Privacy Policy

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by emailing us at privacy@mirrormirror.live, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. HOW MEETINGS WORK
14. RECORDING BY OTHER PARTICIPANTS
15. INVITATION LINKS
16. FILES YOU SHARE IN A MEETING
17. DO WE MAKE UPDATES TO THIS NOTICE?
18. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
19. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• passwords
• audio and video from your camera and microphone during meetings
• files you upload, including presentations and documents
• meeting titles and schedule details you enter
• display name entered by guests joining without an account

Sensitive Information. We do not process sensitive information.

Payment Data. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

Payment card details are entered on Stripe's hosted checkout page and are never transmitted to or stored on our systems. We provide Stripe only with your email address and name, and receive back your subscription status. Where sales tax applies to your subscription, Stripe also collects a billing address in order to calculate it.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services: your IP address, your browser type and version, your operating system, the page or link that referred you, and the date and time of each request. Most of this does not name you on its own — but we would rather not overstate that, because a record of which meeting a particular address opened, and when, can single a person out even without a name attached. We use it to operate the Services and keep them secure. We do not use it for analytics, advertising, or building a profile of you.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy: https://www.mirrormirror.live/cookies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Device Data. What your browser sends us when it makes a request: your IP address, your user-agent string — which names your browser, its version and your operating system — and the referring page. Your choice of camera and microphone is remembered in your own browser and is never sent to us. We do not collect device or advertising identifiers, your hardware model, your mobile carrier, or GPS location.

Usage of our service. Meeting usage and duration measured against your plan's limits.

Google API. Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. (Retention period: For as long as you have an account with us, and until you ask us to delete it.)

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. (Retention period: For as long as needed to deal with your enquiry, and then for a reasonable period to keep a record that we handled it.)

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. (Retention period: For as long as you have an account. These messages are sent on our behalf by our authentication and payment providers and retained under their policies.)

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. (Retention period: Subscription and payment records are retained by our payment processor for as long as required for financial and tax record-keeping.)

To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user. (Retention period: Not retained. Audio, video and presentation content are relayed live between participants and are not recorded or stored by us.)

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. (Retention period: Service and security logs are kept for 30 days. Error reports are retained by our monitoring provider under its own retention settings.)

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

Enforcing subscription plan limits. To enforce the limits of your plan, such as meeting length, number of participants, and included usage.

To deliver and facilitate the delivery of services to the user. We may process your information to provide the Services you request, including hosting your meetings and storing presentation documents you choose to upload and share with other participants. (Retention period: For as long as your meetings exist, and for a short period after you delete one, during which it can still be restored. Files uploaded for processing are deleted after 7 days. Presentations and documents you share in a meeting are deleted 7 days after they are uploaded. Some of our file storage cannot be linked back to an individual account, so we may be unable to delete a particular item sooner in response to a request — but the 7-day expiry applies to it either way.)

Guest participation in video conference meetings. To let people join a meeting by invitation without creating an account.

Show your plan information and suggest upgrade. To show you information about your plan and suggest an upgrade, based on your plan and how much of it you have used.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Diagnose problems and/or prevent fraudulent activities
• Route audio, video and presentation content between participants, including guests who join by invitation link and hold no account with us
• Inform users about their plan and usage options

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with them designed to safeguard your personal information, limiting them to processing it on our instructions. With the four that hold the most — our cloud platform, our payment processor, our authentication provider and our error-monitoring provider — that contract is a data processing agreement incorporating the European Commission's Standard Contractual Clauses. Each of these companies runs on infrastructure of its own, so each has its own sub-processors and publishes a list of them. We would rather tell you that than promise they share your information with nobody, which would not be true of any provider of this kind.

The third parties we may share personal information with are as follows:

• Cloud Computing Services — Google Cloud Platform
• Invoice and Billing — Stripe
• User Account Registration and Authentication — Clerk
• Website Performance Monitoring — Sentry
• Email hosting for our privacy contact address — Google Workspace
• Bot protection on account sign-up — Cloudflare

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use cookies and similar technologies only to operate the Services and remember your preferences.

We use cookies and similar technologies to gather information when you interact with our Services. These help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We do not use cookies or similar technologies for advertising, and we do not permit third parties to use them on our Services for advertising or for analytics.

Specific information about what we store in your browser, why, and for how long — and how you can refuse it — is set out in our Cookie Policy: https://www.mirrormirror.live/cookies.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), including facilities in the United States, Germany, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

Transfer mechanism. Where personal information originating in the EEA, UK or Switzerland is transferred to the United States, it goes to our cloud platform, our payment processor, our authentication provider and our error-monitoring provider. We have entered into a data processing agreement with each of those four, and the European Commission's Standard Contractual Clauses are incorporated into each of those agreements. We have no parent, subsidiary or affiliated companies, so no intra-group transfer arrangements apply.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). If you are located in the EU or UK, see section "HOW DO WE PROCESS YOUR INFORMATION?" for our retention periods by purpose.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at privacy@mirrormirror.live.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

How to make a request, and how we check that it is you

You can make any of these requests by emailing privacy@mirrormirror.live, or by writing to us at the postal address in "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. There is no form to fill in, and you do not need to create an account in order to ask us something.

Deleting your account is the one thing you can do entirely yourself. Signing in and deleting your account from your account settings is the strongest proof of identity there is, because only you can sign in — so where you are able to do that, it is both the fastest route and the most private one. Everything below is for the requests you cannot complete yourself, and for people who can no longer sign in.

How we check that it is you. Before we send out a copy of an account's information, correct it, or delete it on your behalf, we have to be satisfied that the request really comes from the person whose account it is — handing someone's meeting history to a stranger, or deleting their meetings on a stranger's word, would itself be a privacy failure. We do this using what we already hold: we reply to the email address registered to the account and ask you to confirm the request from there. If you can receive that message and answer it, the check is complete.

We ask for as little as we can. We will never ask you for your password, and we will not ask you for a copy of a government identity document, a photograph of yourself or a payment card number unless there is no other way to deal safely with a particular request. If you write to us from an address that is not on any account, we will ask you which address the account uses rather than asking you for new information about yourself. Anything you do send us in order to verify a request is used only for that purpose, there is no charge for being verified, and we delete what you sent once the request is closed.

How long we take. We will acknowledge your request and respond to it within the time the law that applies to you allows. Under most United States state privacy laws that period is 45 days from the day we receive the request; in the United Kingdom, the European Economic Area and Switzerland it is one month. Those laws also allow an extension where a request is complex or you have made several of them — if we need that extra time, we will tell you within the original period and explain why.

If we cannot confirm that it is you. If we cannot satisfy ourselves that a request is yours, we will not act on it, and we will tell you so and explain why rather than simply going quiet. That is not the end of the matter: you are welcome to come back to us with more information, and if you are making a request under a United States state privacy law you can appeal — see "Appeals" below.

Ask for a copy before you close your account. Closing your account is what triggers the deletion of what we hold about you, and once that has happened we can no longer look up what was yours. If you want a copy of your information, ask us for it first, and wait until we have sent it to you.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us:

Email: privacy@mirrormirror.live

Post: See "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

What happens after you complain:

• We will acknowledge your complaint within 30 days of receiving it.
• We will investigate without unjustifiable or excessive delay.
• We will keep you informed of progress and explain the outcome.

If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority.

Website: ico.org.uk/make-a-complaint

Helpline: 0303 123 1113

Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account, you can log in to your account settings and update your user account.

Deleting your account. You can delete your account yourself at any time from your account settings. When you do, we automatically and permanently delete the meetings you created — including their titles, schedules and invite links — and the presentation files stored under your account. Meetings you created will stop working for anyone you invited to them. If you have a paid subscription, we cancel it at the end of the period you have already paid for — but if anything prevents us from matching your account to your subscription, it will not stop on its own, so please tell us if you are billed after closing your account and we will put it right.

Some things are not removed when you delete your account, and we would rather tell you than let you assume otherwise:

• Documents and presentations shared into a meeting are stored by their content rather than by who uploaded them, and an identical file uploaded by two people is stored only once. We cannot tell which of them are yours, so we cannot delete them individually.
• Billing records — your customer record, invoices and payment history — are kept by our payment processor, because tax and accounting rules require us to retain them.
• Server logs can contain your account identifier, meeting identifiers and IP addresses. Logs on our cloud platform are deleted after 30 days. Logs on our media server are not on a fixed schedule and are not searchable by person, but if you ask we will do what we reasonably can to find and remove entries relating to you.
• Information stored in your own browser never reaches us and stays on your device until you clear your site data. See our Cookie Policy.
• A record that you agreed to our Terms of Service and acknowledged this Privacy Notice is kept after your account is deleted. It holds your account identifier, the date and time you agreed, which version of each document you were shown, a fingerprint of that document's exact wording, and the sentence that appeared beside the button. It does not hold your IP address, and nothing about your browser or your device. We keep it because it is the only thing that could show the agreement was made once the account is gone, and deleting it with the account would destroy that evidence at the moment it might be needed. It is held apart from your account data, in a store our application can add to but cannot change or delete, and it is included in any copy of your data you ask us for.

If you cannot sign in to delete your account yourself, email us at privacy@mirrormirror.live and we will do it for you, once we have checked that the request is yours in the way described above.

If you joined a meeting as a guest. If you joined by invitation link without creating an account, there is no guest account and no participant record — nothing in our systems is filed under your name or your email address. That means we cannot look you up, and it also means we usually cannot confirm that a particular record is yours rather than another participant's, which limits what we can safely do in response to a request from you.

We would rather be exact about what that leaves than reassure you. The display name you type is placed into the access pass your browser uses to join the meeting, and for a period your display name, the network address you connected from and the meeting's identifier can appear together in our server logs — on our cloud platform for 30 days, and on our media server for a period bounded by how quickly that log fills rather than by a fixed date.

If you tell us which meeting you joined and roughly when, we will do what we reasonably can to find anything that relates to you, tell you the outcome, and delete what we can identify as yours. We will not disclose one participant's details to another, and we will not collect additional information about you solely in order to identify you in our records.

We may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Policy: https://www.mirrormirror.live/cookies.

If you have questions or comments about your privacy rights, you may email us at privacy@mirrormirror.live.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

Category A — As long as necessary for the purpose it was collected. Account identifiers such as name and email address are kept for the life of the account, with one exception: the account identifier recorded in your agreement to our Terms is kept after the account is deleted, as described under "Deleting your account"; billing records are kept longer where financial record-keeping requires it; IP addresses appear in server logs, which are retained for 30 days on our cloud platform and bounded by log rotation elsewhere; and identifiers held in meeting records are kept until erased on request.

Category B — As long as necessary for the purpose it was collected. Account information is kept for the life of the account; billing records are kept longer where financial record-keeping requires it; a name shown to other participants is not kept in our database once the meeting ends, although it can remain for a time in our server logs; meeting records are kept until erased on request; and names contained in uploaded files remain for as long as the file is stored, which for some stores has no fixed limit.

Category D — As long as necessary for the purpose it was collected. Subscription and billing records are kept for as long as financial and tax record-keeping requires, and some billing identifiers are retained even after a subscription is cancelled; usage records associated with meetings are kept until erased on request; and related entries in server logs are retained for 30 days.

Category F — As long as necessary for the purpose it was collected. Server logs recording interactions with the service are retained for 30 days on our cloud platform and bounded by log rotation elsewhere; error-monitoring records are kept according to our error-monitoring provider's retention settings; and usage records associated with meetings are kept until erased on request.

Category G — As long as necessary for the purpose it was collected. IP addresses appear in server logs, which are retained for 30 days on our cloud platform and bounded by log rotation elsewhere; the time zone associated with a scheduled meeting is kept as part of that meeting record until it is erased on request.

Category H — No longer than the meeting itself. Live audio, video and screen-sharing content is processed only for the duration of the meeting, is never recorded or stored by us, and is discarded when the meeting ends. Any images contained in files a user chooses to upload are kept with that file for as long as the file is stored.

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information as defined in the California Customer Records law
• Category D. Commercial information
• Category F. Internet or other electronic network activity information
• Category G. Geolocation data
• Category H. Audio, electronic, visual, and similar information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can email us at privacy@mirrormirror.live, or write to us at Insight Interfaces, LLC, c/o Registered Agents Inc., 1717 N Street NW STE 1, Washington, DC 20036, or refer to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will verify your identity, so that we never disclose or delete one person's information on another person's say-so. We do this using information we already hold: we reply to the email address registered to your account and ask you to confirm the request from there. We will use what you send us only to verify you and to answer your request, and there is no charge for being verified.

If you are a California resident, we will confirm that we have received your request within 10 business days, as California law requires, and tell you how we verify requests and when to expect our answer. We will respond within 45 days, and where the law allows an extension because a request is complex or because you have made several, we may take up to a further 45 days and will tell you within the first 45 days that we are doing so.

If we cannot verify you to the level a particular request calls for, we will tell you so rather than going quiet, and we will still do what we safely can. Where we cannot confirm your identity well enough to send you the specific pieces of personal information we hold, we will treat your request as one for the categories of personal information we hold, and answer it on that basis.

There is one situation in which we may not be able to verify anybody. If you took part in a meeting as a guest, without an account, nothing we hold is filed under your name or email address, so there is no record for us to match you against. We will not collect additional information about you solely in order to identify you in our records. The section "WHAT ARE YOUR PRIVACY RIGHTS?" above explains what we can still do in that situation.

If you submit the request through an authorized agent, the agent will need to give us written permission signed by you, and we may contact you directly to confirm that you gave it before we act. We will not ask you to submit the request over again in your own name.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@mirrormirror.live. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

13. HOW MEETINGS WORK

Live audio and video is carried by servers we operate and is not recorded or stored by us. It is encrypted in transit and decrypted on our media server so that it can be routed between participants; it is not end-to-end encrypted.

14. RECORDING BY OTHER PARTICIPANTS

Our software includes a feature that lets a participant record a meeting to their own device. The file is created and saved entirely on that person's own computer — it is never uploaded to us, and we never receive or store it. A recording made this way always includes the audio of everyone present; how much of the video it includes depends on what the person chose to capture.

When someone uses this feature, everyone else in the meeting is shown a notice for as long as the recording is running, and anyone who joins while it is still running is shown the same notice. Our servers carry the fact that a recording is happening so that we can show you that notice. They do not carry the recording.

That notice is not a guarantee, and you should not read its absence as one. It tells you only about our own recording feature. We cannot detect any other kind of recording — screen-capture software, a separate device, or a phone camera pointed at the screen — and the notice can fail to reach you if your connection to us drops. Please continue to treat a meeting as something any participant may be recording.

15. INVITATION LINKS

Anyone holding an invitation link can see a meeting's title, start and end time, time zone and recurrence before signing in or joining. Please bear that in mind when naming a meeting.

16. FILES YOU SHARE IN A MEETING

When you upload a presentation we extract and store its text, its speaker notes, its images, and the document author's name recorded in the file's properties — which may be someone who does not use this service. Some of our file storage cannot be linked back to an individual account, so we may be unable to delete its contents in response to an individual request before they expire. Everything in that storage is deleted automatically 7 days after upload, whether or not anyone asks. The section on your rights explains what we can and cannot delete.

You can also attach a Google Doc instead of uploading a file. Google asks your permission for this app to open only the file you pick — not your Drive, and not your other files. We read that file's name and the time it was last changed, ask Google to convert it to PDF, and keep the PDF in the same storage described above, on the same 7-day clock, counted from when you attached it. We do not keep your Google credentials: the permission Google issues is used once, we ask Google to revoke it as soon as the conversion finishes, and we never store anything that would let us return to your Drive later.

17. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

18. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at privacy@mirrormirror.live or contact us by post at:

19. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at privacy@mirrormirror.live.

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