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Privacy Policy

Last updated: December 13th, 2022

Introduction

At Office AnyWhere Inc. ( “welo.space,” “we,” “our” or “us”), we respect your privacy and are committed to protecting it through our compliance with this Privacy Policy.  This Privacy Policy describes how we  collect, store, use and disclose personal data of individuals when they:

  • Visit or otherwise interact with our website available at welo.space or any other website, webpage, or e-mail under our control (collectively the “Sites”)
  • Use our immersive visual space (the “Space”) by:
    – Accessing our application (the “App”) via: Office AnyWhere’s Zoom App (“Office AnyWhere for Zoom”), web browser URL app.welo.space (“Office AnyWhere for Web”), Office AnyWhere’s Progressive Web Application (“Office AnyWhere PWA”)
    – Via the Sites, integrations, addons, or extensions
  • Engage with us in other ways – including any sales, marketing or similar activities (“Users”, and together with the Sites and Space – the “Service”).

This Privacy Policy also describes the rights and choices available to individuals with respect to their data. Please read this Privacy Policy carefully as it will help you understand the data we collect. If there are any terms in this Privacy Policy you do not agree with, please discontinue use of our Service immediately.

This Privacy Policy pertains to Office AnyWhere’s practices as a “Data Controller,” where we determine the means and purposes for processing personal data. Where we process data on behalf of our business customers (“Customers”), we act as their “Data Processor,” pursuant to our agreements with them. If you are a user of the Service (a “User”) on behalf of any of our Customers, we suggest that you contact your account administrator(s) (“Account Admin”) with any questions or requests that pertain to the personal data processed by us on such Customer’s behalf.

What data do we collect?

In short: We collect technical data, profile data, content, and other data received from you, your organization and other third-party sources.

We collect and control various types of personal data regarding our Users of our Sites and Apps. Such data is collected and generated through your interaction with us or with our Service, through automatic means, or directly from you, from other Users, from our Customers, or from other third parties (including our Service Providers, as defined below). Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “personal data”):

  • Data automatically collected or generated: When you visit, interact with, or use our Service, we collect, record or generate certain technical data about you and your device(s). We do so either independently or with the help of third-party Service Providers, including through the use of “cookies” and other tracking technologies. Information on cookies and tracking technology is provided in this Cookie Notice. Automatically collected or generated data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device and application data (like type, operating system, mobile device or app id, browser version, locale and language settings used), date and time stamps of usage, the relevant cookies and pixels installed on or interacted with via such device, geolocation information, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of visitors and Users in connection with our Service.
  • User Data received from you: When you contact us, sign up to the Service and create your individual profile, or sign up to an event that we host, organize or sponsor, you provide us with personal data. This would typically include your name, workplace and position, contact details (such as e-mail, phone and address), account login details (e-mail address and other authenticators are automatically hashed), as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service. You may also provide us with your profile photo, calendar integration, time-zone, skills, device, general location, and activity logs and data, as well as your preferences, characteristics and objectives for using the Service. You may also send us a “Contact Us” or support requests, initiate a support chat, or provide us with feedback, reviews, or responses to our surveys or promotions, including by submitting an online form on our Service or social media channels, by posting on any of our online public forums or communities, by sending an e-mail to any of our designated addresses, or any other form of communication. Such data may include details on an issue you are experiencing, contact information and any other documentation, screen recording, screenshots or other information.
  • Customer Data: Office AnyWhere’s Customers may provide us with additional data such as their billing details, business needs and preferences. To the extent that such data concerns a non-human entity (e.g., the bank account of a company or business), it will not be regarded as “personal data.”
  • User Data received from our Customers and Users: Customers and Users may provide us with the contact details of Users and potential Users, such as their employees, team members and colleagues, in order for us to contact, invite or subscribe them as Users to our Service (including by using single sign-on tools). Such data typically includes these individuals’ names, phone numbers and work e-mails; however additional data may be provided at the discretion of those providing it. For the purposes of this Privacy Policy, this data is also regarded as personal data.
  • Data received from other third parties: We may receive personal data that relates to you from other sources. For example, if you participate in an event that we sponsor or participate in, we may receive your personal data from its organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our Partners (defined below), from our service providers, and through the use of tools and channels commonly used for connecting between companies and individual professionals in order to explore potential business and employment opportunities, such as LinkedIn.
  • Data obtained through analytics tools: We use analytics tools (e.g., Google Analytics) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and visitors visit or use the Service, which pages they visit and when, which website, ad or e-mail message brought them there, and how they interact with and use our Service and its various features. Google’s ability to use and share information collected by Google Analytics about your visits to the site is restricted by the Google Analytics Terms of Use available at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy available at http://www.google.com/policies/privacy/. You can prevent Google Analytics from recognizing you on return visits to the site by disabling cookies in your browser. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.
  • Audio, video, chats and messages: our Service does not store or view user audio or video, which are encrypted in transit. Chats (within the rooms in the space and individual messaging) and messages broadcast to rooms or the Space are transient for the duration of the session and are neither persisted nor stored. For information about customer support chats, please see section “User Data received from you”.
  • Office AnyWhere for Zoom : when utilizing our Service as a Zoom App, the following Zoom data is shared from Zoom to Office AnyWhere Zoom App: display name, email, full name, language, time zone, access token, refresh token, Zoom user ID, profile image URL and Zoom account number. The Office AnyWhere Zoom App does not have access to the following Zoom data: audio/video streams, recordings, transcripts, chats, etc. The Office AnyWhere Zoom App has no visibility into other types of Zoom data, nor organizational/individual configuration settings. For more information please refer to Office AnyWhere in the Zoom Apps Marketplace and Zoom’s Privacy Statement.

How do we use your data?

In short: We use personal data to provide, improve and secure our Service; for analytics, marketing and sales purposes; to comply with applicable laws; and to support legitimate interests. We do not sell your personal data.

Here are specific purposes for which we use personal data:

  • In order to provide, facilitate and operate our Service;
  • In order to authenticate the identity of our Users, and to allow them to access our Service;
  • In order to provide our visitors, Users and Customers with assistance and support, and to notify them about changes to our Service;
  • In order to gain a better understanding on how visitors and Users evaluate, use and interact with our Service, and how we could improve their and others’ user experience, and continue improving the overall utility and performance of our Service;
  • In order to facilitate and optimize our marketing campaigns, sales operations, and to promote our Service, including on other websites and applications.
  • In order to contact our visitors, Users and Customers (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages consistent with consent that has been obtained from you to do so; you may opt out of marketing communications by following the opt-out or unsubscribe instructions at the bottom of the email;
  • In order facilitate, sponsor and offer certain events;
  • In order to support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  • In order create aggregated statistical data, inferred non-personal data or anonymized or pseudonymised data (rendered non-personal), which we or others may use to provide and improve our respective services, or for any other business purpose; and
  • In order to comply with applicable laws and regulations.

Will your data be shared with anyone?

In short: We share your data with our Service Providers; in accordance with legal compliance requirements; and among other Space Users. 

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use it for a specific purpose.
  • Legitimate interest: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal data to fulfill the terms of our contract.
  • Legal Obligations: Although we anticipate such circumstances to be extremely rare, we may disclose or allow government and law enforcement officials access to your personal data when we are legally required in order to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process. This could happen in response to a court order or a subpoena in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or such disclosure is required to protect the security or integrity of our products and services.
  • Service Providers: We engage selected third-party companies and individuals to perform services complementary to our own. Such service providers include providers of cloud infrastructure, communications and content delivery networks (CDNs), data and cyber security services, fraud detection, investigation and prevention services, web and mobile analytics, e-mail and communication distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, compliance and financial advisors and auditors (collectively, “Service Providers”). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such limited purposes as determined in our agreements with them.
  • Partnerships: We engage selected business and channel partners, resellers, distributors and providers of professional services related to our Service (“Partners”), which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our prospective and existing Customers and Users. In such instances, we may share relevant contact, business and usage details with the respective Partner, to allow them to engage with those Customers and Users for such purposes. If you directly engage with any of our Partners, please note that any aspect of that engagement which is not directly related to the Service and directed by Office AnyWhere is beyond the scope of Office AnyWhere’s Terms and Privacy Policy, and may therefore be governed by the Partner’s terms and privacy policy.
  • Application Providers and Event Sponsors: if so instructed or permitted by you or your Account Admin, we may share your personal data (such as your User Profile and contact details, as well as relevant usage data) with the provider(s) of any third party applications or integrations added to your Account. Similarly, if you register for any event that we host, organize or sponsor, then with your permission we may share your registration details with others, including the hosts, organizers, speakers, service providers and sponsors of that event, so that they may contact you with relevant information and offers, or to fulfill any promotions related to the event.
  • Customers and other Users: Your personal data may be shared with the Customer owning the Account to which you are subscribed as a User (including data and communications concerning your User Profile), as well as other Users of that Account or Space. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public. Your personal data and activity within the Service may also be monitored, processed and analyzed by the Account Admin. This includes instances where you contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same Customer). Please note that Office AnyWhere is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer (including sharing of boards or use of broadcast features within the Service), that itself acts as the “Data Controller” of such data.
  • Service integrations: When you access the Space as a User, you or your Account Admin may choose to integrate your Account on the Service with a third-party service (provided that such integration is supported by our Service). The provider of this integrated third-party service may receive certain relevant data about or from your Account on the Service, or share certain relevant data from that account on the third-party provider’s service with our Service, depending on the nature and purpose of such integration. This could include your User Data. Note that we do not receive or store your passwords for any of these third-party services (but do typically require and store your authentication token in order to integrate with them). If you do not wish your data to be shared with such third-party service(s), you may elect not to enable such integrations and/or contact your Account Admin.
  • Protecting Rights and Safety: We may share your personal data with others if we reasonably believe that this will help protect the rights, property or personal safety of Office AnyWhere, any of our Users or Customers, or any members of the general public.
  • Office AnyWhere Internal and Affiliated Companies: We share personal data internally for the purposes described in this Privacy Policy. In addition, if Office AnyWhere were to undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such an event. In the event we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Service.

Additional Purposes: For the avoidance of doubt, your personal data may be shared by Office AnyWhere in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.

Who can see and share my personal data when I use Office AnyWhere?

When you join a meeting and/or participate in a shared visual space (and any other interaction with the Space or the App), other people and organizations, including third parties outside the meeting and/or shared visual space, may be able to see content and information that you share:

  • Customer: A Customer is the organization or individual that signs up for a Office AnyWhere account. Typically, an account owner designates one or more people (called an Account Admin) to manage their account and can grant privileges to users on the account. Depending on their license with Office AnyWhere, the Customer can authorize additional users on their account, and the account owner can create and/or access the profile information for all users on their account. The Customer and their users can invite others (including guests not on their account) to meetings and/or shared visual spaces hosted on their account. Depending on their settings, the Customer and the people they designate can access personal data for people who join a meeting and/or participate in a shared visual space on their account or send messages to users on their account. Specifically, Customers may have access to:
  • Product Usage: Information about how people and their devices interact with their account, which may include duration and interaction metrics, email addresses, IP addresses, device information, and other information about who joined meetings and/or participated in shared visual spaces on their account, and other usage information and feedback metrics.
  • Participant List: Information about the participants in a Office AnyWhere meeting and/or shared visual space, webinar, or chat, which may include name, display name, email address, profile image, and participant or user ID.
  • Registration Information:  Information provided during registration for a meeting and/or shared visual space.
  • Polling, Q&A, and Feedback: Customers can see information about who provided responses to their polls, Q&A, or post meeting or shared visual space feedback requests, including name and contact information, together with the responses or feedback, unless responses are submitted anonymously.
  • Meeting/Shared Space Hosts and Participants: Hosts and other participants may be able to see your email, display name, and profile picture. Facilitators may also be able to see responses to polls, Q&A, and feedback.

Office AnyWhere for Zoom: when utilizing our Service as a Zoom App (“Office AnyWhere Zoom App”), please refer to Office AnyWhere in the Zoom Apps Marketplace and Zoom’s Privacy Statement. Personal data shared to Zoom by Account Owners and Users is collected and processed in accordance with Zoom’s terms and privacy statement, not Office AnyWhere’s.

Is your data transferred internationally?

In short: We may transfer, store, and process your information in countries other than your own.

We are headquartered in the United States and have service providers that are located in other countries. As such, your personal data may be transferred to the United States or other locations outside your state, province, or country where privacy laws are not as protective as those in your state, province or country. We will however take all necessary measures to protect your personal data in accordance with this privacy notice and applicable law.

Your data may be stored in multiple locations around the world, for as long as necessary in accordance with our reasonable business needs; as necessary for the performance of our Service; for supporting and exercising our legitimate interests; and in accordance with our legal obligations.

With respect to personal data of individuals from the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, our legal basis for collecting and using the personal data will depend on the personal data concerned and the specific context in which we collect it. We will generally collect personal data from you or a third party only where: (a) we have your consent to do so, (b) where we need the personal data to perform a contract with you (e.g. to deliver the services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

European Commission’s Standard Contractual Clauses

We have implemented measures to protect your personal data, including using the European Commission’s Standard Contractual Clauses for transfers of information between us and our third-party providers. These clauses require all recipients to protect all personal data that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners, and further details can be provided upon request.

Are cookies and other tracking technology used?

In short: we use cookies and other technologies for performance, functionality and service optimization purposes.

See our Cookie Notice for additional information.

How do we communicate with you?

In short: we engage in service and promotional communications, through email and notifications.

  • Service Communications: We may contact you with important information regarding our Service. For example, we may contact you to inform you about changes or updates to our Service, service changes, log-in attempts or password reset notices, etc. Please note that these communications are integral to the delivery of the service and therefore the option to opt-out is not provided.
  • Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g., e-mail and notification), through the Service, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to info@welo.space, or by following the “unsubscribe,” “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

How long do we keep your data?

In short: We keep your information as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer period is required or permitted by law (such as tax, accounting or other legal requirements). This means that even though we stop processing your personal data for one purpose, we may still need to keep your personal data, if the data is needed for another purpose, using it only for that other purpose. When we have no ongoing legitimate business need to process your personal data, we will either delete or pseudonymise such information, or, if this is not possible then we will securely store your personal data and isolate it from any further processing until deletion is possible.

How do we keep your data safe?

In short: We aim to protect your personal data through a system of organizational and technical security measures.

Your data is protected by industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored. No method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, transmission of personal information to and from our Service is at your own risk. You should only access our Service within a secure environment.

Do we collect data from minors?

In short: We do not knowingly collect data from or market to individuals under 16 years of age.

Our Service is not intended for children or minors younger than sixteen (16) year of age. We do not knowingly collect, nor wish to collect, any personal data from individuals under sixteen (16) years of age. No one under age sixteen (16) may provide any identifying personal data to Us, provide any other information, or attempt to utilize our service in any capacity. If we learn that an individual under the age of sixteen (16) is using the Service, we will attempt prohibit and block such use. Likewise, we will delete any personal data collected that we later determine to be from a user younger than the age of sixteen (16). If you are a parent or guardian of an individual under the age of sixteen (16) and believe that individual has disclosed personal data to us, please contact us at dpo@welo.space.

What are your data subject rights?

In short: If you are governed by applicable data protection laws, you may exercise your rights to access to and control your personal data by contacting us as stated below.

Under California Civil Code section 1798.83 and the California Consumer Privacy Act of 2018, as amended, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. European data protection laws, including the EU or UK General Data Protection Regulation (GDPR), give you certain rights regarding your personal data. If you are a California or European resident and you wish to exercise your privacy rights, such as the right to request access to, rectification or erasure of your personal data held by Office AnyWhere, or to restrict or object to such personal data processing, or to obtain a copy or port such personal data (each to the extent available under the laws which apply to you) – please contact us by email aor

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. Please note however this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.If you have questions or comments about your privacy rights you may email us dpo@welo.space.

Additional notices and how to contact us

  • Updates and Amendments: We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
  • DPO: Office AnyWhere has appointed Erin Benson as our Data Protection Officer, for monitoring and advising on Office AnyWhere’s ongoing privacy compliance and serving as point of contact on privacy matters for data subjects and supervisory authorities. You may contact our DPO about privacy matters via email: dpo@welo.space. 
  • Representative for data subjects in the EU and UK
    • EU Representative:
      Maetzler Rechtsanwalts GmbH & Co KG
      Walter-Gropius-Straße 17
      80807 Munich
      GERMANY
    • UK Representative:
      Prighter Ltd (UK)
      20 Mortlake Mortlake High Street
      London SW14 8JN
      UNITED KINGDOM

      We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
  • Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/19064171098.
  • Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, if you have concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Office AnyWhere, you can contact info@welo.space or dpo@welo.space.