Privacy Policy

BANTOOLINK Privacy Statement  

Last updated: January 1st, 2022 

This statement describes the personal data we collect and/or process (which may include collecting,  organizing, structuring, storing, using, or disclosing) to provide products and services offered di rectly by Border Blaster Group Video Communications, Division. (!BANTOOLINK”), including BANTOOLINK"s websites and its meetings, webinars, and messaging platform (!BANTOOLINK Products” or !Products”). BANTOOLINK Products do not include products developed by BAN TOOLINK that are covered under a separate privacy policy (listed here).  

What Personal Data Do We Receive?  

Personal data is any information from or about an identified or identifiable person, including infor mation that BANTOOLINK 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  BANTOOLINK Products: 

  • Account Information: Information associated with an account that licenses BAN TOOLINK Products, which may include administrator name, contact information, account  ID, billing information, and account plan information. 
  • Profile and Participant Information: Information associated with the BANTOOLINK  profile of a user who uses BANTOOLINK Products under a licensed account or that is pro vided by an unlicensed participant joining a meeting, which may include name, display  name, picture, email address, phone number, job information, stated locale, user ID, or other  information provided by the user or their account owner. 
  • Contacts and Calendar Integrations: Contact information added by accounts or their users  to create contact lists on BANTOOLINK, which may include contact information a user in tegrates from a third-party app. Users can also integrate their calendars from other services  with their BANTOOLINK profile or account.  
  • Settings: Information associated with the preferences and settings on the 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 people provide when registering for a BANTOO LINK calls, chat, VOD, trade, meeting, webinar or recording, which may include name and  contact information, responses to registration questions, and other registration information  requested by other BantooLink users.  
  • Device Information: Information about the computers, phones, and other devices people  use when interacting with BANTOOLINK Products, 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 attri 

butes (like operating system version and battery level), WiFi information, and other device  information (like Bluetooth signals).  

  • Meeting, Webinar, and Messaging Content and Context: Content generated in meetings,  webinars, or messages that are hosted on BANTOOLINK Products, which may include au dio, video, in-meeting messages, chat messaging content, transcriptions, 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, de pending on the account owner"s settings, what you choose to share, your settings, and what you do on BANTOOLINK Products.  
  • Product and Website Usage: Information about how people and their devices interact with  BANTOOLINK Products, such as: when participants join and leave a meeting; whether  participants sent messages and who they message with; performance data; mouse move ments, clicks, keystrokes or actions (such as mute/unmute or video on/off), and other user  inputs that help BANTOOLINK to understand feature usage, improve product design, and  suggest features; which third-party apps users add to a meeting or other Product and what  information and actions the app is authorized to access and perform; features used (such as  screen sharing, emojis, or filters); and other usage information and metrics. This also in cludes information about when and how people visit and interact with BANTOOLINK"s websites, including what pages they accessed, their interaction with the website features,  and whether or not they signed up for a BANTOOLINK Product.  
  • Communications with BANTOOLINK: Information about your communications with  BANTOOLINK , including relating to support questions, your account, and other inquiries. 
  • Information from Partners: BANTOOLINK obtains information about account owners  and their users from third-party companies, such as market data enrichment services, inclu ding information about an account owner"s company size or industry, contact information, or activity of certain enterprise domains. 

How Do We Use Personal Data?  

BANTOOLINK employees do not access calls, chats, trade and business transactions, meeting,  webinar, or messaging content (specifically, audio, video, files, and messages) unless directed by an  account owner, or as required for legal, safety, or security reasons, as discussed below. BAN TOOLINK uses personal data to conduct the following activities:  

  • Provide BANTOOLINK Products and Services: To provide Products, features, and ser vices to account owners, their users, and those they invite to join meetings and webinars  hosted on their accounts, including to customize Product features and recommendations for 

accounts or their users. BANTOOLINK also uses personal data, including contact informa tion, to route invitations and messages to recipients when people send invitations and mes sages using BANTOOLINK Products. This may also include using personal data for cus tomer support, which may include accessing audio, video, files, and messages, at the direc tion of the account owner or their users. We also use personal data to manage our relation ship and contracts with account owners, including billing, compliance with contractual  

obligations, and related administration. 

  • Product Research and Development: To develop, test, and improve BANTOOLINK Pro ducts, including, for example, content-related features (such as background filters), and to  troubleshoot products and features. 
  • Marketing and Promotions: To market, advertise, and promote BANTOOLINK Products,  features, and services, including marketing products or features based on your product usage  or information we receive from third-party partners. If you visit our websites, we may log  information about how and when you visit, and your interactions with them, and use this  information to provide advertisements to you relating to BANTOOLINK Products, features,  and services or to engage third-party marketing partners to log your interactions on our web 

site or deliver advertising to you.  

  • Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, de tect, investigate, and prevent malicious conduct or unsafe experiences, address security  threats, protect public safety, and secure BANTOOLINK Products.  
  • Communicate with You: We use personal data (including contact information) to commu nicate with you about our Products, features, 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 discov ery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential  violations of our Terms of Service or policies. 

BANTOOLINK uses advanced tools to automatically scan content such as virtual backgrounds,  profile images, and files uploaded or exchanged through chat, for the purpose of detecting and pre venting violations of our terms or policies and illegal or other harmful activity, and its employees  may investigate such content where required for legal, safety, or security reasons. 

How Do We Share Personal Data?  

BANTOOLINK 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 BANTOOLINK from a third-party reseller of  BANTOOLINK Products, the reseller may be able to access personal data and content for  users, including meetings, webinars, and messages hosted by the account owner. 
  • Vendors: BANTOOLINK works with third-party service providers to provide, support, and  improve BANTOOLINK Products and technical infrastructure. BANTOOLINK may also  work with third-party service providers to provide advertisements and business analytics  regarding BANTOOLINK Products. 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 BANTOOLINK  or as required by law. 

  • For Legal Reasons: BANTOOLINK may share personal data as needed to: (1) comply with  applicable law or respond to, investigate, or participate in valid legal process and procee dings, 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 po tential 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 and Analytics Partners: BANTOOLINK uses third-party marketing and adver tising providers to provide statistics and analysis about how people are using our website  and to provide advertising and marketing, including targeted advertising based on your use  of our website. These third-party partners may receive information about your activities on  BANTOOLINK"s website through third-party cookies placed on BANTOOLINK "s website. To opt out of our use of third-party cookies that share data with these partners, visit our co okie management tool. Where required by law, BANTOOLINK will first obtain your  consent before engaging in the activities described here. 
  • Corporate Affiliates: BANTOOLINK shares personal information with corporate affiliates,  such as Border Blaster Group VoiceCommunications, Division, to provide integrated and  consistent experiences across BANTOOLINK Products (such as enabling a user to integrate  a BANTOOLINK 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 BANTOOLINK  "s business or assets, including in connection with bankruptcy or similar proceedings. 

Who Can See and Share My Personal Data  When I Use BANTOOLINK ?  

When you send messages or join group meetings and webinars on BANTOOLINK, 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  BANTOOLINK account. Typically, an account owner designates one or more people (cal led an !administrator”) to manage their account and can grant privileges to users on the ac count. Depending on their license with BANTOOLINK , 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) to meetings or webinars hosted on their ac count.  

BANTOOLINK gives account owners controls and features that they can use to determine  whether certain types of content, such as recordings or out-of-meeting 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 people they designate  can access personal data for people 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 people 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 informa tion about who joined meetings or webinars on their account, whether users  viewed or downloaded a recording, how long people participated in their  meetings, the time a message was sent, information about BANTOOLINK  Phone integrations, and other usage information and feedback metrics.  
  • Participant List: Information about the participants in a BANTOOLINK  meeting, webinar, or chat, which may include name, display name, email ad dress, phone number, and participant or user ID. 
  •  Registration Information: Information provided during registration for a webinar,  meeting, or recording hosted by the account.  
  • BANTOOLINK Chat Out-of-Meeting Messages: If enabled on their account,  account owners can see information about who sent and received out-of-meeting  messages to users on their account along with information about the message (for  example, date and time, and number of participants). Depending on their settings,  account owners also can see sender and receiver information, and other messaging  data, along with the content of messages sent to and from users on their account, un less the account owner has enabled Advanced Chat Encryption.  
  • 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 panelists in a webinar that is recorded  
  • Direct messages if the account owner has enabled archiving 
  • Recordings: Account owners can watch the content of recordings of meetings and  webinars hosted on their account. They can also view a transcript of meeting audio,  if enabled.  
  • 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 re quests, including name and contact information, together with the responses or feed back, unless responses are submitted anonymously.  
  • Meeting Hosts and Participants: Hosts and other participants in a meeting may be able to  see your email, display name, and profile picture. Meeting hosts and participants can also  see and (depending on the account owner"s settings) record or save meeting content, audio transcripts, messages sent to Everyone or to them directly, and files, whiteboards, or other  information shared during a meeting. Hosts may also be able to see responses to Q&A and  polls generated during the meeting. 
  • Webinar Panelists and Attendees: Only panelists may be visible to attendees during a  webinar, but attendees who agree to unmute can be heard by other attendees. If an attendee  agrees to become a panelist during a webinar, they may be visible to other attendees, depen ding on settings. Panelists and attendees may be able to see the name of a participant who  asks a question during a Q&A, along with their question, unless the participant submits the  question anonymously. 
  • 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.  
  • Third-Party Apps and Integrations: 
  • Account owners can choose to add third-party apps to their account and the BAN TOOLINK Products they use, and they can also give their users permission to add  and use specific third-party apps, including in meetings, webinars, and chats hosted  on their account. Depending on their settings, account owners and their users and  guests can share your personal data and content with third-party apps and integra tions they approve, which may include all of the personal data available to account  owners, hosts, and participants listed above, such as account information, profile and  contact information, registration information, participants list, settings, content, pro duct usage, and device information.  
  • Other participants in the meeting may be able to see the third-party app that you are  using in a meeting, if the third-party app is receiving real-time features and informa tion from the meeting.  
  • Third-party developers may also integrate or embed BANTOOLINK meetings into  their website or app experiences or build versions of BANTOOLINK that enable ac cess to BANTOOLINK Products from a third-party app. 
  • Personal information shared by account owners and users with third-party apps and  integrations is collected and processed in accordance with the app developers" terms and privacy policies, not BANTOOLINK "s. 

 

Privacy Rights and Choices  

If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of Califor nia, please refer to the respective dedicated sections below. Otherwise, at your request, and as re quired 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 to applicable tools; and/or  
  • Delete such personal data or direct you to applicable tools.  

In order to exercise any of your rights as to personal data controlled by BANTOOLINK, or if you  have any other questions about our use of your personal data, please send a request to  privacy@mybantoolink.com Please identify yourself and, for information relating to BANTOO LINK Products, specify your account and/or user information and other information to enable us to  authenticate and respond to your request. Where legally permitted, we may decline to process re quests 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.  

Children  

BANTOOLINK does not allow children under the age of 16 to sign up for a BANTOOLINK ac count.  

How to Contact Us  

To exercise your rights or if you have any privacy-related questions or comments related to this Pri vacy Statement, please send an email to privacy@bantoolink.com 

You can also contact us by writing to the following address: 

Border Blaster Group Video Communications, Inc.  

Attention: Data Privacy Officer  

Frejgatant 13, 11479 

Stockholm, Sweden  

email: privacy@bantoolink.com  

You can contact our Data Protection Officer by sending an email: privacy@bantoolink.com 

Retention  

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 BANTOOLINK Products 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 en forcement of our agreements, the resolution of disputes, and applicable statutes of limita tions, litigation, or regulatory investigation).  

European Data Protection Specific Informa tion 

Data Subjects Rights  

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data pro cessed 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 incom plete 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 person al data we hold about you is not accurate or lawfully held).  

In order to exercise any of your rights as to personal data controlled by BANTOOLINK, or if you  have any other questions about our use of your personal data, please send a request at the contact  details specified in the How to 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 en 

sure 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.  

Legal Basis for Processing Personal Data  

We only use your information in a lawful, transparent, and fair manner. Depending on the specific  personal data concerned and the factual context, when BANTOOLINK processes personal data as a  controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the fol lowing 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 BANTOOLINK Products,  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, features, and services;  
  • Consistent with specific revocable consents: We rely on your prior consent in order to uti lize 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; 
  • 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, go vernmental, 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 or der 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 overrid den 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 (which includes billing, compliance with contractual obligations, and related ad ministration and support); (ii) develop, test, and improve our Products and troubleshoot  products and features; (iii) ensure authentication, integrity, security, and safety of accounts,  activity, and Products, 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 (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, compe tent 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.  

International Data Transfers 

BANTOOLINK 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 col lected where BANTOOLINK or its service providers have customers or facilities – including in  countries where meeting participants or account owners hosting meetings or webinars that you par ticipate in or receiving messages that you send are based.  

Therefore, by using BANTOOLINK Products 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 ade 

quate level of data protection, we ensure that the transfer is governed by the European Commis sion"s standard contractual clauses. Please contact us if you would like further information in that respect. 

California Privacy Rights  

California Consumer Privacy Act

Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right  to: 

  • Access the categories and specific pieces of personal data BANTOOLINK 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 BANTOO LINK has shared personal data; 
  • Delete personal data under certain circumstances; and  
  • Opt out of the !sale” of personal data. We do not sell your personal data in the conventional sense. However, like many companies, we use advertising services that try to tailor online  ads to your interests based on information collected via cookies and similar technologies  about your online activity. This is called interest-based advertising. The CCPA"s statutory definition of the term !sale” is broad and may include interest-based advertising. You can get more information and opt out of the use of cookies on our sites for interest-based advertising  purposes by clicking the Do Not Sell My Personal Information link, in the webpage footer,  and setting your preferences. 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 reset your  settings. 

BANTOOLINK will not discriminate against you for exercising any of these rights, which is further  in line with your rights under the CCPA.  

To exercise your rights, contact us by emailing : privacy@bantoolink.com 

 To opt out of the use of cookies on our sites for interest-based advertising purposes, follow the in structions above. 

We will acknowledge receipt of your request within 10 business days, and provide a substantive re sponse within 45 calendar days, or inform you of the reason and extension period (up to 90 days) in  writing. 

Under the CCPA, only you or an authorized agent may make a request related to your personal data.  Note that to respond to your requests to access or delete personal data under the CCPA, we must  verify your identity. We may do so by requiring you to log into your BANTOOLINK account (if  applicable), provide information relating to your account (which will be compared to information  we have, such as profile information), give a declaration as to your identity under penalty of perjury,  and/or provide additional information. You may designate an authorized agent to submit your veri 

fied consumer request by providing written permission and verifying your identity, or through proof  of power of attorney. 

California"s Shine the Light 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 pur poses.  

Changes to This Privacy Statement 

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 noti fy you and provide you an opportunity to review before you choose to continue using our Products.