Privacy Policy

OBMeet Inc. ("us", "we", or "our") operates the https://obmeet.com and https://chat.obmeet.com website, the https://obmeet.org community server, the Marketplace, incl. associated OBMeet Apps, OBMeet Chatbot, OBMeet´s Cloud Offering and the OBMeet mobile applications (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Services and the choices you have associated with that data.

We use your data to provide and improve our Services. By using our Services, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Policy have the same meanings as in our Terms and Conditions.

Summary

Administrators are responsible for user privacy

• There are basically two ways of using OBMeet: self-managed (also known as on-premises deployment) on your own or someone else´s infrastructure OR via our hosted offering. In both cases, the administrator in that instance - or the organization behind the administrator - is the person responsible to ensure privacy of OBMeet users. We aim at helping to provide features in our products and services to make your job easier. We also provide this policy to explain what we do as a "helping hand"/data processor for administrators in case we process personal data of users.

You remain in control of your personal data

• We cannot access your personal data in a self-managed instance of OBMeet. Our code is open source; there are no back doors whatsoever. You are however free to connect a self-managed instance to other services, e.g. our marketplace or push notification gateway, where this privacy policy applies. When you do not register your instance, these settings are turned off by default. You can also connect it to third party services, such as external authentication services, in which case their privacy policy applies. It is your choice and you are not forced to do so. In our hosted offering, we only process your data for the purposes of providing you the service in the name of the administrator. Administrators are still in full control over the configuration of their instance.

We don´t sell your data

• We do not sell your personal data. Our business model is to provide you with a free edition and we charge you for extra services or features according to the plan you choose. What you process within OBMeet is yours and remains yours.

Our community server is for testing and development purposes

• Our community server https://obmeet.org is a testing and development ground for our users to test and analyze new features. We track user activities therein with the trackers described below - including google analytics - to learn how our service is used and to improve our product.

Definitions

Service

• Service means the https://obmeet.com website, the https://obmeet.org community server, the OBMeet Marketplace, incl. associated OBMeet Apps, OBMeet Chatbot the https://chat.obmeet.com service offering, push notification gateways and the OBMeet mobile applications operated by OBMeet Inc.

Personal Data

• Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

• Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

• Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

• Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

Data Processors (or Service Providers)

• Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
  
  We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

• Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, if you have provided consent to this processing or if we can base this processing on a legitimate interest that is not overridden by your fundamental rights. You may in the future withdraw that consent or object to receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Account Data

Some Services may allow or require that you register for a personalized account. Account data may include in addition to your account name, authentication information, registration date, contact information, payment information and any other information associated with your account.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service, incl. by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, the IP address of your mobile device, your mobile operating system, the app version, and the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

As a by product of the usage data within the OBMeet instance, Administrators may choose to share aggregated and therefore anonymous, non-personal data with us to help us learn more about how our product is being used. This setting is described here. The information shared is the same information as is shown on the "info"-page of the administration panel of an instance. E.g. this statistics sharing would transmit the total # of channels, but it would not transmit the actual channel names, and so on, preserving privacy of your workspace. This is completely optional to use and can be activated and deactivated any time.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service (only to allow you to share your location to another user via OBMeet, if it was enabled by the administrator).

You can enable or disable location services when you use our Services at any time, through your device settings.

App Data

When you use the Marketplace, you may choose to install Apps provided by OBMeet. These Apps process data from your instance of OBMeet and therefore non personal data, such as software version, amount of users, and similar. Depending on the purpose and your actual usage of the App (e.g. enabling certain features), Personal Data may however be processed. E.g. you enable an integration, which processes your users´ information. The description of the App will make the types of personal data sufficiently clear as well as any potential deviations from this policy.

For Third Party Apps on the Marketplace, the Vendor will provide you with a specific privacy policy that governs his Third Party App.

Content you provide

When you use our Services you may provide content into that service (e.g. upload file, send a message).

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Services and hold certain information. We DO NOT track activity in your self-managed instances. We regularly do monitor aggregated activity data on our infrastructure, but it is not tracking of individual users in the sense of this paragraph, which only occurs when we have a legitimate interest to do so (e.g. for security and compliance purposes). We do perform regular tracking on our community server.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Services.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Distinction of data collection between Self Managed Workspaces and Hosted Workspaces

The following paragraph applies to data processing in OBMeet workspaces and is for clarification purposes only. Self Managed workspaces and workspaces hosted by OBMeet differ in the kind of data we are processing from you, because in case of our hosted offering, all data put into the workspaces is technically processed on our infrastructure.

There is also a difference between registered, self managed workspaces (which consume services from us) and unregistered, self managed workspaces.

See the following table for a general distinction between the data that is processed in each case. Keep in mind that this can differ in individual circumstances, such as cases where apps are installed on unregistered workspaces via workarounds.

Data type	Self Managed (not registered)	Self Managed (registered)	Hosted
Account Data	no	yes - to register your workspace via an account (optional)	yes - to register your      workspace via an account
Usage Data	no	yes - as per the service you are consuming via your registration, e.g. push notifications via our gateway	yes - as part of using the hosted workspace on our infrastructure
App Data	no	yes - if you install apps from the marketplace and based on the use case of the app. Third party apps have their own privacy policy.	yes - if you install apps from the marketplace and based on the use case of the app. Third party apps have their own privacy policy.
User content	no	no - content is not processed, unless it falls under the aforementioned (e.g. the content of a push notification sent via our gateway)	yes - as part of using the hosted workspace on our infrastructure. End-to-end encrypted content is only stored in encrypted form.
Tracking and Cookies	no	yes - tracking occurs on our end to monitor the consumption of the services you use (Usage Data). We do not track inside the workspace.	yes - tracking occurs to monitor the consumption of the services used.

Use of Personal Data

OBMeet Inc. uses the collected data for various purposes:

• To provide and maintain our Services
• To notify you about changes to our Services
• To allow you to participate in interactive features of our Services when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Services
• To monitor the usage of our Services
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about if you have provided consent to receive this information or the processing is in our legitimate interests and it's not overridden by your rights.

We do not process content data beyond the purpose of providing you the service.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), OBMeet Inc. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

OBMeet Inc. may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it's not overridden by your rights
• For payment processing purposes or
• To comply with the law

Retention of Data

OBMeet Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

OBMeet Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Europe (EU Countries) and choose to provide information to us, please note that we transfer the data, including Personal Data, to Europe or other jurisdictions deemed not to have an adequate level of data protection relevant to the competent authorities of your residence. OBMeet Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Transfer due to Business Transaction

Where OBMeet Inc. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, OBMeet Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

OBMeet Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of OBMeet Inc.
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

The security of your data is important to us. Note however that there is no method of transmission over the Internet, or method of electronic storage that is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. OBMeet Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where OBMeet Inc. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers and Subprocessors

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Subprocessors

We employ the subprocessors to process personal data. The current list of subprocessors can be found here.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Services.

Google Analytics

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Firebase

Firebase is analytics service provided by Google Inc.

• You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
  
  We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please visit please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site.

We strongly advise you to review the Privacy Policy of that third party site you wish to visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Specific Provisions to our Cloud Offerings

For our Cloud Offerings, we act as a Data Processor for our Customers, who are the Data Controllers of the instances they have licensed and administer. As a user generally, you will be bound by the Data Controller´s policies. For these instances, please direct your data privacy questions to the Data Controller.

With regards to some of our Cloud Products, Customers have certain options to select the processing location of data and to configure the privacy-relevant settings of the instance. If you are the customer of one of these instances, you can contact us and get more information on where your instance is running.

We generally offer:

• Hosting in the European Union (EU)

Other regions may be added over time.

Where required, we also offer to sign Standard Contractual Clauses approved by the European Commission to guarantee an adequate level of data protection or other mechanisms relevant for the Customer.

The amount of Personal Data we process with our Cloud Offerings is limited to what the Customer and his users entered into. In the cloud offering, we will not process the personalized cookie or analytics data described above. The purposes of processing the data are strictly limited to providing and improving the Service and in accordance with the Data Controller´s instructions. We never access workspace data (i.e. the actual content the customer is entering in his instance), unless the customer asks us to in form of a support request, we are bound by a valid law enforcement request or to protect our own interests, such as investigating potential abuse of the service.

Once your usage of our cloud offering ceases, we will remove all your data, including backups, after a short grace period - or immediately, if you tell us to.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email if you ask us to do so by providing your email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• OBMeet's Data Protection Officer by email: [email protected]
• By visiting this page on our website: https://global.obmeet.com/company/contact