Privacy Policy for vOffice World
Data Controller for Processing under the EU General Data Protection Regulation (GDPR)
The data controller within the meaning of the General Data Protection Regulation (GDPR) and other data protection laws applicable in the member states of the European Union, as well as other provisions with data protection characteristics, is:
vOffice World Communication Equipment Trading L.L.C
19th Floor Conrad Dubai, Sheikh Zayed Road, PO Box 5610, Dubai, UAE
Email: info@voffice-world.ae
Privacy Policy vOffice World
We welcome you to our websites and appreciate your interest. The protection of your personal data is important to us. For this reason, we conduct our activities in accordance with the applicable legal provisions regarding the protection of personal data and data security. Below, we would like to inform you about which data from your visit is used and for what purposes.
1. What is personal data?
The term personal data is defined in the (German) Federal Data Protection Act (BDSG) and the EU General Data Protection Regulation (GDPR). It refers to any information relating to the personal or material circumstances of an identified or identifiable natural person. This includes, for example, your legal name, address, telephone number, or date of birth.
2. Legal Basis for the Processing of Personal Data
Where we obtain the consent of the data subject for the processing of personal data, Article 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.
When the processing of personal data is necessary for the performance of a contract to which the data subject is a party, Article 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations that are necessary for carrying out pre-contractual measures.
Where the processing of personal data is required to fulfill a legal obligation to which the controller is subject, Article 6(1)(c) GDPR serves as the legal basis.
In the event that the processing of personal data is necessary to protect the vital interests of the data subject or another natural person, Article 6(1)(d) GDPR serves as the legal basis.
If the processing is necessary to safeguard our legitimate interest or that of a third party, and this interest is not overridden by the interests, fundamental rights, or freedoms of the data subject, Article 6(1)(f) GDPR serves as the legal basis for the processing.
3. Use of Cookies
The web-based solution vOffice World uses cookies within the framework of Local Storage. Cookies are data stored by the internet browser on the user's computer system. Cookies can be transmitted to the respective page when it is accessed, allowing the user to be identified. Cookies help to simplify the use of websites for users. This constitutes our legitimate interest in processing personal data under Article 6(1)(f) GDPR. We use cookies in vOffice that ensure the simplified and secure use of our solution. Our cookies only record the user's settings and access authorizations. It is possible to object to the setting of cookies at any time by changing the settings in the internet browser accordingly. Cookies that have been set can be deleted. Please note that if cookies are deactivated, using the vOffice World solution may become more complicated.
When visiting our website, users are informed via an information banner about the use of cookies for analytical purposes and are referred to this privacy policy. In this context, there is also a notice explaining how the storage of cookies can be prevented in the browser settings.
4. Collection of Personal Data
Each time the website is accessed, vOffice World Communication Equipment Trading L.L.C collects data and information through an automated system. This data is stored in the server's log files. The data is also stored in the log files of our system. Various types of data are processed when using vOffice World. The extent of the processed data also depends on the information you provide before or during participation in an online meeting. All data is encrypted during transmission and encrypted when stored. The following personal data is subject to processing:
- Information about the browser type and version used
- The user's IP address
- Date and time of access
Additionally, the following personal data may be collected during the setup of a user and the use of the vOffice World product:
- Title
- vOffice World username
- Picture (optional)
- Email address
- Representation
- ID
- User rights
- Company role
- Work location
- Qualification
- Phone (extension, mobile phone)
- Device
- Real office weekly hours
- Home office weekly hours
- Invitation (automatic invitation email)
- Administrative settings
- Guest users (name, email)
- Messages
- Call logs
- File logs
- Metadata from video conferences
Personal user settings and login credentials are stored in your browser. In "Entry Mode" (default setting), vOffice World stores and displays the user's name, email address, and administrator status on the application's user interface. To participate in an online meeting or enter the "conference room," you are required to provide at least your name.
Users, such as companies or other organizations that use vOffice World for their purposes, also have the option to select an additional profile for the organization that allows for individual customization and stores and displays a range of data: availability for calls, location (home office, real office, on the go), weekly hours, first user login, out of office, calendar entries, attendance times, vacation times. The user can voluntarily add a photo.
5. Registration
Registration
If the data subject uses the option to register on the website of the data controller by providing personal data, the data entered in the respective input form will be transmitted to the data controller. The data will be stored exclusively for internal use by the data controller. The data will be deleted as soon as they are no longer necessary for the purpose of their collection.
During registration, the user's IP address and the date and time of registration are stored. This serves to prevent misuse of the services. The data will not be passed on to third parties unless there is a legal obligation to do so.
The registration of the data is necessary for the provision of content or services. Registered persons have the right to request the deletion or modification of their stored data at any time. The data subject can also obtain information about their stored personal data at any time.
When you register, personal data is either stored locally on our server (e.g., user's email address or profile picture) or in a web database (e.g., company name, address data, contact details, data about current position and qualification). In any case, an appropriate level of security in accordance with Article 32 GDPR is ensured.
Please note that both the terms of use and, if applicable, the data processing agreement in accordance with Article 28 GDPR between you and vOffice World Communication Equipment Trading L.L.C must be agreed upon before any processing can take place.
Legal Basis
The legal basis is our contractual relationship in accordance with Article 6(1)(b) GDPR.
Duration of Processing
The data will be deleted as soon as they are no longer necessary for the purpose of their collection. Furthermore, the data will be deleted if you withdraw your consent or request the deletion of the personal data.
6. Invitations to vOffice World
You can use the invitation function to invite employees, customers, or guests into your vOffice World environment. If the invitation function is filled with the personal data of the invited person, this data will be transmitted to the data controller. The data subject will receive an email after the information is entered, requesting them to register in vOffice World. This email already contains the vOffice World privacy policy and our terms of use, ensuring that subsequent consents can always be obtained in an informed manner by you.
When inviting users to vOffice World, only the name and email address are required, and no categories of special personal data are collected. Therefore, our legal basis for processing the invitation is Article 6(1)(f) GDPR.
7. Video Conferencing in vOffice World
It is possible to conduct video conferences within vOffice World between multiple users. The data transmission of the video conference is carried out via end-to-end encryption, meaning that vOffice World itself has no access to this data. If users send direct messages via vOffice World or exchange files, this processing also occurs without intermediate storage in vOffice World’s cloud storage, and the communication is secured through a peer-to-peer connection. From the moment our customers organize and conduct video conferences using vOffice World, our customers are responsible for this processing and must ensure or obtain a legal basis for such processing. Therefore, vOffice World offers you, based on an editable template for informed consent in accordance with Article 9(2)(a) GDPR in conjunction with Article 7 GDPR, the opportunity to obtain a legal basis before processing categories of special personal data. The informed consent is provided through a click confirmation and is available to the data subject along with the microphone and video settings options. Once the data subject has given their explicit and informed consent, the responsible customer will receive confirmation of this consent as a separate email to fulfill accountability obligations.
Please note that the indication of whether consent has been given or not, as well as the microphone and video settings, must be reset after clearing the browser cache.
8. Support for vOffice World
vOffice World includes a support function that can be used for electronic contact for support purposes. Alternatively, contact can be made via the provided email address. If the data subject contacts the data controller through one of these channels, the personal data transmitted by the data subject will be automatically stored. This storage is solely for the purpose of processing or contacting the data subject.
The legal basis for processing data transmitted via email is Article 6(1)(f) GDPR. If the email contact aims to fulfill a contract, an additional legal basis for processing is Article 6(1)(b) GDPR.
The data will be deleted once they are no longer necessary for the purpose of their collection. For personal data provided through the contact form or via email, this occurs when the conversation with the user has ended. The conversation is considered ended when it can be inferred from the circumstances that the relevant issue has been conclusively resolved.
9. Routine Deletion and Blocking of Personal Data
The data controller processes and stores personal data of the data subject only for as long as necessary to achieve the storage purpose. Storage may also occur if required by European or national legislators in EU regulations, laws, or other provisions to which the data controller is subject.
Once the storage purpose no longer applies, or a legally mandated retention period expires, the personal data will be routinely blocked or deleted.
10. Rights of the Data Subject
If your personal data is processed, you are a data subject within the meaning of the GDPR, and you have the following rights vis-à-vis the data controller:
10.1 Right of Access
You can request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing is taking place, you can request the following information from the controller:
- the purposes for which the personal data is being processed;
- the categories of personal data being processed;
- the recipients or categories of recipients to whom your personal data has been or will be disclosed;
- the intended duration of the storage of your personal data or, if specific details are not possible, the criteria used to determine the storage duration;
- the existence of a right to rectification or erasure of your personal data, a right to restrict processing by the controller, or a right to object to such processing
- the existence of a right to lodge a complaint with a supervisory authority;
- all available information about the source of the data, if the personal data was not collected from the data subject;
- the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved as well as the significance and intended consequences of such processing for the data subject.
You have the right to request information as to whether your personal data is transferred to a third country or an international organization. In this context, you can request to be informed about the appropriate safeguards pursuant to Article 46 GDPR in connection with the transfer.
10.2 Right to Rectification
You have the right to rectification and/or completion by the controller if the personal data being processed concerning you is inaccurate or incomplete. The controller must carry out the correction without undue delay.
10.3 Right to Restriction of Processing
You can request the restriction of the processing of your personal data under the following conditions:
- if you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of its use;
- the controller no longer needs the personal data for processing purposes, but you require it for the establishment, exercise, or defense of legal claims; or
- if you have objected to the processing pursuant to Article 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.
If the processing of your personal data has been restricted, these data – apart from being stored – may only be processed with your consent, for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or a Member State. If the restriction of processing has been applied under the above conditions, you will be informed by the controller before the restriction is lifted.
10.4 Right to Erasure
You have the right to request the controller to erase your personal data without undue delay, and the controller is obligated to erase the data without undue delay if one of the following reasons applies:
- The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
- You withdraw your consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) GDPR, and there is no other legal basis for the processing.
- You object to the processing pursuant to Article 21(1) GDPR, and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR.
- The personal data concerning you have been unlawfully processed.
- The deletion of the personal data concerning you is required to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
- The personal data concerning you were collected in relation to the offer of information society services pursuant to Article 8(1) GDPR.
If the controller has made your personal data public and is obliged to delete them pursuant to Article 17(1) GDPR, the controller, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that you, as the data subject, have requested the deletion of any links to, or copies or replications of, those personal data.
The right to erasure does not apply to the extent that the processing is necessary
- for the exercise of the right to freedom of expression and information;
- for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) GDPR, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise, or defense of legal claims.
10.5 Right to Notification
If you have exercised your right to rectification, erasure, or restriction of processing under the GDPR, the controller is obligated to notify all recipients to whom your personal data have been disclosed about these corrections, deletions, or restrictions on processing, unless this proves impossible or involves disproportionate effort.
You also have the right to be informed about these recipients upon request by the controller.
10.6 Right to Data Portability
Under the GDPR, you have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used, and machine-readable format. You also have the right to transmit those data to another controller without hindrance from the controller to whom the data were provided, where:
- The processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a), or on a contract pursuant to Article 6(1)(b); and
- The processing is carried out by automated means.
In exercising this right, you also have the right to ensure that your personal data are transmitted directly from one controller to another, where technically feasible. This must not adversely affect the rights and freedoms of others.
The right to data portability does not apply to the processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
10.7 Right to Object
You have the right to object, at any time and on grounds relating to your particular situation, to the processing of your personal data based on Article 6(1)(e) or (f) GDPR, including profiling based on these provisions.
The controller will no longer process your personal data unless they can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
If your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to direct marketing.
If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes. You also have the option, in connection with the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise your right to object by automated means using technical specifications.
10.8 Right to Withdraw Consent
You have the right to withdraw your data protection consent declaration at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent before its withdrawal.
10.9 Automated Individual Decision-Making, Including Profiling
You have the right not to be subject to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:
- is necessary for entering into or performing a contract between you and the controller;
- is authorized by Union or Member State law to which the controller is subject, and which also lays down suitable measures to safeguard your rights, freedoms, and legitimate interests; or
- is based on your explicit consent.
However, such decisions must not be based on special categories of personal data as referred to in Article 9(1) GDPR, unless Article 9(2)(a) or (g) GDPR, applies and appropriate measures have been taken to protect your rights, freedoms, and legitimate interests.
In the cases referred to in points (a) and (c), the controller must implement suitable measures to safeguard your rights, freedoms, and legitimate interests, which must include at least the right to obtain human intervention on the part of the controller, to express your point of view, and to contest the decision.
10.10 Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data infringes the GDPR.
The supervisory authority with which the complaint has been lodged will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 GDPR.
Berlin Commissioner for Data Protection and Freedom of Information
Maja Smoltczyk
Friedrichstr. 219
10969 Berlin
Tel.: +49 (0)30 13889-0
Fax: +49 (0)30 2155050
Email: mailbox@datenschutz-berlin.de
11. Disclosure of Data to Third Parties
All servers required for the application are located in Germany at the data center Limburg of the OVH GmbH, St. Johanner Str. 41-43, 66111 Saarbrücken, which also serves as a data processor.
The stored data are encrypted at all times, with only access to metadata being available. As the holder of the encryption key, you can access your data at any time.
Users also have the option to operate the required servers within their own IT systems, ensuring full control over all processed data.
Processors are bound by contracts in accordance with Article 28 GDPR and § 43e(3) of the (German) Federal Lawyers' Act (BRAO). They are obligated to confidentiality and may only act upon instructions from the controller. Your data will only be disclosed to third parties where there is a legal obligation to do so.
11.1. Use of Twilio
We offer our customers optional two-factor authentication (2FA) functionality within our software solution, one of which uses SMS as the authentication method. For this purpose, we use the SMS service provider Twilio. Twilio only receives the mobile phone number that the user has entered themselves for the 2FA function to send the SMS. No other data is exchanged.
These mobile phone numbers are stored on Twilio’s servers in the USA. Twilio uses this information to send SMS tokens on our behalf. According to Twilio, they may also use this data to optimize or improve their services, such as for the technical enhancement of SMS delivery and presentation of SMS tokens, or for business purposes, such as determining the countries of the recipients. However, Twilio does not use our users' data to contact them directly or to pass the information on to third parties.
Legal basis
The legal basis for the processing of personal data is our legitimate interest in the efficient provision of SMS functions pursuant to Article 6(1)(f) GDPR.
Recipients
The recipient is Twilio Germany GmbH, located at Rosenheimerstrasse 143c, 80337 Munich, Germany. Due to technical reasons, Twilio may rely on the servers of its parent company, Twilio Inc., located at 375 Beale Street, Suite 300, San Francisco, CA 94105, USA.
Transfer to Third Countries
A transfer of data to a third country does not take place.
Duration of Data Storage
The data will be deleted as soon as it is no longer necessary for the purpose for which it was collected. Furthermore, the data will be deleted if you withdraw your consent or request the deletion of the personal data.
Right to Object
You have the right to object to this data processing at any time. An objection does not affect the lawfulness of data processing operations that have occurred in the past.
Contractual or Legal Obligation
There is no contractual or legal obligation to provide the data.
Further data protection information via link
For more information on data processing and data protection by Twilio, please visit the following link: https://www.twilio.com/legal/privacy
12. Duration of Personal Data Storage
Personal data will be stored for the duration of the applicable statutory retention period. After the retention period has expired, the data will be routinely deleted unless it is necessary for the initiation or fulfillment of a contract.
13. Security
We have implemented extensive technical and operational safeguards to protect your data from accidental or intentional manipulation, loss, destruction, or unauthorized access. Our security procedures are regularly reviewed and adjusted in line with technological advancements. Additionally, we continuously ensure data protection through ongoing audits and optimization of our data protection organization.
We guarantee an appropriate level of protection in accordance with Article 32 GDPR. The specific technical and organizational measures are included as annexes to the data processing agreement, allowing you to review and verify our high security standards for yourself.
13.1 Information on Protocols and Encryption Methods Used
The encryption of content data is carried out using the DTLS-SRTP protocol. Signaling data is encrypted using TLS/DTLS (Data Transport Layer Security), with a key length of 256 bits. These encryption methods are integrated by default in WebRTC-enabled browsers such as Chrome, Firefox, and Opera. Encryption on the system side is exclusively handled with TLS 1.2 or 1.3 protocols; lower versions are not permitted.
DTLS is an extension of the TLS protocol, providing additional security measures such as restoring the reliability of the handshake at the start of communication by resending packets after a certain period to ensure all packets are received. This also enables authentication and key exchange. Another measure includes the explicit numbering of individual packets during transmission, as well as optional Replay Detection for individual packets.
In addition, SRTP (Secure Real-Time Protocol) is used, which is an extension of the RTP protocol. SRTP provides additional security functionalities such as message authentication, confidentiality protection, and replay protection. Through authentication and encryption, SRTP helps minimize security risks, including Denial of Service (DoS) attacks. SRTP is implemented with AES 128-bit encryption.
Beyond the WebRTC standard, the transmission of signaling data is secured through SSL protection, with authentication via appropriate certificates to prevent logging and manipulation attacks.
vOffice uses Signaling, STUN, and TURN servers.
The Signaling Server manages and secures the peer-to-peer network. It establishes the connection between participants and serves as storage for metadata and the user data described above.
STUN Servers (Session Traversal Utilities for NAT) enable communication with devices within corporate networks. If your devices only have a local IP address (common in corporate networks), a STUN server maps them to a publicly accessible IP address. This public IP is used to establish a connection between the two endpoints. STUN is an infrastructure component of WebRTC (and VoIP), with the protocol defined in RFC 3489. Communication occurs between the peers of a WebRTC session and a STUN server.
TURN Servers (Traversal Using Relay NAT) are required in WebRTC applications to relay traffic between two peers when direct transmission is not technically possible. The TURN protocol is defined in RFC 5766. A TURN server only forwards the encrypted SRTP user packets without having access to the packet contents.
The Signaling, TURN, and STUN servers can also be operated on your organization's own IT systems.
vOffice World Communication Equipment Trading L.L.C reserves the right to make changes and updates to this privacy policy