Processing Details and Lumen Privacy Data Sheets

Processing Details and Lumen Privacy Data Sheets

Processing Details and Lumen Privacy Data Sheets

Service type, locations, quantity, configuration, features, term, and similar details selected and ordered by the customer constitute processing instructions to Lumen to the extent required under privacy and 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 similarly constitute processing instructions to Lumen.


Customers determine what information, including personal information, is processed by their use of Lumen products and services, whether and for how long such information 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 information 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 information.  The type of personal information processed by Lumen is determined by the customer and includes any type of personal information 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 information 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

For the products and services with links to Privacy Data Sheets displayed below, Lumen provides additional processing details where Lumen may access or process specific end user personal information while providing the products and services.  These processing details supplement the applicable service descriptions and orders included in the agreement between Lumen and the customer and will be updated as details change.


Privacy Data Sheets for Selected Lumen Products and Services


Lumen Products Only Processing Customer End User Traffic Data

The European Union’s 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), Article 2 (b) 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 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 Products

  • Hosted VoIP (Voice over Internet Protocol)
  • Level 3® Voice Complete®
  • Voice Termination
  • VoIP (Voice over Internet Protocol)


Lumen Products Not Processing Customer End User Traffic Data

For certain products, Lumen is acting as a “mere conduit” of traffic under Article 12 of Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 (the Electronic Commerce Directive 2000). A service provider’s service qualifies as a mere conduit, if the service provider:

(a) does not initiate the transmission;

(b) does not select the receiver of the transmission; and

(c) does not select or modify the information contained in the transmission.


Many Lumen products do not process Customer end user personal information in the course of providing service.