Personal data is any information from or about an identified or identifiable person, including information that Nebulos can associate with an individual person. We may collect, or process on behalf of our customers, the following categories of personal data when you use or interact with Nebulos products and services:

• Account Information: Information associated with an account that licenses Nebulos products and services, which may include administrator name, contact information, account ID, billing and transaction information, and account plan information.
  
• Profile and Participant Information: Information associated with the Nebulos profile of a user who uses Nebulos products and services under a licensed account or that is provided by an unlicensed participant, which may include name, display name, picture, email address, phone number, job information, stated locale, user ID, or other information provided by the user and/or their account owner.
  
• Contact Information: Contact information added by accounts and/or their users to create contact lists on Nebulos products and services, which may include contact information a user integrates from a third-party app, or provided by users to process referral invitations.
  
• Settings: Information associated with the preferences and settings on a Nebulos account or user profile, which may include audio and video settings, recording file location, screen sharing settings, and other settings and configuration information.
  
• Registration Information: Information provided when registering for a Nebulos meeting, webinar, Nebulos Room, or recording, which may include name and contact information, responses to registration questions, and other registration information requested by the host.
  
• Device Information: Information about the computers, phones, and other devices used when interacting with Nebulos products and services, which may include information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
  
• Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features: Content generated in meetings, webinars, or messages that are hosted on Nebulos products and services, which may include audio, video, in-meeting messages, in-meeting and out-of-meeting whiteboards, chat messaging content, transcriptions, transcript edits and recommendations, written feedback, responses to polls and Q&A, and files, as well as related context, such as invitation details, meeting or chat name, or meeting agenda. Content may contain your voice and image, depending on the account owner’s settings, what you choose to share, your settings, and what you do on Nebulos products and services.
  
• Usage Information Regarding Meetings, Webinars, Messaging, Collaborative Features and the Website: Information about how people and their devices interact with Nebulos products and services, such as: when participants join and leave a meeting; whether participants sent messages and who they message with; performance data; mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off), edits to transcript text, where authorized by the account owner and other inputs that help Nebulos to understand feature usage, improve product design, and suggest features; which third-party apps are added to a meeting or other product or service and what information and actions the app is authorized to access and perform; use of third-party apps and the Nebulos App Marketplace; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with Nebulos’s websites, including what pages are accessed, interaction with website features including Nebulos’s website’s virtual chat feature, and whether or not the person signed up for a Nebulos product or service.
  
• Communications with Nebulos: Information about, and contents of, your communications with Nebulos, including relating to support questions, website virtual chats, your account, and other inquiries.
  
• Information from Partners: Nebulos obtains information about account owners and their users from third-party companies, such as market data enrichment services, including information about an account owner’s company size or industry, contact information, or activity of certain enterprise domains. Nebulos may also obtain information from third-party advertising partners who deliver ads displayed on Nebulos products and services, such as whether you clicked on an ad they showed you.
  

In certain jurisdictions, some of the personal data Nebulos receives may be considered sensitive. Please see “California & Other U.S. State Privacy Rights” for more information.

Nebulos employees do not access meeting, webinar, messaging or email content (specifically, audio, video, files, in-meeting whiteboards, messaging or email contents), or any content generated or shared as part of other collaborative features (such as out-of-meeting whiteboards), unless authorized by an account owner, or as required for legal, safety, or security reasons, as discussed below, and where technically feasible. Nebulos uses personal data to conduct the following activities:

• Provide Nebulos Products and Services: To provide and develop products and services to account owners, their users, including to customize Nebulos products and services and recommendations for accounts or their users. Nebulos also uses personal data to determine what products and services may be available in your location, and uses personal data, including contact information, to route invitations, messages, or Nebulos Emails to recipients when users send or receive invitations, messages, or Nebulos Emails using Nebulos products and services. This may also include using personal data for customer support, which may include accessing audio, video, files, messages, and other content or context, at the direction of the account owner or their users. We also use personal data to manage our relationship and contracts with account owners and others, including billing, compliance with contractual obligations, facilitating payment to third-party developers in relation to purchases , and related administration.
  
• Product Research and Development: To develop, test, and improve Nebulos products and services, including, for example, content-related features (such as background and other filters), and to troubleshoot products and services.
  
• Marketing, Promotions, and Third-Party Advertising: To permit Nebulos and/or its third party marketing partners to market, advertise, and promote Nebulos products and services, including based on your product usage, information we receive from third-party partners, information you provide to process referral invitations, or if you visit our websites, information about how and when you visit, and your interactions with them. We may also use this information to provide advertisements to you relating to Nebulos products and services or to engage third party partners to analyze your interactions on our website or app or to deliver advertising to you. Nebulos does not use meeting, webinar, or messaging content (specifically, audio, video, files shared, in-meeting whiteboards, and messages), or any content generated or shared as part of other collaborative features (such as out-of-meeting whiteboards) for any marketing or promotions.
  
• Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, detect, investigate, and prevent malicious conduct, fraudulent activity or unsafe experiences, address security threats, protect public safety, and secure Nebulos products and services.
  
• Communicate with You: We use personal data (including contact information) to communicate with you about Nebulos products and services, including product updates, your account, and changes to our policies and terms. We also use your information to respond to you when you contact us.
  
• Legal Reasons: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, protect you, us, and others from fraudulent, malicious, deceptive, abusive, or unlawful activities, and to enforce or investigate potential violations of our Terms of Service or policies.
  

Nebulos uses advanced tools to automatically scan content such as virtual backgrounds, profile images and files uploaded or exchanged through chat, for the purpose of developing, providing, and improving products and services, and detecting and preventing violations of our terms or policies and illegal or other harmful activity. Nebulos employees may access such content where required for legal, safety, or security reasons or where authorized by an account owner.

Nebulos provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):

• Resellers: If an account owner licensed or purchased Nebulos products and services from a third-party reseller of Nebulos products and services, the reseller may be able to access personal data and content for users, including meetings, webinars, and messages hosted by the account owner.
  
• Vendors: Nebulos works with third-party service providers to provide, support, and improve Nebulos products and services and technical infrastructure, and for business services such as payment processing. Nebulos may also work with third-party service providers to provide advertisements and business analytics regarding Nebulos products and services. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Nebulos or as required by law. Nebulos may integrate third-party technology to provide advanced features, such as Apple’s TrueDepth technology, to process information on your device about face or hand dimensions and gestures to provide video effects. This information is processed on your device, and such information is neither received nor stored by either the third party, or Nebulos.
  
• For Legal Reasons: Nebulos may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers’ rights and property; and (6) resolve disputes and enforce agreements.
  
• Marketing, Advertising, and Analytics Partners: Nebulos uses third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using Nebulos products and services, including our website; and to provide advertising and marketing for Nebulos products and services, including targeted advertising based on your use of our website. These third-party partners may receive information about your activities on Nebulos’s website through third-party cookies placed on Nebulos’s website. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool, available in cookies settings. Where required by law, Nebulos will first obtain your consent before engaging in the marketing or advertising activities described.
  
• Corporate Affiliates: Nebulos shares personal information with corporate affiliates to provide integrated and consistent experiences across Nebulos products and services (such as enabling an account owner or their user to integrate a Nebulos Phone call into a meeting) and to detect, investigate, and prevent fraud, abuse, and threats to public safety.
  
• Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Nebulos’s business or assets, including in connection with bankruptcy or similar proceedings.

When you use Nebulos products and services, other people and organizations, including third parties outside the meeting, webinar, or message, may be able to see content and information that you share:

• Account Owner: An account owner is the organization or individual that signs up for a Nebulos account. Typically, an account owner designates one or more people (called an “administrator”) to manage their account and can grant privileges to users on the account. Depending on their license with Nebulos, the account owner can authorize additional users on their account, and the account owner can create and/or access the profile information for all users on their account. The account owner and their users can invite others (including guests not on their account and unlicensed participants) to meetings or webinars hosted on their account.Nebulos gives account owners controls and features that they can use to determine whether certain types of content, such as recordings or Nebulos Team Chat messages, can be created or sent, and what third-party apps can be used, for meetings and webinars hosted on their account. Depending on their settings, account owners and the users they designate can access personal data for participants who join meetings and webinars on their account or send messages to users on their account. Specifically, account owners may have access to:
  
  
• Account Usage:
  
  • Product Usage: Information about how users and their devices interact with their account, which may include who sent messages to their users in chat, email addresses, IP addresses, device information, and other information about who joined meetings or webinars on their account, whether their users viewed or downloaded a recording, how long participants participated in their meetings, the time a message was sent, information about Nebulos Phone integrations, and other usage information and feedback metrics.
    
  • Participant List: Information about the participants in a Nebulos meeting, webinar, or chat, which may include name, display name, email address, phone number, and participant or user ID.
    
• Registration Information: Information provided during registration for a webinar, meeting, Nebulos Room, or recording hosted by the account.
  
• In-Meeting/Webinar Messages: Depending on their settings, account owners can see sender and receiver information, along with the content of messages sent to and from users on their account, in the following circumstances:
  
  • Messages sent to Everyone in a meeting that is recorded
    
  • Messages sent to the meeting group chat in a meeting when a dedicated meeting group chat is enabled
    
  • Messages sent to panelists in a webinar that is recorded
    
  • Direct messages if the account owner has enabled archiving
    
  • If a participant in a meeting is subject to archiving, their account owner will have access to messages sent to Everyone in the meeting, as well as direct messages sent to that participant. If a participant who is a member of a dedicated meeting group chat is subject to archiving, the member’s account owner will have access to themeeting group chat messages, as well as direct messages sent to that member. If a guest in a meeting with a dedicated meeting group chat is subject to archiving, the guest’saccount owner will have access to messages sent to the meeting group chat, as well as direct messages sent to that guest.
    
• Recordings: Account owners can watch the content of recordings of meetings and webinars hosted on their account. They can also view, share, and enable advanced features for transcripts of meeting audio.
  
• Polling, Q&A, and Feedback: Account owners can see information about who provided responses to their polls, Q&A, or post meeting or webinar feedback requests, including name and contact information, together with the responses or feedback, unless responses are submitted anonymously.
  
• Meeting Hosts, Participants, and Invitees: Meeting hosts, participants, and invitees may be able to see your email, display name, profile picture, and presence status, including in Nebulos meetings and in Nebulos’s native calendar service. Meeting hosts, participants, and invitees can also see and (depending on the account owner’s settings) record, save, and share meeting content, audio transcripts, messages sent to Everyone, messages sent to meeting group chats (where enabled, and whether sent in Team Chat or in-meeting), or messages sent to them directly, and files, whiteboards or other information shared with them (including during a meeting, or through a dedicated meeting group chat). Meeting hosts may also share chat transcripts to Nebulos Team Chat, depending on their account owner’s settings. Meeting hosts may also be able to see responses to Q&A and polls generated during the meeting.
  
• Livestreams: Meeting and webinar hosts can choose to livestream to a third-party site or service, which means anyone with access to the livestream will be able to see the meeting or webinar.
  
  

Marketing Communication: If you don’t want to learn about products and services we or our partners offer, you can opt-out of marketing communications in the communication sent to you (for example, via email or SMS), or by emailing support@nebulos.tech. Not all of our communications are for marketing, and you’ll continue to receive messages related to your products and services, such as bills, transactional notices, or customer service.
Data Rights:If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California or another U.S. state with an applicable privacy law, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:

• Inform you of what personal data we have about you that is under our control;
  
• Amend or correct such personal data or any previous privacy preferences you selected, or direct you toapplicable tools; and/or
  
• Delete such personal data or direct you to applicable tools.
  

Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others. As an account owner or a user under a licensed account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.

Nebulos does not allow children under the age of 16 to sign up for a Nebulos account.
For educational organizations that use Nebulos products and services to provide educational services to children under 18.

If you have any privacy-related questions or comments related to this Privacy Statement, please send an email to support@nebulos.tech.

We retain personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.The criteria used to determine our retention periods include the following:

• The length of time we have an ongoing relationship with you and provide Nebulos products and services to you (for example, for as long as you have an account with us or keep using our products);
  
• Whether account owners modify or their users delete information through their accounts;
  
• Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  
• Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

• Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
  
• Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
  
• Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
  
• Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
  
• Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
  

If you have any other questions about our use of your personal data, please send a request at the contact details specified in the Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Nebulos processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

• As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Nebulos products and services, features and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products and services;
  
• Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool, available Cookies Settings;
  
• As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
  
• To protect your vital interests or those of others :We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
  
• As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the products and services (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our products and services and troubleshoot products and services; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and products and services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the products and services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.

Nebulos operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where Nebulos or its service providers have customers or facilities – including in countries where meeting participants or account owners hosting meetings or webinars that you participate in or receiving messages that you send are based.
Therefore, by using Nebulos products and services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.
We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. Please contact us if you would like further information in that respect.

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:

• Access the categories and specific pieces of personal data Nebulos has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Nebulos has shared personal data, and obtain the personal data in a portable and, to the extent technically feasible, readily usable format;
  
• Delete personal data under certain circumstances;
  
• Correct personal data under certain circumstances; and
  
• Opt out of the “sale” of personal data or “sharing” of personal data for targeted advertising purposes. We do not sell your personal data in the conventional sense. However, like many companies, we may use advertising and analytics services that are intended to analyze your interactions with our website or app, based on information obtained from cookies or other trackers, including for delivering advertising to you (such as interest-based, targeted, or cross-context behavioral advertising). You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings. California and Connecticut residents may also set the Global Privacy Control (GPC) to opt out of the “sale” or “sharing” of your personal information for targeted advertising for each participating browser system that you use. Nebulos does not have actual knowledge that it “sells” or “shares” the personal information of consumers under 16 years of age.
  
• Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or emailing support@nebulos.tech.
  

Nebulos will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law.

California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Statement on our website, with a “Last Updated” date at the top. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review before you choose to continue using our products and services.