Privacy policy
PRIVACY POLICY
Last updated: 14 September 2020
Vaam is committed to protect your privacy. We collect and use your personal data responsibly and with your privacy in mind. We use your personal data to provide our video as a message tool and and associated services.
This Privacy Policy applies to data provided via our website vaam.io (the “Site”), the Vaam application (the “App”), and the content and the services offered by Vaam through the Site and App (collectively, the “Services”). This Privacy Policy describes how we collect and process your personal data when you use the Services and your rights in relation to our use of your personal data, and how to exercise those rights.
By visiting the Site, using the Services, or by using the App, and by clicking the button to indicate your agreement when first registering or logging into the App and/or you are accepting and consenting to us collecting your personal data and using it in accordance with this Policy.
You may withdraw your consent at any time as set out in the “Your rights” section below.
"Vaam”, "we", "our" or "us" means Vaam AB which is registered with the Swedish companies registration office (Org nr 559266-8833) and address is Tegelbacken 4 A, 111 52 Stockholm, Sweden.
For the purposes of EU data protection law, we are a data controller in respect of the personal data entered by you into the App, and we are responsible for ensuring that we use your personal data in compliance with applicable data protection laws.
In relation to data provided to us by our business clients to enable us to provide the Services, the relevant business client will be the data controller and we will be the data processor. Such clients warrant in our agreements with them that they have complied with and shall continue to comply with applicable data protection laws in relation to the data they control and pass to us and that they have the necessary consents to use the data in relation to the Services we provide to them.
Contact and identification information: data provided by you, when register for the App and use any of the Services by filling in a field or forms in our App or Site including name, email and password, and optional information such as a profile photo;
Usage of Services: data provided through the use of the Services, for example, the videos you create, comments on those video, uploaded personal information, or any other details entered into our App or the Site;
Social media and surveys: data provided by you or our clients when subscribing to our emails, participating in discussion boards or other social media functions linked to the Services, including responding to surveys;
Subscription information: data provided by our clients when updating their subscription preferences.
Customer Support and sales: data you or our clients give our Sales, Customer Success, or Customer Support teams when you or they report a problem, request our support services, request or complete a review, register to use the Services or any demo or other trial of the Services, or data provided when you correspond with us;
Third party services: data transferred via any other software services integrated with the Services;
Payments data: payment data collected when our clients subscribe for paid Services including credit card number and billing address;
Cookies: data automatically collected when using the Site, such as cookies;
Device information and unique identifiers: data automatically collected when using the Services, including:
the data we need access to on your device in order to deliver the Services, such as input device identifiers.
technical data, such as the make, model and operating system of your device, a device identifier, device status, your IP address, browser type, access times and referring web site addresses;
usage data, as collected via analytics services; and
Customer feedback: data provided via other sources, for example, customer feedback.
to provide, operate, support use of, maintain and improve the App, Site and the Services;
to carry out our obligations arising from any contracts entered into between our clients and us and to provide you with the Services;
to provide automatic responses for certain Services, like welcoming messaging to the App or Site, and default customer support answers and to notify you or our clients of Vaam service updates, incidents, and product features and news (please note that as automatic responses are considered an essential part of the provision of the Services it is not possible to unsubscribe from them whilst using the Services);
to notify you or our clients about changes to the Services and to provide and deliver any other products and services that you or our clients request;
to ensure that content from our App and Site and the Services is presented in the most optimal way for you and for your device;
to provide you with information about other products and services we offer;
to create anonymised high-level research reports on workplace trends in a given verticals, industries, roles, geographies, or to compare industries and/or geographies on key metrics;
to protect against, investigate and deter fraudulent, unauthorised or illegal activity; and
to comply with applicable laws and protect our legal rights.
Purpose of the processing
Legal basis for processing
Creating and managing your user account
Consent.
Administering the user or business client relationship
Fulfil contractual obligations.
Providing subscribed for services
Fulfil contractual obligations.
Providing customer service
Legitimate interest*
Preventing IT attacks toward the Services, to further our efforts to keep the Services safe and secure.
Legitimate interest.*
Perform research and analysis aimed at improving our products, services and technologies, including sending you surveys.
Legitimate interest.*
Display content and features that are customized to your preferences.
Legitimate interest.*
To run contests, select entrants, and choose prize winners.
Consent.
To communicate with you about the Services including service related communications, for example, welcome emails and transactional confirmations.
Legitimate interest.*
Marketing including: (a) deciding which marketing to provide to you; (b) marketing and offers regarding our Services to you, subject to your ability to opt out by contacting us.
Legitimate interest.*
Transferring your data to suppliers and other recipients.
This will vary depending on the recipients. For example, Vaam has a legitimate interest* to use third party suppliers to help provide the Services and may be under legal obligations to share data with governmental authorities.
For research and improvement of the Services including: (a) enabling performance of internal research and statistical analysis (b) anonymising your personal data for product development to analyse user behaviour and perform trend analysis (b) performing data analysis for product improvement and product testing.
Legitimate interest.*
Compliance purposes including: (a) complying with applicable laws, for example, tax and accounting regulations (b) protecting against legal claims and enforcing Vaam’s legal rights.
Complying with laws and legitimate interest* to protect against legal claims and enforcing legal rights.
Conducting customer surveys relating to the Services by email (subject to you being able to opt-out when your email is used for surveys).
Legitimate interest.*
Vaam’s operational service partners in order to operate the App and the Site and deliver the Services, for example, cloud infrastructure services;
trusted partners to help us perform statistical analysis, marketing campaigns, PR campaigns, send you emails or provide customer support;
any existing or future member of its group, which means any of its subsidiaries, its ultimate holding company and their subsidiaries.
Vaam will not disclose your personal data and/or usage data to any other third parties without your consent unless required to do so by law or in the good faith belief that such action is necessary to:
comply with the law or with legal process served on Vaam;
protect and defend the rights or property of Vaam; and
act under exigent circumstances to protect the personal safety of users of the App and/or the Site.
Please keep in mind that if you publicly disclose personal data and/or usage data through our App or our Site, we are not responsible for the security of the personal data you publicly disclose and it may be collected and used by others.
5. Your Rights
Right to be informed. You have the right to be informed about how we process your information. We do this through this Privacy Policy, other information on the Site and in the App, and by responding to questions that you sent to us.
Right to access your data. If you would like to know what personal data we process about you you may request a copy of your data.
Right to erasure. You have the right to request deletion of your personal data, for example, when you have withdrawn your consent, or when it is no longer necessary for us to process the data for the purpose it was collected. You may delete certain data in the App or on the Site or by contacting privacy@vaam.io. Please note that Vaam needs to comply with certain legal obligations that may prevent us from immediately deleting some of your personal data.
Right to rectification. You have the right and ability to change any inaccurate or incomplete data about yourself by making changes directly in the App or on the Site or by contacting privacy@vaam.io.
Right to restrict processing of your data or object to processing. If you believe your information is incorrect or that we use your data unlawfully, you have the right to ask us to stop the processing. You may also object to our processing where you believe there are circumstances that would make such processing unlawful. In addition, you may always object to us using your data for direct marketing.
Right to portability. You have the right to request a copy of your data in a machine readable format and can do this by contacting privacy@vaam.io.
Right to withdraw consent. You may withdraw your consent at any time in relation to any of your personal data that we process based on your consent or explicit consent.
Right to lodge a complaint. You have the right to lodge a complaint with the Datainspektionen which is the Swedish Data Protection Authority or if you prefer with your national supervisory data protection authority.
Controlling settings. Vaam provides you with the ability to customize your preferences for certain Services in the App. We will always respect your choices.
If you have any query regarding the handling of your data it should be made in the first instance to privacy@vaam.io, addressed for the attention of our Data Protection Officer.
We ensure that an adequate level of protection is maintained, and that suitable safeguards are adopted in line with applicable data protection legislation requirements, such as the GDPR, when we transfer your data outside the EU/EEA. These safeguards consist of ensuring that the third party country is subject to an adequacy decision by the European Commission, implementing the European Commission’s standard contractual clauses or ensuring that the recipient is registered with the US Privacy Shield (or any replacement thereof).
By ticking the “I agree” button when first registering or logging into the Services and by submitting your personal data, you consent to the transfer, storage or processing of your personal data with our business partners located outside of the EEA.
consent and permission management for both you and/or your employer;
embedding data privacy by design into everything we do;
limiting access to personal data to those of our employees and subcontractors who require it to provide the Services to you;
storing personal data in secure computer systems which protect it from unauthorized access or use.
requiring employees to enter into obligations of confidentiality to protect customer and other confidential information;
ensuring that third-party service providers enter into obligations of confidentiality to maintain the confidentiality of personal data and not to use it for any unauthorized purposes;
risk management, business continuity, including disaster recovery, backups, business impact assessments and risk registers;
data breach management in accordance with applicable laws;
securing and alarming Vaam’s office facilities; and
network segregation and penetration testing.
No method of transmission over the internet, or method of electronic storage, is 100% secure. As a result, while we strive to protect personal data, we cannot guarantee its absolute security
Your password enables you to access certain parts of our App or the Site. You are responsible for keeping this password confidential and for updating it regularly. We ask you not to share a password with anyone. Should you forget your password, it is your responsibility to request a new password from us.
Such data may be used by Vaam: (a) for website statistics and analytics; (b) to personalise the website when a visitor returns (for example, language preference, customisations); (c) for marketing purposes (for example, ads, email campaigns).
If you do not wish Vaam.io, or one of the services we use, to collect any information about your visit you may enable the “Block cookies from third parties and advertisers” option in your web browser settings. This will still allow some “non-tracking” cookies to be stored on your computer, such as language preferences. You may also disable cookies altogether in your browser settings. This will, however, limit your web browsing experience and even stop some web services from working.
