Key Definitions
“Policy” refers to this Privacy Policy.
“Rubiktalk”, “we”, “us” and/or “our” refers to Rubiktalk Network, Inc. and any of our
corporate affiliates.
“Services” refers to, individually and collectively, our video conferencing,
collaboration, and related services, support, professional services, websites (including
www.rubiktalk.com), and end user software on any platform. The Services are not intended
for personal or consumer use.
“you” and “your” refer to individuals using or otherwise interacting with our Services.
“information” refers to data about you and your use of Services, that may be retained in
electronic or paper format, and may include personal information as defined by the
California Consumer Privacy Act of 2018 and personal data as defined by the General Data
Protection Regulation and/or as defined by Section 2(1) of the Singapore Personal Data
Protection Act 2012, as applicable.
Reasons We Process Your Information
We may process your information if:
· You, or the company you work for, or the company which provides you access to the
Services, are a customer or a supplier of ours.
· You, or the company you work for, or the company which provides you access to the
Services, use our Services.
· You work for one of our suppliers, resellers, or other business partners.
· You work for someone who uses our products or services.
· You, or the company you work for, may be a candidate for our advertising or marketing
efforts.
· You communicate with us, or we receive a communication from or regarding you, through
our Services or other communication.
· You request information about us, our business, and/or the Services.
Information We Collect
We collect information from you when you voluntarily provide that information to us.
This may occur, for example, when you register for an account, modify your profile and
preferences, complete and submit a form through the Services, provide payment
information to complete a transaction, contact us with inquiries, participate in an
event or promotion, or respond to one of our surveys.
We collect information from you when you voluntarily provide that information as part of
your use of the Services. Examples of this include: when you submit a technical support
request, participate in a chat function as part of a Rubiktalk Meeting or Event, or
request that a Meeting or Event that you are hosting be recorded using the Services.
We collect information about you from third parties including other Service users,
third-party service providers which you have linked to your use of our Services
(including social media accounts, single-sign-on services, and scheduling applications),
resellers, distributors, your employer, your administrator, publicly available sources,
data enrichment vendors, payment and delivery service vendors, advertising networks,
analytics providers, and our business partners. The information which we receive from
third parties depends on what policies that third party follows and our and your
respective relationships with the third party.
Personal data relating to you that we process may include:
· Your name.
· Who you work for, and your job function or department.
· Your address, phone number, email address or other contact details (these details may
relate to your work or to you personally, depending on the nature of our relationship
with you or the company that you work for).
· Information relating to transactions with us involving you or the company you work for
(for example, details of goods or services that we have supplied to, or obtained from,
you or the person you work for).
· Information relating to you which it is necessary for us to process in order to enter
into or perform a contract with you or the company you work for (for example, right to
work information and information obtained from credit references agencies where this is
necessary to enable us to carry out appropriate checks in relation to contracts with you
or someone else that you work for or are otherwise related to).
· Certain device and connection information when you use our Services, including the
type of device or endpoint (e.g. browser type and version, browser plug-in types and
versions, operating system and platform) you are using to access the Services, IP
address, geolocation data, duration of Service use, and connection quality. The amount
of information may vary depending on the nature of the equipment you use to access the
Services and may also include non-identifiable or aggregated information to conduct
research on customer demographics, interests and behavior.
· Information about your visit, including the full Uniform Resource Locators (URL),
clickstream to, through and from our website (including date and time), products you
viewed or searched for, page response times, download errors, length of visits to
certain pages, page interaction information (such as scrolling, clicks, and
mouse-overs), methods used to browse away from the page, and any phone number used to
call our customer service number or social media handle used to connect with our
customer service team.
· When you use our Services for telehealth, medical data shared in the context of a
patient visit.
How We Use Information
How we use the information is shaped by the source of the information, the type of
Services you use, and any privacy preferences that you have specified to us. Below are
the specific purposes for which we use the information we collect or receive about you.
To take steps in order to enter into any contract or carry out our obligations arising
from any contract entered into between Rubiktalk and you, the company you work for, or
the company which provides you access to the services, including:
· To provide the Services, related customer support, and supporting functions. We use
the information you provide to make the Services available to you in a personalized
manner which optimizes your experience. This includes providing supporting functions
like using the information you provide in your profile to identify you to other Service
users, performing billing operations, identifying whether you are complying with your
license grant for the Services, detecting fraudulent activity or other improper uses of
the Services, and verifying your identity.
· To communicate with you about the Service. We may reach out to you using the
information you have provided via email, telephone, in-window messaging, through the
software for the Service, on the website, and otherwise as appropriate for transactional
communications such a change of password confirmation, billing receipts, product
updates, and responding to customer support requests. We also send you information as a
new user for a Service to better help you use the Service. These communications are part
of the Services and, in many cases, you cannot opt out of receiving them.
· For engagement communications – We may communicate with you or the company you work
for to better help you engage with our Services and maximize your use of the Services.
This includes user training, letting you know about newly available features of your
Services and seeking quality-related and engagement feedback.
· For promotional communications - We may communicate with you or the company you work
for to better inform you of the Services available to you. This includes letting you
know about potential new Services, newsletters, events, and related Services we offer
that we believe will be of interest to you. If we do so, and if required by applicable
law, each communication we send you will contain instructions permitting you to
“opt-out” of receiving future communications. You can also object to further marketing
at any time by sending us an email at [email protected].
· To better understand our users, and improve our Services accordingly (when our
legitimate interest in doing so is not overridden by your personal rights that may
apply). We may use such information to track, for example, the total number of visitors
to our website, the number of visitors to each page of our website, the domain names of
your Internet service provider, general geographic location, and how you use and
interact with the Services. We can use this information to identify trends, usage
patterns, service quality interruptions, undiscovered bugs in the Services, and better
optimize your Services experience in the future. Also, in an ongoing effort to better
understand and serve the users of the Services, Rubiktalk often conducts research on its
customer demographics, interests and behavior based on the information on an aggregate
basis.
· For uses as required by law or to otherwise protect our legal rights. There may be
situations where we believe it is required by law or necessary to protect our legal
rights or the interests of others to use the information in connection with pending or
active litigation, regulatory compliance efforts, audits, and disclosures in connection
with the acquisition, merger or sale of a business.
· For other uses with your consent. If Rubiktalk intends on using any information in any
manner that is not consistent with this Policy, you will be informed of such anticipated
use and be given an opportunity to provide your consent for such use and/or discontinue
your use of the Services.
The Services are not intended to be used for profiling, automated processing, personal
data relating to criminal convictions or offenses, other systematic monitoring of a
public area, or any other operations which may result in a high risk of significantly
affecting you or your legal rights.
If you are an EU resident, the following terms also apply:
Rubiktalk processes your personal data when we have an adequate legal basis for doing
so. This means we collect and use your personal data where:
· We need it to provide you the Services;
· It satisfies a legitimate interest (which is not overridden by your data protection
interests);
· You give us consent to use the personal data for a specific purpose; or
· We need to process your personal data to comply with a legal or contractual
obligation.
If you have consented to our use of personal data for a specific purpose, you have the
right to change your mind at any time, and the procedures for communicating that
revocation of consent are detailed below. Any such decision will not affect any
processing that has already occurred. Where you withdraw your consent, but we are using
your information because we or a third party (e.g. your employer) have a legitimate
interest in doing so, or we have different legal basis for using your information (for
example, fulfilling a contract with you), we may continue to process your information,
subject to your rights to access and control your information. However, this may mean
your access to the Services will be limited or suspended, and your accounts may be
terminated, as applicable.
How Long We Keep Information
Rubiktalk will generally retain information for so long as you are an active user of the
Services. Most information is available for you to modify or delete on a self-service
basis. For more extensive requests, you may make a request per the guidelines below.
Metadata and/or connection analytics following use of the Services is retained and made
available for a host user and/or an administrative user to review during an
administrator-set retention period. Information that is older than the pre-set retention
period will be obfuscated and archived.
Following the end of your subscription to the Services, your information will generally
be deleted or obfuscated within six months of the end of your subscription. If the
Services are made available to you through an organization (e.g., your employer), we
retain your information per your organization’s instructions. For more information, see
the “Additional Information Regarding Processing Information of Our Customers” section
below.
Some information may be retained to comply with our legal obligations, to resolve
disputes, to enforce our agreements, to support business operations, for marketing
purposes according to your registered preferences if you have opted to receive such
communication, information derived from cookies, and information required to continue to
develop and improve our Services.
Where we retain information after your use of the Service, we take reasonable steps to
make that data is not personally identifiable beyond the extent required to comply with
our legal and regulatory obligations.
How We Protect Information
Rubiktalk takes appropriate physical, technical, and organizational measures to protect
your personal information from loss, misuse, unauthorized access or disclosure,
alteration, and destruction. We utilize a combination of industry-standard security
technologies, procedures, and organizational measures to help protect your information
from unauthorized access, use or disclosure.
Who We Share Information With
There are certain circumstances in which we may share your information with certain
third-parties. Any access by a third party to the information is managed by Rubiktalk,
and the third parties are vetted based in part on their ability to protect information.
International movement of information consistent with this sharing is discussed in the
“How We Move Information” section below.
As part of your use of the Service, you may share information with other users of the
Service. Those users of the Service may be located in nearly any location around the
world, may be communicating with Third Party Sites (as defined below) while using the
Services, and may be limited by law or by an agreement with us about their use of
information you share. However, this Policy only addresses our use of the information.
We may share information with employees, contractors, agents, or consultants with a
strict need-to-know under appropriate confidentiality obligations.
We may share information with third parties which provide business-related functions on
behalf of Rubiktalk, including:
· Our business partners, customers, suppliers, service providers, vendors, and
sub-contractors for the performance of any contract we enter into or other dealings we
have in the normal course of business with you or the company that you work for or the
company that provides you access to the Services. Some examples of such business-related
functions for which we may share information may include data hosting, analyzing data,
providing marketing assistance, providing customer service and technical support,
processing orders, sending communications to you on our behalf or at our direction, user
engagement and onboarding, soliciting feedback regarding the Services, facilitating
invoicing and/or payments, and others in our reasonable discretion;
· Our auditors, legal advisors and other professional advisors or service providers;
· Credit reference agencies for the purpose of assessing your credit score where this is
in the context of us entering into a contract with you or the person that you work for;
· We may share information with our authorized distributors and resellers if you have
purchased your license to the Services through a party other than Rubiktalk to enable
those distributors and resellers to fulfill their business obligations to you; and
· We may share information obtained via our Services with analytics and search engine
providers that assist us in the improvement and optimization of our site and subject to
the cookie section of this policy.
When we employ another company to perform services of this nature, we only provide such
company the right to use such information that is reasonably necessary to perform their
specific function.
We may share information with other third parties, including when you provide consent
for a specific situation. If Rubiktalk intends on sharing any information in a manner
other than as described above using any personal data in any manner that is not
compatible with this Privacy Policy, and we do not have a legal basis for sharing that
information without your consent, you will be informed of such anticipated use and be
given an opportunity to provide your consent for such use.
We may share information with third parties if we reasonably believe that such action is
necessary to:
· comply with a legal obligation, regulation, or government request,
· enforce our policies and agreements,
· protect and defend the rights, property, and safety of Rubiktalk, our customers,
users, resellers, or others, or
· act in urgent circumstances to protect the personal safety of users of the Services or
the public.
This includes exchanging information with other companies and organizations for the
purposes of fraud protection and credit risk reduction and to prevent cybercrime.
We may share information with our subsidiaries and corporate affiliates including
Verizon who support our processing of personal data under this Policy.
As we develop our business, we might sell or buy businesses or assets. In the event of a
corporate sale, acquisition, merger, reorganization, dissolution or similar event,
information may be part of the transferred assets. You will be notified via email and/or
other means with any news of a transaction and any choices you may have regarding your
information.
For purposes of the California Consumer Privacy Act, we do not “sell” your personal
information.
How We Transfer Information
We provide our Services primarily from the United States, where we are based. Your use
of the Services requires the movement of information to our locations and the locations
of our third-party service providers. Your use of the Services may require that our
international affiliates and subsidiaries in countries including Australia, India,
Netherlands, Singapore, and United Kingdom have access to the information.
If you are an EU resident:
Your information may be transferred to, and stored at, a destination outside the
European Economic Area ("EEA") that may not be subject to equivalent data protection
law. It may be processed by staff situated outside the EEA who work for us or for one of
our suppliers.
We may transfer your personal information outside the EEA:
· In order to store it.
· In order to enable us to provide services to and fulfill our contract with you or the
company your work for or the company that provides you access to the Services. This
includes order fulfillment, processing of payment details, and the provision of support
services.
· Where we are legally required to do so.
· In order to facilitate the operation of our group of businesses, where it is in our
legitimate interests and we have concluded these are not overridden by your rights.
· Where we have your consent to do so.
When we share information about you within Rubiktalk and with entities in countries with
local laws which may differ from yours, we safeguard the transfer of information we
collect from the European Economic Area and Switzerland to the United States. We are no
longer participating in the EU-U.S Privacy Shield, nor the Swiss-U.S. Privacy Shield,
but we are safeguarding transfers through other means such as standard contractual data
protection clauses, which have been approved by the European Commission and Switzerland,
and/or the Verizon Binding Corporate Rules, as applicable. In some cases we may use
other appropriate legal mechanisms to safeguard the transfer. Please see our Trust
Center for further information about standard contractual data protection clauses.
If you are an Australian national, where Rubiktalk discloses personal information (as
defined by the Australian Privacy Act) of Australian nationals with third parties
outside of Australia, Rubiktalk will operate in a manner materially consistent with the
applicable Australian Privacy Principles and seek to ensure that the third party
recipient holds and uses the personal information consistently with the applicable
Australian Privacy Principle and other applicable privacy laws.
Additional Information Regarding Processing Information of Our Customers
Where we provide access to the Services to you under contract with an organization (for
example your employer), or if you use an email address provided by an organization to
access the Services, that organization may act as the controller of the information.
Your use of the Services may be subject to that organization's policies. Each
organization may appoint administrative users of the Services. An administrator may have
the ability to access, modify, and/or delete certain information that you have provided,
give information to Third Party Sites (as defined below), and restrict your access to
the Services and information in whole or in part.
In this situation, Rubiktalk is the processor, rather than the controller, of your
information. Where we are the processor, we do not control why or how your information
is used, and you will need to contact your relevant controller (e.g. your employer
and/or the company which provides you access to the Services) to find out about your
data protection rights and responsibilities. All questions about your organization’s
policies and administrative user access rights should be directed to your organization.
Privacy and Recordings
Video and audio from the video conferencing services may be recorded and saved via the
Services by the host account for the Service in which you are participating. We do not
and cannot control whether your use of the Services is being video recorded or audio
recorded, via the Services or a third-party technology. If you do not want to be
recorded during your use of the Services, you may inform your host of that decision
and/or decline to use the Services.
How You Can Access and Control Information
In accordance with applicable law, your ability to control the information may include
the right to:
· Request a record of information you have provided
· Request that information be corrected or removed
· Request that we restrict the processing of your personal data (while we verify or
investigate your concerns with this information, for example)
· Request that, to the extent reasonably possible, information be provided in a
structured and commonly used electronic format for portability and transfer
· Object to and/or opt-out of our use of your information, including the right to object
to marketing, in whole or in part, subject to certain exceptions prescribed by law.
You can exercise many of these abilities directly through the Services via your
Rubiktalk profile page. You may opt out of non-transactional emails through the email
notification center. For any issue that cannot be handled on a self-service basis,
please reach out to our Support team for assistance. You can also exercise the rights
listed above at any time by contacting us at [email protected]. In some instances, if
you access the Services under contract with an organization, we may be required to
direct your inquiries to an administrative user.
If you no longer want to use our Services, you may choose not to access our website or
video-conferencing services at any time and, as applicable, you will need to reach out
to our Support team or an administrative user to deactivate your account. If you are an
organizational user of the Services, you will need to arrange for an administrative user
to remove personal data associated with your account. Otherwise, personal data will be
deleted or obfuscated within 180 days of the deactivation of your account.
You may contact our Support team to ask us to stop accessing, storing, using and
otherwise processing your information where our legal basis for doing so relies on your
consent or is otherwise objectionable by law. Where you gave us consent to use your
information for a limited purpose, you can contact our Support team to withdraw that
consent, but this will not affect any processing already occurred. Where you withdraw
your consent, but we are also using your information under a different legal basis (for
example, fulfilling a contract with you), we may continue to process your information,
subject to your rights to access and control your information. Please note that we may
need to retain certain information to fulfill legal obligations, in accordance with our
record retention practices, or to complete transactions.
Additional Notes on Your Privacy
Rubiktalk does not knowingly collect information from children under the age of 13, and
our Services are not intended for use by minors (as defined in your relevant
jurisdiction). By using our Services, you confirm to us that you are not under the age
of 13 and/or not a minor.
If you are a minor, please do not submit any information through the Services. We
encourage parents and legal guardians to monitor their children’s Internet usage and to
help enforce our Privacy Policy by instructing their children never to provide
information via the Services without permission. If you have reason to believe that a
minor has provided information to Rubiktalk, please contact us and we will endeavor to
delete that information from our databases.
The Services may contain links, add-ins applications, social media widgets or other
access points that will take you and your information to other websites and resources on
the Internet that are not operated or controlled by Rubiktalk (“Third Party Sites”). The
policies and procedures we described here do not apply to the Third Party Sites. We have
no control over, are not responsible for, and do not endorse the information practices
of such third party websites and resources. Your access to and use of such third party
websites or resources, including your use of any content, information, data,
advertising, products, or other materials on or available through them, is solely at
your own risk and is subject to the terms and conditions of use and privacy policy(ies)
applicable to such Third Party Sites and related resources. Once you choose to be
directed to a Third Party Site, you should read the applicable privacy statement before
sharing any personal or other information. If you object to information about you being
shared with a Third Party Site, please disable any applications or plug-ins which
communicate with the Third Party Site or contact your administrator to do so.
Changes to this Policy
The Services and our business may change from time to time. As a result, at times it may
be necessary for Rubiktalk to make changes to this Policy. Rubiktalk reserves the right
to update or modify this Policy at any time and endeavor to give you the opportunity to
review the revised Policy before you choose to continue using our Services.
Please review this Policy periodically. Your continued use of the Services after any
changes or revisions to this Policy indicates that you have read and understood the
terms of such revised Policy.
This Policy shall not apply to any unsolicited information you provide to Rubiktalk
through this website or otherwise through the Services. This includes, but is not
limited to, any ideas for new products or modifications to existing products. All such
unsolicited information shall be deemed to be non-confidential. Rubiktalk shall be free
to reproduce, use, disclose, distribute and exploit such unsolicited information without
limitation or attribution. However, if such unsolicited information also includes
personal data, we will also determine whether we have a lawful basis for the collection
and use of that information prior to doing so.
How to Submit a Complaint/Dispute Resolution
If you have a complaint about Rubiktalk’ privacy practices, please write to us at the
address below. We will take reasonable endeavors to work with you to attempt to resolve
your complaint.
If you are an EU resident, and you have a request or concern about how we handle your
personal information, you can also contact your local supervisory authority.
If you are an Australian national, and you have a complaint about how we handle your
personal information, you can also contact the Office of the Australian Information
Commissioner, GPO Box 5218, Sydney NSW 2001, Australia, https://www.oaic.gov.au.
How to Contact Rubiktalk
If you have any questions about our Privacy Policy or the information practices of the
Services, please contact to the email [email protected].
Additional Terms
Please note that, in addition to this Policy, your access to and use of
· this website is subject to our Terms of Service; and
· your access and use of our Services is subject to our Acceptable Use Policy and either
the terms and conditions governing your subscription for our Services or, if you are not
a paying customer of Rubiktalk or part of a paying organizational customer of Rubiktalk,
our Terms of Service.