Work Way Solutions has many affiliated entities that act as data controllers around the world who will act as the data controller for your Personal Information, and your Personal Information may therefore be shared with entities outside of the jurisdiction in which it was collected. For more information on the data controller for your jurisdiction please contact [email protected] for the name of the Work Way Solutions entity responsible for your Personal Information and the appropriate contact information for that entity.
We want to help you build a life, and not just a living, through our Services. Before you use our Services, please read this Policy in its entirety, to help you make informed decisions about your relationship with us.
Personal Information. “Personal Information” is data that relates to you and can — either on its own or in combination with other information — identify you as an individual. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using means reasonably available to us.
Our Services. The Services referenced in this Policy include the Services provided by Work Way Solutions. You can read more about how Personal Information is used by clicking below on the name of Work Way Solutions Services, websites, or applications you use.
References to “you.” In this Policy, “you” means anyone who uses our websites, applications, or other Services.
Authoritative Version. When the text of this Policy is available in multiple languages, the English version is the authoritative version, except where prohibited by applicable law.
COVID-19. We may collect, use, disclose, and otherwise process your Personal Information in connection with our response to COVID-19. For more information, please review the Covid 19 Policy
2. INFORMATION WE COLLECT
The Personal Information that we collect, and our use of that information depends on your relationship with us and the requirements of applicable law as described below.
We collect information:
o that you provide to us directly.
o that your company, broker, host, parent, or guardian provides to us;
o If you opt-in to certain features or depending on your device settings, we obtain geo-location data and information about your contacts;
o from third parties such as our landlords, building managers, licensees and property brokers); and
o that we obtain from other sources, including data brokers or information providers (such as Dun & Bradstreet).
INFORMATION COLLECTED FROM YOU
Work Way Solutions requests different types of Personal Information from you and your company or others, depending on the Services you use and your relationship with us. We may collect the following categories of information, depending on the Services that you use:
o Contact Information and other Identifiers, including your name, mailing address, phone number, email address, and other information that enables us to contact you;
o Verification Information, including your personal photograph, photo ID or government issued identification, and date of birth;
o Professional and Employment-Related Information, including your company name, title, role, team, and other information about your profession;
o Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase;
o Email Calendar Information, when we integrate with your corporate email calendar (e.g., Gmail or Microsoft Outlook) and collect data regarding the conference rooms you book;
o Office Preferences, including your requested or preferred temperature, fan speed, desk and chair height, desk location, phone booth, beverage, snack, and other preferences related to the Services;
o Utilization Information, including how frequently you visit, how long you stay, and what types of Services you use when you visit a Work Way Solutions location. These include services such as printer or Wi-fi usage, and desk or conference room bookings;
o Communications, and any other information that you intentionally share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through feedback platforms, automated chatbots or similar technology, calendar invitations, and any other information you choose to share with us — including your photos, videos, blog entries, interests, hobbies, lifestyle choices, and groups with which you are affiliated — and that you send or receive using the Services;
o Device and Usage Information, including information about your computer or device and Internet or other electronic network activity information. This includes:
o Device identifiers, such as IP address, WIFI MAC address, and Bluetooth address.
o Geolocation information, such as through your mobile device’s GPS signal or WIFI signal, and information about your contacts, depending on your device settings;
o Information gathered by sensors about how you use our Services, including through Spatial and People Analytics Sensors (“SPA Sensors”) in offices, kitchens, conference rooms, and other spaces of some facilities that you may work in or visit, to promote more efficient and comfortable uses of the Services. Examples of SPA Sensors include desk occupancy sensors, environmental sensors, WiFi network hubs, and optical camera-powered sensors.
o Other Personal Information, including, in addition to all of the information described above, instant messenger and social media screen names, usernames and passwords, relationship to emergency point of contact, vehicle identification, and other details such as the time and purpose of your visit, photos of you, and data or files that you input, upload, or store with the Services, such as search queries that you submit, and documents that you upload to the Services. We will also process Personal Information included in content and information that you add to your member network or other community profile.
INFORMATION COLLECTED ABOUT YOU
o Social Media. Work Way Solutions collects Personal Information to enable you to use online social media resources, including the use of our Member Network (MENA). If you register or log into your account through a third-party social media service, we will have access to some of your account information from that service, such as your name and other information in that account, as authorized by your settings on that service. You have the ability to disable the connection between our Services and your third-party social media account(s) at any time.
o Third-Party Sources. We obtain Personal Information about you from your company, broker, parent or guardian, or from your host if you are a visitor or guest to one of our spaces. We also may receive your Personal Information from publicly and commercially available sources, as permitted by law and other third parties with whom we have an arrangement . We combine this information with Personal Information or other information that we receive from or about you, where necessary to provide the Services you requested. If we obtain Personal Information about you from a third party, we will confirm that the Personal Information is from a legitimate source.
o Google and Other Third-Party Analytics. We use a tool called “Google Analytics” to collect information about the use of our Website Services (e.g., Google Analytics collects information such as how often users visit the Website Services, what pages they visit when they do so, and what other sites they used prior to visiting the Website Services). Google Analytics collects only the IP address assigned to you on the date that you visit the Website Services, rather than your name or other identifying information. The information collected through the use of Google Analytics is not combined with your Personal Information. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about use of certain online Services.
o “Do Not Track.” If you have enabled the feature, your web browser may transmit “do-not-track” signals to our websites and other online services with which your browser communicates. We currently do not take any action in response to these signals.
o Mobile Computing. We provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of the Services may require you to log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, Work Way Solutions enables you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools transmit Personal Information to Work Way Solutions to enable you to access your user accounts and to enable Work Way Solutions to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.
ANONYMOUS, AGGREGATED, AND OTHER INFORMATION
We also collect certain information about you that is not Personal Information. This may include intellectual property or other company information you share with us or through the Services, in accordance with any applicable agreements between you or, if applicable, your company, including, for example, trademarks, logos, and other intellectual property you own.
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.
3. USE OF PERSONAL INFORMATION
How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to:
o provide you with our products and Services, including online and offline events, and other materials you request;
o protect against fraud, abuse, or harm and to otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);
o respond to or fulfill customer service requests;
o analyze, better tailor, and improve our products and Services;
o contact you about our Services, promotions, and sweepstakes, tailor and provide you with relevant advertising, enhance your engagement with us, and otherwise communicate with you through various means, which may include by email, telephone, post, or by other means as communicated to you from time to time; and
o 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.
LEGAL BASES FOR PROCESSING PERSONAL INFORMATION IF RESIDENT IN THE UK AND EU
The processing of your Personal Information as described above 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. Our legitimate interests may include providing you and others with a secure environment, analyzing, improving, and better tailoring our products and Services, being more efficient, fulfilling any contracts you have with us and helping to prevent fraud.
We also generally rely on our legitimate interests in marketing our Services to you, whether on our own websites or on third-party websites, and in providing promotions or sweepstakes, where permitted by applicable law. We provide you with choices about how we use your Personal Information, in accordance with applicable law, by allowing you to opt-out of receiving all such communications (unless they are transactional solely related to the provision of our Services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where applicable, we also may process Personal Information with your consent. Remember that in certain circumstances, and where permitted by applicable law, you may have the right to object to our uses of your Personal Information as further described in Section 5 of this Policy.
4. SHARING OF PERSONAL INFORMATION
We disclose your Personal Information in limited circumstances to Work Way Solutions, our community, our service providers and advertisers, other end users, in order to provide our Services and to improve ways of working in our community and where required by applicable law. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent. We will require all parties receiving your Personal Information to take appropriate measures to protect your Personal Information and to process your Personal Information only for the purposes described:
o Among Work Way Solutions. We may share your Personal Information among Work Way Solutions businesses or entities depending on where you are located and the Services that you use. Work Way Solutions uses your information in accordance with this Policy, and we share this information for our administrative purposes including activities such as IT management, for them to provide services to you, or to support and supplement the Services that we provide.
o Our Community. Our Services include online and offline member communities, forums, networks, and other features through which you may share information and connect with others. This includes:
o Our Services may make member networks, chat rooms, forums, and/or other groups available to users. Remember that anyone can read, collect, or use your postings on a network or forum or in a chat room or group and we cannot be responsible for any unauthorized third party’s use of information that you publicly disclose online.
o We foster our community by creating profiles for members or permitting members to create their own profiles on member networks or forums. Typically, such a profile contains your name, the name of your company, and other information you provide or add to your profile (content, comments, photos, etc.). Depending on the Services you use, this profile might be created automatically and be accessible to other members of the network or forum. Member Network profile information is accessible to all members. You can also share your profile with a broader audience (e.g., via social media).
o When we receive information about you in connection with your relationship with our members or clients—for example, if you are a member’s employee or if you are visiting one of our clients—we may share your information with the member or client with which you have such a relationship, for example, by alerting the member or client that you have arrived to visit. Please note that we are not responsible for the privacy practices of our members or clients, or their third-party service providers, including those they integrate with our Services.
o We also may share information about you with others in the community to provide you with certain features. For example, if you sign up for a mentoring program, we may share information about you with potential mentors.
o Primary Members. Information on the utilization of our services by individual members may be shared with the primary member or the organization who purchased the memberships. Examples of individual members are employees of a member company or students of a member university.
o Suppliers and Vendors. We rely on various third-parties to perform a variety of services on our behalf and to help us grow and improve our business. We take steps to ensure that where we share your Personal Information with these third parties that they act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.
Landlords and Building Management. In some cases we may share your Personal Information with our landlords and/or building management at Work Way Solutions properties so that they can effectively manage and operate the building.
o Research / Survey Solicitations. From time to time, we will share your Personal Information to perform research (online and offline) via surveys on our behalf. 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 and our advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.
o Third-Party Advertising Partners. We share limited Personal Information with third parties that serve our advertising online, so that they can display our advertisements to individuals who may find them most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively.
o Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose your Personal Information to other parties:
o to provide you with the Services that you or your company request;
o to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;
o to comply with applicable law or respond to a legal process or a request for cooperation by a government entity or law enforcement;
o to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services; or
o to protect our rights, property, and safety or that of any of the Work Way Solutions companies, business partners, members, or employees; and
o where otherwise required by applicable law.
We share Personal Information in this way either to comply with legal obligations to which we are subject, or to meet our legitimate interests in protecting our business, including from fraud and legal claims.
o Other Parties in Connection with a Corporate Transaction. We disclose or share your information in the event that we purchase, sell, finance, transfer, or acquire all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.
o Other Third-Party Partners, in Connection With your Membership Agreement. When the terms of your Membership Agreement allow, and where permitted by applicable law, we may disclose or share your contact information with select third-party partners who may contact you to offer additional services related to your Membership. You may opt out of further communications with such third-party partners by contacting Work Way Solutions and are under no obligation to meet with third-party partners or purchase additional services.
o Other Third-Party Partners, With Your Consent. We may request your consent to share Personal Information about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicize your name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.
4.1 THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES
We partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example:
o Third parties that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they collect information about you, such as your IP address and the pages that you view.
o Advertising providers help us, and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on your online behavior, and analytics companies help us measure and evaluate the usage of our services.
o Other content providers offer products and services on our Services and operate contests, sweepstakes, or surveys on our Services.
Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Advertising Digital Alliance (EDAA) to learn more. Canadian users may also visit the Digital Advertising Alliance of Canada. Further information in local languages is available at www.aboutads.info or www.youronlinechoices.eu.
4.2 SOCIAL MEDIA
We are active on social media (e.g., Twitter, Facebook, etc.) and share information, images, and videos with the public through unaffiliated external social media sites. We encourage you to read their policies. Remember that the social media sites are public, which means that anyone can see your posts, and your posts may even show up in search engine results.
While we will not edit comments, we may delete a comment from our page on a social media site if it, for example, does not relate to the post, promotes a commercial product or service, uses obscene, threatening, or harassing language, or if it is a personal attack or hate speech that targets or disparages any ethnic, racial, age, or religious group (or other legally protected group), or if it advocates illegal activity or violates copyright laws.
5. RIGHTS IN YOUR INFORMATION: ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
We value your rights to your data. In accordance with applicable law, you may have the right to:
1. request confirmation of whether we store, use, or share any of your Personal Information and be informed about third parties with whom your Personal Information has been shared;
2. obtain access to or a copy of your Personal Information;
3. receive an electronic copy of the Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”);
4. restrict our uses of your Personal Information or, as described above, object to those uses or restrict our sharing of your Personal Information;
5. seek correction of inaccurate, partial, untrue, or incomplete Personal Information; In some cases, we may provide self-service tools that enable you to update your Personal Information;
6. request erasure, anonymization, or blocking of Personal Information held about you by Work Way Solutions, subject to certain exceptions prescribed by law, when processing is based on your consent or when processing is unnecessary, excessive or noncompliant; 7. withdraw your consent to our processing of your Personal Information. If you refrain from providing Personal Information or withdraw your consent to processing, some features of our Service may not be available; 8. object to an automated decision Work Way Solutions has made and request the review of decisions taken exclusively based on automated processing if that could affect data subject rights; or 9. cancel your online account if one has been created.