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Snapshot 49990

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Privacy policy
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https://www.digitalsamba.com/hubfs/legal-and-compliance/Privacy-Policy.pdf
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Scripts and page chrome removed; this is what change detection compares.

                                           ​Privacy Policy​
​Last modified:​ ​15 October, 2025 - This Privacy Policy is effective as of the “last modified” date. By​
                  ​continuing to use the Services, you acknowledge acceptance of these changes.​
                   ​Prior versions of this policy can be found​​here​​.​

​Changes:​               ​Included the new SaaS product line.​

​ his is a supplement to the​​Digital Samba Customer​​Agreement​​(the “​​Agreement​​”) and is thereby​
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​included in the Agreement. Any capitalised terms used but not defined below derive their​
 ​meanings from the Agreement.​

​1. What this Privacy Policy covers​
​ e are committed to safeguarding your personal information in accordance with the stringent​
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​regulations laid out by the General Data Protection Regulation (GDPR). We have taken​
 ​comprehensive measures to ensure the protection and confidentiality of your data, and we want to​
  ​make it unequivocally clear that we will never engage in the sale or monetisation of your personal​
   ​information. Your trust is invaluable to us, and we are dedicated to providing you with a safe and​
    ​transparent experience while using our services.​

​ his Privacy Policy outlines our unwavering commitment to your privacy and the steps we take to​
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​uphold it. In what follows, we aim to explain what information about you is collected, used and​
 ​shared by Digital Samba SL and its related entities ("​​Digital Samba​​", “we”, “us”, “our”). You will​
  ​learn:​

​​
●          ​ hat information we collect about you​
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​●​        ​How we process information we collect and legal bases​
 ​●​        ​How we share information we collect​
  ​●​        ​How we store and secure information we collect​
   ​●​        ​How to access and control your information​
    ​●​        ​How we transfer information we collect internationally​
     ​●​        ​Other important privacy information​

​ his policy covers the information we collect about you when you use our products or services, or​
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​otherwise interact with us (e.g. by attending our webinars or events), unless a different policy is​
 ​displayed. We offer a range of products, including cloud and server products. Collectively, we refer​
  ​to all our products, services and websites as "​​Services​​" in this policy.​

​ or the purposes of this policy, “​​Embedded​​” means Digital Samba’s embedded​
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​video-conferencing product integrated into third-party platforms via API/SDK (for example, the​
 ​product administered at dashboard.digitalsamba.com); “​​Samba Live​​” means Digital Samba’s​
  ​legacy SaaS video-conferencing product (for example, the product available at​

​1​.        Privacy Policy​                                               ​© Digital Samba, SL. All rights reserved.​
​ pp.digitalsamba.com); “​​DS Free​​” means Digital Samba’s next-generation SaaS​
a
​video-conferencing product (for example, the product available at​​my.digitalsamba.com​​).​

“​ ​SaaS Products​​” means Samba Live and DS Free together. “​​Products​​” means Embedded, Samba​
 ​Live, and DS Free together. You may be an administrator of the Products, or you may simply be an​
  ​end user participating in online meetings, lectures, webinars, or similar collaborative events​
   ​(“​​Sessions​​” or “​​Session​​”).​

​All Services that are not the Products are referred to as our “​​Websites​​” in this policy.​

​ his policy explains your choices about how we use information about you when you use the​
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​Websites and the Products. Your choices include how you can object to certain uses of information​
 ​about you and how you can access and update certain information about you.​​If you do not agree​
  ​with this policy, do not access or use our Services or interact with any other aspect of our​
   ​business.​

​ here we provide the Services under contract with an organisation (e.g. your employer) that​
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​organisation controls the information processed by the Services. For more information, please see​
 ​section 8.1 (“​​Notice to End Users​​”) below.​

​2. What information we collect about you​
​ e collect information about you when you provide it to us, when you use our Services, and when​
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​other sources provide it to us, as further described below.​

​2.1. Information you provide to us​
​This section covers information that you provide to us through direct interaction with us.​

​ .1.1. Via our Websites.​​When you use our Websites,​​you have the option to interact with us or​
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​submit information to us via forms and other data input mechanisms. Below we list the data that​
 ​you could potentially provide. A form may contain required fields, but not all fields will always be​
  ​required in order to submit the form. At times, a form will be created for a specific purpose (e.g. a​
   ​one-time online event) and will therefore contain input fields that may not be listed here.​

​●​ C
    ​ ontact forms​
    ​first name, last name, email address, company name, position, telephone number, message​
     ​subject, message details.​

​●​ S
    ​ ubscription forms​​(newsletters, blog posts, product release updates)​
    ​email address.​

​●​ L
    ​ ive chat​
    ​first name, last name, email address, company name, position, phone number, chat messages,​
     ​uploaded files.​

​●​ A
    ​ ccount registration form​
    ​email address, chosen password.​

​2​.   Privacy Policy​                                                    ​© Digital Samba, SL. All rights reserved.​
​●​ P
    ​ urchase order form​​(may also be sent manually as​​a PDF via email)​
    ​first name, last name, email address, company name, phone number, product selection, billing​
     ​address (street, city, postal code, country), payment details (credit card number, expiration​
      ​date, card verification code).​

​●​ E
    ​ vent registration forms​​(seminars, workshops, other optional events)​
    ​first name, last name, email address, company name, position, telephone number, other​
     ​event-specific details.​

​●​ C
    ​ ontent download forms​​(e-books, whitepapers, other​​optional content)​
    ​first name, last name, email address, company name, position, telephone number, other​
     ​content-specific details.​

​●​ S
    ​ upport ticket form​
    ​first name, last name, email address, company name, message type, message subject,​
     ​message details, uploaded files.​

​●​ T
    ​ elephone calls​
    ​any details you provide during a phone call with our support or sales agents, calls may be​
     ​recorded for quality assurance (with your consent).​

​●​ W
    ​ ebsite search field​
    ​search terms.​

​ he above data is provided by you with explicit consent from you according to Article 6 (1)(a) of​
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​GDPR, with the exception of the website search terms, which are processed according to Article 6​
 ​(1)(b) of GDPR (required to perform the service).​

​ .1.2. Via our Embedded product.​​When you use the​​Embedded product, you have the option to​
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​submit the following information to us. Not all of this data is required to use the product, and you​
 ​may choose to submit information voluntarily.​

​●​ P
    ​ rofile information​
    ​first name, last name, email address, job title, phone number, company name, industry,​
     ​location.​

​●​ T
    ​ eam settings​
    ​team name, email addresses of team members, subdomain, custom CNAME, custom user role​
     ​data (name, identifier, description), room data (name, description, language), branding (logo,​
      ​colours, custom text), custom consent text and links, webhooks (URL, description,​
       ​authorisation header).​

​●​ S
    ​ ession participation information​
    ​user name,​​microphone audio, camera video, screen​​sharing, whiteboard content, chat​
     ​messages, uploaded content (images, files, URLs), poll content and responses, Q&A content​
      ​and responses, reactions, language, live-streamed content, recorded content.​

​3​.   Privacy Policy​                                                ​© Digital Samba, SL. All rights reserved.​
​ he above data is provided by you and collected by us to provide a functional product. The​
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​collection of this data is therefore necessary for the performance of the contract with you​
 ​according to Article 6 (1)(b) of GDPR.​

​ .1.3. Via our SaaS Products.​​When you use the SaaS Products, you have the option to submit the​
2
​following information to us. Not all of this data is required to use the product, and you may choose​
 ​to submit information voluntarily.​

​●​ P
    ​ rofile information​
    ​first name, last name, email address, username, profile photo, address (street, city, postal​
     ​code, country), date of birth, time zone, language, company name, industry, VAT ID.​

​●​ A
    ​ ccount information​
    ​custom room link, account password, branding details (logo images, redirect URLs,​
     ​background images, colours, Javascript code, custom platform URL, etc), account settings​
      ​(various settings for default state, permissions, etc).​

​●​ A
    ​ ddress book information​
    ​contact details (first name, last name, email address, contact image, company name, industry,​
     ​full address, job title, phone number, website URL, social media handles, VAT ID).​

​●​ S
    ​ ession administration information​
    ​Session title, Session description, start time/date, duration, friendly Session URL, Session​
     ​password, time zone, Session settings (calendar file, agenda, participant names, participant​
      ​email addresses, CSV files with participants, Session access settings, default media settings,​
       ​UI layout settings, event registration form settings).​

​●​ S
    ​ ession participation information​
    ​user name, microphone audio, camera video, screen sharing, whiteboard content, chat​
     ​messages, shared notes, uploaded content (images, files, URLs), poll content and responses,​
      ​Q&A content and responses, reactions, language, live-streamed content, recorded content.​

​ he above data is provided by you and collected by us to provide a functional product. The​
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​collection of this data is therefore necessary for the performance of the contract with you​
 ​according to Article 6 (1)(b) of GDPR.​

​2.2. Information we collect when you use the Services​
​This section covers information that we collect about you as you use the Services.​

​ .2.1. When you use our Websites.​​When you use our Websites, we collect the following data​
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​related to your interactions with the Websites.​

​●​ D
    ​ evice and connection information​
    ​device type (computer or mobile), operating system name and version, browser name and​
     ​version, IP address (to infer general location at a city or country level), URLs of referring​
      ​pages, telephone number used to dial into the Services.​

​4​.   Privacy Policy​                                                ​© Digital Samba, SL. All rights reserved.​
​●​ C
    ​ ookies and other tracking technologies​
    ​We use cookies and tracking technologies to provide functionality and to recognise you across​
     ​the Services. For more information, please see our​​Cookies & Tracking Notice​​, which includes​
      ​information on how to control or opt out of these cookies and tracking technologies.​

​ ith the exception of optional cookies (which are collected with explicit consent from you​
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​according to Article 6 (1)(a) of GDPR), the above data is collected by us to provide a functional​
 ​product according to Article 6 (1)(b) of GDPR.​

​ .2.2. When you use our Embedded product.​​When you​​use the Embedded product, we collect​
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​the following data related to your interactions with the product. The collection of data depends on​
 ​the features you use.​

  ​●​ D
      ​ evice and connection information​
      ​device type (computer or mobile), camera and microphone names (upon consent), operating​
       ​system name and version, browser name and version, IP address (to infer general location at​
        ​a city or country level), performance data, error data, crash data.​

  ​●​ Y
      ​ our use of the product​
      ​user ID, metadata of uploaded files, Session join data and time, time spent in Sessions,​
       ​features used, user ID’s of other Session participants, time spent broadcasting, time spent​
        ​screen sharing, audio-to-text transcriptions, Session summarisation.​

  ​●​ C
      ​ ookies and other tracking technologies​
      ​We use cookies and tracking technologies to provide certain product functionality. For more​
       ​information, please see our​​Cookies & Tracking Notice​​,​​which includes information on how to​
        ​control or opt out of these cookies and tracking technologies.​

I​f you use a server version of the Embedded product, server administrators can disable our​
 ​collection of data via configuration settings or prevent data from being shared with us by blocking​
  ​transmission at the local network level.​

​ he above data is collected by us to provide a functional product. The collection of this data is​
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​therefore necessary for the performance of the contract with you according to Article 6 (1)(b) of​
 ​GDPR.​

​ .2.3. When you use our SaaS Products.​​When you use the SaaS Products, we collect the​
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​following data related to your interactions with the product. The collection of data depends on the​
 ​features you use.​

  ​●​ D
      ​ evice and connection information​
      ​device type (computer or mobile), camera and microphone names (upon consent), operating​
       ​system name and version, browser name and version, IP address (to infer general location at​
        ​a city or country level), telephone number used to dial into the Services, performance​
         ​monitoring, error tracking, crash data.​

  ​●​ Y
      ​ our use of the product​
      ​user ID, metadata of uploaded files, Session join data and time, time spent in Sessions,​

​5​.   Privacy Policy​                                                 ​© Digital Samba, SL. All rights reserved.​
       f​ eatures used, user ID’s and user names of other Session participants, time spent​
        ​broadcasting, time spent screen sharing, audio-to-text transcriptions, Session​
         ​summarisation.​

  ​●​ C
      ​ ookies and other tracking technologies​
      ​We use cookies and tracking technologies to provide certain product functionality. For more​
       ​information, please see our​​Cookies & Tracking Notice​​, which includes information on how to​
        ​control or opt out of these cookies and tracking technologies.​

I​f you use a server version of the SaaS Products, server administrators can disable our collection​
 ​of data via configuration settings or prevent data from being shared with us by blocking​
  ​transmission at the local network level.​

​ he above data is collected by us to provide a functional product. The collection of this data is​
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​therefore necessary for the performance of the contract with you according to Article 6 (1)(b) of​
 ​GDPR.​

​2.3. Information we receive from other sources​
​ e receive information about you from other users of the Services, from third-party services, from​
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​our related companies, and from our business and channel partners.​

​ .3.1. Other users of the Services.​​Other users of​​our Services may provide information about you​
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​when they submit content through the Services. For example, you may be mentioned in a Session​
 ​invitation, in a live Session or in a Session recording. We also receive your email address from​
  ​other users of the Services when they provide it in order to invite you to the Services. Similarly, an​
   ​administrator may enter your contact information when they set up an account on your behalf for​
    ​you to use the Services.​

​ .3.2. Other services you link to your account.​​We​​receive information about you when you or​
2
​your administrator integrate or link a third-party service with our Services. You or your​
 ​administrator may also integrate our Services with other services you use, such as to allow you to​
  ​access, store, share and edit certain content from a third-party through our Services. For example,​
   ​you may authorise our Services to access, display and store files from a third-party​
    ​document-sharing or video-sharing service within the Services interface. Or you may authorise​
     ​our Services API to connect with a third-party calendaring service so that your Sessions are​
      ​available to you through the Services. The information we receive when you link or integrate our​
       ​Services with a third-party service depends on the settings, permissions and privacy policy​
        ​controlled by that third-party service. You should always check the privacy settings and notices in​
         ​these third-party services to understand what data may be disclosed to us or shared with our​
          ​Services.​

​ .3.3. Digital Samba Partners.​​We work with a global network of partners who provide consulting,​
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​implementation, training, and other services around our products. Some of these partners also​
 ​help us to market and promote our products, generate leads for us, and resell our products. We​
  ​receive information from these partners, such as billing information, billing and technical contact​
   ​information, company name, which of our products you have purchased or may be interested in,​

​6​.   Privacy Policy​                                                   ​© Digital Samba, SL. All rights reserved.​
​ valuation information you have provided, what events you have attended, and what country you​
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​are in.​

​ .3.4. Other Partners.​​We receive information about​​you and your activities on and off the​
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​Services from third-party partners, such as advertising and market research partners who provide​
 ​us with information about your interest in and engagement with our Services and online​
  ​advertisements.​

​3. How we process information we collect and legal bases​
​ ow we use the information we collect depends in part on which Services you use, how you use​
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​them, and any preferences you have communicated to us. Below are the specific purposes for​
 ​which we use the information we collect about you.​

​ .1. To provide the Services and personalise your experience.​​We use information about you to​
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​provide the Services to you, including to process transactions with you, authenticate you when you​
 ​log in, provide customer support, and operate and maintain the Services. For example, we use the​
  ​name you enter in the Services to identify you to other users of the Services. Our Services also​
   ​include tailored features that personalise your experience, enhance your productivity, and improve​
    ​your ability to collaborate effectively with others. When you use multiple Services, we combine​
     ​information about you and your activities to provide an integrated experience, such as to allow you​
      ​to find information from one component of the Services while searching from another component​
       ​of the Services, or to present relevant product information as you travel across our Services.​

​ .2. For research and development.​​We are always looking​​for ways to make our Services​
3
​smarter, faster, more secure, more integrated, and more useful to you. We use collective learnings​
 ​about how people use our Services and feedback provided directly to us to troubleshoot and to​
  ​identify trends, usage, activity patterns and areas for integration and improvement of the Services.​
   ​In some cases, we apply these learnings across our Services to improve and develop similar​
    ​features or to better integrate the Services you use. We also test and analyse certain new features​
     ​with some users before rolling the feature out to all users.​

​ .3. To communicate with you about the Services.​​We​​use your contact information to send​
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​transactional communications via email and within the Services, including confirming your​
 ​purchases, reminding you of subscription expirations, responding to your comments, questions​
  ​and requests, providing customer support, and sending you technical notices, updates, security​
   ​alerts, and administrative messages. We send you email notifications when you or others interact​
    ​with you on the Services, for example, when you are invited by another user to their Session, we​
     ​send you an email invitation with instructions on how to join that Session. We also send you​
      ​communications as you are on-boarded to the Services to help you become more proficient in​
       ​using the Services. Some of these communications are part of the Services and in those cases you​
        ​cannot opt out of them. If an opt out is available, you will find that option within the communication​
         ​itself.​

​ .4. To market, promote and drive engagement with the Services.​​With your consent, we use​
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​your contact information and information about how you use the Services to send promotional​
 ​communications that may be of specific interest to you, including by email and by displaying our​

​7​.   Privacy Policy​                                                     ​© Digital Samba, SL. All rights reserved.​
​ ds on other companies' websites and applications, as well as on platforms like Facebook and​
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​Google. These communications are aimed at driving engagement and maximising what you get out​
 ​of the Services, including information about new features, survey requests, newsletters, and​
  ​events we think may be of interest to you. We also communicate with you about new product​
   ​offers, promotions and contests. You can control whether you receive these communications as​
    ​described in section 6.1.6 ("Opt out of communications") below.​

​ .5. Customer support.​​We use your information to​​resolve technical issues you encounter, to​
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​respond to your requests for assistance, to analyse crash information, and to repair and improve​
 ​the Services.​

​ .6. For safety and security.​​We use information about​​you and your use of the Services to verify​
3
​accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of our​
 ​terms or policies.​

​ .7. To protect our legitimate business interests and legal rights.​​Where required by law or where​
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​we believe it is necessary to protect our legal rights, interests and the interests of others, we use​
 ​information about you in connection with legal claims, compliance, regulatory, and audit functions,​
  ​and disclosures in connection with the acquisition, merger or sale of a business.​

​ .8. With your consent.​​We use information about you​​where you have given us consent to do so​
3
​for a specific purpose not listed above. For example, we may publish testimonials or featured​
 ​customer stories to promote the Services, with your permission.​

​ .9 Legal bases for processing.​​According to applicable​​European Union (EU) laws, we collect​
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​and process information about you only where we have legal bases for doing so. The legal bases​
 ​depend on the Services you use and how you use them. This means we collect and process your​
  ​information only where:​

       ​●​ W
           ​ e need it to provide you the Services, including to operate the Services, provide​
           ​customer support and personalised features and to protect the safety and security of the​
            ​Services- Article 6 (1)(b) of the GDPR​

       ​●​ I​t satisfies a legitimate interest (which is not overridden by your data protection interests),​
            ​such as for research and development, to market and promote the Services and to protect​
             ​our legal rights and interests- Article 6 (1)(f) of the GDPR​

       ​●​ ​You give us consent to do so for a specific purpose- Article 6 (1)(a) of the GDPR​

       ​●​ ​We need to process your data to comply with a legal obligation- Article 6 (1)(c) of the GDPR​

I​f you have consented to our use of information about you for a specific purpose, you have the​
 ​right to change your mind at any time, but this will not affect any processing that has already taken​
  ​place. Where we are using your information because we or a third party (e.g. your employer) have​
   ​a legitimate interest to do so, you have the right to object to that use though, in some cases, this​
    ​may mean no longer using the Services.​

​8​.    Privacy Policy​                                                   ​© Digital Samba, SL. All rights reserved.​
​4. How we share information we collect​
​ e make collaboration tools, and we want them to work well for you. This means sharing​
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​information through the Services and with certain third parties. We share information we collect​
 ​about you in the ways discussed below, including in connection with possible business transfers,​
  ​but we are not in the business of selling information about you to advertisers or other third parties.​

​4.1. Sharing with other users of the Services​
​ hen you use the Services, we share certain information about you with other users of the​
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​Services.​

​ .1.1 For collaboration.​​You can create content, which​​may contain information about you, and​
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​grant permission to others to see, share, edit, copy and download that content based on settings​
 ​you or your administrator (if applicable) select. Some of the collaboration features of the Services​
  ​display some or all of your profile information to other users of the Services when you share or​
   ​interact with specific content. For example, when you join a Session, we display your name so that​
    ​other users with access to the Session understand who they are interacting with. When you send a​
     ​chat message to another user or a group of users in the Session, the recipients will see your name​
      ​next to the chat message. Similarly, when you message or send invitations to other users, your​
       ​name and email is displayed as the sender of that message. Please be aware that some aspects of​
        ​the Services like public pages or event registration pages can be made publicly available, meaning​
         ​any content posted, including information about you, can be publicly viewed and indexed by and​
          ​returned in search results of search engines. You can confirm whether certain properties of the​
           ​Services are publicly visible from within the Services or by contacting the relevant administrator.​

​ .1.2. Managed accounts and administrators.​​If you​​register or access the Services using an​
4
​email address with a domain that is owned by your employer or organisation, and such​
 ​organisation wishes to establish an account or site, certain information about you including your​
  ​name, contact info, content and past use of your account may become accessible to that​
   ​organisation’s administrator and other users of the Services sharing the same domain. If you are an​
    ​administrator for a particular site or group of users within the Services, we may share your contact​
     ​information with current or past users of the Services, for the purpose of facilitating​
      ​service-related requests.​

​ .1.3. Community Forums.​​Our Websites offer publicly accessible blogs, forums, issue trackers,​
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​and wikis. You should be aware that any information you provide on our Websites - including​
 ​profile information associated with the account you use to post the information - may be read,​
  ​collected, and used by any member of the public who accesses our Websites. Your posts and​
   ​certain profile information may remain even after you terminate your account. We urge you to​
    ​consider the sensitivity of any information you input into these Services. To request removal of​
     ​your information from our publicly accessible Websites, please contact us as provided below. In​
      ​some cases, we may not be able to remove your information, in which case we will let you know if​
       ​we are unable to and why.​

​9​.   Privacy Policy​                                                     ​© Digital Samba, SL. All rights reserved.​
​4.2. Sharing with third parties​
​ e share information with third parties that help us operate, provide, improve, integrate,​
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​customise, support and market our Services.​

​ .2.1. Service Providers.​​We work with third-party​​service providers to provide website and​
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​application development, hosting, maintenance, backup, storage, virtual infrastructure, payment​
 ​processing, analysis and other services for us, which may require them to access or use​
  ​information about you. If a service provider needs to access information about you to perform​
   ​services on our behalf, they do so under close instruction from us, including policies and​
    ​procedures designed to protect your information.​

​ .2.2. Digital Samba Partners.​​We work with third​​parties who provide consulting, sales, and​
4
​technical services to deliver and implement customer solutions around the Services. We may share​
 ​your information with these third parties in connection with their services, such as to assist with​
  ​billing and collections, to provide localised support, and to provide customisations. We may also​
   ​share information with these third parties where you have agreed to that sharing.​

​ .2.3. Third Party Apps.​​You, your administrator or​​other users of the Services may choose to add​
4
​new functionality or change the behaviour of the Services by integrating and running them within​
 ​third party apps. Doing so may give third-party apps access to your account and information about​
  ​you like your name and email address, and any content you choose to use in connection with those​
   ​apps. Third-party app policies and procedures are not controlled by us, and this privacy policy​
    ​does not cover how third-party apps use your information. We encourage you to review the​
     ​privacy policies of third parties before connecting to or using their applications or services to learn​
      ​more about their privacy and information handling practices. If you object to information about you​
       ​being shared with these third parties, please uninstall the third-party apps.​

​ .2.4. Links to Third Party Sites.​​The Services may​​include links that direct you to other websites​
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​or services whose privacy practices may differ from ours. If you submit information to any of those​
 ​third party sites, your information is governed by their privacy policies, not this one. We encourage​
  ​you to carefully read the privacy policy of any website you visit.​

​ .2.5. Social Media Widgets.​​The Services may include​​links that direct you to other websites or​
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​services whose privacy practices may differ from ours. Your use of and any information you​
 ​submit to any of those third-party sites is governed by their privacy policies, not this one.​

​ .2.6. Third-Party Widgets.​​Some of our Services contain widgets and social media features,​
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​such as the Twitter "tweet" button. These widgets and features collect your IP address, which​
 ​page you are visiting on the Services, and may set a cookie to enable the feature to function​
  ​properly. Widgets and social media features are either hosted by a third party or hosted directly on​
   ​our Services. Your interactions with these features are governed by the privacy policy of the​
    ​company providing it.​

​ .2.7. With your consent.​​We share information about you with third parties when you give us​
4
​consent to do so. For example, we often display personal testimonials of satisfied customers on​
 ​our public Websites. With your consent, we may post your name alongside the testimonial.​

​10​​.   Privacy Policy​                                                  ​© Digital Samba, SL. All rights reserved.​
​ .2.8. Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights.​
4
​In exceptional circumstances, we may share information about you with a third party if we believe​
 ​that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal​
  ​process or governmental request, including to meet national security requirements, (b) enforce our​
   ​agreements, policies and terms of service, (c) protect the security or integrity of our products and​
    ​services, (d) protect Digital Samba, our customers or the public from harm or illegal activities, or​
     ​(e) respond to an emergency which we believe in good faith requires us to disclose information to​
      ​assist in preventing the death or serious bodily injury of any person.​

​4.3. Sharing with affiliated companies​
​ e share information we collect with affiliated companies and, in some cases, with prospective​
W
​affiliates. Affiliated companies are companies owned or operated by us. The protections of this​
 ​privacy policy apply to the information we share in these circumstances.​

​ .3.1. Digital Samba companies.​​We share information​​we have about you with other Digital​
4
​Samba corporate affiliates in order to operate and improve products and services and to offer​
 ​other Digital Samba affiliated services to you. This includes companies that own or operate the​
  ​services listed here.​

​ .3.2. Business Transfers.​​We may share or transfer​​information we collect under this privacy​
4
​policy in connection with any merger, sale of company assets, financing, or acquisition of all or a​
 ​portion of our business to another company. You will be notified via email and/or a prominent​
  ​notice on the Services if a transaction takes place, as well as any choices you may have regarding​
   ​your information.​

​5. How we store and secure information we collect​
​5.1. Information storage and security​
​ e implement extensive technical and operational measures to protect your data, which includes​
W
​performing thorough due diligence of the service providers that we work with. Data access is​
 ​restricted, and access is granted only as far as is necessary to carry out activities related to the​
  ​provision of the Services or internal processes surrounding the provision of the Services.​

​ .1.1. Websites.​​When you interact with us via our​​Websites, your data is processed and stored on​
5
​servers belonging to third-party service providers. We contract a wide range of services and tools​
 ​from various providers, including customer support tools, customer relationship management​
  ​platforms, payment gateways, and marketing tools.​

​ or these types of services, we prioritise selecting European-owned providers that store data on​
F
​European servers. This is not always feasible, as certain sectors lack adequate European​
 ​providers.​

​ e perform due diligence on all our providers to ensure that they meet our data security and data​
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​privacy standards.​

​11​​.   Privacy Policy​                                               ​© Digital Samba, SL. All rights reserved.​
​ .1.2. Embedded product.​​In our Embedded product, all user data is stored and processed on​
5
​European infrastructure contracted from trusted European service providers.​

​ .1.3. Samba Live product.​​Our Samba Live product serves a global user base. We therefore​
5
​contract server infrastructure in both Europe and the United States to store and process Samba​
 ​Live user data. European OEM customers can choose a configuration (by contacting us) where all​
  ​personal data processing is performed exclusively on European infrastructure belonging to​
   ​European service providers.​

​ .1.4. DS Free product.​​In our DS Free product, all user data is stored and processed on European​
5
​infrastructure contracted from trusted European service providers.​

I​f you use a server version of our Services, responsibility for securing storage and access to the​
 ​information you put into the Services rests with you and not Digital Samba. We strongly​
  ​recommend that server users configure proper technical and operational safeguards to prevent​
   ​interception of data transmitted over networks and to restrict access to the databases and other​
    ​storage points used.​

​5.2. How long we keep information​
​ e store your personal information for a period of time that is consistent with the business​
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​purposes set forth in Section 3 of this policy, or as long as needed to fulfill and comply with legal​
 ​obligations. The data retention period will vary depending on the type of data and the processing​
  ​purpose.​

I​f we have a business relationship with you (which includes users of our free plans), we will retain​
 ​your data for the duration of the business relationship. In the Samba Live product we retain the​
  ​data a further 90 days thereafter to allow for re-activation of the Services, which is not an​
   ​uncommon request. In the Embedded product and the DS Free product, no such re-activation​
    ​period applies, and your data is deleted when you choose to end the business relationship by​
     ​deleting your account.​

​ ote that we are obligated by law to retain business transaction data (e.g. contracts, invoices,​
N
​correspondence, etc) for a minimum period of 5 years following the date of the transaction, and for​
 ​a maximum period of 10 years following the date of the transaction.​

​ e believe data minimisation is mutually beneficial, and our aim is to keep as little data as​
W
​necessary to perform the purposes set forth in Section 3. Where we require historical data in order​
 ​to analyse usage trends or learnings (e.g. website or product usage patterns), we will make every​
  ​effort to anonymise the data and purge it of personally identifiable information.​

​ hen a data retention period expires, we will either delete or anonymise your information or, if this​
W
​is not possible (e.g. because the information has been stored in backup archives), we will securely​
 ​store your information and isolate it from any further use until deletion is possible.​

​ e will not be able to delete all information or content that you have provided to other users of the​
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​Services, as this will impact the ability of those users to make full use of the Services.​

​12​​.   Privacy Policy​                                              ​© Digital Samba, SL. All rights reserved.​
I​f the Services are made available to you through an organisation (e.g. your employer), we retain​
 ​your information as long as required by the administrator of your account. For more information,​
  ​see section 4.1.2 ("Managed accounts and administrators") above.​

​6. How to access and control your information​
​ ou have certain choices available to you when it comes to your information. Below is a summary​
Y
​of those choices, how to exercise them and any limitations.​

​6.1. Your Choices​
​ ou have the right to request a copy of your information, to object to our use of your information​
Y
​(including for marketing purposes), to request the deletion or restriction of your information, or to​
 ​request your information in a structured, electronic format. Below, we describe the tools and​
  ​processes for making these requests. You can exercise some of the choices by logging into the​
   ​Services and using settings available within the Services or your account. Where the Services are​
    ​administered for you by an administrator (see section 8.1 "Notice to End Users" below), you may​
     ​need to contact your administrator to assist with your requests first. For all other requests, you may​
      ​contact us via the details in the “Contact Us” section at the bottom of this document.​

​ .1.1. Certain limitations on your requests and choices.​​We cannot comply with a data deletion​
6
​request if fulfilling your request would reveal information about another person, or if you ask to​
 ​delete information which we or your administrator are permitted by law or have compelling​
  ​legitimate interests to keep. Where you have asked us to share data with third parties, for example,​
   ​by installing third-party apps, you will need to contact those third-party service providers directly​
    ​to have your information deleted or otherwise restricted. If you have unresolved concerns, you​
     ​may have the right to complain to a data protection authority in the country where you live, where​
      ​you work or where you feel your rights were infringed.​

​ .1.2. Access and update your information.​​Our Services​​and related documentation give you the​
6
​ability to access and update certain information about you from within the Services. For example,​
 ​you can access your profile information from your account and review Sessions, recordings,​
  ​contacts and messages you have created in the Services. You can update your profile information​
   ​within your profile settings and modify content that contains information about you using the​
    ​editing capabilities associated with that content.​

​ .1.3. Deactivate your account.​​If you no longer wish​​to use our Services, you or your​
6
​administrator may be able to deactivate your Services account. If you can deactivate your own​
 ​account, that setting is available to you in your account settings. Otherwise, please contact your​
  ​administrator. If you are an administrator and are unable to deactivate an account through your​
   ​administrator settings, please contact Digital Samba support. Please be aware that deactivating​
    ​your account does not delete your information; your information remains visible to other users of​
     ​the Services based on your past participation within the Services. For more information on how to​
      ​delete your information, see below.​

​ .1.4. Delete your information.​​Our Services and related documentation give you the ability to​
6
​delete certain information about you from within the Services. For example, you can remove​
 ​certain profile information within your profile settings, and you can remove rooms, recordings,​

​13​​.   Privacy Policy​                                                 ​© Digital Samba, SL. All rights reserved.​
​ ontacts and messages you have created. Please note, however, that we may need to retain​
c
​certain information for record keeping purposes, to complete transactions or to comply with our​
 ​legal obligations.​

​ .1.5. Request that we stop using your information.​​In some cases, you may ask us to stop​
6
​accessing, storing, using and otherwise processing your information where you believe we don't​
 ​have the appropriate rights to do so. For example, if you believe a Services account was created​
  ​for you without your permission or you are no longer an active user, you can request that we delete​
   ​your account as provided in this policy. Where you gave us consent to use your information for a​
    ​limited purpose, you can contact us to withdraw that consent, but this will not affect any​
     ​processing that has already taken place at the time. You can also opt-out of our use of your​
      ​information for marketing purposes by contacting us, as provided below. When you make such​
       ​requests, we may need time to investigate and facilitate your request. If there is delay or dispute as​
        ​to whether we have the right to continue using your information, we will restrict any further use of​
         ​your information until the request is honoured or the dispute is resolved, provided your​
          ​administrator does not object (where applicable). If you object to information about you being​
           ​shared with a third-party app, please disable the app or contact your administrator to do so.​

​ .1.6. Opt out of communications.​​You may opt out​​of receiving promotional communications from​
6
​us by using the unsubscribe link within each email or by contacting us as provided below to have​
 ​your contact information removed from our promotional email list or registration database. Even​
  ​after you opt out from receiving promotional messages from us, you will continue to receive​
   ​transactional messages from us regarding our Services.​

​ ou may be able to opt out of receiving personalised advertisements from other companies who​
Y
​are members of the Network Advertising Initiative or who subscribe to the Digital Advertising​
 ​Alliance's Self-Regulatory Principles for Online Behavioral Advertising. For more information about​
  ​this practice and to understand your options, please visit: http://www.aboutads.info,​
   ​http://optout.networkadvertising.org/ and http://www.youronlinechoices.eu.​

​ .1.7. Turn off cookie controls.​​Relevant browser-based​​cookie controls are described in our​
6
​Cookies & Tracking Notice​​.​

​ .1.8. Data portability.​​Data portability is the ability​​to obtain some of your information in a format​
6
​you can move from one service provider to another (for instance, when you transfer your mobile​
 ​phone number to another carrier). Depending on the context, this applies to some of your​
  ​information, but not to all of your information. Should you request it, we will provide you with an​
   ​electronic file of your basic account information and the information you created under your sole​
    ​control.​

​7. How we transfer information we collect internationally​
​ igital Samba is a European company based in Spain. When we transfer data outside the European​
D
​Economic Area (EEA), we make use of European Commission-approved​​standard contractual​
 ​clauses​​, binding corporate rules for transfers to data processors, or other appropriate legal​
  ​mechanisms to safeguard the transfer.​

​14​​.   Privacy Policy​                                                  ​© Digital Samba, SL. All rights reserved.​
​7.1. Data transfers initiated by you​
​ .1.1. Websites.​​Your interactions with our Websites​​encompass the processing of data in our​
7
​customer support tools, customer relationship management platforms, payment gateways, and​
 ​marketing tools. Data you provide to us over these channels is transferred from your country of​
  ​residence to Europe, depending on which provider is involved in the transaction.​

​ .1.2. Embedded Product.​​Data you provide to us is transferred from your country of residence to​
7
​Europe.​

​ .1.3. Samba Live product.​​Data you provide to us is transferred from your country of residence to​
7
​servers in Europe or the United States. If you are an OEM customer, you can choose for the data to​
 ​be transferred exclusively to European servers.​

​ .1.4. Embedded Product.​​Data you provide to us is transferred from your country of residence to​
7
​Europe.​

​7.2. Data transfers between Digital Samba providers​
I​n certain scenarios, your data is transferred from one Digital Samba provider to another. We have​
 ​agreements in place with our providers which stipulate that the data must reside on European​
  ​servers. Depending on which provider is involved in the transaction, your data will be transferred​
   ​from one European country to another.​

​7.3. Data transfers within Digital Samba​
​ igital Samba is headquartered in Spain, with a remote workforce located mainly in Europe.​
D
​Access to your data by our workforce is protected by stringent legal contracts and data security​
 ​policies. Data access is restricted by technical and operational measures, and access is granted​
  ​only as far as is necessary to carry out specific duties related to the provision of the Services or​
   ​internal processes surrounding the provision of the Services. Depending on which member of our​
    ​workforce is involved in the transaction, your data may be accessed from a European country​
     ​other than the European country on which the data resides.​

​8. Other important privacy information​
​8.1. Notice to End Users​
​ any of our products are intended to be used by organisations. Where the Services are made​
M
​available to you through an organisation (e.g. your employer), that organisation is the administrator​
 ​of the Services and is responsible for the accounts and/or sites over which it has control. If this is​
  ​the case, please direct your data privacy questions to your administrator, as your use of the​
   ​Services is subject to that organisation's policies. We are not responsible for the privacy or​
    ​security practices of an administrator's organisation, which may be different from this policy.​

​Administrators can:​

         ​ ​ r​ equire you to reset your account password;​
         ●
         ​●​ ​restrict, suspend or terminate your access to the Services;​

​15​​.     Privacy Policy​                                                   ​© Digital Samba, SL. All rights reserved.​
         ​​ a
         ●     ​ ccess information in and about your account;​
         ​●​ ​access or retain information stored as part of your account;​
          ​●​ ​install or uninstall third-party apps or other integrations​

​In some cases, administrators can also:​

         ​​
         ●         r​ estrict, suspend or terminate your account access;​
         ​●​        ​change the email address associated with your account;​
          ​●​        ​change your information, including profile information;​
           ​●​        ​restrict your ability to edit, restrict, modify or delete information​

​ ven if the Services are not currently administered to you by an organisation, if you use an email​
E
​address provided by an organisation (such as your work email address) to access the Services,​
 ​then the owner of the domain associated with your email address (e.g. your employer) may assert​
  ​administrative control over your account and use of the Services at a later date.​

I​f you do not want an administrator to be able to assert control over your account or use of the​
 ​Services, use your personal email address to register for or access the Services. If an​
  ​administrator has not already asserted control over your account or access to the Services, you​
   ​can update the email address associated with your account through your account settings in your​
    ​profile. Once an administrator asserts control over your account or use of the Services, you will no​
     ​longer be able to change the email address associated with your account without administrator​
      ​approval.​

​ lease contact your organisation or refer to your administrator’s organisational policies for more​
P
​information.​

​8.2. Our policy towards minors​
​ he Services are not directed to individuals under 16 (“​​Minors​​” or “​​Minor​​”). We do not knowingly​
T
​allow Minors to create accounts in the Services, and we do not knowingly collect personal​
 ​information from Minors. If we become aware that a Minor has provided us with personal​
  ​information, we will take steps to delete such information. If you become aware that a Minor has​
   ​provided us with personal information, please contact our support services.​

​ e do however allow educational customers to contract our Services to provide educational​
W
​services to Minors. If you provide such educational services, please consult our​​Privacy Policy for​
 ​Education​​and ensure that you understand your responsibilities.​

​8.3. Changes to our Privacy Policy​
​ e may change this privacy policy from time to time. We will post any privacy policy changes on​
W
​this page and, if the changes are significant, we will provide a more prominent notice by adding a​
 ​notice on the Services homepages, login screens, or by sending you an email notification. We will​
  ​also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to​
   ​review our privacy policy whenever you use the Services to stay informed about our information​
    ​practices and the ways you can help protect your privacy.​

​16​​.           Privacy Policy​                                                       ​© Digital Samba, SL. All rights reserved.​
I​f you disagree with any changes to this privacy policy, you will need to stop using the Services​
 ​and deactivate your account(s), as outlined above.​

​9. How to contact us​
​ s a controller and a processor of your data, Digital Samba provides you with contact details so​
A
​you can contact us about our data processing activities, as required under Article 13 (1)(a) and (b)​
 ​of the GDPR.​

​For general information or inquiries, you can use the contact details below:​

​ igital Samba, S.L.​
D
​Travessera de Gràcia 98 bis 6-2​
 ​08012, Barcelona​
  ​Spain​

​Phone: +34 937 370 415​

​If you prefer, you can also open a support ticket by visiting​​http://support.digitalsamba.com​​.​

​ or more information about our privacy practices, or to exercise your data privacy rights, you can​
F
​contact our Data Protection Officer by sending an email to​​[email protected]​​.​

​17​​.   Privacy Policy​                                               ​© Digital Samba, SL. All rights reserved.​