THIS POLICY APPLIES TO OUR SERVICES AND ONLINE TOOLS, INCLUDING THE WEBSITE AND MOBILE APPLICATIONS, AND OTHER (COLLECTIVELY “THE WEBSITES”), AS WELL AS OTHER INTERACTION (E.G. CUSTOMER SUPPORT CONVERSATIONS, USER SURVEYS AND INTERVIEWS ETC.) YOU MAY HAVE WITH US.
For the purpose of the processing personal data, we may engage data processors and/or, at its sole discretion, hire other persons to perform certain functions on behalf of Remotehour. In such cases, we shall take necessary measures to ensure that such data is processed by the personal data processors in accordance with instructions of and applicable European Union legislation. Shall also require the personal data processors to implement appropriate measures for the security of personal data. In such cases, we shall ensure that such persons will be subject to the non-disclosure obligation and will no video calling and messaging t be able to use this information for any other purpose, except to the extent necessary to perform the functions assigned to them.
- 1) Introduction
- 2) Acceptance and Use
- 3) Data Protection Principles
- 4) Personal Information We Collect About You (PIPEDA)
- 5) Types of Data We Collect From You
- 6) Non-Personal Information
- 7) Information Collected Through Technology
- 8) Information We Collect From You Automatically
- 9) Meeting Rooms, User Content
- 10) How We Use Your Data
- 11) Your Media (Audio/Video) Contents
- 12) Remarketing On the App and website
- 13) Google Adwords
- 14) With Whom We Share Your Data
- 15) Do Not Track
- 16) Interest-Based Advertising Technologies
- 17) Data Retention
- 18) EEA Data Subjects
- 19) Your Privacy Choices
- 20) Our COPPA Policy towards Children
- 21) Chat History
- 22) Cross Border Transfers
- 23) Data Transferred Out Of the EU
- 24) Privacy Shield
- 25) Legal Bases for Processing (For EEA Users):
- 26) Security Measures for Safeguarding Your Information
- 27) Third-Party Site and Links
- 28) California / Delaware Do Not Track Disclosures
- 29) Emails Communications
- 30) Data Security
- 31) GDPR Statement for (EEA Users)
- 32) Your Right To Withdraw Consent
- 33) Opting Out Of Messages from Us
- 34) Opting Out Of Sharing With Third Parties for Marketing
- 35) Opting Out Of Interest Based Advertising
- 36) Security of Personal Information
- 38) Terms and Conditions
- 39) Jurisdiction
- 40) Contact Us
2. Acceptance and Use
3. Data Protection Principles
“Personal data” means any information that enables us to identify you or the beneficiary of your transaction with us, directly or indirectly, such as name, email, address, telephone number, any form of identification number or one or more factors specific to your or your beneficiary’s identity.
We are committed to complying with applicable data protection laws and will ensure that personal data is:
- * Used lawfully, fairly and in a transparent way;
- * Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- * Relevant to the purposes we have told you about and limited only to those purposes;
- * Accurate and kept up to date;
- * Kept only as long as necessary for the purposes we have told you about;
- * Kept securely.
4. Personal Information We Collect About You (PIPEDA)
According to the personal information protection and electronic documents act, 2000 (PIPEDA), “personal information” means information about an identifiable individual. The information you provide to Remotehour is considered personal information it is possible to relate it back to you through your name, address, e-mail address, telephone number and any other information that can identify you. If information cannot be related to an identifiable individual it is considered anonymous information (such as laboratory results identified by alpha-numeric identifier instead of individual’s name). Whenever possible, Remotehour works with anonymous information. This privacy statement does not apply to anonymous information.
5. Types of Data We Collect From You
Remotehour may collect two (2) types of information about you: personal data and non-personal data.
Personal Data The following are personal data we collect, process or store, with the purpose and that we have the legal ground to do so in accordance with the GDPR:
Room information. As a user in Remotehour platform you will have to choose a room name. This name will be visible publicly, and will be accessed by other users meeting in that room. You are responsible for the content you post into a room including the room name, and you agree that your contents will be compliant with our community guidelines and Terms of Services. This is required to deliver the Service to you as user, by taking steps, at your request, to enter into and to fulfilling such a contract (Terms of Service) cf. GDPR art. 6 (1) item b.
Payment information. Users that choose to purchase a Service on the website will be ask to provide a billing details such as credit card information, billing email, banking information, location at the time of transaction and/or a billing address. This data may be used for the purpose of delivering the Services to you. Processing this information is required for fulfilling the contract we entered into with you, at your request (our Terms of Service) cf. GDPR art. 6 (1) item b. additionally, this information needs to be retained in order to comply with accounting and tax regulation cf. GDPR art. 6 (1)
Your Geo Location. We collect information about your location when you use our services, which helps us offer interesting features depending on your location. Your location will be determined with varying degrees of accuracy such as: GPS, IP Address, sensor data, Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices
Correspondence: Survey responses, information provided to our support team or user research team. Customer Support Information. We may process information you send to us, should you choose to submit a ticket to our support channel. If you contact us, we may use your Account, Room, Transaction or Usage Information to respond.
Anonymous Data. Some of the non-personal Data that we are data that cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.
6. Non-Personal Information
Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or web site visitations). Remotehour may collect non-personal information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.
7. Information Collected Through Technology
While you are able to visit the Remotehour site and remain anonymous, Remotehour or its third party service providers may still collect non-personal information about your use of the Remotehour materials (e.g. Your internet browser, operating system, ip address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:
- (a)Cookies. Cookies, including local shared objects, are small pieces of information that are stored by your browser on your device’s hard drive which work by assigning to your computer a unique number that has no meaning outside of the Remotehour site. Cookies do not generally contain any personal information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the Remotehour materials unavailable to you.
- (b)IP address. You may visit many areas of the Remotehour site anonymously without the need to become a registered user. Even in such cases, Remotehour may collect ip addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an internet services provider. Each time you access the Remotehour site and each time you request one of Remotehour’ pages, the server logs your ip address.
- (c)Beacons. Beacons are small pieces of data that are embedded in web pages and e-mails. Remotehour may use these technical methods in html e-mails that Remotehour sends to users to determine whether they have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that constitutes personal information.
- (d)Tracking content usage. If you use the Remotehour services and you post audio visual materials including, without limitation, text, videos, pictures, ideas, sound and other related intellectual property contained in such materials (collectively, “content”) to your app site or to a third party app site, Remotehour tracks and captures non-personal information associated with user accounts and the use of content.
- Your Activity. We collect information about your activity when using our services. Activities such as Voice and audio information when you use the video features, People with whom you communicate or share content etc.
8. Information We Collect From You Automatically
We receive and store certain types of information automatically, such as whenever you interact with or use Remotehour Application and website. This information helps us address customer support issues, improve the performance of Remotehour Application and website, providing you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
- * Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
- * Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.
For example, we may automatically receive and record the following information on our server logs:
- * How you came to and use Remotehour Application and website;
- * Device type and unique device identification numbers;
- * Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
- * How your device interacts with Remotehour Application and website and Services, including pages accessed and links clicked;
- * Broad geographic location (e.g. country or city-level location); and
- * Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.
We may also use identifiers to recognize you when you access our service and or App via an external link, such as a link appearing on a third party site
9. Meeting Rooms, User Content
10. How We Use Your Provided Data
- * Identification and authentication: we use your data to verify you when you access your account.
- * Communicating with you: we use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).
- * Improving our services: we use your data to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).
- * Customizing your experience: we use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying app that you might enjoy, based upon your viewing choices.
- * To ensure network and data security: We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of Remotehour Services.
- * Marketing and advertising: we use your data to display ads and send you offers. We may also use your data in delivering third-party advertisements to you. This may include "targeted ads" based upon your activities.
- * Exercising our rights: where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our terms of service.
- * Legal compliance: we use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.
- * Protecting your information: where appropriate, we may anonymize, backup, and delete certain data.
- * For research and development: We process your personal information to better understand the way you use and interact with Remotehour's Services. In addition, we use such information to customize, measure, and improve Remotehour features and the content and layout of our App and applications, and to develop new services.
We may use algorithms and other automated means to implement any of the above.
11. Your Media (Audio/Video) Contents
Part of the features to use our services is to create audio, or video contents in rooms among users. If you do this, please note that Remotehour will never store any media sent between users in a created room on the Remotehour platform. Video and audio contents transmitted in the Service is sent directly between the users in a room (meeting) and is encrypted (DTLS-SRTP) with client-generated encryption key. Users who have access to these feature will be able to record room meetings, after collecting consents from all users in the meeting room before recording the meeting room. The users are also responsible for storing and processing the recorded data in compliance with required regulations before downloading the material.
12. Remarketing On the App and website
13. Google Adwords
14. With Whom We Share Your Data
We share data with third parties as follows:
- * With your consent: we may share your data with third parties where we have obtained your express consent to do so. You may revoke these consents.
- * Authorized vendors: we may share your data with third-party vendors that help us operate our services, process payments, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (cdns), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (crm) vendors
- * Advertising: we may share your data with advertising companies to display relevant ads to you. Unless you expressly agree, we will not share or sell your name, email address, or physical address with such persons.
- * Analytics: we may share your data with persons who provide analytics showing how customers are using our services.
- * Affiliates and advisors: we may share your data with our affiliates company, and our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. Unless you expressly agree, we will not share your data with our parent or any affiliate for other purposes, such as direct marketing.
- * Certain legal situations: we may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction.
- * Aggregated or anonymized information: we may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users.
15. Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and devices. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
16. Interest-Based Advertising Technologies
As noted above, you may limit advertising tracking using advertising identifiers through your mobile device’s privacy settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, atttp://www.networkadvertising.org/managing/opt_out.asp, orhttp://www.youronlinechoices.eu/andhttp://www.aboutads.info/choices/.
17. Data Retention
We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may retain logs of automatically collected information (for internal analytics); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.
If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.
18. EEA Data Subjects
Legal Bases for Processing your Information:
For individuals who are located in the European Economic Area, United Kingdom or Switzerland (collectively “EEA Residents”) at the time their personal data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation (“GDPR”). We generally only process your data where we are legally required to, where the processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business or to protect Remotehour application and website or your, property, rights, or safety, or where we have obtained your consent to do so. Below is a list of the purposes described in our policy with the corresponding legal bases for processing.
19. Your Privacy Choices
We enable you to make numerous choices about your data:
- * You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.
- * You may change your account and privacy settings. You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.
- * You may opt out of receiving commercial emails from us.
- * You may close your account
- * Users from certain countries may have additional rights.
20. Our COPPA Policy towards Children
Remotehour complies with both the Children’s Online Privacy Protection Act of 1998 (COPPA) and, with regard to EU data subjects, with GDPR. We do not knowingly request to collect personal information required for Remotehour Premium Membership from any person under the age of 13. If a user submitting personal information is suspected of being younger than 13 years of age, Remotehour will prevent user from registering for Premium Plan or Package, cancel his/her membership without being liable to refund any paid subscription fees, also Remotehour retains the right to close such account and or not allow such users to continue using Remotehour Service. We will also take steps to delete the information as soon as possible.
Please notify us if you know of any individuals under the age of 13 using our Premium Services so we can take action to prevent access to our Services.
21. Chat History
What is it?
- * We will collect, save and store all information contained in your Remotehour chat history for up to 90 days, including your photos, voice messages, videos, and sticker. If you are a premium user, you can elect to save this information on our servers for a longer period of time. You can permanently delete your Remotehour chat history at any time.
How do we use it?
- * To allow you to access your chat history, photos, and videos for your own purposes.
- * To collect aggregated data from your chat history. We use the data to build language models which help us improve the Service. We will only collect this data on an aggregated basis, and in a manner which does not reveal any personally identifiable information about any individual user. We will use this data to help us understand our users’ interests, analyze trends, and customize the user experience.
22. Cross Border Transfers
To facilitate our global operations, Remotehour may transfer, store, and process your information within our family of companies, partners, and service providers based throughout the world.
We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with Remotehour, you acknowledge and agree to your personal information being processed in this way.
If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please submit your request via any of Remotehour provided CONTACT US mediums.
23. Data Transferred Out Of the EU
Our Estonian based company, Remotehour, is the publisher of Remotehour Mobile App and website, confirms its compliance with the EU-US Privacy Shield Framework. We are committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov.
Remotehour does its best to process personal information it receives under the standards of Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Before we share your information with any third party that is not also certified under the EU-US Privacy Shield Framework, Remotehour will enter into a written agreement that the third party provides at least the same level of privacy safeguard as required under those Frameworks, and assures the same level of protection for the personal information as required under applicable data protection laws.
Worldwide data subjects with inquiries or complaints relating to Remotehour Privacy Shield internal policy should first contact Remotehour by filling the CONTACT US form provided in www.Remotehour.com. If we are unable to resolve your complaint or dispute, you may refer your complaint to our designated independent dispute resolution mechanism, i.e. the International Centre for Dispute Resolution ("ICDR").
24. Privacy Shield
25. Legal Bases for Processing (For EEA Users):
If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
- * We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services;
- * It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
- * You give us consent to do so for a specific purpose; or
- * We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services
26. Security Measures for Safeguarding Your Information
Remotehour takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. These include, but are not limited to, internal reviews of: (a) Remotehour’s data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Remotehour stores personal information. All Remotehour employees, contractors and agents who access personal information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of personal information.
27. Third-Party Site and Links
The Remotehour contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, Remotehour may use third parties to provide components of the Remotehour contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of Remotehour. Remotehour: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such App; and (c) does not make any warranties or representations about the contents, products or services offered on such App or the security of any information you provide to them
28. California / Delaware Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, Remotehour do not monitor or take any action with respect to these signals or other mechanisms.
29. Emails Communications
By creating an account, you consent to receive commercial emails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt out or opt in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).
30. Data Security
We are committed to maintaining the security of your personal data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorized individuals, and we regularly upgrade our security as better methods become available.
Our data centers and those of our partners utilize modern physical security measures to prevent unauthorized access to the facility. In addition, all personal data is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.
All our employees who have access to, or are associated with, the processing of personal data are contractually obligated to respect the confidentiality of your data and abide by the privacy standards we have established. Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.
The App may offer chat rooms, Chatbots, forums, message boards, or news groups to users. It is important to remember that any information disclosed in these areas becomes public information. Accordingly, as with any public forum, you should exercise extreme caution when deciding whether to disclose your personal information.
31. GDPR Statement for (EEA Users)
This applies only to natural persons residing in the European economic area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Remotehour's policy to comply with the EU'S general data protection regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the United States (or other countries) based upon the following legal frameworks:
- * Legitimate business interests: we could not provide our services or comply with our obligations to you without transferring your personal information to the United States
- * Consent: we may transfer your personal information when we receive your express, revocable consent. Our use of standard contractual clauses (also known as "model clauses") where appropriate.
We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.
If you have a request, complaint or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.
32. Your Right To Withdraw Consent
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us [email protected] You can also change your marketing preferences. You can also exercise the rights listed above at any time by contacting us at [email protected] If your request or concern is not satisfactorily resolved by us, you may contact our data protection officer, his email is [email protected]
He can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
33. Opting Out Of Messages from Us
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at [email protected] We will process your request within a reasonable time after receipt.
34. Opting Out Of Sharing With Third Parties for Marketing
If you do not want your Personal Information or Personal Data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to [email protected] Please note that if you opt out in this manner, certain aspects of the App and platform may no longer be available to you. We will process your request within a reasonable time after receipt.
35. Opting Out Of Interest Based Advertising
36. Security of Personal Information
The Site uses its best endeavors to store all Personal Information on servers with restricted access, and all electronic storage and transmission of Personal Information are secured with appropriate security technologies. 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. Not to withstand the foregoing, the platform cannot guarantee that such precautions would render the Site and its servers immune to security breaches.
38. Terms and Conditions
To learn more about our terms and conditions, please visit our Terms and Conditions page establishing the use, disclaimers, and limitations of liability governing the use of our website
40. Contact us