Corporate Privacy Policy

Last Modified: November 12, 2018

Introduction

Oblong respects your privacy and is committed to protecting your personal information. This Privacy Policy will inform you as to how we look after your personal information when you visit our websites (regardless of where you visit them from) and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.   

1. Important Information and Who We Are

Purpose of This Privacy Policy

This Privacy Policy aims to give you information on how Oblong collects and processes your personal information through your use of the Oblong corporate website at https://www.oblong.com, its website for support at https://support.oblong.com/s/, its community website at https://community.oblong.com, and their respective subdomains (collectively, the “Website”), including any information you may provide through the Website when you schedule a demo of our services, sign up to receive our newsletter, complete one of our online forms, or apply for one of our available positions at Oblong. Please note that this Website is not intended for children. No one under age 18 may provide any information to or on this Website. We do not knowingly collect personal information from children. If you are under 18, do not use or provide any information on this Website or on or through any of its features, use any of the interactive features of this Website or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child without verification of parental consent, we will erase that information. If you believe we might have any information from or about a person under 18, please contact our Data Privacy Manager, whose contact information can be found below. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.

Controller

Oblong is made up of different legal entities, details of which can be found here https://www.oblong.com/contact. This Privacy Policy is issued on behalf of Oblong, as a group, so when we mention “Oblong”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Oblong group that is responsible for processing your information. Oblong Industries Inc. is the controller and the responsible entity for this Website. We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your information access rights, please contact our Data Privacy Manager using the details set out below.

Contact details Our full details are: Oblong Industries Inc. Data Privacy Manager Email address: privacy@oblong.com

Postal address:

US Residents: 923 E 3 rd Street, Suite 111, Los Angeles, CA 90013, U.S.A.

UK Residents: Oblong Europe Ltd, 1 st Floor, 131 Shoreditch High Street, London, E1 6JE, England

Germany Residents: Oblong Europe Ltd (German Branch), Lyonel-Feininger-Str. 28, 80807, Munich, Germany

Spanish Residents: Oblong Europe S.L., Carrer Del Pi, 3, Principal Interior, 08002 Barcelona, Spain

If you are based in the European Union, you have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact our Data Privacy Manager in the first instance.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We reserve the right to change the terms of this Privacy Policy at any time. When we do, we will post the revised Privacy Policy to our Website and the last revision date of revision will be updated so that you will always be able to understand what information we collect, how we use your information, and under what circumstances we may share your information with others. We may notify you of any material changes by way of a pop-up notice on the Website announcing that the Privacy Policy has changed. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Third-Party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

2. The Information We May Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identi ed. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer di erent kinds of personal information about you which we have grouped together follows:

  • Identity Data which may include first name, last name, username or similar identi er, marital status, title, date of birth and gender.
  • Contact Data which may include billing address, delivery address, email address and telephone numbers.
  • Financial Data which may include bank account and payment card details.
  • Transaction Data which may include details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data which may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Profile Data which may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data which may include information about how you use our Website, products and services.
  • Marketing and Communications Data which may include your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity (except for employment purposes only), religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

If You Fail to Provide Personal Information

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is Your Personal Information Collected

We use different methods to collect information from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

  • purchase one of our products or services
  • schedule a demo with us
  • subscribe to our newsletter
  • request marketing to be sent to you
  • give us some feedback
  • employment related interactions
  • contract related interactions

Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie notice (https://www.oblong.com/cookies-notice/) for further details.

Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers, advertising network and search information providers based inside or outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
  • Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
  • Identity and Contact Data from publicly available sources based inside or outside the EU.

4. How We Use Your Personal Information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes For Which We Will Use Your Personal Information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact our Data Privacy Manager if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Marketing And Promotional Offers

We strive to provide you with choices regarding certain personal information uses, particularly around marketing. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third Party Marketing

We will get your express opt-in consent before we share your personal information with any company outside Oblong for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.

Opting Out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Notice at https://www.oblong.com/cookies-notice/.

Change Of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Privacy Manager. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of Your Personal Information

We may have to share your personal information with the parties set out below for the purposes set out in the table in Section 4, above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

6. International Transfers

We may share your personal information within Oblong. This will involve transferring your information outside the European Economic Area (EEA). When we transfer your personal information to the United States, we rely on our self-certification under the EU-U.S. Privacy Shield Framework administered by the U.S. Department of Commerce. Oblong adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability for all personal information from the EU and Switzerland, including the Privacy Shield onward transfer liability provisions. For purposes of enforcing compliance with the Privacy Shield, Oblong is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review Oblong’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https:// www.privacyshield.gov/list. Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA. Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact our Data Privacy Manager if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

7. Information Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Information retention

How Long Will You Use My Personal Information For?

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal information are available upon request by contacting our Data Privacy Manager. In some circumstances you can ask us to delete your information: see “Request erasure” below for further information. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Recourse, Enforcement and Liability

Since we are committed to protecting your privacy as set forth in this Policy, if you think we are not in compliance with our Policy, or if you have any question or if you wish to take any other action concerning this Policy or your Personal Information, we encourage you to contact us at  legal@oblong.com or call us at +1 213 683 8863 and ask for Scott Martin. We will investigate your complaint, take appropriate action and report back to you within 45 days.

If the Personal Information in question was transferred from the EU to the United States, and you are not satisfied with our response, Oblong Industries Inc. has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the EU-US Privacy Shield Principles. A resident of the European Union (EU) whose enquiry has not been satisfactorily addressed may contact either the EU DPAs panel at ec-dppanel-secr’ ec.europa.eu or individual EU DPAs using the information provided at https://ec.europa.eu/info/law/law-topic/data-protection_en to resolve disputes pursuant to the EU-US Privacy Shield Principles.

Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

The services of the EU DPAs panel are provided at no cost to you.

11. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Data Privacy Manager. Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply With A Legal Or Regulatory Obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

Internal Third Parties Other companies in Oblong acting as joint controllers or processors and who are based in the U.S. or the E.U. and provide IT, HR, system administration services, Products and services, and company reporting. External Third Parties

  • Service providers acting as processors based in the U.S. or the E.U. who provide IT, system administration and marketing services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the U.S. or the E.U. who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities acting as processors or joint controllers based in the U.S. or the E.U. who require reporting of processing activities in certain circumstances.
EU Residents Legal Rights

You have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.