Effective date: November 5th, 2020
The following additional terms are incorporated into this Notice as if fully set forth herein:
- Cookie Notice
- User Terms of Service
- Customer Terms of Service
Capitalized terms not otherwise defined herein have the meaning given to them in the Terms of Service.
Who we are
We are Remo USA, Inc. (“Remo”). We can be reached at email@example.com or
Remo USA, Inc.
2093 Philadelphia Pike #8552
Claymont, DE 19703
We provide an online video office and conference space on the Websites. Our business model is to provide paid Service to users who need additional features on top of the free trial version of the Service . References to “we”, “us”, and “our” mean Remo. References to “third-party” mean someone who is not you or us. When we market the Service and analyze information about how Users and Customers interact with the Service, we are a Controller. We are a Processor of the personal information you provide to us to use the Service.
Who you are
In the Notice, “you” means you as a:
- User of Remo — a user of the free trial version of the Service
- Customer of Remo — a user of the paid version of the Service
You, either as a User or a Customer of the Service, are a Controller of the personal information you provide to us to use the Service.
What legal basis do we have for processing your personal information?
We process your personal information based on:
- Taking action on your requests, such as providing live, virtual conference space for events and networking and providing live, virtual in-office space for interaction and collaboration.
- Our legitimate interest in marketing the Service and receiving usage information about how Users and Customers interact with the Service (e.g. when you interact with the Websites or applications, when you visit a page, when you visit a room or when you have a conversation, when you access or use the Service, what devices are used to access the Service, and receiving location information to know where the Service is used)
- Consent you provide when you submit a ticket to our support email when you opt-in to emails through your account (e.g. digests, newsletters, and activity notifications), when you communicate with us by participating in a focus group, contest, activity of event, apply for a job, and interact with our social media and where we do not rely on another legal basis. You have the right to withdraw your consent at any time.
What information do we collect?
We collect the following personal information from Users and Customers:
- Account and Workspace or Event Information – If you choose to register in Remo, you have to provide a valid email address or use Google Authentication, and you can choose to enter a display name and/or add a profile picture that will be used to represent you in conversations. To create a Workspace or Event in Remo, you have to select a Workspace or Event name which will be publicly visible and will be used by Users accessing meetings in that room.
- Usage Information – When you interact with the Service, metadata to provide additional context about the way the Service is being used are collected and may include 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 use of the Service.
- Correspondence Information – We collect the information 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 us.
- Product and Marketing Communications – We collect information that you provide to us for the purpose of subscribing to our email newsletters by opting-in through your account to emails such as digests, newsletters, and activity notifications.
- Customer Support Information – We may collect information that you send to us at firstname.lastname@example.org, and we may use your Account, Workspace, Event, Transaction, and Usage Information to respond.
Where do we collect information from?
The types of information about you we collect depend on the relationship we have with you. We may collect:
- Account and Workspace and Event Information from you when you register in Remo and create a Workspace or Event in Remo.
- Usage Information from our server software and our analytics tracking system, including:
- Product analytics data from clicks Remo logs when you interact with the Websites, or when you visit a page, when you visit a room or when you have a conversation.
- Technical log data, which may include the Internet Protocol (IP) address, the address of the web page visited within the Service, browser type and settings, the date and time the Service was used, information about browser configuration and plugins, language preferences, and cookie data, are automatically collected by our servers when you access or use the Websites or the Service.
- Device information, which may include the type of device, what operating system is used, device settings, application IDs, unique device identifiers, and crash data, depending on the type of device used and its settings.
- Location information, which may include a business address provided by your employer or an IP address received from your browser or device to determine approximate location, from your devices in accordance with the consent process provided by your device and from third-parties that help us approximate your location.
- Correspondence Information from you when you communicate with Remo (e.g. by participating in a focus group, contest, activity, or event, apply for a job, interact with our social media accounts)
- Product and Marketing Communications from you through your account for the purpose of subscribing to our emails (e.g. digests, newsletters, and activity notifications).
- Customer Support Information that you send us when you submit a ticket to our support email.
How do we use personal information?
We use the information we collect from you as Users and Customers to provide live, virtual conference space for events and networking and to provide live, virtual in-office space for interaction and collaboration. Specifically:
- Account and Workspace or Event Information is used to deliver and secure delivery of the Services to you, to operate and secure the Websites, to maintain backups of our databases, and to communicate with you.
- Usage Information is used to properly administer the Websites and our business, analyze the use of the Websites and the Service, monitor and improve the Websites and the Service, improve the User and Customer experience, prevent abuse and assist Users and Customers with support inquiries.
- Correspondence Information is used for the purpose of communicating with you and recordkeeping.
- Product and Marketing Communications are used to send you relevant product information or newsletters.
- Customer Support Information is used to handle your requests.
When do we share personal data?
We may share information about you with third-parties in some circumstances, including:
- Service providers or partners who meet our data protection standards
- Hosting/infrastructure/storage providers that host our servers
- A third-party service that uses your IP address to help us approximate your location
- Payment processors that help us with billing
- Analysis tools providers that help us analyze our data
- Customer Support tools providers that help resolve customer issues and help manage support tickets
- Marketing and email providers that help with customer relationship management and email communications
- Recruiting tool providers that helps recruit and onboard top talent
- Internal communication tool providers to provide employee communications
- When we have a good faith belief it is required by law (e.g. pursuant to subpoenas or other legal processes)
- To protect the vital interest of others, when we have reason to believe that doing so will prevent harm to someone or illegal activities
- To any member of our group of companies (i.e. our subsidiaries, our ultimate holding company, and all of its subsidiaries) insofar as reasonably necessary for the purposes and on the legal bases set out in the Policy
- When we are involved in a merger, acquisition, bankruptcy, reorganization, or sale of assets (if your information would be transferred or become subject to a different policy, we will notify you)
Where do we store and process personal data?
We store the information we collect from you on servers in the United States. For development and testing purposes, the information we collect from you may also be stored on desktop and laptop computers used by Remo employees in the U.S. and other countries. The information we collect from you in the European Union may be transferred from and kept outside the EU because our operations are located in the U.S. We rely on the Standard Contractual Clauses in order to transfer personal information outside the EU.
How long do we keep your information?
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Specifically, we retain:
- Account and Workspace or Event Information until you decide to delete your account or delete a Workspace in Remo
- Usage Information based on the need for historical data to determine statistical validity and relevance for product decisions and technical monitoring
- Correspondence Information until you decide to delete your account
- Product and Marketing Communication for as long as you have given us consent to use this information
- Customer Support Information for as long as it is necessary to resolve the issue
Regardless of the provisions above, we may retain your personal information 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 individual.
How do we protect your information?
We 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 transmit 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 on 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 eavesdropping or interruption of the video/audio streams.
We will never store any audio or video media sent between participants in a Workspace or Event without your consent. We will never collect or record the content in conversations. Customers who have access to the “Recording” feature will be able to record meetings, and if a Customer records a meeting, then the Customer is responsible for collecting consents from all participants in the meeting prior to starting the recording. After downloading the recording from Remo, the Customer also is responsible for storing and processing the recording in compliance with all laws and regulations.
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 addresses, that will be placed in a guest list of individuals. The Event landing page will be visible to all Users and Customers, but only Users and Customers on the guest list 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.
You as a User or a Customer are responsible for the content you enter into a Workspace or Event name, and the Content has to be compliant with the Prohibited User Content provisions of Remo’s User Terms of Service.
What are your rights?
You have the right:
- To know if we are collecting, using, or sharing your information and to request access to this information.
- To request that we correct your information if it is inaccurate or incomplete.
- To ask us to erase your information if
- Your information is no longer necessary for the purposes for which it was collected, used, or shared.
- You withdraw the consent on which the collection, use, or sharing is based.
- You object to the collection, use, or sharing and there is no overriding legitimate interest for continuing the collection, use or sharing.
- You object to the collection, use, or sharing of your information for direct marketing purposes.
- Your information was unlawfully collected, used, or shared.
- Your information has to be erased in order to comply with a legal obligation.
- Your information was collected in order to offer online services to children.
- To obtain from us a restriction on the collection, use or sharing of your information if
- You contest the accuracy of your information.
- You have objected to the collection, use, or sharing based on legitimate interest and we are considering whether our or a third party’s legitimate interest ground overrides your interest.
- The collection, use, or sharing is unlawful, and you oppose erasure and request the use be restricted instead.
- We no longer need your information, but you require your information to establish, exercise, or defend a legal claim.
- To be able to take with you the information you provided to us and to transmit that information to another organization where our collection, use, or sharing of that information is carried out by automated means and is based on your consent or the performance of a contract.
- To object to collection, use or sharing based on the purposes of legitimate interest or performance of a legal task, direct marketing, and scientific/historical research and statistics.
- Not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you.
- To lodge a complaint with a supervisory authority.
How do you exercise your rights?
If you have a Remo account, you can access, modify, correct, or export your personal information or delete your account. If you delete your account, your information and content will be unrecoverable after that time. Please note that in some cases we may retain certain information about you as required by law or for legitimate business purposes to the extent permitted by law.
You can instruct us at any time not to process your personal information for marketing purposes. You can opt-out of our marketing communications at any time, and you have the right to be removed from our email list at any time, using the opt-out link provided in our mailings. If you opt-out, we may still send you non-promotional communications, such as those about your account or about our ongoing business relations. We may withhold personal information that you request to the extent permitted by law.
Do we change this Policy?
We can change this Policy at any time. We keep a historical record of all changes to this Policy. Remo will inform you when changes take effect. By using Remo on or after that effective date, you agree to the new Policy. If you don’t agree with the changes, then you should delete your account before the changes take effect, otherwise your use of the Service and Websites will be subject to the new Policy.