Dated 15 July 2021.
Like most website operators, Qumu collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Qumu’s purpose in collecting non-personally identifying information is to better understand how Qumu’s visitors use its website. From time to time, Qumu may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
Qumu also collects potentially personally-identifying information like Internet Protocol (IP) addresses. Qumu does not use such information to identify its visitors, however, and does not disclose such information, other than under the same circumstances that it uses and discloses personally-identifying information, as described below.
Gathering and Use of Personal Data
Certain visitors to Qumu’s websites choose to interact with Qumu in ways that require Qumu to gather personal data (as that term is defined in the General Data Protection Regulation (“GDPR”)). The amount and type of personal data that Qumu gathers depends on the nature of the interaction by you. Qumu typically collects information about visitors, including personal data, in order to provide and improve our Services and to support the advertising and marketing of such Services. For example, we ask visitors who register as Partners at www.qumu.com to provide their name, email address, and company address. In each case, Qumu collects such information only insofar as is necessary or appropriate to fulfil the purpose of the visitor’s interaction with Qumu. Qumu does not disclose personal data other than as described below, and visitors can always refuse to supply personal data, with the caveat that it may prevent them from engaging in certain website-related activities.
We collect certain information directly from you, such as when you fill out forms with a name or email address or when you otherwise engage with us, such as by phone, email or video-call. We collect other information, usually about devices, browsers, or locations, automatically. We may also collect information about you from other sources, such as licensing the temporary use of a targeted database of contacts who may be interested in our Services.
You have choices about whether you visit our sites, install our apps, or provide information to us. However, if you do not provide us with certain information, you may not be able to use some parts of our Services.
Information We Collect from You.
You provide us with information about yourself, including personal data, when you:
- Register or log in to your account;
- express an interest in obtaining additional information about our services; request customer support, use our “Contact Us” or similar features; register to use our websites; sign up for an event, webinar or contest;
- Create or edit your user profile;
- Download content from our websites such as marketing collateral and materials;
- Apply for roles or vacancies at Qumu;
- Contact customer support; and/or
- Comment on Qumu Webcasts.
Examples of the information you provide are: name, email address, mailing address, phone number and/or billing information.
If you take part in calls or video calls with one of our sales personnel, then we may record that call for internal training and quality control purposes. You will be informed about the recording at the time of the call. You do not have to take part in the recorded call and if you refuse to join it, you will be sent a separate link to a non-recorded call instead.
If you are applying for a vacancy or job at Qumu then we may (dependent on the location of the vacancy) also collect the following for the purposes of the recruitment process:
- Identity Data, which includes your title, first name, last name, maiden name, date of birth, gender, national insurance number (or equivalent in your country), nationality and other information relating to residency and citizenship which may be required to establish a right to work in a given country;
- Contact Data, which includes your home address, email address and telephone numbers, emergency contact details and contact details history;
- Historical Data, which includes educational history and credentials, employment history, skills and qualifications, and results from any other background and disclosure checks in countries where it is lawful to carry out such checks;
- Employment-related Data, which includes your current remuneration, pension and benefits, third party references (if taken) and interview and assessment feedback created either ourselves following an interview or assessment;
- Verification Data, which includes a copy of your driving licence, passport, identity card or another form of identification and referee details;
Where do we send your personal data to for storage or other specific purposes?
We, our third party data storage providers and/or the third parties to whom we may disclose your personal data, may store your personal data on a server overseas.
If we do transfer your personal data outside the UK/EEA, we will make sure that suitable safeguards are in place in accordance with applicable data protection legislation such as the GDPR, for example by using approved contractual agreements, unless certain exceptions apply, or where we are authorised to do so.
Qumu has implemented an intra-group data transfer agreement with the standard contractual clauses in place to govern the transfer and sharing of any personal data from Qumu’s entity in the United Kingdom to its affiliates in India and the United States of America.
We will provide you with further details of the safeguards that we have implemented if you would like to know what they are.
Information We Collect Automatically.
We automatically collect information from you and your devices when you use our Services, even when you visit our sites or apps without logging in.
The information we automatically collect includes:
- Device and usage Information. We collect information about how you use our Services and the computers or other devices, such as mobile phones or tablets, you use to access our Services. Some examples include:
- IP address;
- Precise geolocation information that you allow our apps to access (usually from your mobile device);
- Unique device identifiers and device attributes, like operating system and browser type;
- Usage data, such as: web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information;
- Tailored Advertising.
Information We Collect from Other Sources.
We may collect information about you from others, such as:
Third-Party Sources. Examples of third-party sources include marketers, partners, researchers, affiliates (like companies connected to Qumu), service providers, and others where they are legally allowed to share your information with us. For example, if you register for our Services on another website, the website may provide your information to us.
Use of personal data by Qumu
Qumu collects, uses, stores, and processes your personal data to provide our Services, to fix and improve them, to develop new Services, and to market our companies and their products and Services. Here are some examples of how we use the information we process:
- To provide you with information concerning our products and services;
- Marketing communications about third party products and services we think may be of interest to you;
- Provide you with our Services and products you request and collect payments;
- Choose and deliver content and tailored advertising;
- Create and review data about our users and how they use our Services;
- Test changes in our Services and develop new features and products;
- Fix problems you may have with our Services, including answering support questions and resolving disputes;
- Manage the Services platform including support systems and security;
- For internal training and quality control purposes;
- Prevent, investigate and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behaviour;
- Comply with legal obligations;
- Meet legal retention periods;
- If you have applied for a vacancy at Qumu, matching your details against job vacancies which we feel may be appropriate for you in order to assess your suitability for them; and
- Allowing you to submit your CV or apply for specific jobs or vacancies at Qumu.
Lawful Basis for Processing Your Information.
Qumu collects or uses information from you or others only where: i) we have your consent to do so; ii) where we need the information to perform a contract with you; or iii) where the processing is in our legitimate interests and is not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or may need the personal information to protect your vital interests or those of another person. For example, when we:
- Use names and email addresses for email marketing purposes, we do so with your consent (which you can withdraw at any time);
- Gather usage data and analyze it to improve our Services, we do so based on our legitimate interest in safeguarding and improving our Services;
- Provide notifications on important changes or the product and/or Services which may be tailored to specific customers, users, and other criteria; we do so based on our legitimate interest in to provide and improve our Services;
- We process personal data to perform our obligations under an agreement we have with you. For example, we use your personal data to make you a job offer or complete a contract of employment with you;
- Reviewing compliance with applicable usage terms: We process your personal data to review compliance with the applicable usage terms in our customer’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
- Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of our services the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our Service offerings;
- Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences;
- Recording our sales calls for internal training and quality control purposes. Please note we only do so with your consent;
- Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes; or
- Use information to create and manage an account, we need it in order to provide relevant Services to you or your organisation.
Who do we share your personal data with?
- Any of Qumu’s group companies;
- Pre-employment screening and background checking organisations;
- Individual’s referees if you are applying to work at Qumu;
- Individual’s past educators and employers and relevant education authorities if you are applying to work at Qumu;
- Individual’s professional bodies if you are applying to work at Qumu;
- Governmental and regulatory bodies such as such as tax and social security authorities if you are applying to work at Qumu;
- Third party recruitment management and applicant tracking system software for recruitment processes such as a Greenhouse Software, Inc.;
- External consultants, professional advisors and business associates;
- The service provider that records our sales calls;
- Outsourced IT and document storage providers including, but not limited to, Salesforce.com Inc in relation to the provision of our products and services to our customers only;
- Business partners who resell Qumu’s Services to their customers; and
- Software as a Service (SaaS) or IaaS providers and subcontractors solely in relation to the provision of our products and services to customers (including but not limited to: i) Zendesk, Inc. for customer support services; ii) DocuSign, Inc. for document execution purposes; iii) Oracle Netsuite for business management purposes including billing and invoicing); iv) Google LLC for the provision of our IaaS which underpins our cloud products; v) Gong.io Inc for recording sales calls; and vi) Salesforce.com Inc for the management of customer accounts on our CRM platform;
Retention of Personal Data
Qumu keeps your personal data for no longer than necessary for the purposes for which it is processed and originally collected. The length of time for which we retain personal data depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal data and limit active use of it. Qumu has specified data retention policies which govern various subsets of personal data dependent on the original purpose for collection.
After expiry of the applicable retention periods, your personal data will be deleted. If there is any data (which may include personal data) that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.
Qumu may collect statistics about the behaviour of visitors to its websites. For instance, Qumu may monitor www.qumu.com site and Qumu may display this information publicly or provide it to others. However, Qumu does not disclose personally-identifying information other than as described below.
Protection and Security of Personal Data
Qumu discloses personal data only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Qumu’s behalf or to provide services available at Qumu’s websites, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country. Qumu will not rent or sell personal data to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Qumu discloses personal data only when required to do so by law, or when Qumu believes in good faith that disclosure is reasonably necessary to protect the property or rights of Qumu, third parties or the public at large. If you are a registered user of a Qumu website and have supplied your email address, Qumu may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Qumu and our products. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Qumu takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of personal data including the use of industry leading physical, electronic, and managerial tools and technologies.
Qumu takes appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the personal data we process or use.
While we follow generally accepted standards to protect personal data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions.
Cookies and Other Technologies
If you want to disable cookies, check with your browser provider to find out how to disable cookies. Please note that certain features of the Qumu website and Qumu Services including the Qumu Cloud Platform will not be available if certain essential cookies are disabled.
As is true of most websites, we gather some information automatically and store it in log files. This information may include IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), user ID, browser type and language, Internet service provider (ISP), referring and exit pages, operating system, date/time stamp, clickstream data and other technical information.
We use this information to understand and analyze trends, to administer the site, to learn about user behaviour on the site, and to gather demographic information about our user base as a whole. Qumu may use this information in marketing and advertising services.
In some of our email messages, we may use a “click-through URL” linked to content on the Qumu website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
The Qumu apps only collect personal data for the purposes of the provision of Services to you in the same manner that our products and services collect personal data. Our apps operated in the same manner as our other products and services and process personal data in exactly the same way as our other products (including but not limited to Qumu Cloud Platform and Qumu’s Video Control Center (“VCC”).
The Qumu app will store comments and ratings entered by the user and for users of VCC, will track the view count of all videos residing on the VCC server.
You may have certain rights related to your personal data, subject to local data protection laws. These rights may include:
- You have a right to request access to and a copy of your personal data;
- You also have a right to correct your personal data. In certain situations, you can ask that we erase or stop using your information (and object to use of your personal data) or export your data. You also have a right to restriction under applicable legislation;
- Where we rely on your consent to process your personal data, you have the right to decline consent and/or if provided, to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your information for direct marketing purposes;
- You have a right to raise questions or complaints with your local data protection authority at any time; and
- You may have the right to receive information about the financial incentives that we offer to you. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Please note your rights and choices vary depending upon your location. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the product and Services to you. If you ask us to delete it, you may no longer be able to access or use our product and Services. We will take reasonable steps to verify your identity.
If you wish to exercise these rights, please contact us at email@example.com.
Transfers to the U.S. and Third Countries. You understand and acknowledge that Qumu may transfer your personal data outside of your jurisdiction for further processing in relation to or as required for the provision of our Services to you. Any such transfers will be made by Qumu in accordance with its Intra Group Data Transfer Agreement and in accordance with the requirements under GDPR and other applicable data protection legislation.
Your California Privacy Rights
This section provides additional details about the personal information (as the term is defined in the CCPA) we collect about California consumers and the rights afforded to them under the CCPA.
For more details about the personal information we have collected, including the categories of sources, please see the ‘Gathering and Use of Personal Data’ section above. We collect this information for the business and commercial purposes described in the ‘Use of personal data by Qumu’ section above. We share this information with the third parties described in the ‘Who do we share your personal data with’ section above. Qumu does not sell (as the term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out if (in the unlikely scenario) Qumu chose to change its position on the sale of the personal information we collect).
In addition to the foregoing, the CCPA requires that we detail the categories of personal information that we share or disclose for certain “business purposes,” such as disclosures to service providers that assist us with securing our services or marketing our products. We disclose the following categories of personal information for our business purposes:
- Commercial information;
- Internet activity information;
- Financial information;
- Professional and employment-related information;
- Education information; and
- Inferences drawn from any of the above information categories.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at firstname.lastname@example.org. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorised agent to exercise these rights on their behalf.
If you are a California resident under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our website(s). Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another user.
Our Services are not designed for and are not marketed to people under the age of 16 (“minors”). We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use our Services. If you are a minor, please do not use our Services or send us your information. We delete information that we learn is collected from a minor without verified parental consent. Please contact us if you believe we might have information from or about a minor.