Omnivor Studio Beta Privacy Statement 

Last updated: July 8, 2022

This Privacy Statement describes the personal data we collect and/or process (which may include collecting, organizing, structuring, storing, using, or disclosing) to provide products and services offered directly by Omnivor, Inc. (“Omnivor”), including Omnivor’s Oculus client application (“Omnivor Studio Beta”).

What Personal Data Do We Receive?

Personal data is any information from or about an identified or identifiable person, including information that Omnivor can associate with an individual person. We may collect, or process on behalf of our customers, the following categories of personal data when you use or interact with Omnivor Products:

• Participant Information: a licensed or unlicensed participant joining a meeting, which may include display name.
• Meeting Entry Information: Information people provide when joining an Omnivor meeting, broadcast or recording, which may include display name, meeting room name.
• Device Information: Information about the computers, phones, and other devices people use when interacting with Omnivor Products, which may include information about the MAC address and/or IP address.
• Meeting, Broadcast, and Messaging Content and Context: Content generated in meetings, broadcasts, or messages that are hosted on Omnivor Products, which may include audio data
• Product Usage: Information about how people and their devices interact with Omnivor Products, interactions such as when participants join and leave a meeting, when you mute/unmute the microphone.
• Communications with Omnivor: Information about your communications with Omnivor, including relating to support questions, your account, and other inquiries.
• Environmental, Dimensions and Movement Data: We use information provided by your Oculus account and/or device about your audio and spatial environment, physical movements, and dimensions when you use an XR device. For example, when you set up the Oculus Guardian System to alert you when you approach a boundary, we receive information about the play area that you have defined so that you can easily remain in the Oculus Guardian during the Omnivor meeting experience.

How Do We Use Personal Data?

Omnivor employees do not access Personal data unless directed by a meeting participant, or as required for legal, safety, or security reasons, as discussed below. Omnivor uses personal data to conduct the following activities:

• Provide Omnivor Products and Services: To provide Products, features, and services to users, and those they invite to join meetings and broadcasts.
• Legal Reasons: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Terms of Service or policies.

How is Personal Data shared?

Omnivor provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):

• For Legal Reasons: Omnivor may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers’ rights and property; and (6) resolve disputes and enforce agreements.
• Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Omnivor’s business or assets, including in connection with bankruptcy or similar proceedings.

Who Can See and Share My Personal Data When I Use Omnivor?

When you send messages or join meetings on Omnivor, other people and organizations, including third parties outside the meeting, may be able to see content and information that you share:

• Meeting Hosts and Participants:  Hosts and other participants in a meeting may be able to see your display name.  Meeting hosts and participants can also see and record meeting content or other information shared during a meeting.  

Privacy Rights and Choices

If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:

• Inform you of what personal data we have about you that is under our control;
• Amend or correct such personal data or any previous privacy preferences you selected, or direct you to applicable tools; and/or
• Delete such personal data or direct you to applicable tools.

In order to exercise any of your rights as to personal data controlled by Omnivor, please privacy@omnivor.io. Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others. As an account owner or a user under a licensed account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.

Security

We value your trust in providing us your Personal Data, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Children

Omnivor’s product do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

How to Contact Us

To exercise your rights, please click here. If you have any privacy-related questions or comments related to this Privacy Statement, please send an email to privacy@omnivor.io

Right to Know and Delete

You have the right to delete the personal information we have collected from you and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

To exercise any of these rights, contact us at privacy@omnivor.io. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

European Data Protection Specific Information

Data Subjects Rights

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

• Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
• Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
• Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
• Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
• Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

To exercise your rights, please click here. If you have any other questions about our use of your personal data, please send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Omnivor processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

• As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Omnivor Products, features and services to account owners, their users, and those they invite to join meetings and broadcasts hosted on their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all Products, features, and services;
• Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool, available Cookies Settings;
• As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;

International Data Transfers

Omnivor operates globally, which means personal data may be transferred and processed outside of the country or region where it was initially collected where Omnivor or its service providers have customers or facilities – including in countries where meeting participants are based.

Therefore, by using Omnivor Products or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as transferred to other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.

We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. Please contact us if you would like further information in that respect.

California Privacy Rights

California Consumer Privacy Act

Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:

• Access the categories and specific pieces of personal data Omnivor has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Omnivor has shared personal data;
• Delete personal data under certain circumstances

Omnivor will not discriminate against you for exercising any of these rights, which is further in line with your rights under the CCPA.

Under the CCPA, only you or an authorized agent may make a request related to your personal data.

California’s Shine the Light Law

California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

Changes to This Privacy Statement

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.