Effective date: April 21st, 2020
This policy describes what information we collect when you use Remo’s sites, services, mobile applications, products, and content (“Services”). It also provides information about how we store, transfer, use, and delete that information, and what choices you have with respect to the information.
This policy applies to Remo’s online video office space and conference meetup tool, including the website and other Remo websites (collectively “the Websites”), as well as other interaction (e.g. customer support conversations, user surveys and interviews etc.) you may have with Remo.
This policy applies where we are acting as a Data Controller with respect to the personal data of users of our Services; in other words, where we determine the purposes and means of the processing of that personal data. For content and data that you upload to or make available through the Service (“User Content”), you are responsible for ensuring this content is in accordance with our Terms of Service, and that the content is not violating other users’ privacy.
How we collect, process and store information
We at Remo are committed to safeguarding the privacy of our users. Our business model is to provide a paid service to users who need additional features on top of the TRIAL version, and does not rely on widespread collection of general user data. We will only collect information that we need to deliver the service to you, and continue to maintain and develop the service.
Remo may collect, store and process various kinds of data, with different legal grounds, as listed below. For the categories of data that require your consent, we will actively ask you for consent before collecting any data. You can give and revoke your consents at any time.
The following is a list of data we collect, process or store, with the purpose and legal ground listed for each item or group of items having the same purpose and legal ground:
- User account information. Users that choose to register in Remo, will have to provide a valid email address or use Google Authentication. The user can also choose to enter a display name and/or add a profile picture that will be used to represent them in conversations.
- Workspace or Event information. To create a workspace or Event in Remo, you as a user will have to select a Workspace or Event name. This name will be publicly visible, and will be used by other users accessing meetings in that room. You as a user are responsible for the content you enter into a Workspace or Event name, and the content has to be compliant with our guidelines for Prohibited Content in Terms of Services.
The information above may be used for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. This is required to deliver the Service to you as user, by taking steps, at your request, to enter into such a contract (Terms of Service) cf. GDPR art. 6 (1) b.
- Transaction information. Customers that choose to purchase a paid version of the Services provide Remo (and our payment processors) with billing details such as credit card information, billing email, banking information, location at the time of transaction and/or a billing address.
The transaction data mentioned above may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. This data may be used for the purpose of delivering the Services to you. Collecting this information is required for performing the contract we entered into with you, at your request (our Terms of Service) cf. GDPR art. 6 (1) b.Additionally, this information needs to be retained in order to comply with accounting and tax regulation cf. GDPR art. 6 (1) c.
- Usage information. When you as a user interact with the Services, we collect metadata to provide additional context about the way the Service is being used. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our server software and our analytics tracking system.
- Product Analytics data. Remo logs clicks when you as a user interact with our websites or apps, when you visit a page, room or have a conversation. We will never collect or record the content in conversations.
- Technical log data. Like most digital services, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited within the Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
- Device information. Remo may collect information about devices used to access the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this information depends on the type of device used and its settings.
- Location information. We receive information from you and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Remo may also collect location information from devices in accordance with the consent process provided by your device.
- Customer Support Information. We may process information that you send to us, should you choose to submit a ticket to our support email. If you contact us, we may use your Account, Workspace, Event, Transaction or Usage Information to respond.
Collecting this information it is required for performing the contract we entered into with you, at your request (our Terms of Service), as well as our legitimate interest of handling your requests cf. GDPR art. 6 (1) f.
- Product & Marketing communication. We may process information that you provide to us for the purpose of subscribing to our email newsletters. You can opt in to emails such as digests, newsletters, and activity notifications through your account.
The notification data may be processed for the purposes of sending you relevant product information or newsletters. The legal basis for this processing is your consent cf. GDPR art. 6 (1) a.
- Service and transactional notifications. Sometimes we’ll send you emails about your account, service changes or new policies. You can’t opt out of this type of “service or transactional” emails (unless you delete your account).
The legal grounds for collecting this information is that it is required for performing our commitment about communicating changes in plans and pricing to you in the contract we entered into with you, at your request (our Terms of Service) cf. GDPR art. 6 (1) b, and our legitimate interest of communicating important information about your account to you, cf. GDPR art. 6 (1) f.
- Correspondence information. We may process information that you choose to share with us if you participate in a focus group, contest, activity or event, apply for a job, interact with our social media accounts or otherwise communicate with Remo
The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests cf. GDPR art. 6 (1) f, namely the proper administration of our website and business and communications with users.
How we process media (audio/video)
We will never store any media sent between participants in a Workspace or Event without your consent. Customers who have access to the “Recording” feature will be able to record meetings, and they are then responsible for collecting consents from all participants in the meeting prior to starting the recording. They are also responsible for storing and processing the recording in compliance with regulations after downloading it from Remo.
Video and audio security
In the TRIAL and paid version of the Service, we will use a dedicated server infrastructure to allow more people in conversation, and better stability. Your stream will be sent through video router servers which transmit it to the other participants in the call, and also transmits their streams to you. Streams will always be encrypted (AES-128 or AES-256 algorithm) in transit, but will be decrypted and re-encrypted when passing through the video routers. We operate an infrastructure of video routers distributed across the world, and you will be automatically routed to the closest one. The video router servers and all of our infrastructure adhere to strict security measures, preventing any eavesdropping or interruption of the video/audio streams.
Protecting your meeting
In the TRIAL and paid version of the Service, Remo has the ability to make your event PRIVATE by selecting the option in the event settings followed by entering a list of individuals, with their email address, that will be placed in a whitelist of individuals. The event landing page will be visible to all users, but only users on the whitelist will be allowed to access the event. Remo also has the ability to allow the owner of the event to expel and ban users from the event.
Providing your personal data to others
We may share information about with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (4) to protect the vital interest of others, when we have reason to believe that doing so will prevent harm to someone or illegal activities.
Our categories of service providers and partners are:
- Hosting/infrastructure/storage providers
- Payment processors
- Analysis tools providers
- Customer Support tools providers
- Marketing and email providers
- Recruiting tools providers
- Internal communication tools providers
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
International transfers of your personal data
In some circumstances your personal data may be transferred to countries outside the United States of America. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
We and our other group companies have offices and facilities in Hong Kong and the United States. The hosting facilities for Account information stored by Remo are situated in the United States. The hosting facilities for Usage information are situated in the United States.
Retaining and deleting personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
- Transaction information will be retained for a minimum period of 5 years following the date of the transaction, and for a maximum period of 10 years following the date of the transaction.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
- Account information, Workspace information will be retained until you decide to delete your account or delete a Workspace in Remo
- Information about you used for Product & Marketing communication will be retained as long as you have given us consent to use this information
- The period of retention of usage information will be determined based on the need for historical data to determine statistical validity and relevance for product decisions and technical monitoring.
Regardless of the provisions above, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Changes to this policy
We can change these Terms at any time. We keep a historical record of all changes to our Terms. If a change is material, we’ll let you know before it takes effect. By using Remo on or after that effective date, you agree to the new Terms. If you don’t agree to them, you should delete your account before they take effect, otherwise your use of the Service and Content will be subject to the new Terms.
Managing and deleting your personal information
If you have a Remo account, you can access, modify or export your personal information, or delete your account. If you delete your account, your information and content will be unrecoverable after that time. You may instruct us at any time not to process your personal information for marketing purposes. We may withhold personal information that you request to the extent permitted by law.
As an individual you are granted rights according to the applicable data protection law:
- The right to access to your personal data
- The right to rectification of your personal data
- The right to object to and restriction of our processing of your personal data
- The also right to be forgotten; erasure of your data.
- The right to data portability.