Wirtualus Private Policy

Wirtualus Privacy Policy

This Privacy Policy 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 Wirtualus[1], including Wirtualus’s website(s) and its events, chats, phone calls, meetings, conferences, webinars, and messaging platform (i.e., Wirtualus Products).

What Personal Data Do We Receive?

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

  • Account Information: Information associated with an account that licenses Wirtualus Products, which may include administrator name, contact information, account ID, billing information, and account plan information.
  • Profile and Participant Information: Information associated with the Wirtualus profile of a user who uses Wirtualus Products under a licensed account or that is provided by an unlicensed participant joining a meeting, which may include name, display name, picture, email address, phone number, job information, stated locale, user ID, or other information provided by the user or their account owner.
  • Contacts and Calendar Integrations: Contact information added by accounts or their users to create contact lists on Wirtualus Products, which may include contact information a user integrates from a third-party app.
  • Settings: Information associated with the preferences and settings on a Wirtualus account or user profile, which may include audio and video settings, recording file location, screen sharing settings, other settings, and configuration information.
  • Registration Information: Information people provide when registering for a Wirtualus meeting, webinar, or recording, which may include name, contact information, responses to registration questions, and other registration information requested by the host.
  • Device Information: Information about the computers, phones, and other devices people use when interacting with Wirtualus Products, which may include information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
  • Meeting, Webinar, and Messaging Content and Context: Content generated in meetings, webinars, or messages that are hosted on Wirtualus Products, which may include audio, video, in-meeting messages, chat messaging content, transcriptions, written feedback, responses to polls, and Q&A, files, as well as related contexts, such as invitation details, meeting or chat name, or meeting agenda. Content may contain your voice and image, depending on the account owner’s settings, what you choose to share, your settings, and what you do on Wirtualus Products.
  • Product and Website Usage: Information about how people and their devices interact with Wirtualus Products, such as: when participants join and leave a meeting; whether participants sent messages and who they message with; performance data; mouse movements, clicks, keystrokes, or actions (such as mute/unmute or video on/off), and other user inputs that may help Wirtualus to understand feature usage, improve product design, and suggest features; which third-party apps users add to a meeting or other Product and what information and actions the app is authorized to access and perform; use of third-party apps and the Wirtualus App Marketplace; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with Wirtualus’s website(s), including what pages they accessed, their interaction with the website features, and whether or not they signed up for a Wirtualus Product.
  • Communications with Wirtualus: Information about your communications with Wirtualus, including relating to support questions, your account, and other inquiries.
  • Information from Partners: Wirtualus may obtain information about account owners and their users from third-party companies, such as market data enrichment services, including information about an account owner’s company size or industry, contact information, or activity of certain enterprise domains. Wirtualus may also obtain information from third-party advertising partners who deliver ads displayed on Wirtualus Products, such as whether you clicked on an ad they showed you.

How Do We Use Personal Data?

Wirtualus employees do not access meetings, webinars, or messaging content (specifically, audio, video, files, and messages) unless directed by an account owner or as required for legal, safety, or security reasons, as discussed below. Wirtualus uses personal data to conduct the following activities:

  • Provide Wirtualus Products and Services: To provide Products, features, and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, including customizing Wirtualus Product features and recommendations for accounts or their users. Wirtualus also uses personal data, including contact information, to route invitations and messages to recipients when people send invitations and messages using Wirtualus Products. This may also include using personal data for customer support, which may include accessing audio, video, files, and messages at the direction of the account owner or their users. We also use personal data to manage our relationships and contracts with account owners, including billing, compliance with contractual obligations, and related administration.
  • Storage: All collected information is securely and safely stored. The collected information is used only by us and will not be transferred to a third party without your prior consent.
  • We use encrypted technology for storing and transmitting your information to make your interaction with us safe and dependable. In case your information gets hacked, we will let you know as soon as practically possible.
  • Payment Information: We do not collect, use or retain any financial information, i.e., credit/debit card information, during and for the payment of any Wirtualus product/service. Your financial transactions are independently handled by Stripe, Square, or Paypal. Your website or at-our-site payment(s) are powered by Stripe, Square, or Paypal, which have a good international reputation for payment security and service.
  • We do not collect and store your information unless it is essential for us to provide a good service.
  • Product Research and Development: To develop, test, and improve Wirtualus Products, including, for example, content-related features (such as background filters), and to troubleshoot products and features.
  • Marketing, Promotions, and Third-Party Advertising: To permit Wirtualus and/or its third-party marketing partners to market, advertise, and promote Wirtualus Products, features, and services, including based on your product usage, the information we receive from third-party partners, or if you visit our website(s), information about how and when you visit, and your interactions with them. We may also use cookies or similar technology, including from third-party advertising partners, to show you ads within Wirtualus Products about products, services, or causes from third parties. Wirtualus does NOT use meeting, webinar, or messaging content (specifically, audio, video, files, and messages) for any marketing, promotions, or third-party advertising purposes.
  • Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, detect, investigate, and prevent malicious conduct or unsafe experiences, address security threats, protect public safety, and secure Wirtualus Products.
  • Communicate with You: We may use personal data (including contact information) to communicate with you about Wirtualus Products, features, and services, including product updates, your account, and changes to our policies and terms. We also use your information to respond to you when you contact us[2].
  • Legal Reasons: To comply with applicable law or respond to valid legal processes, 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.

Wirtualus may use advanced tools to automatically scan content such as virtual backgrounds, profile images, and files uploaded or exchanged through chat for the purpose of detecting and preventing violations of our terms or policies and illegal or other harmful activity, and its employees may investigate such content where required for legal, safety, or security reasons.

How Do We Share Personal Data?

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

  • Resellers: If an account owner licensed or purchased Wirtualus Products from a third-party reseller of Wirtualus Products, the reseller may be able to access personal data and content for users, including meetings, webinars, and messages hosted by the account owner.
  • Vendors: Wirtualus may work with third-party service providers to provide, support, and improve Wirtualus Products and technical infrastructure and business services. Wirtualus may also work with third-party service providers to provide advertisements and business analytics regarding Wirtualus Products. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Wirtualus or as required by law.
  • For Legal Reasons: Wirtualus may share personal data as needed to (1) comply with applicable law or respond to, investigate, or participate in valid legal processes 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.
  • Marketing, Advertising, and Analytics Partners: Wirtualus may use third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using Wirtualus Products and our website; to provide advertising and marketing for Wirtualus Products, including targeted advertising based on your use of our website; and to show you third-party advertising within Wirtualus Products. These third-party partners may receive information about your activities on Wirtualus’s website through third-party cookies placed on Wirtualus’s website. If applicable, you may be able to opt-out of our use of third-party cookies that share data with these partners by visiting our cookie management tool. Where required by law, Wirtualus will first obtain your consent before engaging in the marketing or advertising activities described.
  • Corporate Affiliates: Wirtualus may share personal information with corporate affiliates, such as TaaCam Inc., to provide integrated and consistent experiences across Wirtualus Products (such as enabling a user to integrate a Wirtualus Phone call into a meeting) to detect, investigate, and prevent fraud, abuse, and threats to public safety.
  • 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 Wirtualus’s business or assets, including in connection with a bankruptcy or similar proceedings.

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

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

  • Account Owner: An account owner is an organization or individual that signs up for a Wirtualus account. Typically, an account owner designates one or more people (called an “administrator”) to manage their account and can grant privileges to users on the account. Depending on their license with Wirtualus, the account owner may authorize additional users on their account, and the account owner may create and/or access the profile information for all users on their account. The account owner and their users can invite others (including guests not on their account) to meetings or webinars hosted on their account. Wirtualus gives account owners controls and features that they can use to determine whether certain types of content, such as recordings or out-of-meeting messages, can be created or sent and what third-party apps can be used for meetings and webinars hosted on their account. Depending on their settings, account owners and the people they designate can access personal data for people who join meetings and webinars on their account or send messages to users on their account. Specifically, account owners may have access to:
    • Account Usage:
      • Product Usage:  Information about how people and their devices interact with their account, which may include who sent messages to their users in chat, email addresses, IP addresses, device information, and other information about who joined meetings or webinars on their account, whether users viewed or downloaded a recording, how long people participated in their meetings, the time a message was sent, information about Wirtualus Phone integrations, and other usage information and feedback metrics.
      • Participant List:  Information about the participants in a Wirtualus meeting, webinar, or chat, which may include name, display name, email address, phone number, and the participant or user ID.
    • Registration Information: Information provided during registration for a webinar, meeting, or recording hosted by the account.
    • Wirtualus Team Chat Out-of-Meeting Messages: If this feature is available and enabled on their account, account owners can see information about who sent and received out-of-meeting messages to users on their account, along with information about the message (for example, date and time, and the number of participants). Depending on their settings, account owners also can see sender and receiver information and other messaging data, along with the content of messages sent to and from users on their accounts.
    • In-Meeting/Webinar Messages:  Depending on their settings, account owners can see sender and receiver information, along with the content of messages sent to and from users on their account, in the following circumstances:
      • Messages sent to Everyone in a meeting that is recorded
      • Messages sent to panelists in a webinar that is recorded
      • Direct messages if the account owner has enabled archiving
    • Recordings: Account owners can watch the content of recordings of meetings and webinars hosted on their accounts. They can also view a transcript of the meeting audio if enabled.
    • Polling, Q&A, and Feedback:  Account owners can see information about who provided responses to their polls, Q&A, or post-meeting or webinar feedback requests, including name and contact information, together with the responses or feedback unless responses are submitted anonymously.
  • Meeting Hosts and Participants:  Hosts and other participants in a meeting may be able to see your email, display name, and profile picture. Meeting hosts and participants can also see and (depending on the account owner’s settings) record or save meeting content, audio transcripts, messages sent to Everyone or to them directly, and files, whiteboards, or other information shared during a meeting. Hosts may also be able to see responses to Q&A and polls generated during the meeting.
  • Webinar Panelists and Attendees:  Only panelists may be visible to attendees during a webinar, but attendees who agree to unmute can be heard by other attendees. If an attendee agrees to become a panelist during a webinar, they may be visible to other attendees, depending on settings. Panelists and attendees may be able to see the name of a participant who asks a question during a Q&A, along with their question, unless the participant submits the question anonymously.
  • Livestreams:  Meeting and webinar hosts can choose to live stream to a third-party site or service, which means anyone with access to the live stream will be able to see the meeting or webinar.
  • Third-Party Apps and Integrations:
    • Account owners may choose to add third-party apps to their accounts and the Wirtualus products they use. They can also control whether their users can add and use specific third-party apps, including in meetings, webinars, and chats hosted on their accounts. Depending on their settings, account owners and their users and guests can share your personal data and content with third-party apps and integrations they approve, which may include all of the personal data available to account owners, hosts, and participants listed above, such as account information, profile and contact information, registration information, participants list, settings, content, product usage, and device information.
    • Other participants in the meeting may be able to see the third-party app that you are using in a meeting if the third-party app is receiving real-time features and information from the meeting.
    • Third-party developers may also integrate or embed Wirtualus meetings into their website or app experiences or build versions of Wirtualus that enable access to Wirtualus Products from a third-party app.
    • Personal information shared by account owners and users with third-party apps and integrations is collected and processed in accordance with the app developers’ terms and privacy policies, not Wirtualus’s.

Privacy Rights and Choices

If you are in the European Economic Area (EEA), Switzerland, the UK, or a resident of California, please refer to the 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 Wirtualus, please contact us. 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. In some Wirtualus products, an account owner or a user under a licensed account may also take steps to affect your personal data by visiting your account and modifying your personal data directly.

Retention

We retain personal data for as long as required to engage in the uses described in this Privacy Statement unless a longer retention period is required by applicable law. Subject to this policy, once a user cancels their account, all their personal information will be completely removed from our server and database.

The criteria used to determine our retention periods include the following:

  • The length of time we have an ongoing relationship with you and provide Wirtualus Products to you (for example, for as long as you have an account with us or keep using our Products);
  • Whether account owners modify or their users delete information through their accounts;
  • Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).

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 the 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).

If you have any other questions about our use of your personal data or need assistance in exercising your privacy rights, please contact us. Please note that we may request you 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 Wirtualus 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 Wirtualus Products, features and services to account owners, their users, and those they invite to join meetings and webinars 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.
  • 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;
  • To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
  • As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the Products (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our Products and troubleshoot products and features; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and Products, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the Products; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.

International Data Transfers

Wirtualus may be used by the users globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where Wirtualus or its service providers have customers or facilities – including in countries where meeting participants or account owners hosting meetings or webinars that you participate in or receiving messages that you send are based.

Therefore, by using Wirtualus 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 Canada, where we are established, as well as in other countries outside of the EEA, Switzerland, USA, and the UK. Such countries may have data protection rules that are different and less protective than those of your country. We adhere to and comply with Canadian privacy laws. As of September 12, 2022, the European Commission has recognized Canada as providing adequate protection and safeguards necessary for protecting your personal information.

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 that 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.

Changes to This Privacy Statement

We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data and will post the updated Privacy Statement on our website, with a “Last Updated” date at the top. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review it before you choose to continue using our Products.

[1] Wirtualus is a trademark of Taacam Inc., which is a corporation incorporated under the laws of Canada. Taacam’s agents, owners, officers, affiliates, volunteers, participants, employees, and all other persons or entities acting in any capacity on their behalf are hereinafter collectively referred to as Wirtualus. 
[2] You may contact us by filling out an online form under the tab “Contact Us” at our website wirtualus.com. You may also contact us by mailing us at Wirtualus, 2351 Royal Windsor Drive, Suite 206, Mississauga, Ontario, Canada, L5J 4S7.