Qumu Corporation Privacy Policy

Dated 01 January 2020.

Qumu Corporation and its group of companies (“Qumu”) operates several websites including www.qumu.com. It is Qumu’s policy to respect your privacy regarding any information we may collect or receive while operating our Services. This Privacy Policy sets out how Qumu collect and use information from customers and other individuals who access or use our websites, who apply for roles or vacancies at Qumu, our mobile applications, and/or any of our other sites, products, or services that link to this Privacy Policy (the “Services”). By using our Services, you understand that we will collect and use your information as described in this Privacy Policy (collectively “you”).

If you or your organization has a separate agreement with us, that agreement may have privacy terms that also apply to the information you provide to us under that agreement. Please review the terms in that agreement as they may be different or more restrictive than the terms in this Privacy Policy.

This Privacy Policy does not apply to any third-party websites and apps that you may use, including any linked to in our Services. You should review the terms and policies for third-party websites and apps before clicking on any links.

Website Visitors

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. 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 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 delivery 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?

The personal data we collect from you may be transferred outside the EEA either by us and/or by any of the third parties to whom your personal data may be disclosed to as listed in the ‘Who do we share your personal data’ section of this Privacy Policy. Such transfers will occur only where they are necessary as part of the recruitment and/or related intermediary services we provide, e.g. where you apply for a vacancy or position outside the EEA, or where the transfer is authorised by law.

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 EEA, we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply, or we are authorised to do so.

We will provide you with 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;
  • Cookies and Related Technologies. We may use cookies, which are text files containing small amounts of information that are downloaded on your device (“Cookies”), or related technologies, such as web beacons, local shared objects and tracking pixels to store or collect information. We also allow others to use Cookies within the Services as described below. Cookies can store your preferences, your username, and help tailor advertisements; and
  • 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:

  • 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;
  • 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. If the GDPR (or if other applicable data protection legislation, including but not limited to, the California Consumer Privacy Act (“CCPA”)) applies and Qumu acts as a controller, Qumu’s lawful basis for collecting and using the information described in this Privacy Policy will depend on the information concerned and the specific context in which Qumu collects or uses it.

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; or
  • Use information to create and manage an account, we need it in order to provide relevant Services.

If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us using the contact details provided in this Privacy Policy.

Who do we share your personal data with?

We may share your personal data with the following entities for the purposes set out in this Privacy Policy:

  • Any of our group companies;
  • Pre-employment screening and background checking organisations;
  • Your referees;
  • Your past educators and employers and relevant education authorities;
  • Your professional bodies;
  • Governmental and regulatory bodies such as such as tax and social security authorities;
  • External consultants, professional advisors and business associates;
  • Outsourced IT and document storage providers including but not limited to Salesforce in relation to the provision of our products and services to customers only; and
  • Software as a Service (SaaS) 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; and iii) Oracle Netsuite for business management purposes including billing and invoicing);

We do not allow our third-party service providers or subcontractors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, which includes this Privacy Policy.

Aggregated Statistics

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 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; by using Qumu’s websites, you consent to the transfer of such information to them. 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.

Cookies and Other Technologies

Qumu’s website, online services and email messages, may use cookies and other technologies such as pixel tags and web beacons. These technologies help us better understand user behaviour and tell us which parts of our website people have visited.

Qumu uses cookies and other technologies to remember personal information when you use our website. Our goal is to make your experience with Qumu more convenient and personal. For example, if you give us permission to send you and email or you request an email on a specific topic, knowing your contact information helps us send you e-mail that is relevant to you.

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 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.

Mobile Apps

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.

Your Rights

By using Qumu’s Services, you:

  • acknowledge that your information will be processed as described in this Privacy Policy;
  • consent to having your information transferred to our affiliates and facilities, in the United States or elsewhere, and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

You may have certain rights related to your personal data, subject to local data protection laws. These rights may include:

  • You can request the following information from Qumu: how we collect and use your information and why; the categories of personal data involved; the categories of recipients of your personal data; how we received your personal data; and how long we use or store your personal data or the manner in which we determine relevant retention periods.
  • 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.
  • 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.
  • 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 legal@qumu.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 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.

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).

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:

  • Identifiers;
  • 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 legal@qumu.com. 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.

Children’s Privacy

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.

Privacy Policy Changes

Although most changes are likely to be minor, Qumu may change its Privacy Policy from time to time, and in Qumu’s sole discretion. Qumu encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

Contacting Us

For questions or complaints regarding Qumu’s use of personal data or this Privacy Policy, please contact us at legal@qumu.com or Qumu, Attention: Head of Legal, 3rd Floor, One West Smithfield, London, EC1A 9JU, England.