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This privacy notice serves to provide comprehensive information to users of the Onomi Services and respective Backstage users, in the EU within the meaning of Art. 12 para. 1 GDPR.
Onomi provides the Services as a processor to Clients as controllers who shall use it for the purposes and according to the modalities described in their privacy notice. In case of any inconsistency or discrepancy between the present document and the Client privacy notice, this latter document shall prevail.
The contractual relationship between Onomi and the Client is specifically addressed in the related paragraphs of the present document.
Onomi takes care of protecting the confidentiality of the information you share, and commits itself to the strictest compliance with the data protection law that applies. This document is aimed at providing all users with an outline of what the Services provided by Onomi consists of, what Personal Data are collected via the Services and how such Data are processed.
Onomi is a company specialized in providing virtual and hybrid event and engagement application solutions that may either be built autonomously by Clients or with the assistance of a Onomi trained team of specialists. Each of these applications provide App Users with a digital solution to interact and communicate during events, meetings or community engagements. Such communication is carried out in a paperless environment through the functionalities available in the App. Once the App User has joined the event environment, they can start using the engagement features of the Onomi App, including but not limited to, posting questions, receiving learning or training material, communicating in real time with other App Users, taking notes, casting votes etc., the exact functionalities depending on the feature set made available on that application and on the setting thereof, as established by the Client.
The use of and navigation through the Services (as well as the use of any third party’s application embedded and/or available therein), implies the communication of Usage Data, which is implicitly acquired during the navigation of the App User or Backstage User through the internet communications protocol.
Usage Data includes but is not limited to, the IP addresses or domain names of the devices utilized by the App Users or Backstage Users, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the App User or Backstage User, the various time details per visit (e.g., the time spent on each page within the Onomi Platform) and the details about the path followed within the Onomi Platform with special reference to the sequence of pages visited, and other parameters about the device’s operating system and/or the App User’s or Backstage User’s IT environment.
Usage Data is not collected for the purpose of identifying the App User or Backstage User. However, all users must be aware that the identification may be possible through further elaborations and associations, as well as with information held by third parties.
Should any willful act of misconduct, fraud or criminal offence be perpetrated, Usage Data could potentially be used for ascertaining individual responsibilities.
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR in the EU. The data processing for the provision of the services and the storage of the data in log files is absolutely necessary for the operation of the App. Consequently, there is no possibility of objection on the part of the user.
To use the Services, App Users and Backstage Users may need to register and disclose the information requested in the relevant forms in a complete and truthful manner. Whenever a field in the forms provided is described as “optional” or “not compulsory” or is not marked with “*” symbol it means that the App User or Backstage User is free not to communicate the requested Data and that their request can be fulfilled notwithstanding the absence of this information. The Data collected by the Onomi App or Backstage for registration purposes are: email address, first name, last name, password. App User’s and Backstage User’s Personal Data shall be processed upon their prior, free and informed consent, when required by the law, and solely for the purposes outlined in the present privacy notice. App Users and Backstage Users are responsible for any third party Personal Data obtained, published or shared through using thе Onomi Services and confirm that they have the third party’s consent to provide the Data to the Client and / or Onomi. The data will be archived and deleted after 2 years. As the processing of data aims at the fulfillment of a contract, the legal basis for processing is Art. 6 para. 1 lit. b GDPR in the EU.
The Data of App Users and Backstage Users is processed in an appropriate manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
The Data is processed at the Client’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact
Onomi privacy@onomi.io.
The Data is kept for the time necessary to provide the Services requested by the App User or Backstage User, or stated by the purposes outlined in this document.
The Data concerning the App Users and Backstage Users is collected for the purposes described below.
In particular, Usage Data is solely processed to:
As for the Data communicated by App User or Backstage User on a voluntary basis, it is processed for the following purposes:
App Users must be aware that other users of the Onomi App might have access to, or re-post, or otherwise share what they have published, which could also include Personal Data such as name, nickname/screen name, location and other information about the App User, as well as information about the event they are participating to. These other users might make such information publicly available. Also, App Users must be aware that the Onomi App allows interactions among mobile
devices running the Onomi App or between mobile devices running the Onomi App and other components of the Onomi App. In particular, at each event at which the Onomi App is employed, the Event Organizer determines the rules as to how individually-identifiable information in the Onomi App will be made accessible to other App Users. Where applicable and once these rules have been determined, Onomi enforces them, including by withholding Data from the Event Organizer where that Data was gathered under a commitment of anonymity.
Some of the ways in which individually-identifiable information about a participant are made available to others vary from event to event including, but not limited to the following:
App Users who are not comfortable with the functioning of the Onomi App may return their Onomi device at any time (if they have been provided with such a device), may delete the Onomi App from their personal mobile device or may request the deletion of their Personal Data to the Event Organizer.
Backstage Users must be aware that their data will not be shared with others, unless they are also listed as Backstage Users by the Client under the same Organization in Backstage. In this case, the data that will be visible for all Backstage Users under one Organization are their names.
The Onomi Platform usually provides for a closed environment, meaning that the App User must be
authenticated with an email link or a similar authentication scheme before joining the Onomi App, and the Backstage User by authenticating with email and password before joining Backstage. If no authentication scheme is available, App Users can access the Onomi App by providing the following Data: email address, first name and last name. Onomi does not automatically collect, via the service, any personal identifiable information from the App Users. Nonetheless, the use of the Services may imply the automatic collection of some App User’s information and other Usage Data, including but not limited to, IP address, operating system and type of browser used by App User’s mobile device.
Notwithstanding the above, under specific circumstances and, namely, as part of the functioning of the Onomi Platform related to a meeting or event at which the Onomi App is employed, Onomi may receive some personal identifiable information about the App Users and Backstage Users, including but not limited to, their name, surname and email address, in order to enable the particular features of the Onomi Platform.
Onomi does not own any such Data and shall process them, as Data Processor, according to the instructions and the terms and conditions set forth in the agreement entered into with the Client who remains the sole Data Controller.
Clients are solely liable for the lawful transmission of Personal Data referring to App Users and Backstage Users to Onomi. Clients shall inform such Data Subjects accurately about the intended data transfer and collect their prior explicit consent, if needed. In particular, Clients shall inform their users about profiling activities possibly performed through recourse to services provided by Onomi. In case such profiling activities take place, Clients are solely liable for the fulfilment of the notification, if required, to the competent Data Protection Authority, as well as to comply with any requirements prescribed by the applicable privacy laws which are relevant to the aforesaid data processing activities.
Therefore, Clients are bound to inform the App Users and Backstage Users correctly about the
data treatment performed with recourse to services provided by Onomi according to applicable law, i.e. providing a privacy notice including information about data treatment performed by Onomi on their behalf.
To the same extent, Clients are solely liable for the enforcement of consent revocations or other requests received by Data Subjects. Clients shall inform Onomi accurately and without undue delay about the revocation of consent or the request and about the Data to be deleted, amended, rectified etc. Clients are solely liable for any damage possibly arising to third parties (e.g. their users or other Users) due to an unlawful processing of Personal Data transferred to Onomi.
Onomi operates through a network of subsidiaries.
As for the transfer of Personal Data to countries outside of the European Union, European Users must be aware of the following:
European Users must be aware that such transfer is lawfully carried out pursuant to the European Commission’s decision 2000/518/EC of 26 July 2000 on the adequate protection of Personal Data provided in Switzerland.
Notice to Swiss App Users – Data transfer from Switzerland to the US
Onomi’s subsidiary, Onomi Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Onomi Inc. has certified its adherence to the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles regarding the processing of personal data received from the European Union, the United Kingdom, and Switzerland. Onomi Inc. commits to subjecting all personal data received from these regions in reliance on the applicable DPF Principles.
Individuals can contact Onomi with inquiries or complaints via privacy@onomi.com.
Onomi Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). Onomi may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Under certain conditions, individuals may invoke binding arbitration for unresolved complaints, as described in the DPF Principles.
Onomi Inc. is liable for the onward transfer of personal data to third parties and ensures compliance with the DPF Principles in such cases. For more information about the Data Privacy Framework (DPF) program and to view Onomi Inc.’s certification, please visit https://www.dataprivacyframework.gov/.
Given the information above, Personal Data can be collected by using some of the following services:
Onomi uses Cookies. To learn more and for a detailed cookie notice, please visit onomi.io/specifications.
The Data Subjects’ Personal Data may be used for legal purposes by the Client, in Court or in the stages leading to possible legal action arising from improper use of the Onomi Services. Insofar as processing of personal data is necessary to fulfill a legal obligation to which the Client is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.
In addition to the information contained in this privacy notice, Onomi may provide the Data Subject with additional and specific information concerning particular services or the collection and processing of Personal Data upon request.
For operation and maintenance purposes, the Onomi Platform, or where applicable, third party services may collect files that record interaction with the Onomi App or Backstage (System logs) or use for this purpose other Personal Data (such as IP Address). The legal basis for the temporary storage of those files is Art. 6 para. 1 lit. f GDPR in the EU.
The Service is directed to the general public. Client and Onomi do not knowingly collect information
from children under 13 years of age or have any reasonable grounds for believing that children under the age of 13 are accessing the Service. If Client or Onomi learn that they have inadvertently collected Personal Data from a child under age 13, that Data will be deleted as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us at privacy@onomi.io.
More details concerning the collection or processing of Personal Data may be requested from Onomi at any time at privacy@onomi.io.
Data Subjects have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller or Onomi to learn about their contents and origin, to access, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons or to request data portability. They may at any time revoke any consent they may have given to data processing and, under certain
conditions, object to data processing. Requests should be sent to the Data Controller (the Client) at the contact information provided in its privacy notice or to Onomi at privacy@onomi.io. Data Subjects can lodge a complaint with the competent supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement of GDPR in relation to the processing of their Personal Data.
In the case of a personal data breach of data where Onomi is the data processor, but not data controller, Onomi will notify the Data Controller without undue delay after becoming aware of a personal data breach. In the case of a personal data breach of data where Onomi is the data controller, Onomi will without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55 GDPR, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification to the supervisory authority is not made within 72 hours, it will be accompanied by reasons for the delay. In the data breach notification, Onomi will describe the nature of the personal data breach including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned, and communicate the name and contact details of the data protection officer or other contact point where more information can be obtained and describe the likely consequences of the personal data breach; describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects. Onomi will document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken.
App users and Backstage users are always entitled to request information about any of their data that Onomi has stored, as well as their origin and recipient and the purpose it was stored for. If App users and Backstage users have any questions about data protection or if they wish to access, request data portability, correct, block or delete their profile or any of their personal data, or if they would like to object to the processing of data, or, at any time, to revoke a granted authorization regarding the use of their customer data or e-mail address, they can do so either directly via the Onomi App, depending on its version or contact the following: Onomi Holding SA, Attn: Data Protection Officer, Avenue du Théâtre 1, 4th floor, 1005 Lausanne, Switzerland or the Data Protection Officer by email privacy@onomi.io.
The Data Controller reserves the right to make changes to this privacy notice at any time by giving notice to its App Users and Backstage Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If an App User or Backstage User objects to any of the changes to the privacy notice, they must cease using Onomi Platform and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy notice applies to all Personal Data the Data Controller has about App Users and Backstage Users.
For any further information about the Data processing by Onomi as regards the provision of the Service, Users can write an email to the following address privacy@onomi.io.
“App User” (also “Event Participant”, or “User”) means the end users of the Workspace, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.
“Backstage” is the web-based Content Management System service for the creation and management of workspaces, including design, content, configuration, and analytics.
“Backstage User” is an individual who is assigned and authorized by the Client to access and manage the functionalities of Onomi App via Backstage.
“Client” means the natural or legal person who has purchased Onomi services for its professional, commercial or entrepreneurial purposes and has thus access to the Service.
“Cookies” means a small piece of data stored in the User’s device.
“Data Controller (or Owner)” means the natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of Onomi Platform. The Data Controller of the Onomi Platform, unless otherwise specified, is the Client.
“Data Processor (or Data Supervisor)” means the natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy notice.
“Data Subject” means the legal or natural person to whom the Personal Data refers.
“Event Organizer” means any User who has been granted permission by the Client to define the functionalities and permissions of the Onomi App during an event or a community engagement where the Onomi App is used.
“Organization” means a deployment of Onomi with a defined set of Backstage Users. An Organization is the virtual space provided to the Client and includes all the Client Data, and is separate from all other Organizations.
“Personal Data (or Data)” means any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
“Services” means the services, such as access to software, content, platform, infrastructure, and storage space, that are provided to Client and made available online by Onomi, including associated Onomi offline or mobile components and which may entail the processing of App Users’ Data. Using Onomi Services means granting access and enabling use of the Onomi Platform.
“Onomi” means the company Onomi Holding SA with registered office at Avenue du Théâtre 1, 4th floor, 1005 Lausanne, Switzerland and including its subsidiaries Onomi SA, Onomi Inc., Onomi Pte. Ltd., and Onomi EOOD.
“Onomi App” (or “the App” or “the Web App“) means the Onomi software that is used by Event Participants to access the event. It can either be via the web app (browser), or via the mobile app (phone or tablet).
“Onomi Cloud” means the backend system for Backstage, the Onomi Apps, and the core and advanced modules. It allows Client to upload and store data into Workspaces, configure Onomi developed application templates and system objects, and deploy these applications to App Users.
“Onomi Platform” means the entire Onomi solution. It is composed of Backstage, the Onomi App, and the Onomi Cloud.
“Usage Data” means information collected automatically from the Onomi App or Backstage (or third party services employed in Onomi), including but not limited to, the IP addresses or domain names of the computers utilized by the Users who use Onomi, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
“Workspace” (or “Event”, or “Engagement Instance”) means a virtual space provided to Client that includes all the Client Data related to a specific event. A Workspace belongs to an Organization and is separate from all other Workspaces.
Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, Art. 13 and Art. 14 of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.
This privacy notice relates solely to Onomi.
Latest update: September 1, 2024
