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STO Building Group Recorded Meeting Privacy Notice
Effective date: May 16, 2025
This Recorded Meeting Privacy Notice (“Notice”) explains how STO Building Group (defined for purposes of this Notice as STO Building Group Inc. and its member companies and subsidiaries) (“we,” “us,” or “our”) collect, use, store, and disclose your personal information when you attend a meeting that is recorded or transcribed (“Recorded Meeting”), including through Microsoft Teams and other similar tools (the “Platform”).
This Notice supplements our existing privacy notices, including the STO Building Group Privacy NoticeGo to https://stobuildinggroup.com/policies/privacy-policy/ and our Employee Handbooks and local addenda.
The purpose of this Notice is to explain how and why we process personal information about you when you participate in a Recorded Meeting. However, you may also have responsibilities in relation to other individuals’ personal information, including safeguarding personal information; reporting any losses or accidental sharing of personal information; and incorporating data protection requirements if you work on our systems, practices, or procedures.
STO Building Group Inc. is the controller processing your personal information.
We may obtain or generate the following categories of personal information from or about you when you participate in a Recorded Meeting (note that the specific personal information we collect about you may not include all the examples listed below, and we will follow the personal information collection limitations and requirements of the country where you work):
- Profile and Participant Information associated with your profile or provided by you via the Platform, such as name, display name, picture, email address, phone number, job information, stated locale, and user ID.
- Settings Information associated with the preferences and settings on your profile, such as audio and video settings, recording file location, screen sharing settings, and other settings and configuration information.
- Registration Information provided when registering for a meeting, webinar, or other virtual gathering, such as contact information, responses to registration questions, and other registration information requested by the host.
- Content and Context Generated in the Platform, such as audio, video, in-meeting and out-of-meeting messages, chat messaging content, transcriptions, transcript edits and recommendations, and files, as well as related context, such as invitation details, meeting or chat name, or meeting agenda.
- Platform Usage Information about how you and your devices interact with the meeting, such as when you join and leave a meeting; whether you sent messages and who you message with; performance data; actions such as mute/unmute or video on/off; and edits to transcript text.
- Audio and Visual Recordings, such as images and/or videos of you when you turn your camera on or upload a photo, which will include any background content in your photo or video, such as your home or office; audio recordings of your voice if you engage in the meeting vocally; and personal information disclosed during the Recorded Meeting.
Please note that STO Building Group cannot control what personal information you share during meetings and chats. We highly recommend that you do not discuss or share sensitive personal information about yourself or another natural person in chats or when a meeting is being recorded. Sensitive personal information may include religious or philosophical beliefs, race or ethnic origin, citizenship or immigration status, trade union membership, political opinions, sexual orientation, gender identity, health information, biometric information, criminal history, and other categories defined by applicable law. If you share your sensitive personal information during a Recorded Meeting, it will be collected and retained as part of the recording and transcription processes.
HOW WE USE PERSONAL INFORMATION
We may use and otherwise process your personal information for the following purposes:
- Our Business Operations, such as customer support, information technology, regulatory compliance, litigation, information security, fraud detection and prevention, supplier and vendor management, and improving our internal operations, which include:
- Meeting and Event Facilitation, Implementation, and Memorialization, such as providing or developing minutes or another record of the discussions held in the Recorded Meeting; developing internal materials; facilitating or providing training; and improving meeting quality and efficiency.
- Communications and Information Exchangesbetween participants of meetings.
- Recorded Meeting Content Publication, with consent, such as publicizing webinars, trainings, and our events hosted virtually or in a hybrid setting.
- Business Operations, such as managing our internal operations and technology; performing business functions; managing our business relationships; performing research; developing insights; and improving our products, services, and business.
- Authentication, Integrity, Security, and Safety, such as authenticating accounts and activity; detecting, investigating, and preventing malicious conduct, fraudulent activity or unsafe experiences; addressing security threats; protecting public safety; and securing our systems. We use advanced tools to automatically scan certain types of content such as files uploaded or exchanged through chat, for the purpose of detecting and preventing violations of our policies and illegal or other harmful activity.
- Legal, Regulatory, and Compliance Obligations, such as fulfilling legal requirements; complying with applicable law; responding to valid legal processes; complying with law enforcement or government authority requests for information; investigating and obtaining advice for legal claims, or for compliance, regulatory, investigative and disciplinary purposes (including disclosure of such information in connection with anticipated or actual legal process or litigation); protecting you, us, and others from fraudulent, malicious, deceptive, abusive, or unlawful activities; and enforcing or investigating potential violations of our policies.
We generally rely on the lawful basis of performance of a contract when processing personal information related to virtual meetings. When recording a meeting we generally rely on your consent. Additionally, we may process your personal information for our legitimate interests to provide optional programs and initiatives, operate our business, meet our contractual and legal obligations, and protect the security of our systems.
You can opt out of recording by keeping your camera off and participating by chat instead of audio; please note that chat messages may be retained for all meetings in accordance with our retention policies.
HOW WE COLLECT PERSONAL INFORMATION
We may collect, access, or otherwise obtain personal information about you from the following categories of sources:
- Directly from You, when you set up a profile and initiate or participate in a Recorded Meeting.
- Automatically from Your Device, including your computers, mobile phones, smartphones, and tablet devices, including personal devices if logged on to our network and/or using the Platform.
OUR DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information for the uses described above to the following entities and individuals:
- Our Affiliates, Member Companies, and Subsidiaries as a normal part of conducting business.
- Meeting Invitees and Attendees that were invited to a meeting, even if they did not attend.
- Business Operation Service Providers and Suppliers working on our behalf to help us manage our business or assist in protecting and securing our systems and services, including IT and IT support, consultants, contractors, and professional advisors.
- Trade Unions and Works Councils as contemplated by our collective and recognition agreements.
- Law Enforcement Agencies, Courts, Regulatory Agencies, and Other Entities to comply with reporting obligations (such as anti‐discrimination laws); legal processes (such as court orders, subpoenas); or other legal requirements of any governmental authority, in connection with threatened or actual litigation, to protect our legal rights or property, to protect the legal rights or property or physical security of others, to investigate possible misconduct, or for the prevention or detection of crime as such disclosure is lawful.
- Parties to Corporate Transactions as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
- Other Recipients, such as persons or entities upon your request; to the general public; and as part of other public disclosures.
Personal information will be stored in STO Building Group’s systems, including Microsoft O365 and Teams, which may be hosted and managed by our service providers and suppliers. These systems may be located in your country of residence or in another location where STO Building Group, its service providers, or suppliers have operations, as described in the Location and Transfer of Personal Information Go to https://stobuildinggroup.com/policies/sto-building-group-recorded-meeting-privacy-notice/#ltopisection below. When required by applicable law, disclosures of personal information shall be subject to an agreement that limits the purpose of processing, requires appropriate security safeguards, and ensures compliance with applicable law. For more information about the specific persons and entities who may process your personal information, please contact us as described in the How to Contact UsGo to https://stobuildinggroup.com/policies/sto-building-group-recorded-meeting-privacy-notice/#htcontact section below.
Microsoft online services are used for the recording and transcription of Microsoft Teams meetings. For more information about how Microsoft processes personal information, please visit the Microsoft Trust CenterGo to https://www.microsoft.com/en-us/trust-center/product-overview.
We may disclose anonymized, de-identified, and aggregated information in accordance with applicable law.
AUTOMATED PROCESSING
We may use artificial intelligence, algorithms, machine learning, and other automated means to process your personal information in Recorded Meetings, including through Microsoft . Information collected through Recorded Meetings may also be used to train such automated tools. Microsoft Teams Premium and Microsoft Copilot provide features to optimize the meeting experience, including summarizing key discussion points, analyzing meeting effectiveness using discussion prompts, and identifying next steps.
You may have certain rights related to such automated processing, which may vary depending on your location and the location of your job. Where required by applicable data protection laws, we will notify you prior to making decisions based solely on automated processing when such decisions would have a significant legal impact on you. We will make such decisions only when we have a lawful basis for such processing.
CONFIDENTIAL INFORMATION
Any confidential or proprietary information discussed or shared during a Recorded Meeting should not be shared beyond the intended recipients. Recipients of Recorded Meetings should only disclose recordings to persons invited to the Recorded Meeting or specifically authorized to receive the recording.
CHOICE AND CONTROL OF PERSONAL INFORMATION
Subject to applicable data protection laws, you may have rights related to your personal information, including the rights to:
- Request access to or a copy of your personal information, such as a meeting recording, that we collect, use, and/or disclose.
- Obtain your personal information in an electronic format and transmit such personal information to another data controller.
- Request that your personal information be corrected, updated, and/or completed if you become aware that any personal information we hold about you is incorrect, incomplete, or if you wish to update your personal information.
- Request that we delete, destroy, or anonymize personal information that we have collected, used, disclosed, or otherwise processed about you.
- Object to or restrict collection, use, disclosure, or other processing of your personal information under certain circumstances.
- Withdraw your consentto process your personal information in circumstances where our collection, use, disclosure, or other processing is based on your consent. Any withdrawal of consent will not affect the legality of the processing carried out on the basis of consent before its withdrawal.
Your rights may depend on local law. STO Building Group will be guided by local law in responding to privacy rights requests. Please note that we must maintain certain personal information about you to comply with our legal obligations and for other business purposes.
If you wish to exercise any of your rights regarding your personal information, ask questions about this Notice, or file a complaint, please submit a request via our webformGo to #. If you have any complaints about the processing of your personal information, please contact us first. Without prejudice to the above, you may exercise your right of appeal to your local data protection authority.
Under applicable law, and depending on the sensitivity of the personal information, we may need to verify your identity and the validity of the request before fulfilling your request. This may require you to provide several pieces of information that we can match against our records to verify your identity.
The exercise of these rights may be restricted by the applicable law in your country of residence or locality and exemptions permitted under relevant laws. In some cases, we may lawfully refuse your request, such as where we are legally obligated or have a court order. However, if we refuse to comply with your request, we will inform you of the reason as required by law.
We will not discriminate against you for exercising any of your privacy rights under applicable law.
RETENTION OF PERSONAL INFORMATION
We keep the categories of personal information described above for as long as is necessary for the purposes described in this Notice or otherwise permitted or authorized by law. This generally means holding each category of personal information for as long as it is reasonably necessary for us to manage our records, our operations, or your relationship with us; satisfy another disclosed purpose for which we collected the information; or carry out a purpose that is reasonably compatible with the context in which the personal information was collected. We may also maintain your personal information where it is reasonably required to protect or defend our rights or property or where we are otherwise required or permitted to keep your personal information by applicable laws or regulations. Where personal information is used for more than one purpose, we may retain it until the purpose with the latest period expires.
Recordings of public webinars, training sessions, and similar events might be kept as long as the webinar or training is relevant for our employees or as long as permitted under our general retention policies. Transcripts may be maintained as long as permitted under our general retention policies.
For information on how to delete your Microsoft Copilot Interaction History, please click hereGo to https://support.microsoft.com/en-us/office/delete-your-copilot-for-microsoft-365-interaction-history-76de8afa-5eaf-43b0-bda8-0076d6e0390f.
LOCATION AND TRANSFER OF PERSONAL INFORMATION
The personal information we collect from you may be stored in, accessed from, and processed in the United States, your country or region, or in any other country where we or our affiliates, subsidiaries, or vendors maintain facilities. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that the data we collect under this Notice is processed according to the provisions of this Notice and applicable law wherever the data is located. Please be aware that the data protection laws and regulations that apply to your personal information that is transferred to the United States or other countries may be different from the laws in your country of residence, and different standards may apply to how your personal information is used and protected. We use appropriate safeguards to ensure your personal information is protected in accordance with applicable legal requirements. Where applicable, we use standard contractual clauses to govern the transfer of your personal information, including the European Union approved Standard Contractual Clauses.
This section shall act as a notice of transfer of your personal information. Where required, we will provide additional notice or obtain your consent to transfer your personal information outside of your relevant jurisdiction. Because our operations are international in nature, if you do not consent to such transfer, your participation in Recording Meetings may be impacted. You can withdraw your consent by contacting us using the information in the How to Contact UsGo to https://stobuildinggroup.com/policies/sto-building-group-recorded-meeting-privacy-notice/#htcontact section below.
SECURITY OF PERSONAL INFORMATION
While no systems, applications, or websites are 100% secure, we take reasonable and appropriate steps to help protect personal information from unauthorized access, use, disclosure, alteration, and destruction.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to amend this Notice at our discretion and at any time. If we make material changes to this Notice, we will provide notice or obtain consent regarding such changes as may be required by law.
HOW TO CONTACT US
If you have any questions about this Notice, please email us at Privacy@STOBG.comGo to mailto:Privacy@STOBG.com?subject=Recorded%20Meeting%20Privacy with the subject line Recorded Meeting Privacy.