Effective: May 25, 2018
As used in this Policy, the terms listed below have the following meanings:
Customer – A “Customer” is anyone who purchases SecureVideo products or services, or is employed by an organization that has purchased SecureVideo products or services. When a Customer purchases retail products or services for use by others, those individuals also may be considered Customers for purposes of this Policy
User – A “User” is anyone who visits our websites.
Personal Information – “Personal Information” is information that directly identifies or reasonably can be used to identify an individual Customer or User. Examples include name, telephone number, or e-mail address. Personal Information does not include Published Listing Information as discussed in more detail below or information that is readily available to the public through no fault of SecureVideo.
Anonymous Information – “Anonymous Information” means information that does not directly identify and cannot reasonably be used to identify an individual Customer or User.
Aggregate Information – “Aggregate Information” means information about groups or categories of Customers or Users, which does not identify and cannot reasonably be used to identify an individual Customer or User. Aggregate Information is a kind of Anonymous Information.
Website – “Website” means any page or location on the Internet, no matter what device (cell phone, lap top, PC, etc.) or protocol (http, WAP, ftp or other) is used to access the page or location. In this Policy, we use the term website other similar terms such as “Internet site,” “site,” and “web page.”
1. When we collect Information
1.1 – Contact information: we collect contact information you provide when you create an account (or one is created for you), schedule a session through our system and choose to use our email or SMS invite system, submit a support or sales request, start a chat with a support or sales agent using our chat widget, or leave a comment on the SecureVideo blog.
1.2 – Payments and billing information: accounts are normally billed using a credit card on file, for which we collect the credit holder’s name, credit card number, expiration date, and CVV code. For customers that arrange to be invoiced rather having a credit card on file, we will collect the billing contact name, email address, and phone number.
1.3 – Automated information: when you visit our website, we receive and collect information regarding actions taken on the website, IP addresses used to determine approximate geolocation (in a range between 5 and 5,000 miles of your IP address) and then encrypted in a one-way hash, referral URL, exit URL, browser software, operating system, date/time and/or clickstream data.
1.4 – Website analytics: we use analytics services by third parties to collect information about the use of this Site, to catch and address browser errors, check site load during maintenance periods, and other digital monitoring for improving performance. We collect this information on an anonymous basis and may anonymize the personal information we collect about you into data groups. When we employ non-SecureVideo companies to anonymize or aggregate data on our behalf, the requirements for sharing Personal Information with non-companies apply. We may share aggregate or anonymous information in various formats with trusted non-SecureVideo entities, with whom we have contracted with to aggregate such data and may work with those entities to do research and provide products and services.
2. How we use information
We collect, store, and use the information for the following reasons:
2.1 – Contact information: to send account holders notices related to their account, updates regarding status of services, functionality changes and other updates to our products or company; to send account administrators billing-related communications; and to send session participants notifications regarding sessions; to send newsletters to users who opt-in, in accordance with our Terms of Service and applicable law.
2.2 – Payments and billing information: we use this information to process payments on an account, to invoice you, and to fulfill our legal obligations for tax calculations.
2.3 – Automated information: to diagnose problems with our servers, to administer our Site and services, and to prevent fraud or abuse on our Site and systems.
2.4 – Website analytics tools: to monitor and improve performance on our site.
3. Purposes of data processing
Our purpose for collecting and using the information described above will depend on the type of information and context in which it was collected.
3.1 – Consent: we send newsletters to users that have opted in to receive those communications from us. Consent can be withdrawn at any time by updating your personal settings in your user account, or using our “Unsubscribe” option within the email newsletter.
3.2 – Contract: to provide our services in accordance with our Terms of Service, whether as an account holder or as a user invited to join a session through our platform.
3.3 – Legal obligation: to comply with a necessary legal obligation, a court order, or to exercise or defend legal claims, or to support our users in complying with the U.S. federal regulation, Health Insurance and Portability and Accountability Act (HIPAA).
3.4 – Legitimate interests: when data processing is in our legitimate interests to do so and not overridden by your rights, such as to develop and provide our services and security; detect and prevent fraudulent activities; or determine the effectiveness of promotional campaigns and advertising.
We use a technology called “cookies.” A cookie is a piece of information that give to your browser when you access the SecureVideo website. Cookies are required if user will be logging into a SecureVideo account. Cookies are recommended to display the correct branding (if applicable), and signal if user has already installed our video software.
Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users and we anonymize IP addresses. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.
5. How we share your personal information and who we share it with
We do not sell your Personal Information to anyone for any purpose, and we maintain information about you in our business records while you are a customer, or until it is no longer needed for business, tax, or legal purposes. We have implemented encryption or other appropriate security controls to protect Personal Information when stored or transmitted by SecureVideo. Subject to applicable legal restrictions, such as those that exist for Customer Proprietary Network Information (CPNI), the SecureVideo family of companies may share your Personal Information with each other to make sure your experience is as seamless as possible, and you have the full benefit of what SecureVideo and its subsidiaries have to offer. Customer Proprietary Network Information (CPNI) is information that relates to the quantity, configuration, type, destination, location and amount of use of the telecommunications services you purchase from us, as well as the information contained in your bills for those services. We collect CPNI in the normal course of providing you with telecommunications services. Your telephone number, name and address are not CPNI.
We share your Personal Information only with non-SecureVideo companies that perform services on our behalf, and only as necessary for them to perform those services. We require those non-SecureVideo companies to protect any Personal Information they may receive in a manner consistent with this policy, and we do not provide Personal Information to non-SecureVideo companies for the marketing of their own products and services without your consent. We may provide Personal Information to non-SecureVideo companies or other third parties for purposes such as emergencies, pursuant to court orders, identity verification to prevent fraud and identity theft, enforcing of property rights, or obtaining payment for products and services that appear on your SecureVideo billing statements.
SecureVideo reserves the right to use or disclose information provided if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or legal process.
We have established physical, technical and administrative safeguards designed to secure the information we collect, to prevent unauthorized access to or disclosure of that information and to ensure it is used appropriately.
To protect against unauthorized access to your account and information, we implement session management, login expiration mechanisms, and blacklisting IP addresses after 20 consecutive failed login/access attempts. As an additional safety measure, be sure to sign off when you finish using your account.
Although we strive to keep your Personal Information secure, no security measures are absolute, and we cannot guarantee that your Personal Information will never be disclosed in a manner inconsistent with this Policy (for example, as the result of unauthorized acts by third parties that violate the law or this Policy). We will make reasonable attempts to notify you if we determine that SecureVideo has experienced a security breach and there is a reasonably likely risk of identity theft, or where otherwise required by law.
7. Retention periods
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.
8. Your rights
You may access/edit your information through your SecureVideo account, or contact SecureVideo to request Customer Information held by SecureVideo in order to correct, amend or delete information that is inaccurate. Contact information is provided in Section 12 below.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, 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. If you are a California resident and would like a copy of this notice, please submit a written request to the address in Section 12 below.
9. Account set-up
When selecting passwords for SecureVideo accounts, you should choose words or characters that are not obvious. Likewise, you should always keep Personal Information such as account numbers, Usernames, passwords or similar information in a secure place and not share the information with others. If you are an Account Administrator setting a password for one of your users, that temporary password will be emailed to them, and they will be required to change that password the first time they log in.
10. Privacy Shield
In compliance with the Privacy Shield Principles, SecureVideo commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact SecureVideo at: [email protected] attention to Michelle Dong, Director of Operations, or by postal mail: SecureVideo, 1050 Marina Village Parkway, Suite 203, Alameda, CA 94501.
SecureVideo has further committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution/American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the ICDR/AAA website for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you. EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
For more information about the EU-U.S. Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website.
In cases of onward transfer of personal information to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, SecureVideo remains liable. The Federal Trade Commission has jurisdiction over SecureVideo’s compliance with the Privacy Shield.
11. Policy changes
12. Contact us
If you reside in the EU or EEA, you can also contact our Chief Privacy Officer.