EFFECTIVE: May 27, 2021
This policy outlines our data handling practices, and in particular how Shanghai Donghan Communication Technology Co., Ltd. (“Donghan”) collects, uses, and discloses Personal Data. It covers all Personal Data that you affirmatively provide during your interactions with us, information that we automatically collect when you interact with our Products, and information that we collect about you from third parties. The policy is applicable worldwide, and also describes rights you may have to control our use of Personal Data and how to exercise those rights.
As used in this Privacy Policy, “Personal Data” means any information that can be used to identify or is reasonably linkable to a specific person.
Whether you have a Donghan account or not, we may collect Personal Data from or about you when you use or otherwise interact with our Products. We may gather the following categories of Personal Data about you:
We collect this data to provide you with the best experience with our Products. Mostly, we gather Personal Data directly from you, directly from your devices, or directly from someone who communicates with you using the services, such as a meeting host, participant, or caller. Some of our collection happens on an automated basis – that is, it’s automatically collected when you interact with our Products. In certain instances, you can choose whether to provide Personal Data to Donghan, but note that you may be unable to access certain options and services if they require Personal Data that you have not provided.
We may also obtain information about you from a user who uses Donghan. For example, a user may input your contact information when you are invited to a Donghan meeting or call. Similarly, a Donghan meeting host may record a Donghan meeting and store the recording on our system. If a Donghan meeting host decides to record a meeting, that person is responsible for obtaining any necessary consent from you before recording a meeting.
We may also gather some Personal Data from third-party partners. Sometimes, other companies who help us deliver the service (our service providers) and may collect or have access to information on our behalf when you use our Products. We have agreements with our service providers to ensure that they do not use any of the information that they collect on our behalf for their own commercial purposes or for the commercial purposes of some other company or third party. We may also receive Personal Data that third parties collect in other contexts, which we use in order to better understand our users, advertise and market, and enhance our services.
Customer Content is information provided by the customer to Donghan through the usage of the service. Customer Content includes the content contained in cloud recordings, and instant messages, files, whiteboards, and shared while using the service. Customer Content does not refer to data generated by Donghan’s network and systems (i.e., data that Donghan creates because the customer is using the system (e.g., meeting routing information and other meeting metadata).
Donghan, our third-party service providers, and advertising partners (e.g., Google Ads and Google Analytics) automatically collect some information about you when you use our Products, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referrer URL, exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We use this information to offer and improve our services, trouble shoot, and to improve our marketing efforts.
Passive collection involves using cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather information about our user base, such as location information at the city level (which we derive from IP addresses). Users can control the use of cookies at the individual browser level and through the “Cookie Preferences” link on our homepage. We will also make reasonable efforts to ensure that we do not use our Products to collect information when you visit websites offered by companies other than Donghan. For more information regarding cookies or similar technologies, please review our Cookie Policy.
You may choose to use our referral service to tell others about our products, which will require you to provide us with their name and email address. We rely on you to obtain the intended recipient’s consent to be contacted. We will automatically send a one-time email inviting them to visit the website. Unless we are authorized to communicate further, we will only use that person’s name and email address for the purposes of sending this one-time email and maintaining an activity log of our referral program.
If you participate in a Recorded Meeting or you subscribe to Donghan’s cloud recording services, we collect information from you in connection with and through such Recordings. This information may include Personal Data. Meeting hosts are responsible for notifying you if they are recording a meeting, and you will generally hear a notice or see an on-screen notification when recording is in progress.
We process your Personal Data (i) with your consent (where necessary), (ii) for the performance of any contract you have with us (such as your agreement with us that allows us to provide you with the Products), and (iii) for other legitimate interests and business purposes including in a manner reasonably proportionate to:
We may use all of the types of Personal Data that we collect for:
Some of this information may be shared with other meeting participants. For example, all messages and content you share in a meeting, including Personal Data about you or others, will be available to all other participants in that meeting (unless you elect to chat with a subset of meeting participants). If you share a meeting link with another user who is not already in the meeting, when that user tries to join the meeting he or she will be able to see the list of other users in the meeting, as well as other invitees joining the meeting.
Much of the Personal Data we collect, we collect on behalf of our customers. (More specifically, for purposes of GDPR and CCPA, we are the “Processor” of that Personal Data, acting as a service provider on behalf and at the direction of our customer, and our customer is the “Controller” or decisionmaker.) For example, the customer may determine when meetings can be recorded, how long they are kept, and the like.
We are typically required to follow a customer’s instructions related to Personal Data we have collected on behalf of that customer. On a customer’s instructions, we may provide reports containing Personal Data relating to the customer’s account.
Keeping you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information.
We may use identifiers, employment information, payment information, technical information, demographic information, usage information, and user-generated information:
You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails.
We send you push notifications from time to time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
This includes responding to a legally binding demand for information, such as a warrant issued by a law enforcement entity of competent jurisdiction, or as reasonably necessary to preserve Donghan’s legal rights.
As discussed above, we may collect information about your broad geographic location (city-level location) when you are using our Products or have them installed on your device. We use this information for service-related purposes (such as optimizing your connection to our data center), supporting compliance (such as by telling us where you’re located, which can determine what laws or regulations apply to you), and suggesting customizations to your experience with our Products (e.g. your language preference). We do not “track” you using location data and we only use this information in connection with providing the best experience with the Products to you.
Note that we may use third-party service providers and our affiliated entities to help us do any of the things discussed here, and they may have access to Personal Data related to the specific activity they are doing for us in the process. We forbid our service providers from selling Personal Data they receive from us or on our behalf, and require them to only use Personal Data in order to perform the services we have asked of them, unless otherwise required by law.
We do our best to give you reasonable controls over the Personal Data we process about you as set forth below. Depending on where you reside, you may be entitled to certain legal rights with respect to your Personal Data.
Here are the types of requests you may make related to Personal Data about you, subject to applicable laws, rules, or regulations:
Donghan does not exchange your Personal Data with third parties for payment, even if you do not opt-out of the “sale” of information. If you opt-out, we will adjust your preferences accordingly.
Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters including a user’s rights to data contained in their account, we cannot verify your identity, or it involves disproportionate cost or effort. But in any event, we will respond to your request within a reasonable timeframe and provide you an explanation.
Shanghai Donghan, Attention Data Privacy Officer, Room 07-119, Tower 2, Li & Fung Plaza, 2000 Yishan Road, Minhang District, Shanghai (021-52217938).
If you have a password protected account, we will use your account information to verify your identity. If not, we will ask you to provide additional information needed to verify your identity. The type and amount of information we request will depend on the nature of your request, the sensitivity of the relevant information, and the risk of harm from unauthorized disclosure or deletion. If you are a California resident and would like to designate an authorized agent to exercise any of your rights, please contact us.
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have legal rights with respect to your Personal Data, including those set forth under the EU’s General Data Protection Regulation (“GDPR”).
If you reside in California, you may have legal rights with respect to your Personal Data, including those set forth under the California Consumer Privacy Act (“CCPA”). Donghan is prohibited from discriminating against California consumers that choose to exercise their privacy-related rights under the CCPA.
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required by law.
Donghan is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use, or disclosure. When we transfer credit card information over the Internet, we protect it using Transport Layer Security (TLS) encryption technology.
We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of upper and lower-case letters, numbers, and symbols when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us.
Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.