OfficeTogether Privacy Policy

Effective Date: February 16, 2021

This Privacy Policy describes how OfficeTogether, Inc. and our affiliates (collectively, “OfficeTogether”, “we”, and “us”) collect, use, disclose, transfer, store, retain or otherwise process your personal information and data when you apply or sign up for an account with OfficeTogether and other services through OfficeTogether’s website or applications (collectively, the “Services”). OfficeTogether collects, uses, and discloses your information ONLY as directed by your company. Under data protection laws, OfficeTogether is identified as a data processor or service provider (“Service Provider”) of your information with respect to the Services and not the controller or business (“Company”). In this Privacy Policy, “you” means anyone who uses our Services.

This Privacy Policy applies to information collected in connection with your access to and use of our Services. Please read this Privacy Policy in its entirety, to help you make informed decisions about the use of your personal information. Since OfficeTogether is a Service Provider, you should also read the Privacy Policy of your Company to ensure you agree with its practices. By continuing to use our Services, you consent to the practices described in this Privacy Policy.

LEGAL BASIS FOR PROCESSING UNDER GDPR AND CCPA.

This Privacy Policy is meant to be compliant with the General Data Protection Regulation 2016/679 (“GDPR”) and California Consumer Privacy Act (“CCPA”). The processing of your Personal Information as described herein is necessary to meet our contractual obligations to you or your Company, to meet our legal obligations, or to meet our legitimate interests in providing our Services. Moreover, OfficeTogether does not sell your personal information as the terms “sell” and “personal information” are defined by the CCPA and, in providing its services to the Company, OfficeTogether will not retain, use, or disclose your personal information to any other third parties that would constitute “selling” as the term is defined by the CCPA. Our legitimate interests may include analyzing, improving, and better tailoring our products and Services. Any questions or requests regarding OfficeTogether’s processing of your personal information in respect of your rights under GDPR and CCPA should be directed to the Customer Data Controller that is responsible for your personal information.

California residents have the right not to receive discriminatory treatment by OfficeTogether for the exercise of their rights conferred by the California Consumer Privacy Act.

INFORMATION WE COLLECT

OfficeTogether requests different types of Personal Information from you and your company or others, depending on the Services you use. We may collect the following categories of information, depending on the Services that you use:

  • Personal Information” is data that can identify you as an individual either on its own or in combination with other information, including your name, phone number, your company or personal email address, usernames and passwords and other information that enables us to contact you.
  • Professional and Employment-Related Information: This includes your company, your name, title, role, team, and other information about your profession.
  • Email Calendar Information: Our Services integrate with your corporate email calendar (e.g., Gmail or Microsoft Outlook) and collect data regarding your seating choices and the conference rooms you book; we do not collect information contained on your calendar.
  • Communications: Any other information that you intentionally share, send, or receive using the Services, including your email, Slack, calendar, and any other information you choose to share with us — including your photos — and that you send or receive using the Services.
  • Device and Usage Information: Including information about your computer or device and internet or other electronic network activity information. This includes:
    • Device identifiers, such as IP address for bug reporting purposes.
    • Information about your online activity, including information collected through the use of standard internet technologies, such as cookies, logs, and other internet technologies, as further set forth in our Cookie Policy, and your offline activity, including information about your office attendance; and
    • Space utilization information and information about how you use our Services.
  • Answers to COVID-19 Health check: If your Company requires that you certify that you are not suffering from symptoms of COVID-19 by responding to certain health related questions then you will not be able to use the Services unless you certify that none of the COVID-19 related questions apply to you. 1 Evidence of your certification is retained by us and stored confidentially on behalf of your Company.
  • Anonymous, Aggregated, and Other Information Collected: In addition, we collect and/or generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymized or aggregated information is not Personal Information.

HOW WE COLLECT YOUR DATA

We collect information and process data from the following sources:

  • When you register online to use our Services and during your use of our Services after being invited by your Company.
  • Your employer provides us with your information to invite you to register for our Services.
  • When you voluntarily complete a customer survey or provide feedback on any of our Services via email or third party services.
  • Use or view our website via your browser’s cookies.
  • Google and other third-party analytics.

USE OF INFORMATION COLLECTED:

OfficeTogether collects your data so that we can:

  • Provide you with our products and Services, including online scheduling and reservation of work space; 1 The Health Insurance Portability Accountability Act of 1996 (“HIPAA”) does not apply to the COVID-19 information collected on behalf of your company. HIPAA applies only to covered entities, health plans, health care clearinghouses, and most health care providers, not to employers acting in their capacity as employers.
  • Ensure compliance with government or company issued protocols designed to prevent the spread of Covid-19;
  • Protect against fraud, abuse, or harm and otherwise provide secure physical environments;
  • Respond to or fulfill customer service requests;
  • Analyze, better tailor, and improve our Services;
  • Contact you about our Services, enhance your engagement with us, and otherwise communicate with you; and
  • Comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

SHARING OF PERSONAL INFORMATION

We disclose your Personal Information in limited circumstances to OfficeTogether, our service providers, your Company and other users at your company, in order to provide our Services and to improve your company’s workspace experience. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent.

  • OfficeTogether: We may share your Personal Information among OfficeTogether representatives depending on where you are located and the Services that you use. OfficeTogether uses your information in accordance with this Privacy Policy.
  • Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. We take steps to ensure that these service providers act only in line with our instructions and only use Personal Information as described in this Privacy Policy and data protection agreements with equivalent protections for your Personal Information.
  • Research / Survey Solicitations: Your participation is voluntary, and we will use the information that we collect for research and reporting purposes, and to help us to improve the quality of our Services. We use the survey responses to determine the effectiveness of our Services, including the quality of our communications. If you participate in a survey, your responses will be used along with other participants’ responses.
  • Other Parties When Required by Law: There may be instances when we disclose your Personal Information to other parties:
    • to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;
    • to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement;
    • to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services; or
    • to protect our rights, company property, and safety of other company employees; and
    • where otherwise required by law.

HOW WE STORE YOUR DATA AND SECURITY

The security of all Personal Information provided to OfficeTogether is important to us. OfficeTogether uses commercially reasonable physical, electronic, and procedural safeguards designed to protect your Personal Information against unauthorized or unlawful processing and accidental loss, destruction, or damage. OfficeTogether regularly conducts security reviews, vulnerability scans, and/or penetration tests to ensure compliance with industry security practices and standards. Unfortunately, no data transmission
over the internet or storage of information can be guaranteed to be 100% secure. As a result, while OfficeTogether strives to protect your Personal Information, we cannot ensure or warrant the security of

any information that you transmit to OfficeTogether, and you do so at your own risk. As such, we ask that you help us be safer together by implementing your own security controls, such as a strong password, not sharing your credentials with others, logging out when you are done using our Services, and other security best practices.

OfficeTogether will keep your Personal Information for 30 days after the end of the contract with your Company if you do not request deletion earlier. Once this time period has expired, we will delete all related company data, including reservations, offices, floor plans, emails and integration info.

NO MARKETING

OfficeTogether does not sell your Personal Information and, in providing the services to your Company, OfficeTogether will not retain, use, or disclose your personal information to any third parties that would constitute selling of your Personal Information as the term “sell” or “selling” is defined by applicable law.

YOUR DATA PROTECTION RIGHTS

OfficeTogether would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

  • The right to access – You have the right to request OfficeTogether for copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification – You have the right to request that OfficeTogether correct any information you believe is inaccurate. You also have the right to request OfficeTogether to complete information you believe is incomplete.
  • The right to erasure – You have the right to request that OfficeTogether erase your personal data, under certain conditions. If you as an individual request your data be deleted, we will anonymize your name and Personal Information while leaving your reservation history intact for recording keeping purposes.
  • The right to restrict processing – You have the right to request that OfficeTogether restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to OfficeTogether’s processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that OfficeTogether transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@officetogether.com

Call us at: +1 (707) 652-9246

PRIVACY POLICIES OF OTHER WEBSITES

If links to other websites are contained in the services, this Privacy Policy applies only to our Services. If you click on a link to another website, you should read their privacy policy.

CHANGES TO OUR PRIVACY POLICY

OfficeTogether keeps its privacy policy under regular review and places any updates on this web page. This Privacy Policy was last updated on February 16, 2021.

HOW TO CONTACT US

If you have any questions about OfficeTogether’s Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: privacy@officetogether.com

Call us: 1(415)234-0521

Or write to us at: OfficeTogether, Inc. [1355 Valencia St Apt 02, San Francisco, CA 94110]

HOW TO CONTACT THE APPROPRIATE AUTHORITIES

If you are located in the United Kingdom and wish to report a complaint or if you feel that OfficeTogether has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/ or call 0303 123 1113.

If you are located in the European Economic Area and wish to report a complaint or if you feel that OfficeTogether has not addressed your concern in a satisfactory manner, you may contact theInspectorate of the Personal Data Protection Commission at 2 Professor Tsvetan Lazarov, Sofia 1592 Bulgaria; kzld@cpdp.bg; www.cpdp.bg.

If you are located in the state of California and wish to report a complaint or if you feel that OfficeTogether has not addressed your concern in a satisfactory manner, you may contact the California’s Office of the Attorney General.

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