Collaboration Squared Privacy Policy – October 2019
Collaboration Squared Ltd (CSQ) is committed to protecting your privacy and ensuring you have a positive experience on our website and in using our Video Window product. This policy covers the Video Window website videowindow.com and the Video Window application and infrastructure itself.
This policy outlines our handling practices and how we collect and use the Personal Data you provide during your online and offline interactions with us. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, postal or other physical address, credit or debit card number, title, and other personally identifiable information.
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
Collaboration Squared Ltd will be the Controller of your Personal Data that is provided, collected and/or processed pursuant to this Privacy Policy in order to, for example, respond to requests for information or service, conclude a business transaction, provision the service, or otherwise for CSQ’s business purposes. CSQ will be a Processor of data that is entered into the service when a Customer uses the Services (see “User-Generated Information”, below.). If you have any questions about whether any of foregoing applies to you, please contact us using the information set forth in the “Contact Us” section below.
This policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our website. If we propose to make any material changes, we will notify you by means of a notice on this page prior to
the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Collection of your Personal Data
We may collect, either as Controller or Processor, the following categories of Personal Data about you when you use or otherwise interact with our Service:
• Name
• Title
• Email address
• Telephone number
• Postal or other physical address
• IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
• Our servers automatically record certain information when you use the Service, including your IP address, operating system type and version, client version, IP addresses along the network path, and the MAC address of your internet connection (“Host Information”)
• We also automatically record information about your usage of the Service, including actions taken, date and time, frequency, duration, quantity, quality, network connectivity, and performance information related to logins, clicks, use of the Whiteboard, Dial-Out usage and other feature usage information (“Usage Information”)
• Other information you upload, provide, or create while using the Service (“User-Generated Information”), as further detailed in the “User Generated Information” section below
Passive Collection
Collaboration Squared and our third-party service providers automatically collect some information about you when you use Video Window, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or Video Window.
In addition, when you use Video Window, network information is transmitted back to us such as Video Window usage information. This information is transmitted back to us, so we can determine how users are interacting with Video Window, to assist us with improving Video Window, and to correct any problems that may occur.
Processing of your Personal Data
We will use your Personal Data only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Data in this manner, you can request that your account be deactivated by contacting us as specified in the “Contact Us” section.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with Video Window) and our “legitimate interests” or the legitimate interest of others (e.g. our users),
We process Personal Data when you use Video Window for purposes such as:
• Account configuration
• Account maintenance
• Enabling meetings and webinars between users and third-party participants • Personalizing, improving or operating our Service and business
• Fulfilling requests you make related to the Service
• Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
• Providing reports based on information collected from use of our Service
• Processing your orders and deliver the Service that you have ordered
• Providing support and assistance for our Service
• Providing the ability to contact you and provide you with shipping and billing information • Providing customer feedback and support
• Complying with our contractual and legal obligations, resolving disputes with users, enforcing our agreements
We process Personal Data when you visit our website to:
• To keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information
• To provide customer feedback and support (videowindow.com/support)
• Providing you with information and offers from us or third parties
• To the extent you choose to participate, to conduct questionnaires and surveys in order to provide better products and services to our customers and end users
• To personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest
Choice
You can choose whether to provide Personal Data to Collaboration Squared, but note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided. You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy.
Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
• Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
• Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
• Erasure: You can request that we erase some or all of your Personal Data from our systems. Data subjects who want their data deleted can do so by deactivating their account. Deactivation will delete all account usage and related information. If you are not a customer and would like your data deleted, please contact the data Controller directly about deleting information.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
• Right to File Complaint: You have the right to lodge a complaint about Collaboration Squared’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Under certain circumstances we will not be able to fulfil your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please contact our Privacy Team at support@collabsq.com.
Data Retention
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data. We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
Cookies and Tracking Technologies
Collaboration Squared and our partners use cookies or similar technologies to analyse trends, administer the website, track users’ movements around the website, and gather information about our user base, such as location information based on IP addresses. Users can control the use of cookies at the individual browser level.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Products do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Products and after you leave our properties.
Geolocation
We collect information about where you are located when you are using our Products. We use this information for purposes such as optimizing your connection to our data centre, supporting compliance, and suggesting customizations to your experience with our Products (e.g. your language preference).
Sharing your Personal Data
We do not sell or rent your Personal Data to third parties for any purposes, including marketing.
We share Personal Data within CSQ and with third party service providers for purposes of data processing or storage.
We also share Personal Data with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested Products or transactions, including processing orders, processing credit card transactions, hosting websites, hosting event and seminar registration and providing customer support. We provide these third parties with Personal to complete/utilize the requested Product or transaction.
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the
assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of CSQ’s terms of service, or as otherwise required by law.
Security of your Personal Data
CSQ is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer credit card information over the Internet, we protect it using Transport Layer Security (TLS) encryption technology.
We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of upper and lower-case letters, numbers, and symbols when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us at support@collabsq.com.
Linked websites and third-party services
Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.
Transfer and Storage of Personal Data
Our Products are hosted and operated in the United States (“U.S.”) through CSQ and its service providers. We may transfer your Personal Data to the U.S., to any CSQ affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our Products or providing any Personal Data for any of the purposes stated above, you consent to the transfer and
storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.