Last Modified: November 12, 2018
Contact details Our full details are: Oblong Industries Inc. Data Privacy Manager Email address: firstname.lastname@example.org
US Residents: 923 E 3 rd Street, Suite 111, Los Angeles, CA 90013, U.S.A.
UK Residents: Oblong Europe Ltd, 1 st Floor, 131 Shoreditch High Street, London, E1 6JE, England
Germany Residents: Oblong Europe Ltd (German Branch), Lyonel-Feininger-Str. 28, 80807, Munich, Germany
Spanish Residents: Oblong Europe S.L., Carrer Del Pi, 3, Principal Interior, 08002 Barcelona, Spain
If you are based in the European Union, you have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact our Data Privacy Manager in the first instance.
Personal data, or personal information, means any information about an individual from which that person can be identi ed. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer di erent kinds of personal information about you which we have grouped together follows:
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect information from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie notice (https://www.oblong.com/policy/cookies-notice/) for further details.
Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact our Data Privacy Manager if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal information uses, particularly around marketing. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal information with any company outside Oblong for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Privacy Manager. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal information with the parties set out below for the purposes set out in the table in Section 4, above.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We may share your personal information within Oblong. This will involve transferring your information outside the European Economic Area (EEA). When we transfer your personal information to the United States, we rely on our self-certification under the EU-U.S. Privacy Shield Framework administered by the U.S. Department of Commerce. Oblong adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability for all personal information from the EU and Switzerland, including the Privacy Shield onward transfer liability provisions. For purposes of enforcing compliance with the Privacy Shield, Oblong is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review Oblong’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list. Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA. Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact our Data Privacy Manager if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal information are available upon request by contacting our Data Privacy Manager. In some circumstances you can ask us to delete your information: see “Request erasure” below for further information. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you are based in the EU, under certain circumstances, you have rights under data protection laws in relation to your personal information. Please see the Glossary to find out more about these rights:
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Since we are committed to protecting your privacy as set forth in this Policy, if you think we are not in compliance with our Policy, or if you have any question or if you wish to take any other action concerning this Policy or your Personal Information, we encourage you to contact us at email@example.com or call us at +1 213 683 8863 and ask for Scott Martin. We will investigate your complaint, take appropriate action and report back to you within 45 days.
If the Personal Information in question was transferred from the EU to the United States, and you are not satisfied with our response, Oblong Industries Inc. has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the EU-US Privacy Shield Principles. A resident of the European Union (EU) whose enquiry has not been satisfactorily addressed may contact either the EU DPAs panel at ec-dppanel-secr’ ec.europa.eu or individual EU DPAs using the information provided at https://ec.europa.eu/info/law/law-topic/data-protection_en to resolve disputes pursuant to the EU-US Privacy Shield Principles.
Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
The services of the EU DPAs panel are provided at no cost to you.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Data Privacy Manager. Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply With A Legal Or Regulatory Obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties Other companies in Oblong acting as joint controllers or processors and who are based in the U.S. or the E.U. and provide IT, HR, system administration services, Products and services, and company reporting. External Third Parties
You have the right to: