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BeMo Privacy Policy (PP)

You agree that we may modify this BeMo Privacy Policy (PP) by posting a revised version on the BeMo Website which is an integral part of BeMo Terms of Service and by notifying You by email. It is your responsibility to read and understand BeMo Privacy Policy (PP) and changes made to it. This Policy was last updated on September 11, 2017.

This Privacy Policy describes BeMo’s information practices.

1.      Web Sites Covered

This Privacy Policy covers the information practices of the BeMo Websites (as defined in the Terms of Use and Subscription Agreement).  However, www.bemopro.com or store.bemopro.com may contain links to other Web sites, and BeMo is not responsible for the information practices or the content of other web sites. BeMo encourages you to review the privacy statements of other websites to understand their information practices.

2.      Personal Information Collected

BeMo (or “the Company”) offers a variety of services that are collectively referred to as the “Service.” BeMo collects information from individuals who visit the Company’s Web sites (“Visitors”) and individuals who register to use the Service (“Customers”).

When expressing an interest in obtaining additional information about the Service or registering to use the Service, BeMo requires you to provide the Company with contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Service, BeMo requires you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Service (“Billing Information”). BeMo may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information are referred to collectively as “Data About BeMo Customers.”

As you navigate BeMo’s Web sites, BeMo may also collect information through the use of commonly used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).

2.1         Information Collected

At Your request or the request of an Appointee(s), the Service may collect certain information, including but not limited to: (a) which meeting slides were viewed by You and by Meeting Attendees; (b) Your answers and the answers of Meeting Attendees to polls initiated by You or an Appointee; (c) real time “chat” between users of the Service and between users and You or Appointee(s); and (e) any other information You provide to the Service, either on Your own accord or as requested by an Appointee(s), such as Your name, address, phone number, e-mail address, or any other personally identifying information. The Service will record such information. You and Appointees may see such information, and some information, such as “chat” or Your questions, may be shared with and stored by other users of the Service at the request of You or an Appointee(s) or as an automatic function of the Service. Except as otherwise stated in Section 6 below, BeMo do not share your Information with any other third parties.

2.2         Notice Regarding Recording and Privacy

THE MICROSOFT SKYPE FOR BUSINESS AND THIRD-PARTY SERVICES MAY ALLOW YOU OR AN APPOINTEE(S) TO RECORD MEETINGS AND TO COLLECT AND UTILIZE IDENTIFYING INFORMATION ABOUT YOU AND MEETING ATTENDEES, SUCH AS YOUR NAME, VOICE, OR LIKENESS. THE LAWS OF SOME STATES OR COUNTRIES REQUIRE (A) A MEETING ATTENDEE TO GRANT HIS/HER CONSENT PRIOR TO ANY RECORDING OF COMMUNICATIONS; AND (B) RESTRICTIONS ON THE COLLECTION, STORAGE, AND USE OF PERSONALLY IDENTIFYING INFORMATION. You are responsible for ensuring collection of all such consents and compliance with all such restrictions, and therefore you shall indemnify, defend, and hold BeMo harmless from any claim or suit connected to recordings by You or Appointee(s) of the communications and likeness of Meeting Attendees.

3.      Use of Information Collected

BeMo uses Data About BeMo Customers to perform the services requested. For example, if you fill out a “Contact Me” web form, BeMo will use the information provided to contact you about your interest in the Service.

BeMo may also use Data About BeMo Customers for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in BeMo, the Service, and to send you information regarding the Company and its partners, such as information about promotions or events.

BeMo uses credit card information solely to check the financial qualifications of prospective Customers and to collect payment for the Service.

BeMo uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information in combination with Data About BeMo Customers to provide personalized information about the Company.

4.      Web Site Navigational Information

BeMo uses commonly used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information the Company may collect and how the Company may use this information.

4.1         Cookies

BeMo uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, BeMo’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you. They merely recognize your Web browser. Unless you choose to identify yourself to BeMo, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Me” or a “Beta Test” or “risk free trial” Web form), you remain anonymous to the Company.

There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.

If you have chosen to identify yourself to BeMo, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Service, a session cookie containing an encrypted, unique identifier that is tied to your account is placed in your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Service and to process your online transactions and requests. Session cookies are required to use the Service.

BeMo uses persistent cookies that only the Company can read and use to identify browsers that have previously visited the Company’s Web sites. When you purchase the Service or provide the Company with personal information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that the Company places on your Web browser. The Company is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, the Company does not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web sites, but you will not be able to successfully use the Service.

BeMo may use information from session and persistent cookies in combination with Data About BeMo Customers to provide you with information about the Company and the Service.

4.2         Web Beacons

BeMo uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, BeMo may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. BeMo uses Web beacons to operate and improve the Company’s Web sites and email communications. BeMo may use information from Web beacons in combination with Data About BeMo Customers to provide you with information about the Company and the Service.

4.3         IP Addresses

When you visit BeMo’s Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personally identifiable information. For example, BeMo uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.

BeMo also collects IP addresses from Customers whey they log into the Service as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.

4.4         Third Party Cookies

From time-to-time, BeMo engages third parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit the Company’s Web sites. BeMo may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it. This Privacy Statement does not cover the use of third party cookies.

5.      Public Forums, Refer a Friend, and Customer Testimonials

BeMo may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personally identifiable information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. BeMo is not responsible for the personally identifiable information you choose to submit in these forums.

Customers and Visitors may elect to use the Company’s referral service to inform friends about the Company’s Web sites. When using the referral service, the Company requests the friend’s name and email address. BeMo will automatically send the friend a one-time email inviting him or her to visit the Company’s Web sites. BeMo does not store this information.

BeMo posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. BeMo obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

6.      Sharing of Information Collected

BeMo may share Data About BeMo Customers with the Company’s agents so that these agents can contact Customers and Visitors who have provided contact information on our behalf. BeMo may also share Data About BeMo Customers with the Company’s agents to ensure the quality of information provided. BeMo may also share Data with BeMo’s contractors and service providers for the purpose of providing, and billing for, the Services.  BeMo does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes unless You initiate it by contacting a third party through our website.

BeMo uses a third-party intermediary to manage credit card processing. The intermediary is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.

BeMo reserves the right to disclose personally identifiable information of the Company’s Customers or Visitors if required by law or if the Company reasonably believes that disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

7.      Communications Preferences

BeMo offers Customers and Visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by browsing to http://www.bemopro.com , clicking “Log In” using your BeMo username and password and selecting your email preference option under “My BeMo Account”, or by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may it the "unsubscribe" link from our marketing emails, send a request specifying your communications preferences to privacy@bemopro.com . Customers cannot opt out of receiving transactional emails related to their account with BeMo or the Service.

8.      Correcting and Updating Your Information

Customers may update or change their subscription and Customer Data including address, username, password and payment method. To make such modification, , please login to http://www.bemopro.com  with your BeMo username and password, click “Log In” and select one of the option under “My BeMo Account”. Alternatively you can email your request to privacy@bemopro.com or call (702) 529 0820. Requests to access, change, or delete your information will be handled within 30 days.

9.      Your Data

BeMo Customers use the Service to host data and information (“Customer Data”). BeMo will not review, share, distribute, or reference any such Customer Data except as provided in the BeMo Services Subscription Agreement, or as may be required by law. Individual records of Customer Data may be viewed or accessed only for the purpose of resolving a problem, support issues, or suspected violation of the BeMo Services Subscription Agreement, or as may be required by law. Customers are responsible for maintaining the security and confidentiality of their BeMo usernames and passwords.

10.    Security

BeMo uses robust security measures to protect Customer Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Customer Data. The Service may only be accessed using Internet Explorer version 10 or later. When using Internet Explorer version 10 or later, Secure Socket Layer (“SSL”) technology protects Customer Data using both server authentication and data encryption. These technologies help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. BeMo also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Web sites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.

Because the Company uses the Service to maintain Data About BeMo Customers, this information is secured in the same manner as described above for Customer Data.

11. Privacy Shield Framework

BeMo has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that BeMo obtains from Customers located in the European Union and Switzerland.

BeMo complies with the US-EU Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. BeMo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ 

The Federal Trade Commission (FTC) has jurisdiction over BeMo’s compliance with the Privacy Shield. Therefore, BeMo is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

All BeMo employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy. 

Any questions, concerns, or comments regarding this Policy also may be directed to privacy@bemopro.com

11.1 Scope

This Policy applies to the processing of Individual Customer Personal Data that BeMo receives in the United States concerning Individual Customers who reside in the European Union and Switzerland. BeMo provides products and services to businesses and consumers.

This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.) 

11.2 Responsibilities and management

BeMo has designated its Company’s officers execteam@bemopro.com to oversee its information security program, including its compliance with the EU Privacy Shield program and Swiss-U.S. Privacy Shield Framework. Its officers shall review and approve any material changes to this program as necessary.
BeMo will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. BeMo personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section “Data Integrity and Security” for a discussion of the steps that BeMo has undertaken to protect Personal Data.

11.3 Renewal / verification

BeMo will renew its EU Privacy Shield and Swiss-U.S. Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, BeMo will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, BeMo will undertake the following:

A. Review this Privacy Shield policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data

B. Ensure that the publicly posted privacy policy informs Individual Customers of BeMo's participation in the EU Privacy Shield and Swiss-U.S. Privacy Shield Frameworks and where to obtain a copy of additional information (e.g., a copy of this Policy)

C. Ensure that this Policy continues to comply with the Privacy Shield and Swiss-U.S. Privacy Shield principles

D. Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (BeMo may do so through its publicly posted website, Individual Customer contract, or both)

E. Review its processes and procedures for training Employees about BeMo's participation in the Privacy Shield and Swiss-U.S. Privacy Shield and the appropriate handling of Individual's Personal Data 

BeMo will prepare an internal verification statement on an annual basis.

11.4 Collection and use of personal data 

BeMo provides various solutions to its Individual Customers who purchase its products. BeMo collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, BeMo individual customers may choose to seek live support or post to a message board.

The Personal Data that we collect may vary based on the Individual Customer's interaction with our website and request for our services. As a general matter, BeMo collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person's name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Individual customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals.

When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website. 

The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.

For certain products, BeMo serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent. 

BeMo uses Personal Data that it collects directly from its Individual Customers and for its partners indirectly in its role as a service provider for the following business purposes, without limitation:

A. as per section 6 above “SHARING OF INFORMATION COLLECTED”

B. to maintain and support its products, deliver and provide the requested products/services, and comply with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to an Individual Customer); 

C. to satisfy governmental reporting, tax, and other requirements (e.g., import/export); 

D. to store and process data, including Personal Data, in computer databases and servers located in the United States; 

E. to verify identity (e.g., for online access to accounts); 

F. to satisfy request made by the Individual Customer; 

G. for other business-related purposes permitted or required under applicable local law and regulation; 

H. and as otherwise required in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

11.5 Disclosures / onward transfers of personal data

Except as otherwise provided herein, BeMo discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.

BeMo may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, BeMo may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by BeMo and they must either:

A. comply with the Privacy Shield principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Data; 

B. or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy.

BeMo also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that BeMo may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. BeMo is liable for appropriate onward transfers of personal data to third parties.

11.6 Sensitive data 

BeMo does not collect Sensitive Data from its Individual Customers.

11.7 Data integrity and security 

BeMo uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. BeMo has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to BeMo's electronic information systems requires user authentication via password or similar means. BeMo also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.

Further, BeMo uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all the time.

11.8 Notification

BeMo notifies Individual Customers about its adherence to the EU-US Privacy Shield and Swiss-U.S. Privacy Shield Framework through its publicly posted website privacy policy, available at: http://www.bemopro.com/PrivacyPolicy.aspx and take Individual customers approval and adherence to the current policy when they provide their information to us in the transactional process.

11.9 Accessing personal data

BeMo personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

11.10 Right to access, change or delete personal data

Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which BeMo collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and BeMo policies. Upon reasonable request and as required by the Privacy Shield principles, BeMo allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting BeMo by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local BeMo office.

Requests for Personal Data. BeMo will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If BeMo receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, BeMo will refer such Data Subject to the Individual Customer.

Satisfying Requests for Access, Modifications, and Corrections. BeMo will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

11.11 Changes to this policy

This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees aware of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

11.12 Questions or complaints 

EU Individual customers may contact BeMo with questions or complaints concerning this Policy at the following address: privacy@bemopro.com

11.13 Enforcement and dispute resolution

In compliance with the Privacy Shield Principles, BeMo commits to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with questions or concerns about the use of their Personal Data should contact us at: privacy@bemopro.com.

If a Customer's question or concern cannot be satisfied through this process BeMo has further committed to refer unresolved privacy complaints under Privacy Shield principles to an independent dispute resolution mechanism operated by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice gien by such authorities with regard data transferred from the EU and Switzerland.

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by BeMo, EU individuals may bring a complaint before the EU data protection authorities (DPAs). Information about how to file a complaint before the EU data protection authorities (DPAs) program can be found at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm . Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed please visit: http://www.bbb.org/EU-privacy-shield for more information and to file a complaint.

11.14 Defined terms

"Individual Customer" means an Individual customer or client of BeMo from the EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of BeMo and all employee of BeMo where BeMo has obtained his or her Personal Data from such Individual Customer as part of its business relationship with BeMo.

"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.

"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of BeMo or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.

"Europe" or "European" refers to a country in the European Union.

"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.

"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither BeMo nor an BeMo employee, agent, contractor, or representative.

13.    Changes to this Privacy Statement

BeMo reserves the right to change this Privacy Statement. BeMo will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

14.    Contacting Us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to BeMo Privacy by clicking http://www.bemopro.com/privacy  or by mailing BeMo Privacy, privacy@bemopro.com.