- 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: Welo’s Zoom App (“Welo for Zoom”), web browser URL app.welo.space (“Welo for Web”), Welo’s Progressive Web Application (“Welo 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”).
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: Welo’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.”
- 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.
- 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”.
- Welo for Zoom : when utilizing our Service as a Zoom App, the following Zoom data is shared from Zoom to Welo 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 Welo Zoom App does not have access to the following Zoom data: audio/video streams, recordings, transcripts, chats, etc. The Welo Zoom App has no visibility into other types of Zoom data, nor organizational/individual configuration settings. For more information please refer to Welo 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.
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.
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 firstname.lastname@example.org, 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.
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 email@example.com.
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 Welo, 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 firstname.lastname@example.org.
Additional notices and how to contact us
- DPO: Welo has appointed Erin Benson as our Data Protection Officer, for monitoring and advising on Welo’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: email@example.com.
- Representative for data subjects in the EU and UK
- EU Representative:
Maetzler Rechtsanwalts GmbH & Co KG
- UK Representative:
Prighter Ltd (UK)
20 Mortlake Mortlake High Street
London SW14 8JN
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.
- EU Representative:
- 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.