Vevomo Framework Privacy Statement
Vevomo, and its subsidiaries, affiliates and parent companies (“Vevomo”, “we”, “us” or “our”) is committed to protecting your privacy and ensuring you have a positive experience when you use our video conferencing and communication services (the “Services”), visit our webpages, interact with us on social media, or attend a Vevomo event offline or online.
This Statement explains Vevomo’s practices when we process your “personal data,” which is information that relates to an identified or identifiable individual. To “process” or “processing” means any use of personal data including, transferring, collecting, recording, storing, using, analyzing, combining, disclosing or deleting it.
This Statement may be updated periodically. If we plan to make any material changes to the way we handle personal data as described here, we will notify you by posting an updated version of this Statement on our website. Changes to this Statement are summarized in our Change Log. We may supplement this Statement with “just-in-time” notices, or other disclosures contained within or in connection with the provision of the Services, which may describe in more detail our data collection, use and sharing practices. Unless we say otherwise, such supplemental privacy statements will govern how we may process the information in the context of the specific product or service.
What this Statement Covers
This Statement applies to the personal data we process as a data controller, that is, as the party that determines what data to collect and why. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with the Services. The data we collect depends on the context of your interactions with Vevomo and the choices you make, including the products and features you use. We also obtain data about you from third parties.
When you use Vevomo’s Services through a Vevomo account holder, the processing of your personal data is determined and administered by that account holder under its privacy policies. If you have questions about how and why your personal data is collected, the legal basis for processing, or requests regarding your personal data, please refer to the account holder’s privacy statement and direct your inquiries to the account holder or its administrator.
Your California Privacy Rights
If you are a resident of the State of California, this Privacy Statement is supplemented by our California Privacy Rights Statement that explains your California privacy rights and how you can exercise these rights.
Vevomo and Children
Vevomo does not knowingly allow children under the age of 16 to sign up for their own accounts.
Who This Policy Applies To
Customers: Our Customers are typically corporations and organizations that contract with Vevomo to provide one or more Vevomo Services for managing their virtual conferences and other events. The Customer’s employees, independent contractors, and other associates interact with the Vevomo Services on behalf of the Customer.
Users: These are individuals and businesses who interact with our Customers through one or more Vevomo Services in connection with our Customer’s event. They include attendees who register for the event using Vevomo Services; suppliers of services to our Customer for the event; and buyers of services on behalf of our Customer to manage the event.
Visitors: These are individuals who interact with www.vevomo.com in order to learn more about Vevomo and our services, to request a demo, to download information, or similar purposes. Our Vevomo Services allow our Customers to collect a variety of Personal Data from and about their Users such as name, organization, title, mailing address, e-mail address, telephone number, social media account ID, credit or debit card number, and content that the User chooses to upload.
Personal Data We Process & How We Use It
The table below describes Vevomo’s processing of personal data as a data controller. The table does not cover Customer content or User content, including any personal data about you and Users that may be contained in Customer content—such as event recordings or transcripts—because the Customer (the Vevomo account holder), or User, rather than Vevomo, controls how Customer and User content is processed. Any questions about the processing of Customer and User content should be addressed to the Customer directly.
Personal Data Processing
Types of Personal Data
How We Get It
What We Do With It
[Applies only in the EEA, and only within the meaning of the EU’s General Data Protection Regulation (GDPR)]
Account User Data
Information we collect when you or your Users register for a Vevomo Account, such as:
From the Vevomo Account registrant
Technical information from Vevomo’s software or systems hosting the Services, and from the systems, applications and devices that are used to access the Services, such as:
Automatically through use of the Services
Support and Feedback Data,
Directly from a Vevomo Customer or User
(e.g., nearest city or town)
Automatically through your use of the Services
VEVOMO uses the following Sub-Processors. VEVOMO shall include privacy provisions which are the same or reasonably equivalent to those in this Statement in its agreements with its Sub-Processors. VEVOMO shall ensure that all Sub-Processors comply with VEVOMO’s obligations hereunder and shall be liable for any act or omission by its Sub-Processors. “Sub-Processor” means any third party that VEVOMO uses to process Personal Data, and any downstream third party that processes Personal Data on behalf of such subcontractor.
Customer content is the “in-session” information you or Users give us directly through your use of the Services, such as event recordings, files, chat logs, making and responding to comments, reacting to comments, watching videos or presentations, downloads, and transcripts, and any other information uploaded while using the Services. Vevomo uses Customer and User content only in connection with providing the Services – we do not monitor, sell or use Customer or User content for any other purposes.
Our Customers use personal data in planning and managing their events and related activities. For example, if a User chooses to use the Services to conduct business with our Customer (such as registering for an event, or providing input related to the event), any personal data or other information provided by the User will be transferred to, and under the control of, our Customer.
Our Customers will also have access to information (including personal data) related to how the User interacts with the Services they choose to use.
In collecting and using personal data, our Customers act as data controllers with regard to the User, under the European Union General Data Protection Regulation (“GDPR”). Vevomo cannot, and does not, take responsibility for the privacy practices of our Customers or their event planners, event organizers, or other suppliers. Vevomo encourages Users to review the particular Customer’s privacy policies to understand its privacy practices and procedures.
We do not control the actions of anyone with whom you, your Users, or any other Service user may choose to share information. Therefore, we cannot and do not guarantee that any Customer content you or any User provides to the Services will not be viewed by unauthorized persons. Nor can Vevomo control the information a User may choose to share during an event. Although Vevomo account holders can set privacy options that limit access to certain areas of the Services, please be aware that no security measures are perfect or impenetrable and that we are not responsible for circumvention of any security measures contained on the Services. You should be cautious about the access you provide to others when using the Services, and the information you choose to share when using the Services.
How does Vevomo handle Personal Data of Visitors?
A visitor who is examining www.vevomo.com for informational purposes will have Personal Data, such as the visitor’s IP address, cookies, and similar technologies.
If a visitor requests a demonstration of the Services or decides to download a buyer’s guide, with the visitor’s permission we will collect and/or process Personal Data such as the visitor’s name, email address and phone number. We will use this information to fulfill the visitor’s order, send the visitor the requested product or service information, or respond to Customer service requests.
The personal data of visitors has substantially the same rights as personal data of Users.
How We Share Personal Data
We only share personal data with companies, organizations or individuals outside of Vevomo when one of the following circumstances applies:
We may share personal data with companies, organizations, individuals outside of Vevomo and others when we have consent from an individual (as applicable).
For Corporate Transactions
We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Vevomo’s business or assets, including in connection with bankruptcy or similar proceedings.
For Business Purposes
We provide personal data to vendors and services providers to help us provide the Services and for Vevomo’s business purposes. Examples include public cloud storage vendors, carriers, payment processor, and service provider for managing Customer or User support tickets. Vevomo contractually prohibits such vendors from using the personal data for any reason other than to provide the contracted-for services and Vevomo contractually requires its vendors to comply with all appropriate privacy and security requirements.
For Legal Reasons
We share personal data with companies, organizations or individuals outside of Vevomo if we believe that access, use, preservation or disclosure of the information is reasonably necessary to:
Data Subject Privacy Rights and Choices
Right to Correct or Update Your Information
If you would like to correct or update information that you have provided to us, please logon to www.vevomo.com and update your profile.
You may receive marketing email communications from us where permissible. If you would like to stop receiving these communications, you can update your preferences by using the “Unsubscribe” link found in those emails.
European Privacy Rights
If you reside in the European Economic Area, you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.
How to Exercise Your Rights
To exercise any of the rights above, email us at email@example.com. You and Users may also submit a request to the following address:
Attention: Data Privacy Officer
17 Edgewood Way
San Rafael, California 94901
Please identify yourself and specify your request. If you have a password protected Vevomo account, we will use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.
We use commercially reasonable efforts to delete your personal data as required but retain records necessary to comply with a governmental authority or applicable federal, state, or local law. Where legally permitted, we may decline to process requests, including requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.
Vevomo operates globally, which means personal data may be stored and processed (for example stored in a data center) in any country where we or our service providers have facilities or hold events. By using Vevomo or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States or in other countries around the world. Such countries may have data protection rules that are different and less protective than those of your country.
If you are a resident of the European Economic Area (EEA), and your personal data is transferred outside of the EEA, we will:
We will retain personal data for as long as required to do what we say we will in this Statement, unless a longer retention period is required by applicable law. The criteria used to determine our retention periods include:
Customers can delete their own accounts.
Vevomo is committed to protecting your personal data. We use reasonable and appropriate technical and organizational measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data. If you have any questions about the security of your data, please contact our security team at firstname.lastname@example.org
How to Contact Us
If you have any privacy-related questions or comments related to this Statement, please send an email to email@example.com. You can also contact us by writing to this address:
Attention: Data Privacy Officer
17 Edgewood Way
San Rafael, California 94901
Data Protection Officer
Bruce Wheaton is our Data Protection Officer for the EEA and he can also be contacted at firstname.lastname@example.org
California Privacy Rights Statement
This California Privacy Rights Statement (this “Statement”) explains how Vevomo, a California corporation, and our subsidiaries, affiliates and parent companies ("Vevomo," "we," "us," or "our") collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act of 2018 (CCPA). This Statement also explains California residents’ rights under the CCPA and California Civil Code section 1798.83 (the "Shine the Light law”).
For purposes of this Statement, unless a different definition is noted, "Personal Information" has the definition given in the CCPA. However, this Statement does not apply to:
Your California Privacy Rights under the CCPA
You can request the following information about how we have collected and used your Personal Information during the past 12 months:
How to Exercise Your Rights
You may submit requests to exercise your California privacy rights described above as follows:
Right to information, access, and deletion. If you are a California resident, you may submit a request to exercise your information, access, and deletion rights by emailing dataprivacy@vevomo.
Right to opt-out of the “sale” of your Personal Information. We do not sell your personal information in the conventional sense.
We will need to verify your identity to process your information, access, and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require you to log into your Vevomo account (if applicable), provide government identification, give a declaration as to your identity under penalty of perjury, and/or provide additional information.
Your authorized agent may make a request on your behalf upon our verification of the agent's identity and our receipt of a copy of the valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.
Our Personal Information Collection and Use Practices
The categories of Personal Information we collect are described below by reference to the statutory categories of Personal Information specified in the CCPA (California Civil Code section 1798.140):
Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described above.
Sources. Internet/network activity information, geolocation, IP address, and other online identifiers are collected automatically through your use of our online services. We may collect some professional information, and California customer records information from our affiliates, third party data providers, or publicly available sources. Otherwise, we collect the information above from you.
Disclosures to third parties for business purposes. We describe the categories of third parties to whom we disclose Personal Information described above for business purposes in the section of our Privacy Statement entitled How We Share Personal Data.
Business/commercial purposes for use. We describe the business and commercial purposes for which we use the Personal Information described above in the section of our Privacy Statement entitled Data We Process & How We Use It.
This section describes our practices currently and during the 12 months preceding the ‘Last Updated’ date of this Statement.
California Shine the Light Law
Under California’s Shine the Light law, you may also ask companies with whom you have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to email@example.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.