial information; and
      • Any content that is required by any applicable laws or regulatory authorities.
    • When you browse our website, you do so anonymously, unless you have previously indicated that you wish Pear Comms to remember your login and password. Like many other commercial website, the Pear Comms website may use a standard technology called a “cookie” to collect information about how you use the site. The Company may store and access such “cookies” on your computer. Making use of this technologyis necessary for using The Service. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. We seta persistent cookie to store your preferences. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. If you reject cookies, you may stilluse our site, but your ability to use some areas of our site, will be limited. The use of cookies by our partners, affiliates, tracking utility company, service providers is not covered by our privacy statement. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, service providers use session ID cookies to make it easier for you to navigate our site.
    • Pear Comms collects certain User Information when you register with Pear Comms for QuickDesk account, when you use certain Pear Comms solutions, products and/or services, when you ask to be included in an email or other mailing list, or when you submit User Information to Pear Comms for any other reason. From time to time, Pear Comms receives User Information from business partners and vendors. Pear Comms only uses such information if it has been collected in accordance with acceptable privacy practices consistent with this Privacy Policy and applicable laws.
    • Access to certain Pear Comms web pages may require a username and a password. The use of the web pages, information or programs downloadable from those sites, and solutions, product and/or services available from Pear Comms’s web pages shall be governed by the Terms of Use and this Privacy Policy. Unless you request deletion of User Information as specified below, User Information may be retained by Pear Comms to verify compliance with the Terms of Use and this Privacy Policy, log software licenses granted, to track software, solutions, product and/or services downloaded from those web pages, or track usage of other applications, solutions, product and/or services available on those web pages.
    • When you use Pear Comms applications, you may be asked to import your leads / contacts information. A copy of your contacts will be stored on our servers and will be used strictly for your own sales activities.
    • You may have the right to access and, if necessary, to rectify your User Information.
  2. Notice
    • When User Information is collected, we will inform you at the point of collection the purpose for the collection.
    • Pear Comms will not transfer User Information to third parties without your consent, except under the limited conditions described under the discussion entitled “Information Sharing and Disclosure” below.
    • If you choose to provide us with User Information, we may only transfer that information, within Pear Comms or to Pear Comms’s third party service providers with your permission.
    • Upon receiving your permission, we may transfer your information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
  3. Opt-Out Policy
    • We will always give you the opportunity to “opt out” of receiving direct marketing or market research information. This means we assume you have given us your consent to collect and use your information in accordance with this Privacy Policy unless you take affirmative action to indicate that you do not consent, for instance by
      • clicking or checking the appropriate option or box at the point of collection; or
      • by e-mailing us at
    • In some cases, when applicable, we will provide you with the opportunity to “opt in.” This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted.
    • Pear Comms is not responsible for removing User Information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy.
    • You may also ask Pear Comms and its group of companies to stop processing User Information. However, please note that this will most likely prevent you from using some or all of our solutions, products and/or services since Pear Comms must use User Information in order to provide you with our solutions, products and/or services. You can exercise your right to prevent further processing of User Information by contacting Pear Comms at
  4. Information Usage
    • Our primary purpose in collecting User Information is to provide you with a safe, smooth, efficient, and customised experience. Pear Comms collects and uses, or has third party service providers acting on Pear Comms’s behalf collecting and using, User Information relating to you, as permitted or necessary to:
      • provide communication products, in particular to convey the communications you make by means of our solutions, products and/or services;
      • process transactions and payment for the purchase of credits;
      • offer or provide other solutions, products and/or services to you from time to time;
      • provide you with customer support and troubleshoot problems;
      • compare information for accuracy;
      • inform you about service updates and faults;
      • request feedback or participation in on-line surveys;
      • resolve disputes;
      • verify your identity;
      • customize, measure, and improve our website, solutions, products and/or services;
      • to improve our search functionality and help you find contacts more easily;
      • organise and carry out marketing or promotional operations, offers, contests, games and similar events; and
      • protect both yours and Pear Comms’s interests, including fraud detection and enforcement of our Terms of Use.
    • Pear Comms and, where relevant, the Pear Comms group companies will retain User Information for as long as is necessary to carry out any of the purposes set out in this Privacy Policy and to comply with applicable laws and orders of competent authorities.
  5. Role as Data Intermediaries
    • According to the Personal Data Protection Act, Pear Comms and Hoiio are data intermediaries providing the subscribers with the relevant DNC and communication services and therefore will not be subjected to the main obligations except for: – Protection of Personal Data – Retention of Personal Data
    • Pear Comms will take reasonable measures to comply with the above obligations as required by the Act as a data intermediary. The User is advised to ensure its own compliance with the Act.
    • Pear Comms via the Leads Management module shall collect leads information and transaction records relating to calls, SMS, made using a third Party application Hoiio, and with Spidergate if there is a need for DNC screening which are only accessible to the Users. Straits Interactive and its partners shall be permitted access and use of such transaction records for the purpose of providing assistance in the event of an Error or Support Request.
    • In the event of any claim made against the User of a breach of the Act, Pear Comms and its partners shall be entitled to disclose the subscriber’s transaction records for the purpose of assisting the Personal Data Protection Commission in any investigation.
    • When you terminate your Hoiio/QuickDesk account, your personal data will also be deleted or anonymized and will not be retained.
  6. Information Sharing and Disclosure
    • User Information may be stored and processed in any country in which Pear Comms and its group companies maintain facilities. In this regard, or for purposes of sharing or disclosing User Information in accordance with this Privacy Policy, Pear Comms reserves the right to transfer User Information outside of your country of residence. By using Pear Comms’s website, solutions, products and/or services you consent to any such transfer of User Information outside of your country of residence. Such User Information may be subject to supervision by the regulatory authorities in each jurisdiction where Services are performed or User Information resides, as well as in the jurisdiction of your residence or citizenship
    • In order to provide you with Pear Comms solutions, products and/or services you have requested, Pear Comms may sometimes, if necessary, share some of User Information and traffic data with Pear Comms group companies, carriers, partner service providers and/or agents, for example the PSTN-VoIP gateway provider, Wifi access services providers, distributors of Pear Comms solutions, products and/or services, and/or the third party banking organizations or other providers of payment, email delivery, analytical services, customer support, or hosting services. Pear Comms will always require these third parties to take appropriate organizational and technical measures to protect User Information and traffic data and to observe applicable laws. Pear Comms group companies are governed by this Privacy Policy or are bound by appropriate confidentiality and data transfer agreements.
    • Some Pear Comms solutions, products and/or services may be co-branded and offered together with or via a partner company. If you register for or use such solutions, products and/or services, you consent to both Pear Comms and the partner company’s use of some of the User Information collected in connection with the co-branded product, as necessary. Pear Comms may offer its website, solutions, products and/or services in connection with other websites, solutions, products and/or services or may team with other online services to give you the combined results of both solutions, products and/or services or additional solutions, products and/or services and benefits. To determine whether you would benefit from the combined offer, if you have provided your consent, Pear Comms may match your email address and/or phone number, and email addresses and/or phone number of your contacts against email addresses and/or phone number you have provided to the third party website/service provider.
    • Within Pear Comms, User Information and traffic data are stored in controlled servers with limited access. Pear Comms shall not share, sell, rent, trade or otherwise transfer any personal and/or User Information, traffic data and/or communications content to any third party without your explicit permission, except as provided in this Privacy Policy.
    • Pear Comms may send User Information to other companies or people under any of the following circumstances:
      • when we have your consent to share the User Information;
      • we need to share your information to provide the solutions, products and/or services that you have requested; and
      • we need to send the User Information to third parties who on behalf of Pear Comms provide solutions, products and/or services to you (we will only provide such third parties the relevant information required for the delivery of the solutions, productions and/or services, and the third parties are prohibited from using such User Information for any other purpose).
    • Pear Comms considers any and all messages transmitted via our webpages, solutions, products and/or services to be private communication between our customer and the recipient. You agree that Pear Comms may monitor, edit or disclose the content of our customer’s private communications, and/or disclose User Information to third parties:
      • as required by applicable laws, to comply with legal process or by the order of competent authorities;
      • where necessary to enforce the Terms of Use and/or this Privacy Policy;
      • to respond to legal claims that the customer violated the rights of third parties; or
      • to protect the safety, interests, rights or property of Pear Comms or others.
    • You acknowledge, understand and agree that Pear Comms may in its sole discretion cooperate with any affected third party by providing information and/or data in either a civil or criminal forum if you violate the provisions of the Terms of Use and/or the Privacy Policy. You acknowledge, understand and agree that Pear Comms does not endorse the content of any customer communications and Pear Comms is not responsible or liable for any unlawful, harassing, libellous, privacy invading, abusive, threatening, harmful, vulgar, obscene, tortuous, or otherwise objectionable content, or content that infringes or may infringe upon the intellectual property or other rights of another.
    • We also may use User Information to keep you updated on our latest solutions, products and/or services announcements, software updates and special offers or other information you may be interested to hear about from us unless you have opted out of these types of communications. 6.9 As Pear Comms continues to develop its business, Pear Comms may sell or buy subsidiaries or business units. In such transactions as well as in the event that all or substantially all of Pear Comms’s assets are acquired by a third party, User Information of Pear Comms users will generally be one of the transferred business assets. We reserve the right to include User Information, collected as an asset, in any such transfer to a third party.
  7. Data Security
    • QuickDesk account information is password-protected for your privacy and security. Pear Comms has implemented reasonable security policies, rules and technical measures to safeguard the security of User Information and the data you send us with physical, electronic, and managerial procedures. While Pear Comms strives to protect User Information, we cannot ensure the security of the information you transmit to us, andwe urge you to take every precaution to protect your personal information when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
    • You undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorized person, and to inform us as soon as reasonably practicable at if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised inany way or that actual or possible unauthorized transactions have taken place. Pear Comms is not liable for any damages resulting from any security breaches, on unauthorized and/or fraudulent use of your username and password.
  8. Anti-Spyware Policy
    • Pear Comms believes that spyware is a threat to customer privacy and a customer’s experience online.
    • Spyware refers to any executable software application that is installed on a user’s personal computer and covertly gathers and transmits User Information through the user’s Internet connection without the knowledge or consent of the user. Cookies and web beacons are not considered spyware. Spyware may gatherUser Information, such as e-mail addresses and credit card information, and may even alter personal computer settings.
    • Intentional use of spyware by any Pear Comms employee, agent, partner, or affiliate on Pear Comms’s behalf will not be tolerated and will be considered grounds for dismissal, contract termination, and/or loss of payment.
  9. Anti-Spam Policy
    • Pear Comms has zero tolerance for spam. If you receive spam messages and want to report it to Pear Comms, please forward the message you have received to
  10. Contacting You
    • Pear Comms may contact you to notify you of issues and faults with our solutions, products and/or services, and if you are considered to have breached any of the terms of the Terms of Use and/or Privacy Policy, or if another person makes a complaint about your use of our solutions, products and/or services.
    • Pear Comms may occasionally ask you to provide information on your experiences with our solutions, products and/or services. Any such feedback will always be voluntary and will be used only for the purposes of measuring and improving the quality of our solutions, products and/or services and not stored as User Information or combined with other User Information.
  11. Changes to Privacy Policy
    • Pear Comms may, at its sole and absolute discretion, amend this Privacy Policy from time to time. If we make any substantial changes in the way we use User Information we will make that information availableby posting a notice on this web site or by publishing the modified Privacy Policy.
    • It is your responsibility to review the terms of this Privacy Policy from time to time, particularly if the most recent revision date is after the date on which you last reviewed them.
    • Any changes will become effective as specified in the notice. If you access the web site and/or use the solutions, products and/or services after notification of a change in this Privacy Policy, you will be bound by all such changes.

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