Effective from May 2018 (v3)
Last Updated on March 31, 2021 (v4)
- Organizing it into the sections listed in the Table of Contents below,
- Providing a series of examples that help illustrate how the policies may be implemented, and
- Defining and capitalizing key terms that are used more than once for simplicity and brevity.
• X2O Media Customers
- Bilateral Relationships
- Their users
- Their staff
• X2O Media Partners
- Customers (and their clients)
- Bilateral Relationships
- Their staff
• X2O Media Database
- Demo participants
Other information may include but not limited to:
• Aptitudes and Preferences
• Interactivity and Engagement/Commitment
• Personal Characteristics (ethnicity, taste, gender, orientation, surrounding, etc.)
• Others around you
X2O Media services and products, such as: online workplace productivity tools and platform (X2O Cloud), including X2O Mobile, X2O Desktop and OneRoom Collaboration applications (collectively, the “Services”),
X2O Media websites, including www.x2omedia.com (collectively, the “Websites”)
X2O Media business, including customer service support, user conferences, and demo sessions, (collectively, the “Business”).
A separate agreement governs delivery, access and use of the Service (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Service accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls their instance of the Service (their “Workspace” - such as: online workplace productivity tools and platform (X2O Cloud), including X2O Mobile, X2O Desktop and One Room Collaboration applications) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use. If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the sender (employer, partners, institution, representative and/or point of contact at X2O Media) who sent the invitation.
Information We Collect and Receive
X2O Media’s Services, Websites and Business are intended for use by Customers (“end users” and their audience) and are administered and controlled by trained, chosen administrators selected by the Customer.
X2O Media may collect and receive Customer Data, and/or information and data (“Other Information”) in a variety of ways:
Customer Data. Customers, or individuals granted access to a Workspace by that Customer (“Authorized Users”) routinely submit Customer Data to X2O Media when using the Service, Websites and/or Business.
Other Information. X2O Media also collects, generates and/or receives Other Information:
I. Workspace and Account Information.
To create or update a Workspace account, you, or your employer (the Customer) supply X2O Media with a name (first and last name), an email address and a password and/or similar account details. At your own discretion, you can upload information to the X2O system, where applicable, which can be personal data (location, job title, photo). If the system is setup to use Active Directory for authentication and authorization, certain account information (Active Directory identifier, X2O role, X2O permission, division) will be used, and stored automatically by the X2O system when you access the Service. X2O does not control or verify accuracy and/or use of data. We rely on the physical and/or juridical person handling the data to do so transparently, accurately and with express consent, in accordance with GDPR, SOC2 and other data privacy regulations that may apply.
The X2O platform can link to the Customer’s Active Directory database. We do this for authentication and authorization purposes. Some of the information from the Customer’s Active Directory Database will be converted in metadata and stored in the X2O database (e.g., in Active Directory the customer can specify which roles in the X2O system a certain user of the system should have. This knowledge, together with a user ID will be duplicated in the X2O system).
II. Usage Information.
Service Metadata. When an Authorized User interacts with the Service, metadata is generated that provides additional context about the way Authorized Users work. For example, X2O Media logs the Workspaces, channels, features, content, and links you interact with, the types of files uploaded or shared, and what Third Party Services are used (if any). Some of this information is made available through the Service’s Audit Trail.
Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Service and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Websites or Service, browser type and settings, the date and time and the duration the Websites or Service is used, information about browser configuration and plugins, language preferences and cookie data.
Device information. X2O Media collects information about devices accessing the Service, including the type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all this Other Information often depends on the type of device used and its settings.
Location information. We receive information from you, your Customer and other third parties that help us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. X2O Media may also collect location information from devices in accordance with the consent process provided by your device.
III. Cookie Information.
IV. Third Party Services.
Customers can choose to permit or restrict Third Party Services for their Workspace. Typically, Third Party Services are software that integrates with our Service, and Customers can permit their Authorized Users to enable and disable these integrations for their Workspace. Once enabled, the provider of a Third-Party Service may share certain information with X2O Media. For example, if a cloud storage application is enabled to permit files to be imported to a Workspace, we may receive the username and email address of Authorized Users, along with additional information that the application has elected to make available to X2O Media to facilitate the integration and interface. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to X2O Media. When a Third-Party Service is enabled (such as SSO), X2O Media is authorized to connect and access Other Information made available to X2O Media in accordance with our agreement with the Third-Party Provider. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Service.
V. Third Party Data.
X2O Media may receive data about organizations, industries, website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates, and subsidiaries, partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries, or it might be used more specifically, for example, to analyze how well an online marketing or email campaign performed.
VI. Additional Information Provided to X2O Media.
We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity, event, session training, X2O demo, or when you apply for a job, request support, interact with our social media accounts or otherwise communicate with X2O Media. Our Websites includes contact form, in which we ask you to fill out relevant personal information in advance of our representatives contacting you. For example, when Authorized Users participate in OneRoom Collaboration sessions, they will submit their name, location, web camera live feed, microphone sound, and they can chat with the other participants, answer polls, or annotate on shared documents. The collaboration sessions can be recorded, and the recordings can be saved on some users’ hard drive, based on permissions.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Service.
How We Use Information
At X2O Media, we strive to gather and retain the minimum data possible pertaining to any one single person, without compromising the services and quality expected by customers. It is the customers discretion (non-compulsory), to inform X2O Media the data required and expected to be collected and/or analyzed at their end. Note that this information may be being used for your and others safety and security. It is your right to ask to remove the data collected; the impact of removing such information will be done at your own risk and not recommended by X2O Media. May you have been exposed to data being collected, stored, processed, transferred, and/or analyzed without your consent, please reach out to the X2O Media’s Customer in question, from where you have accessed the Workspace platform. Customer Data will be used by X2O Media in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Service functionality, and as required by applicable law. X2O Media is a Processor of Customer Data and Customer is the Controller. Customer may, for example, use the Service to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Service.
X2O Media uses Other Information in furtherance of our legitimate interests in operating our Service, Websites and Business. More specifically, X2O Media uses Other Information:
To provide, update, maintain and protect our Service, Websites and Business. This includes use of Other Information to support delivery of the Service under a Customer Agreement, prevent or address service errors, address security or technical issues, analyze and monitor usage, review trends and other activities or at an Authorized User’s request.
As required by applicable law, legal process, or regulation.
To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your Other Information to respond.
To develop and provide search, learning and productivity tools and additional features. X2O Media tries to make the Service as useful as possible for specific Workspaces and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels, or expertise to an Authorized User, make Service suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Service experience or create new productivity features and products.
To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Service, our Service offerings, and important Service-related notices, such as security and fraud notices. These communications are considered part of the Service and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications, newsletters, or other news about X2O Media. These are marketing messages so you can control whether you receive them.
For billing, account management and other administrative matters, X2O Media may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
To investigate and help prevent security issues and abuse.
If Information is aggregated or anonymized so it is no longer reasonably associated with an identified or identifiable natural person, X2O Media may use it for any business purpose.
X2O Media will retain Customer Data in accordance with a Partners and/or Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Service functionality, and as required by applicable law. The deletion of Customer Data and other use of the Service by Customer may result in the deletion and/or anonymization of certain associated Other Information.
How We Share and Disclose Information
Customers determine their own policies and practices for the sharing and disclosure of Information, and X2O Media does not control how they or any other Third Parties choose to share or disclose Information.
Customer Agreement. X2O Media will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Service functionality, and in compliance with applicable law and legal process.
Displaying the Service. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Workspaces. For example, an Authorized User’s email address may be displayed with their Workspace profile.
Collaborating with Others. The Service provide different ways for Authorized Users working in independent Workspaces to collaborate, such as collaboration sessions. Other Information, such as an Authorized User’s profile Information (ex.: name, location, photo avatar), may be shared, subject to the policies and practices of the other Workspace(s).
Customer Access. Owners, Administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Workspace activity or accessing or modifying your profile details.
Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. X2O Media may use the following Sub-processors to host Customer Data or provide other infrastructure that helps with delivery of our Service: Microsoft Azure as a cloud service provider, Salesforce.com as a CRM system, NetSuite as an ERP system, Atlassian’s Confluence and JIRA for project information, and SharePoint for project information.
Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, X2O Media may share Other Information with Third Party Services. Third Party Services are not owned or controlled by X2O Media and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third-Party Services or contact the provider for any questions.
Corporate Affiliates. X2O Media may share Other Information with its corporate affiliates, parents and/or subsidiaries.
During a Change to X2O Media’s Business. If X2O Media engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all X2O Media’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g., due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective X2O Media customer the type of content shared within a typical Workspace.
To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.
To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of X2O Media or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With Consent. X2O Media may share Other Information with third parties when we have consent to do so.
X2O Media takes data security very seriously. X2O Media works hard to protect Other Information you provide, from loss, misuse, and unauthorized access or disclosure. These efforts take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. X2O Media strives to be in accordance with the law, apply GDPR and give autonomy to data used belonging to any individual; unless against advice by court, law or legal teams involved. As proof of our commitment to transparency, security and safety of all impacted by X2O Media, we are SOC2 Type 2 certified. Given the nature of communications and information processing technology, X2O Media cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.
Identifying the Data Controller and Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, for cloud deployment of our Service, the Customer is the Controller of Customer Data, and X2O Media is the Processor of Customer Data and the controller of Other Information.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Service account. If you cannot use the settings and tools, contact the Customer for additional access and assistance.
To the extent that X2O Media’s processing of your Personal Data is subject to the General Data Protection Regulation, X2O Media relies on its legitimate interests, described above, to process your data. X2O Media may also process Other Information that constitutes your Personal Data for direct communication purposes, and you have a right to object to X2O Media’s use of your Personal Data for this purpose at any time.
In accordance with GDPR and other regulations, such as Subject Action Request (SAR) and Right to Erasure (RTE), any EU and UK citizen, national and/or resident has the right to request full disclosure of the information collected, stored, and analyzed; as well as the right to be forgotten, unless X2O Media is expressly informed otherwise by authorities and/or for legal matters.
To apply your rights, please contact your supplier (our Customer) and/or your point of contact at X2O Media; ensure to cc the Compliance Department at X2O Media at email@example.com
Data Protection Authority
Subject to applicable law, you also have the right to restrict X2O Media’s use of Other Information that constitutes your Personal Data and lodge a complaint with your local data protection authority.
Contacting X2O Media
X2O Media Inc.
147 Saint Paul St West, Suite 300
Montreal, Quebec, Canada
X2O Media prides itself in its transparency and Data Privacy. We will strive to maintain all information accurately and up to date.
X2O Media’s current DPO is:
DPO & Senior Project Manager
X2O MEDIA INC
The firstname.lastname@example.org is accessible and checked regularly by X2O Media’s President and Data Privacy Officer (DPO).