Effective Date: March 23, 2022

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 our business client with whom you have a relationship with (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.  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 your Company as the 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 by the data itself or in combination with other information, including your name, phone number, your company or personal email address, usernames and passwords, IP address of your work station, your geolocation data you submit via the Services and other information that enables us to contact you.
• Professional and Employment-Related Information: This includes your company name, your 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 or otherwise have access to 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. 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 may not identify you as an individual, thus is not Personal Information as defined in this Privacy Policy.

HOW WE COLLECT YOUR DATA

****We collect information and process data from the following sources: