Last Updated January 6th, 2020
Welcome to Lifesize!
Lifesize, Inc. (“Lifesize”) is committed to ensuring the privacy and security of personal information that we collect about you. Please take a moment to read the following policy to learn about how we handle your personal information and contact us at firstname.lastname@example.org with any questions or concerns.
2. HOW LIFESIZE COLLECTS INFORMATION
Lifesize collects information in a variety of ways, including:
- Through the Website: Lifesize collects information through the Website as described in Section 3.
- Through the Services: Lifesize collects information through the Services as described in Section 4.
- Offline: Lifesize may collect information from you offline, such as when you attend a trade show or Lifesize event, or during a phone call or in-person meeting with a Lifesize sales representative or other employee.
- From Other Sources: Lifesize may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, distributors, resellers, or other third parties.
3. PERSONAL INFORMATION COLLECTED THROUGH THE WEBSITE
Types of Personal Information Collected through the Website
Personal information collected through the Website includes information that reasonably can be used to identify or describe you as an individual, such as: name, employer, business role, professional title, contact information (company, email address, telephone number, and physical business address), localization data, IP address, domain name, and demographic information such as geographic location.
Why We Collect Personal Information through the Website
Lifesize collects personal information that you voluntarily provide when you visit the Website in order to communicate with you about our Services, enter into transactions with Customers, and to ensure you have a positive experience when visiting the Website and using the Services. In addition, we use your personal information to keep you up-to-date on the latest product announcements, software updates, special offers, and other information we think you would like to hear about. This may occasionally include information from other companies about products and services that can add value to your Lifesize products. From time to time, we may also use your personal information to contact you online, through the mail or via telephone to participate in a market research survey so that we can gauge customer satisfaction and improve our products and services.
Submission of Personal Information
You may provide personal information through the Website when you access product information and updates, register for a seminar, subscribe to our newsletter, download a report or other materials, register for a free trial or demonstration equipment, place an order for or use products or Services, access a portal for technical service or support, or sign into a page that requires authorization. You will know which personal information you submit in each case because you will manually enter the information. If you choose not to register and provide information, you can still use most of the Website. Unfortunately, you will not be able to access areas that require registration.
Social Media Features
Any payment information, including credit card information, that you submit through the Website is collected by our payment processor and not collected by Lifesize. Our payment processor is authorized to collect and use the submitted information only for the purposes of providing this service. Please read the privacy statement of our payment processor, which is accessible where your information is collected.
If you use this Website to apply for employment with Lifesize, we will use the personal information you provide to process your application and to monitor recruitment statistics. Unless otherwise required by law, we will not disclose your personal information to a third party (for example, in connection with verifying professional references) without informing you. Subject to applicable law, we may retain personal information about unsuccessful candidates after the recruitment exercise has been completed. We may also retain de-identified statistical information about applicants to help our recruitment activities. Employee information and recruitment data is retained at Lifesize’s corporate headquarters in Austin, Texas, and in other Lifesize locations worldwide.
Access and Data Retention of Personal Information Collected through the Website
Upon request Lifesize will provide you with information about whether we hold any of your personal information collected through the Website. You may access, correct, or request deletion of your personal information by sending an email request to email@example.com. We will respond to your request within a reasonable timeframe. We will store your personal information, in a form which permits us to identify you, for no longer than is necessary for the purposes for which the personal information is processed.
Lifesize will retain personal information for as long as your Lifesize account is active or as otherwise needed to provide you Services. Lifesize may also retain such information as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights.
4. PERSONAL INFORMATION COLLECTED AND PROCESSED THROUGH THE SERVICES
Notice to End Users of the Services
If you access the Services through an account provided by an organization you are affiliated with, such as your employer or school, such organization may control and administer your Lifesize account, and access and process your personal information and data transmitted through the Services. Please be aware that your Account Administrator has the ability to access and review any recorded video calls, Chat transcripts, and Call Data Records. In addition, if you sign up for the Services using your work email address, your username will be visible to other users who have the same email domain or another domain enabled by your Account Administrator.
Types of Personal Information Collected and Processed through the Services
The types of information collected and processed by Lifesize in connection with Customer’s use of the Services include, but are not limited to: name, employer, business role, professional title, contact information (company, email address, telephone number, and physical business address), account username, localization data, device identification data, software/operating system version, connected hardware products, custom settings and preferences, other systems information, Customer Content and Call Data Records (such as time of call, participants, and call duration).
Why We Collect and Process Personal Information through the Services
Lifesize collects and processes personal information of end users using Lifesize’s Services under the direction of the Customer in order to provide the Services to end users in accordance with the Terms of Service and any additional instructions provided by its Customers. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure and/or obtaining consent prior to transferring the data to Lifesize for processing purposes.
We also use your information to display your identity to other users during a video call and in Chat messages, to communicate with you about features of the Services and updates, to understand how the Services are being used, to send you marketing communications, to optimize your connection to our data centers, and to improve the Services.
Lifesize collects and processes personal information contained in Customer Content, including information related to:
- Video Calls and Virtual Meeting Rooms (“VMRs”): VMR titles, invitations, participants, VMR link, features used during the call, date, time and duration of the call. We transmit audio and video call content and screen sharing content between call participants during the call, but we do not retain or store the content unless Lifesize Record and Share is activated by a participant.
- Chat Transcripts: Chat content, sender and recipients, date, time, and read receipts.
- Status: Status information, for example about whether and when you are logged-in to the Services, which you can choose to share with other users or disable.
Any personal information about yourself or others that you share during a video call or using Chat will be available to all other participants in such call or receiving your Chat message. In addition, recordings of a call may be automatically shared with each registered user of the Customer’s account who participated in the call. This access may be modified by the individual responsible for the recording, who is either the VMR organizer or, if a VMR is not used, the participant who selected to record the call. The recording is not shared with guest participants or registered users associated with a different Lifesize account. Lifesize is not responsible for the accuracy, content and legality of any Customer Content or data displayed, transmitted, distributed or stored by or on behalf of Customer and its authorized end users, including any personal information contained in such Customer Content.
Call Data Records
The Services automatically collect information about your usage of the Services, including actions taken during calls, date and time of calls, duration of calls, participants, quality and packet loss issues, network connectivity, and performance information related to other aspects of your use of the Services, such as your of certain features such as video and screen sharing, VMRs, Record and Share, Live Stream and Chat (“Call Data Records”). We use Call Data Records to understand how Services are used, to diagnose problems, to respond to customer support requests, to conduct analytics and aggregate statistical analysis, to prevent or address service or technical problems and to improve the Services.
Mobile and Browser Permissions
The Service makes use of a number of features available on mobile device and web browser platforms to support your video conferencing and collaboration experience. Depending on your device, your application may request or automatically obtain some or all of the following permissions in order to enable your use of the Services and its features: phone, microphone, camera and speaker; screen sharing; calendar and contacts; and push notifications.
The Services will only make use of these permissions when you choose to enable them or when you initiate or receive a call using such device or application. You may configure your device to disable these permissions.
Access and Data Retention of Personal Information Collected and Processed through the Services
Lifesize has no direct relationship with individual end users who use Services through a Lifesize Customer. If you seek access to or wish to correct, amend, update or delete personal information or data maintained in a Lifesize Customer account, or if you wish to disable or delete your Lifesize account entirely, please contact your Account Administrator directly. If the Customer requests Lifesize’s assistance in modifying personal information or data in order to comply with applicable data protection regulations, Lifesize will respond to such request within a reasonable period of time. If you are using a free service, and you seek access to or wish to correct, amend, update or delete personal information or data maintained, or to delete your Lifesize account entirely, please contact us using the information below in Section 10.
We will store your personal information, in a form which permits us to identify you, for no longer than is necessary for the purposes for which the personal information is processed. Lifesize will retain personal information that we collect or process on behalf of a Customer for as long as needed to provide the Services to such Customer. Lifesize may also retain such information as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights.
5. HOW WE USE YOUR PERSONAL INFORMATION
Use of Personal Information
Sharing Personal Information with Third Parties
Lifesize does not trade, rent or sell customer or user information to unaffiliated companies. However, because Lifesize is a global company, your personal information may be shared with other third parties around the world who work with or support Lifesize in its provision of products and Services. For example, we may disclose your personal information in connection with the following:
- Third Party Distributors and Resellers: Lifesize contracts with distributors, resellers and agents around the world to sell products and Services to Customers and may disclose personal information to such partners for the purposes described above.
- References Providers: Where required by applicable law, we may share copies of job applications with those providing references to support your application. When we do so, we will inform you in advance.
- Shipping Providers: Lifesize hires shipping companies to efficiently deliver products to customers and may provide them with only the personal information necessary for shipping and delivery purposes.
- Service Providers: Lifesize may hire third party service providers to perform certain tasks and functions on its behalf. For example, Lifesize may use service providers to distribute email communications to you, provide data analysis, or host a data center. All service providers are subject to strict confidentiality, privacy and security obligations and process your information only on our behalf and subject to our instructions.
- Community and Social Media Platforms: If you post any information in public areas of the Website, such as community forums, blogs or other areas, it will be available to the public and we may reuse and republish such information at our discretion.
- Business Transfers: Lifesize may disclose information to another business entity in the event we plan to merge with or be acquired by that business entity; or to any organization involved in a merger, transfer, or sale of our assets or business.
- Protection of Lifesize and Others: Lifesize may disclose information to protect and defend its rights or property, including this Website, or if we believe that disclosure is necessary for the public interest. We may also be required by mandatory law to disclose your personal information to governmental authorities such as law enforcement agencies in countries where Lifesize provides Services or where third parties act on our behalf.
- Anonymized Data: We may share anonymized information freely, but only after we redact it to ensure that recipients cannot use the data to identify you or link the data to you.
Before we disclose your personal information for reasons other than as described above, we will first obtain your consent, for example via e-mail, click-through, or an online opportunity to opt-out where permitted by applicable law. In the event that we disclose your personal information to a third party, we will require such third party to protect and maintain your information in compliance with our policies and in accordance with applicable law. We hold our vendors responsible for complying with the law, and we routinely review their assertions, certifications and registrations relating to privacy and data security. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA Personal Data that we transfer to them.
Where we transfer EEA personal data to a third party located in a country not recognized by the European Commission, or another relevant body, as ensuring an adequate level of protection, we will take appropriate steps, such as implementing Standard Contractual Clauses recognized by the EU Commission, to safeguard such personal data. For further information, please contact us using the details listed at Section 10.
Lifesize and its third party service providers collect information about how you use the Website and Services through “cookies” (small text files that can be read by a web server in the domain that put the cookie on your hard drive), internet tags (e.g., web beacons) in the aggregate, and track navigational data. We also collect information such as the URL of the website you previously visited, the pages you visit within the Website and any transaction details (downloads, requests, etc.). This information is used to understand how you interact with the Website, and to help us optimize our marketing efforts including managing our advertising on other sites providing you ads based on your activities on the Website. Please note that whatever your preference, you will continue to receive non-personalized ads. You may also set your browser to notify you when a cookie is set or to refuse or delete cookies altogether, but certain features of the Website might not work in this case.
7. YOUR CONSENT & CHOICES
Your Choices and Opting-Out
You may stop the delivery of marketing e-mails by following the unsubscribe instructions contained in the email received or at the subscription management page on the Website. Lifesize will respond to your request to review the information we have on file for you within a reasonable period of time from receiving such request. We will also provide you the opportunity to opt-out of having your personal information used for certain purposes whenever we ask for this information.
International Transfers of Data
Personal information may be stored and processed in the United States or in any other country in which Lifesize or its affiliates, subsidiaries or agents maintain facilities. By using the Website or Services, you acknowledge the collection, processing, maintenance and transfer of personal information outside of your country, including to the United States and other applicable regions in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside.
8. PROTECTION OF INFORMATION
Lifesize is committed to the protection and security of your personal information. To ensure your personal information remains confidential and secure, every Lifesize employee is required to complete mandatory data security and privacy training. We also implement a variety of industry-standard technical and organizational measures, including SSL encryption, to secure your personal information from unauthorized access, use, loss or disclosure.
However, no system in which personal information is transmitted via the internet can ensure complete security 100% of the time. Lifesize cannot guarantee the security of your information transmitted through the Website or the Services. To the extent permitted by applicable law, such transmission is at your own risk.
It is your responsibility to take precautions when using the Website and Services such as protect your log-in credentials, do not send credit card information or sensitive data in an unsecured email, change your password often, and log-off or exit from the Website and/or Services when not in use.
If you think that your account or personal information has been compromised, or if you have any questions or concerns about the security of your personal information, please contact us as soon as possible at firstname.lastname@example.org. These policies are managed in accordance with https://www.privacyshield.gov.
9. PRIVACY SHIELD CERTIFICATION
10. ENFORCEMENT & DISPUTE RESOLUTION
Phone: +1-877-LIFESIZE or +1-512-347-9300
Contact: Privacy Officer
Postal Mail: Lifesize, Inc.
1601 South Mopac Expressway, Suite 100
Austin, Texas 78746
Email Address: email@example.com
If, after first contacting our Privacy Officer and allowing us a reasonable amount of time to address your complaint, you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. The dispute resolution process will be conducted in English.
For EU and Swiss individuals, Lifesize commits to cooperate with EU Data Protection Authorities and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by such authorities with regard to unresolved Privacy Shield complaints concerning data transferred from the EU or Switzerland.
11. EUROPEAN DATA SUBJECTS
If you visit our Website or use our Services from the European Union, we will process your personal information on the following “legal bases”:
- Where you have given us your consent to processing;
- Where processing is necessary for the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract; and/or
- Where processing is necessary for certain legitimate interests (including our legitimate business interests).
In particular, we will process personal information for the following purposes as is necessary for the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract:
- To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
- To assist you in completing a transaction or order and to allow you to place an order for Services;
- To prepare and process invoices;
- To provide the Services to end users in accordance with the Terms of Service and any additional instructions provided by our Customers;
- To communicate with you about features of the Services and updates and to provide technical support;
- To provide aftersales customer relationship management;
- To create and manage our customer accounts;
- To notify you about changes to our Services;
- To administer any promotion or competition;
- To facilitate candidate onboarding processes;
- Process job applications; and
- To allow you to use our Services in full, including making and receiving video calls and using our VMR services, and supporting your video conferencing and collaboration experience.
We will process your personal information for the following purposes as is reasonably necessary for certain legitimate interests (including our legitimate business interests), or where you have given your informed consent to such processing if required by applicable law (such consent may be withdrawn at any time):
- To allow you to access information about our Services, updates and to display your identity to other users during a video call and in chat messages;
- To allow you to subscribe to our newsletter and register for seminars;
- To allow you to participate in contests and surveys and benefit from personalized promotional offers;
- To allow you to download a report;
- To allow you to sign-into a page that requires authorization;
- To keep you up-to-date on the latest product announcements, software updates, special offers, and other information we think you would like to hear about. This may occasionally include information from other companies about products and services that can add value to your Lifesize products;
- To contact you online, through the mail or via telephone to participate in a market research survey so that we can gauge customer satisfaction and improve our products and Services;
- To administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
- To monitor and improve the performance and quality of the Website, to ensure that content is presented most effectively for you and your computer or device;
- To understand how the Services are being used, for example, by reviewing visits to our Website and its various subpages, to optimize your connection to our data centers, and to improve the Services;
- As part of our efforts to keep the Website safe and secure;
- To ensure the security of your account and our business, for example, by requesting verification information in order to reset your account password (if applicable);
- To investigate, prevent or detect fraud, malicious activity or abuses of our Website;
- To monitor quality control and ensure compliance with any and all applicable laws or ordinances, for example, in response to a request from a court or regulatory body;
- To resolve any disputes and to protect, enforce or defend our rights;
- To allow you the ability to post information about your activities on the Website to your profile page to share with others within your social network;
- To assess your qualifications with respect to available positions within Lifesize, to review references and facilitate background screening and to decide whether to enter into an employment relationship with you;
- To monitor recruitment statistics.
We may also process your personal information in order to protect your vital interests or the vital interests of another person. For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”), under some limited circumstances, the Data Controller is Lifesize, Inc., and is registered in Austin at 1601 S. MoPac Expy Suite 100, Austin, Texas 78746.
European Data Subject Rights
Under European data protection law, in certain circumstances, you have the following rights:
- Request access to your personal information. You may have the right to request confirmation from us as to whether we process your personal information and to request access to your personal information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
- Request correction of your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you. To the extent required by applicable laws, any correction requests will be communicated to recipients of your personal information.
- Request erasure of your personal information. You may have the right to request that your personal information is deleted. To the extent required by applicable laws, any erasure requests will be communicated to each recipient of your personal information.
- Request restriction of processing your personal information. You may have the right to prevent or restrict processing of your personal information. To the extent required by applicable laws, any restriction of processing requests will be communicated to each recipient of your personal information.
- Request transfer of your personal information. You may have the right to request transfer of your personal information directly to a third party where technically feasible.
- Right to object. You may have the right to object to the processing of your personal information when you have legitimate reasons to do so.
- Right to withdraw consent. Where processing is based on consent, you may have the right to withdraw such consent. In some cases, if you withdraw your consent to use of your personal information, we may not be in a position to continue to provide our Services or products to you.
You can exercise any of these rights by contacting us using the information in Section 10 above. We reserve the right to request the provision of additional information necessary to confirm the identity of the enquirer.
12. CALIFORNIAN DATA SUBJECTS
Under California law, a California customer with whom we have an established relationship has the right to request certain information with respect to the types of personal information that we have shared with third parties for their direct marketing purposes and the identities of those third parties during the prior calendar year. All requests for such information must be in writing and using the contact information in Section 10 above.
California Consumer Privacy Act Rights
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their “personal information”. This section describes your CCPA rights and explains how to exercise those rights.
During the past twelve (12) months, Lifesize may have collected and/or shared the following categories of personal information with our strategically aligned businesses. The categories of information include information we collect from our job applicants, suppliers, vendors, customers, resellers, partners and Website visitors, and any other person that interacts with us either online or offline. Not all information is collected about all individuals.
- Identifiers such as name, business role, professional title, contact information (company, email address, telephone number, and physical business address), demographic data, username and status;
- Sensitive information such as recorded video calls, Chat Transcripts, call duration, Call Data Records, calendar and contacts, and invoicing data;
- Commercial information such as transaction history, products/services purchased, obtained or considered and product preferences;
- Professional or employment-related information such as cover letter, job role and Lifesize office location interested in, preferred job conditions, professional history, academic history, answers to questions about suitability for a position, extracurricular activities, professional references, and professional and personal competencies;
- Internet or other electronic network activity such as IP address, web browser type and version, domain name, device identification data, software/operating system version, connected hardware products, custom settings and preferences, other systems information;
- Geolocation; and
- Inferences from the above such as preferences, characteristics, behavior, attitudes and abilities.
The categories of personal information collected come from the following sources: individuals submitting information to us; information we may receive from third-party marketing and data partners; information we automatically collect from website visitors and internal analytics.
During the past twelve (12) months, we may have shared the categories of personal information the following categories of third parties: service providers (such as those listed in Section 5); affiliated companies; government regulators; law enforcement; strategically aligned businesses.
Your rights and choices
As of January 1, 2020, if you are a verified California resident, you have the right to obtain certain information about our collection and use of personal information over the past twelve (12) months, including:
- The categories of personal information we collect;
- The categories of sources of personal information we collect;
- Our business purpose for collecting or sharing that personal information;
- The categories of third parties with whom we share that personal information;
- The specific personal information we have collected about you over the past twelve (12) months;
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- the categories of personal information sold and the category of third party recipients; and
- list of the categories of personal information that we disclosed for a business purpose.
You have the right to request that we do not sell personal information about you, and to request that we delete (and direct our service providers to delete) your personal information subject to certain exceptions. Lifesize will not sell your personal information without your prior consent.
Exercising your rights
You can exercise any of these rights by contacting us using the contact details set out above or you may submit a request to us by emailing firstname.lastname@example.org or calling 1.877.LIFESIZE (877.549.9143). You may make a request up to twice within a twelve (12) month period.
We will ask you for information to verify your identity (that you are the person about whom we collected personal information) and we will use that information only for that purpose. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
Response timing and format
We will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of the reason and extension period in writing.
Where you request a copy of your personal information, we will endeavor to provide the information in a format that is readily useable. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of you verified request.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you as a result of your exercise of any of these rights.
13. CHILDREN’S PERSONAL INFORMATION
Lifesize does not knowingly collect personal information from Website visitors or users of Lifesize’s products or Services who are under the age of 16. If we are made aware that we have such personal information, we will take reasonable steps to delete such information.
14. CHANGES TO THIS STATEMENT
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