What Personal Data Do We Receive?
Personal data is any information from or about an identified
or identifiable person, including information that Chatroom can associate with
an individual person. We may collect, or process on behalf of our customers,
the following categories of personal data when you use or interact with Chatroom
products and services:
Account Information: Information associated with an account
that licenses Chatroom products and services, which may include administrator
name, contact information, account ID, billing and transaction information, and
account plan information.
Profile and Participant Information: Information associated
with the Chatroom profile of a user who uses Chatroom products and services
under a licensed account or that is provided by an unlicensed participant
joining a meeting, which may include name, display name, picture, email
address, phone number, job information, stated locale, user ID, or other
information provided by the user and/or their account owner.
Contact Information: Contact information added by accounts
and/or their licensed end users to create contact lists on Chatroom products
and services, which may include contact information a user integrates from a
third-party app, or provided by users to process referral invitations.
Settings: Information associated with the preferences and
settings on a Chatroom account or user profile, which may include audio and
video settings, recording file location, screen sharing settings, and other
settings and configuration information.
Registration Information: Information provided when
registering for a Chatroom meeting, webinar, Chatroom Room, or recording, which
may include name and contact information, responses to registration questions,
and other registration information requested by the host.
Device Information: Information about the computers, phones,
and other devices used when interacting with Chatroom products and services,
which may include information about the speakers, microphone, camera, OS
version, hard disk ID, PC name, MAC address, IP address (which may be used to
infer general location at a city or country level), device attributes (like operating
system version and battery level), WiFi information, and other device
information (like Bluetooth signals).
Content and Context from Meetings, Webinars, Messaging, and
Other Collaborative Features: Content generated in meetings, webinars, or
messages that are hosted on Chatroom products and services (“Customer
Content”), which may include audio, video, in-meeting messages, in-meeting and
out-of-meeting whiteboards, chat messaging content, transcriptions, transcript
edits and recommendations, responses to account owner / host-sponsored
post-meeting or webinar feedback requests, responses to polls and Q&A, and
files, as well as related context, such as invitation details, meeting or chat
name, or meeting agenda. Customer Content may contain your voice and image,
depending on the account owner’s settings, what you choose to share, your
settings, and what you do on Chatroom products and services. As referenced
below, Chatroom employees do not access or use Customer Content without the
authorization of the hosting account owner, or as required for legal, safety,
or security reasons.
Usage Information Regarding Meetings, Webinars, Messaging,
Collaborative Features and the Website: Information about how people and their
devices interact with Chatroom products and services, such as: when
participants join and leave a meeting; whether participants sent messages and
who they message with; performance data; mouse movements, clicks, keystrokes or
actions (such as mute/unmute or video on/off), edits to transcript text, where
authorized by the account owner and other inputs that help Chatroom to
understand feature usage, improve product design, and suggest features; which
third-party apps are added to a meeting or other product or service and what
information and actions the app is authorized to access and perform; use of
third-party apps and the Chatroom App Marketplace; features used (such as
screen sharing, emojis, or filters); and other usage information and metrics.
This also includes information about when and how people visit and interact
with Chatroom’s websites, including what pages are accessed, interaction with
website features including Chatroom’s website’s virtual chat feature, and
whether or not the person signed up for a Chatroom product or service.
Limited Information from Chatroom Email and Calendar
Services: “Chatroom Email” refers to Chatroom’s native email service and emails
sent from Chatroom’s native email service. Chatroom Email is designed to be
end-to-end encrypted by Chatroom by default for emails sent and received
directly between active Chatroom Email users. Support for end-to-end encryption
requires Chatroom Email users to have added a device to their Chatroom Email
account with the associated email address and to use a supported Chatroom
client. When an email is end-to-end encrypted, only the users, and, depending
on their settings, account owners, or designated account administrators control
the encryption key and therefore access to the email content, including body
text, subject line, attachments and custom labels applied to messages by users
in their inboxes. Emails sent to or received from non-Chatroom Email users are
encrypted after the email is sent or received from Chatroom’s servers, if the Chatroom
Email user chooses to send them with encryption. In all cases, Chatroom does
have access to email metadata used for basic email delivery—specifically, email
addresses in the from, to, cc, and bcc fields, time, mimeID, and the number and
size of attachments. From use of Chatroom’s native calendar service, Chatroom
receives information regarding meeting invitations, body text, sender and
recipients, and other calendar information.
Content from Third-Party Integrations: Users can access
email and calendars from third-party services through their Chatroom client, if
they choose to integrate them. This information is not end-to-end encrypted by Chatroom,
but Chatroom employees do not access the contents of third-party-service email
or calendar entries, unless authorized to, or required for legal, safety, or
security reasons. If account owners and/or their licensed end users integrate
their third-party emails with products and services offered or powered by Chatroom,
such as business analytics tools like Chatroom Revenue Accelerator, Chatroom
may collect or process Customer Content and email information, including email
content, headers and metadata, from such third-party services.
Communications with Chatroom: Information about, and contents of, your
communications with Chatroom, including relating to support questions, website
virtual chats, your account, feedback provided by users to Chatroom about Chatroom’s
products and services (which is owned by Chatroom), and other inquiries.
Information from Partners: Chatroom obtains information
about account owners and their users from third-party companies, such as market
data enrichment services, including information about an account owner’s
company size or industry, contact information, or activity of certain
enterprise domains. Chatroom may also obtain information from third-party
advertising partners that deliver ads displayed on Chatroom products and
services, such as whether you clicked on an ad they showed you.
In certain jurisdictions, some of the personal data Chatroom
receives may be considered sensitive. Please see “California & Other U.S.
State Privacy Rights” for more information.
How Do We Use Personal Data?
Chatroom employees do not access or use Customer Content
including meeting, webinar, messaging, or email content (specifically, audio,
video, files, in-meeting whiteboards, messaging, or email contents), or any
content generated or shared as part of other collaborative features (such as
out-of-meeting whiteboards), unless authorized by the account owner hosting the
Chatroom product or service where the Customer Content was generated, or as
required for legal, safety, or security reasons. Chatroom does not use any of
your audio, video, chat, screen sharing, attachments or other
communications-like Customer Content (such as poll results, whiteboard and
reactions) to train Chatroom’s or third-party artificial intelligence models.
As discussed below, and where technically feasible, Chatroom
uses personal data to conduct the following activities:
Provide Chatroom Products and Services: To provide products
and services to account owners, their licensed end users, and those they invite
to join meetings and webinars hosted on their accounts, including to customize Chatroom
products and services and recommendations for accounts of their users. Chatroom
also uses personal data to determine what products and services may be
available in your location, and uses personal data, including contact
information, to route invitations, messages, or Chatroom Emails to recipients
when users send or receive invitations, messages, or Chatroom Emails using Chatroom
products and services. This may also include using personal data for customer
support, which may include accessing audio, video, files, messages, and other
content or context, including information you provide through Chatroom’s
website’s virtual chat feature, at the direction of the account owner or their
users. We also use personal data to manage our relationships and contracts with
account owners and others, including billing, compliance with contractual
obligations, facilitating payment to third-party developers in relation to
purchases made through the Chatroom App Marketplace, and related
administration.
Local Device Video Features: If you elect to enable certain
video features, if available in your area, such as filters, studio effects,
avatars, and gestures, information about your movements or the positioning of
your face or hands may be processed on your device to apply the selected
features. Such data does not leave your device, is not retained, cannot be used
to identify you, and is only used to generate the selected effects.
Enhanced Audio Features: If you elect to enable enhanced
audio features and provide the requisite consent, if available in your area, Chatroom
may analyze your voice and create a voiceprint to enhance your audio quality
(such as suppressing background noise). Chatroom may generate your voiceprint
from a recording of your voice (if you upload it for this purpose) and/or from
meetings that you participate in, but only if you enable enhanced audio
features. Chatroom will store and use your voiceprint and reference audio
recording for these purposes while you have features that use your voiceprint
enabled. You can disable these features and delete this data any time in your
Settings. We will retain this data until and unless you choose to disable these
features and delete this data or for up to three years after you last interact
with Chatroom.
Intelligent Features: Chatroom provides intelligent features
and products to its customers, their licensed end users and guests, such as Chatroom
AI or other tools to recommend chat, email or other content. These tools may
use artificial intelligence, machine learning, or other technology to process
Customer Content solely to provide the intelligent features.
Product Research and Development: If authorized by any
applicable settings, to develop, test, and improve Chatroom products and
services, and to troubleshoot products and services. Chatroom does not use any
of your audio, video, chat, screen sharing, attachments or other
communications-like Customer Content (such as poll results, whiteboard and
reactions) to train Chatroom’s or its third-party artificial intelligence
models.
Marketing and Promotions: If authorized by any applicable
settings, to permit Chatroom and/or its third party marketing partners to
market, advertise, and promote Chatroom products and services, including based
on your product usage, information we receive from third-party partners,
information you provide to process referral invitations, or if you visit our
websites, information about how and when you visit, and your interactions with
them. We may also use this information to provide advertisements to you
relating to Chatroom products and services or to engage third party partners to
analyze your interactions on our website or app or to deliver advertising to
you. Chatroom does not use Customer Content for any marketing or promotions.
Authentication, Integrity, Security, and Safety: To
authenticate accounts and activity, detect, investigate, and prevent malicious
conduct, fraudulent activity or unsafe experiences, address security threats,
protect public safety, and secure Chatroom products and services. Chatroom uses
advanced tools to automatically scan certain types of content such as virtual
backgrounds, profile images, incoming emails to Chatroom’s native email service
from someone who is not a Chatroom Email user, and files uploaded or exchanged
through chat, for the purpose detecting and preventing violations of our terms
or policies and illegal or other harmful activity.
Communicate with You: We use personal data (including
contact information, and information you provide through Chatroom’s website’s
virtual chat feature, including the content of the messages) to communicate
with you about Chatroom products and services, including product updates, your
account, and changes to our policies and terms. We also use your information to
respond to you when you contact us.
Legal Reasons: To comply with applicable law or respond to
valid legal process, including from law enforcement or government agencies, to
investigate or participate in civil discovery, litigation, or other adversarial
legal proceedings, protect you, us, and others from fraudulent, malicious,
deceptive, abusive, or unlawful activities, and to enforce or investigate
potential violations of our Terms of Service or policies.
How Do We Share Personal Data?
Chatroom provides personal data to third parties only with
consent or in one of the following circumstances (subject to your prior consent
where required under applicable law):
Resellers: If an account owner licensed or purchased Chatroom
products and services from a third-party reseller of Chatroom products and
services, the reseller may be able to access personal data and content for
users, including meetings, webinars, and messages hosted by the account owner.
Vendors: Chatroom works with third-party service providers
to provide, support, and improve Chatroom products and services and technical
infrastructure, and for business services such as payment processing, including
in relation to purchases made through the Chatroom App Marketplace. Chatroom
may also work with third-party service providers to provide advertisements and
business analytics regarding Chatroom products and services. These vendors can
access personal data subject to contractual and technical requirements for
protecting personal data and prohibiting them from using personal data for any
purpose other than to provide services to Chatroom or as required by law. Chatroom
may integrate third-party technology to provide advanced features, such as
Apple’s TrueDepth technology, to process information on your device about your
face or hand dimensions and gestures to provide video effects. This information
is processed on your device, and such information is neither received nor
stored by either the third party, or Chatroom.
For Legal Reasons: Chatroom may share personal data as
needed to: (1) comply with applicable law or respond to, investigate, or
participate in valid legal process and proceedings, including from law
enforcement or government agencies; (2) enforce or investigate potential
violations of its Terms of Service or policies; (3) detect, prevent, or
investigate potential fraud, abuse, or safety and security concerns, including
threats to the public; (4) meet our corporate and social responsibility
commitments; (5) protect our and our customers’ rights and property; and (6)
resolve disputes and enforce agreements.
Marketing, Advertising, and Analytics Partners: Chatroom
uses third-party marketing, advertising, and analytics providers: to provide
statistics and analysis about how people are using Chatroom products and
services, including our website; and to provide advertising and marketing for Chatroom
products and services, including targeted advertising based on your use of our
website. These third-party partners may receive information about your
activities on Chatroom’s website through third-party cookies placed on Chatroom’s
website. To opt out of our use of third-party cookies that share data with
these partners, visit our cookie management tool, available in Cookies
Settings. Where required by law, Chatroom will first obtain your consent before
engaging in the marketing or advertising activities described.
Corporate Affiliates: Chatroom shares personal information
with corporate affiliates, such as Chatroom Voice Communications, Inc., to
provide integrated and consistent experiences across Chatroom products and
services (such as enabling an account owner or their user to integrate a Chatroom
Phone call into a meeting) and to detect, investigate, and prevent fraud,
abuse, and threats to public safety.
Change of Control: 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 Chatroom’s business or assets,
including in connection with bankruptcy or similar proceedings.
Third-Party Developers: If you purchase a third-party app or
integration from the Chatroom App Marketplace, Chatroom may share information
about the purchase with the third-party developer, to provide the app or
integration.
Who Can See, Share, and Process My Personal Data When I Join
Meetings and Use Other Chatroom Products and Services?
When you send messages or join meetings and webinars on Chatroom,
other people and organizations, including third parties outside the meeting,
webinar, or message, may be able to see content and information that you share:
Account Owner: An account owner is the organization or
individual that signs up for a Chatroom account. Typically, an account owner
designates one or more people (called an “administrator”) to manage their
account and can grant privileges to users on the account. Depending on their
license with Chatroom, the account owner can authorize additional users on
their account, and the account owner can create and/or access the profile
information for all users on their account. The account owner and their users
can invite others (including guests not on their account and unlicensed
participants) to meetings or webinars hosted on their account. Chatroom gives
account owners controls and features that they can use to determine whether
certain types of content, such as recordings or Chatroom Team Chat messages,
can be created or sent, and what third-party apps can be used, for meetings and
webinars hosted on their account. Depending on their settings, account owners
and the users they designate can access personal data for participants who join
meetings and webinars on their account or send messages to users on their
account. Account owners may also be able to determine what information Chatroom
and others can access and use. Specifically, account owners may have access to:
Account Usage:
Product Usage: Information about how users and their devices
interact with their account, which may include who sent messages to their users
in chat, email addresses, IP addresses, device information, and other
information about who joined meetings or webinars on their account, whether
their users viewed or downloaded a recording, how long participants
participated in their meetings, the time a message was sent, information about Chatroom
Phone integrations, and other usage information and feedback metrics.
Participant List: Information about the participants in a Chatroom
meeting, webinar, or chat, which may include name, display name, email address,
phone number, and participant or user ID.
Registration Information: Information provided during
registration for a webinar, meeting, Chatroom Room, or recording hosted by the
account.
Chatroom Team Chat and Out-of-Meeting Collaborations: If enabled on their account, account owners
and those they authorize can see information about who sent and received Chatroom
Team Chat messages, including synced in-meeting messages (e.g., from a
dedicated meeting group chat that is synced with Chatroom Team Chat), to users
on their account, along with information about the message (for example, date
and time, and number of members or participants). Depending on their settings,
account owners also can see sender and receiver information, and other messaging
data, along with the content of messages sent to and from users on their
account (including from in-meeting chat where dedicated meeting group chats are
enabled), unless the account owner has enabled Advanced Chat Encryption.
Depending on their settings, account owners and those they authorize may also
see the content shared through collaborative features, including whiteboards,
files, and images shared in Chatroom Team Chat.
In-Meeting/Webinar Messages:
Depending on their settings, account owners can see sender and receiver
information, along with the content of messages sent to and from users on their
account, in the following circumstances:
Messages sent to Everyone in a meeting that is recorded
Messages sent to the meeting group chat in a meeting when a
dedicated meeting group chat is enabled
Messages sent to panelists in a webinar that is recorded
Messages sent in dedicated meeting group chats in Team Chat
Direct messages if the account owner has enabled archiving
If a participant in a meeting is subject to archiving, their
account owner will have access to messages sent to Everyone in the meeting, as
well as direct messages sent to that participant. If a participant who is a
member of a dedicated meeting group chat is subject to archiving, the member’s
account owner will have access to the meeting group chat messages, as well as
direct messages sent to that member. If a guest in a meeting with a dedicated
meeting group chat is subject to archiving, the guest’s account owner will have
access to messages sent to the meeting group chat, as well as direct messages
sent to that guest.
Recordings: Account owners can watch the content of
recordings of meetings and webinars hosted on their account. They can also
view, share, and enable advanced features for transcripts of meeting audio.
Polling, Q&A, and Feedback: Account owners can see
information about who provided responses to their polls, Q&A, or
post-meeting or webinar feedback requests, including name and contact
information, together with the responses or feedback, unless responses are
submitted anonymously.
Chatroom Email and Chatroom Calendar Content: Depending on
their settings,account owners, and designated account administrators, can
access email and calendar content sent to and from users on theirChatroom Email
or Chatroom Calendar accounts, even if those Chatroom Emails are encrypted.
Meeting Hosts, Participants, and Invitees: Meeting hosts,
participants, and invitees may be able to see your email, display name, profile
picture, and presence status, including in Chatroom meetings and in Chatroom’s
native calendar service. Meeting hosts, participants, and invitees can also see
and (depending on the account owner’s settings) record, save, and share meeting
content, audio transcripts, messages sent to Everyone, messages sent to meeting
group chats (where enabled, and whether sent in Team Chat or in-meeting), or
messages sent to them directly, and files, whiteboards or other information
shared with them (including during a meeting, or through a dedicated meeting
group chat). Meeting hosts may also share chat transcripts to Chatroom Team
Chat, depending on their account owner’s settings. Meeting hosts may also be
able to see responses to Q&A and polls generated during the meeting.
Chatroom Email, Calendar and Chatroom Team Chat Recipients:
Recipients of Chatroom Emails and Chatroom Calendar invites can see, save, and
share your email and calendar content with others, including by sharing emails
to Chatroom Team Chat. If a recipient shares encrypted content with others, for
example, by sharing an encrypted Chatroom Email to Chatroom Team Chat, or
forwarding an encrypted Chatroom Email to a third-party recipient without a Chatroom
Email account, the shared or forwarded content will not be end-to-end encrypted
by Chatroom. Those with access to your device and login credentials may be able
to see, save and share your email and calendar contents on that device.
Recipients of Chatroom Team Chats can see your messages, reactions, emojis, and
related content, including content from Chatroom Emails, Chatroom Calendar, and
emails from third-party services integrated in the Chatroom client, that you or
a third-party choose to share to Chatroom Team Chat, and in-meeting messages
that participants send that are synced with Chatroom Team Chat through
dedicated meeting group chats. Depending on the account owner’s settings, Chatroom
Team Chat recipients may record, save, or share your messages.
Webinar Panelists and Attendees: Only panelists may be
visible to attendees during a webinar, but attendees who agree to unmute can be
heard by other attendees. If an attendee agrees to become a panelist during a
webinar, they may be visible to other attendees, depending on settings.
Panelists and attendees may be able to see the name of a participant who asks a
question during a Q&A, along with their question, unless the participant
submits the question anonymously.
Livestreams: Meeting and webinar hosts can choose to
livestream to a third-party site or service, which means anyone with access to
the livestream will be able to see the meeting or webinar.
Apps and Integrations:
Account owners can choose to add Chatroom-developed apps and
third-party apps to their account and the Chatroom products they use, including
via use of the Chatroom App Marketplace, and they can also control whether
their users can add and use specific Chatroom and third-party apps, including
in meetings, webinars, and chats hosted on their account.
Account owners can also choose to integrate other content
from third-party services– such as third-party email communications on their
corporate account – to apps and services that they use, such as Chatroom
Revenue Accelerator (that provides insights and business analytics related to
businesses when they use Chatroom products). Further, account owners may choose
to have Chatroom analyze the meeting’s audio recording to distinguish one
speaker from another in order to create an accurate transcript. The audio
analysis is not retained after the transcript is generated.
Depending on their settings, account owners’, users’ and
guests’ personal data and content may be shared with apps and integrations,
including Chatroom-developed apps, approved by account owners, which may
include all of the personal data categories listed above, such as account
information, profile and contact information, registration information,
participants list, settings, content, product usage, device information, or
third-party emails that have been shared with the app.
Other participants in the meeting may be able to see the app
that you are using in a meeting, if the app is receiving content (including
audio and video) from the meeting.
Third-party developers may also integrate or embed Chatroom
meetings into their website or app experiences or build versions of Chatroom
that enable access to Chatroom products from a third-party app.
Personal information shared by account owners and users with
third-party apps and integrations is collected and processed in accordance with
the app developers’ terms and privacy policies, not Chatroom’s.
Privacy Rights and Choices
Marketing Communications
If you don’t want to learn about products and services we or
our partners offer, you can opt-out of marketing communications in the
communication sent to you (for example, via email or SMS), or by emailing
privacy@Chatroom.us. Not all of our communications are for marketing, and
you’ll continue to receive messages related to your products and services, such
as bills, transactional notices, or customer service. Chatroom will not share
any mobile data originating from you through a text messaging campaign except
with your consent or as necessary to provide you communications about our
services or services that you requested.
Data Rights
If you are in the European Economic Area (EEA), Switzerland,
or the UK, or a resident of California or another U.S. state with an applicable
privacy law, please refer to the respective dedicated sections below.
Otherwise, at your request, and as required by applicable law, we will:
Inform you of what personal data we have about you that is
under our control;
Amend or correct such personal data or any previous privacy
preferences you selected, or direct you to
applicable tools; and/or
Delete such personal data or direct you to applicable tools.
In order to exercise any of your rights as to personal data
controlled by Chatroom, please click here. Where legally permitted, we may
decline to process requests that are unreasonably repetitive or systematic,
require disproportionate technical effort, or jeopardize the privacy of others.
As an account owner or a user under a licensed account, you may also take steps
to affect your personal data by visiting your account and modifying your
personal data directly.
Children
Chatroom does not allow children under the age of 16 to sign
up for a Chatroom account.
For educational organizations that use Chatroom products and
services to provide educational services to children under 18, Chatroom’s
Children’s Educational Privacy Statement is available here.
How to Contact Us
To exercise your rights, please click here. If you have any
privacy-related questions or comments related to this Privacy Statement, please
send an email to privacy@Chatroom.us.
You can also contact us by writing to the following address:
Chatroom Video Communications, Inc.
Attention: Data Protection Officer
55 Almaden Blvd, Suite 600
San Jose, CA 95113
Or to our representative in the EU or UK:
Lionheart Squared (Europe) Limited
Attn: Data Privacy
2 Pembroke House
Upper Pembroke Street 28-32
Dublin
DO2 EK84
Republic of lreland
email: Chatroom@LionheartSquared.eu
Lionheart Squared Limited
Attn: Data Privacy
17 Glasshouse Studios
Fryern Court Road
Fordingbridge
Hampshire
SP6 1QX
United Kingdom
Contact: Chatroom@LionheartSquared.co.uk
You can contact our Data Protection Officer by sending an
email to privacy@Chatroom.us.
Retention
We retain personal data for as long as required to engage in
the uses described in this Privacy Statement, unless a longer retention period
is required by applicable law.
The criteria used to determine our retention periods include
the following:
The length of time we have an ongoing relationship with you
and provide Chatroom products and services to you (for example, for as long as
you have an account with us or keep using our products);
Whether account owners modify or their users delete
information through their accounts;
Whether we have a legal obligation to keep the data (for
example, certain laws require us to keep records of your transactions for a
certain period of time before we can delete them); or
Whether retention is advisable in light of our legal
position (such as in regard to the enforcement of our agreements, the
resolution of disputes, and applicable statutes of limitations, litigation, or
regulatory investigation).
European Data Protection Specific Information
Data Subjects Rights
If you are in the EEA, Switzerland, or the UK, your rights
in relation to your personal data processed by us as a controller specifically
include:
Right of access and/or portability: You have the right to
access any personal data that we hold about you and, in some circumstances,
have that data provided to you so that you can provide or “port” that data to
another provider;
Right of erasure: In certain circumstances, you have the
right to the erasure of personal data that we hold about you (for example, if
it is no longer necessary for the purposes for which it was originally
collected);
Right to object to processing: In certain circumstances, you
have the right to request that we stop processing your personal data and/or
stop sending you marketing communications;
Right to rectification: You have the right to require us to
correct any inaccurate or incomplete personal data;
Right to restrict processing: You have the right to request
that we restrict processing of your personal data in certain circumstances (for
example, where you believe that the personal data we hold about you is not
accurate or lawfully held).
To exercise your rights, please click here. If you have any
other questions about our use of your personal data, please send a request at
the contact details specified in the How to Contact Us section of this Privacy
Statement. Please note that we may request you to provide us with additional
information in order to confirm your identity and ensure that you are entitled
to access the relevant personal data.
You also have the right to lodge a complaint to a data
protection authority. For more information, please contact your local data
protection authority.
Legal Basis for Processing Personal Data
We only use your information in a lawful, transparent, and
fair manner. Depending on the specific personal data concerned and the factual
context, when Chatroom processes personal data as a controller for individuals
in regions such as the EEA, Switzerland, and the UK, we rely on the following
legal bases as applicable in your jurisdiction:
As necessary for our contract: When we enter into a contract
directly with you, we process your personal data on the basis of our contract
in order to prepare and enter into the contract, as well as to perform and
manage our contract (i.e., providing Chatroom products and services, features
and services to account owners, their users, and those they invite to join
meetings and webinars hosted on their accounts, and manage our relationship and
contract, including billing, compliance with contractual obligations, and
related administration). If we do not process your personal data for these
purposes, we may not be able to provide you with all products and services;
Consistent with specific revocable consents: We rely on your
prior consent in order to utilize cookies to engage advertising and analytics
partners to deliver tailored advertising and analysis of our website usage. You
have the right to withdraw your consent at any time by visiting our cookie
management tool, available Cookies Settings;
As necessary to comply with our legal obligations: We
process your personal data to comply with the legal obligations to which we are
subject for the purposes of compliance with EEA laws, regulations, codes of
practice, guidelines, or rules applicable to us, and for responses to requests
from, and other communications with, competent EEA public, governmental,
judicial, or other regulatory authorities. This includes detecting,
investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal
activity (“fraud and abuse detection”) and compliance with privacy laws;
To protect your vital interests or those of others: We
process certain personal data in order to protect vital interests for the
purpose of detecting and preventing illicit activities that impact vital
interests and public safety, including child sexual abuse material; and
As necessary for our (or others’) legitimate interests,
unless those interests are overridden by your interests or fundamental rights
and freedoms, which require protection of personal data: We process your
personal data based on such legitimate interests to (i) enter and perform the
contract with the account owner and/or reseller providing you with the products
and services (which includes billing, compliance with contractual obligations,
and related administration and support); (ii) develop, test, and improve our
products and services and troubleshoot products and services; (iii) ensure
authentication, integrity, security, and safety of accounts, activity, and
products and services, including detect and prevent malicious conduct and
violations of our terms and policies, prevent or investigate bad or unsafe
experiences, and address security threats; (iv) send marketing communications,
advertising, and promotions related to the products and services; and (v)
comply with non-EEA laws, regulations, codes of practice, guidelines, or rules
applicable to us and respond to requests from, and other communications with,
competent non-EEA public, governmental, judicial, or other regulatory
authorities, as well as meet our corporate and social responsibility commitments,
protect our rights and property and the ones of our customers, resolve
disputes, and enforce agreements.
International Data Transfers
Chatroom operates globally, which means personal data may be
transferred, stored (for example, in a data center), and processed outside of
the country or region where it was initially collected where Chatroom or its
service providers have customers or facilities – including in countries where
meeting participants or account owners hosting meetings or webinars that you
participate in or receiving messages that you send are based.
Therefore, by using Chatroom products and services 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
where we are established, as well as in other countries outside of the EEA,
Switzerland, and the UK. Such countries may have data protection rules that are
different and less protective than those of your country.
We protect your personal data in accordance with this
Privacy Statement wherever it is processed and take appropriate contractual or
other steps to protect it under applicable laws. Where personal data of users
in the EEA, Switzerland, or the UK is being transferred to a recipient located
in a country outside the EEA, Switzerland, or the UK which has not been
recognized as having an adequate level of data protection, we ensure that the
transfer is governed by the European Commission’s standard contractual clauses.
Please contact us if you would like further information in that respect.
Chatroom complies with the EU-U.S. Data Privacy Framework
(EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data
Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of
Commerce. Chatroom has certified to the U.S. Department of Commerce that it
adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF
Principles) with regard to the processing of personal data received from the
European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and
Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Chatroom has
certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S.
Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to
the processing of personal data received from Switzerland in reliance on the
Swiss-U.S. DPF. If there is any conflict between the terms in this privacy
policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the
Principles shall govern. To learn more about the Data Privacy Framework (DPF)
program, and to view our certification, please visit
https://www.dataprivacyframework.gov/.
In compliance with the EU-U.S. DPF and the UK Extension to
the EU-U.S. DPF and the Swiss-U.S. DPF, Chatroom commits to resolve DPF
Principles-related complaints about our collection and use of your personal
information. EU and UK and Swiss individuals with inquiries or complaints
regarding our handling of personal data received in reliance on the EU-U.S. DPF
and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first
contact Chatroom at: privacy@Chatroom.us..
In compliance with the EU-U.S. DPF and the UK Extension to
the EU-U.S. DPF and the Swiss-U.S. DPF, Chatroom commits to cooperate and
comply respectively with the advice of the panel established by the EU data
protection authorities (DPAs) and the UK Information Commissioner’s Office
(ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data
Protection and Information Commissioner (FDPIC) with regard to unresolved
complaints concerning our handling of personal data received in reliance on the
EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
Chatroom Video Communications, Inc., Chatroom Voice
Communications, Inc., and Solvvy, Inc., are adhering to the DPF Principles. The
Federal Trade Commission has jurisdiction over Chatroom’s compliance with the
EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the
EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
If third-party agents process personal data on our behalf in
a manner inconsistent with the DPF Principles, we remain liable unless we prove
we are not responsible for the event giving rise to any damages. If you have a
question or complaint related to our compliance with the DPF Principles, please
contact us as indicated at the bottom of this privacy statement.
Under limited circumstances and after other available
dispute resolution mechanisms have been exhausted, binding arbitration is
available to address certain residual complaints under the DPF not resolved by
other means.
California & Other U.S. States Notice at Collection
Categories of Personal Information Chatroom Receives: Chatroom
may collect, or process on behalf of our customers, the following categories of
personal data, as described above, in the “What Personal Data Do We Receive?”;
section: identifiers (such as in Account Information, Profile and Participant
Information, Contact Information, and Registration Information), financial
account information (such as in Account Information); commercial information
(such as in Account Information); internet or other electronic network activity
information (such as Device Information, Usage Information Regarding Meetings,
Webinars, Message, Collaborative Features, and the Website, and Limited
Information from Chatroom Email and Calendar Services); audio, electronic, and
visual information (such as in Content and Context from Meetings, Webinars,
Messaging, and Other Collaborative Features) education information such as from
university customers; inferences we derive from the preceding or other
information we collect; and sensitive personal information (such as certain
categories in Account Information, Content and Context from Meetings, Webinars,
Messaging, and Other Collaborative Features.
Sources: We receive information from sources as described in
the “What Personal Data Do We Receive?”; section, including: from you
(including through your use of our products and services); from partners; from
customers; and from publicly available sources. We collect education
information from schools that use our services. Please see our Children’s
Educational Privacy Statement for more information.
Chatroom’s business and commercial purposes for use: Chatroom
uses personal data for the following business and commercial purposes: to
provide Chatroom Products and Services; for Product Research and Development;
for Marketing and Promotions (Chatroom does not use meeting, webinar, or
messaging content, or any content generated or shared as part of other
collaborative features for any marketing or promotions); Authentication,
Integrity, Security, and Safety; to Communicate with You; and for Legal Reasons.
For more information, please see “Data We Process & How We Use It.”;
Categories of third parties to whom we disclose Personal Information for
business purposes are described in “How Do We Share Personal Data?”;
Chatroom may permit advertising and analytics services that
are intended to deliver advertising to you and/or analyze your interactions,
based on your interactions with our website or app which may constitute a
“sale” or “sharing” of data for targeted advertising purposes under certain
state privacy laws. See “California & Other U.S. State Privacy Rights” for
more information regarding your right to opt-out.
Retention: Chatroom retains personal data for as long as
required to engage in the uses described in this Privacy Statement, unless a
longer retention period is required by applicable law. Additional detail on
retention criteria can be found under Retention, above.
California & Other U.S. State Privacy Rights
Under some U.S. state laws, including the California
Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy
Rights Act) (CCPA), residents may have a right to:
Access the categories and specific pieces of personal data Chatroom
has collected, the categories of sources from which the personal data is
collected, the business purpose(s) for collecting the personal data, and the
categories of third parties with whom Chatroom has shared personal data, and
obtain the personal data in a portable and, to the extent technically feasible,
readily usable format;
Delete personal data under certain circumstances;
Correct personal data under certain circumstances; and
Opt out of the “sale” of personal data or “sharing” of
personal data for targeted advertising purposes. We do not sell your personal
data in the conventional sense. However, like many companies, we may use
advertising and analytics services that are intended to analyze your
interactions with our website or app, based on information obtained from
cookies or other trackers, including for delivering advertising to you (such as
interest-based, targeted, or cross-context behavioral advertising). You can get
more information and opt out of the use of cookies and other trackers on our
website and app by clicking the Cookies Settings Your Privacy Choices, also on
our homepage, and setting your preferences. You will need to set your
preferences from each device and each web browser from which you wish to opt
out. This feature uses a cookie to remember your preference, so if you clear
all cookies from your browser, you will need to re-select your preferred
settings. California and Connecticut residents may also set the Global Privacy
Control (GPC) to opt out of the “sale” or “sharing” of your personal
information for targeted advertising for each participating browser system that
you use. Chatroom does not have actual knowledge that it “sells” or “shares”
the personal information of consumers under 16 years of age.
Appeal a denial of your request. Some states provide
additional rights to their residents. If we decline to process your request,
you may have the right to appeal our decision. You can do so by replying
directly to our denial or emailing privacy@Chatroom.us.
Chatroom will not discriminate against you for exercising
any of these rights, which is further in line with your rights under state law.
Sensitive Information.
Chatroom receives information that may be considered sensitive under
some state laws, such as certain Account Information (e.g., financial
information, log-in information), certain Content and Context from Meetings,
Webinars, Messaging, and Other Collaborative Features and certain Limited
Information from Chatroom Email and Calendar Services (e.g., messaging content
in cases described in this statement) as well as voiceprints if you choose to
enable certain features and provide the requisite consent. Chatroom processes
sensitive personal information to provide Chatroom products and services, for
product research and development, for authentication, integrity, security, and
safety reasons, to communicate with you, for legal reasons, and with your
consent. Chatroom does not use or disclose sensitive personal information (as
defined under CCPA) for purposes of inferring characteristics about a consumer,
or in any way that would require Chatroom to provide a right to limit under the
CCPA. Under certain laws, residents may also be permitted to opt out of certain
profiling relating to automated processing analyzing certain categories of an
individual’s information that would produce a legal or similarly significant
effect. Chatroom does not engage in this type of profiling of individuals.
To exercise your rights, please click here. California
residents may also call +1-888-799-0566. To opt out of the use of cookies on
our sites for interest-based advertising purposes, follow the instructions
above.
We will acknowledge receipt of your request within 10
business days, and provide a substantive response within 45 calendar days, or
inform you of the reason and extension period (up to a total of 90 days) in
writing.
These rights are not absolute, are subject to exceptions and
limitations, and may not be afforded to residents of all states. In certain
cases, we may decline requests to exercise these rights where permitted by law.
We will need to verify your identity to process your access, deletion, and
correction requests and reserve the right to confirm your state residency. To
verify your identity, we may require you to log into your existing Chatroom
account (if applicable), give a declaration as to your identity under penalty
of perjury, and/or provide additional information, such as providing at least
two pieces of personal information relating to your account (which will be
compared to information we have, such as profile information) or as we
otherwise may already have in our possession, such as your email address and
phone number. We will verify your consumer request by comparing the information
you provide to information already in our possession, and take additional steps
to minimize the risk of fraud. You may designate an authorized agent to submit
your verified consumer request by providing written permission and verifying
your identity, or through proof of power of attorney.
To see our Disclosure of Privacy Rights Requests, please
click here.
California’s 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 privacy@Chatroom.us. 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.
Changes to This Privacy Statement
We may update this Privacy Statement periodically to account
for changes in our collection and/or processing of personal data, and will post
the updated Privacy Statement on our website, with a “Last Updated” date at the
top and an Update Note at the bottom. If we make material changes to this
Privacy Statement, we will notify you and provide you an opportunity to review
before you choose to continue using our products and services.