WorkSpace Privacy Policy

Last Updated: July 5, 2018

Welcome to the Workspace Privacy Policy ("Privacy Policy"). We take the security of your information seriously, and work hard to maintain secure websites and services for your use. Work Space LLC together with its affiliates (collectively, "Workspace", "we," or "us"), provides a centralized real estate software platform for real estate owners, brokers, managers, tenants and staff to manage real estate. We also offer consulting and professional services including training, configuration, and assistance with day-to-day use of any such services. This Privacy Policy is intended to better help you understand our practices regarding information collected, including through (i) our websites, including, but not limited to, www.workspace.cc, our mobile sites and our other affiliated websites (collectively, "Websites"), (ii) our products and services, including consulting and professional services, and related software, and (iii) any other digital properties that we own or control (collectively, the "Workspace Services" or "Services"). The Policy is applicable whether you are a customer that uses Workspace Services, a prospective customer, an end user of our customers’ services that utilize our solutions, a prospective employee or whether you are simply visiting our Websites. This Privacy Policy describes how Workspace collects, processes, shares and retains the information that does, or can be used to, identify you ("Personal Information" or, in the EU/Switzerland, "Personal Data") and that you provide to us.

When you interact with the Workspace Services, you consent to such collection, processing, sharing and retaining of information (including Personal Information/Personal Data) as described in this Privacy Policy and all additional terms and conditions governing your use of the Services. You are also responsible for ensuring that the other people that you are acting on behalf of, are aware of the content of this Privacy Policy and that you have checked with them that they agree to their Personal Data being given to us to make a purchase on their behalf. If you do not consent to the terms of this Privacy Policy and the additional terms and conditions, do not continue to interact with or use the Workspace Services.

European Privacy Policy: Please also see our European Privacy Policy for further information on your rights under applicable European privacy law.

Due to the global nature of the Workspace Services, our privacy practices may vary among the states, countries and regions in which we operate in order to comply with applicable legal requirements.

Personal Data may be transferred outside of Europe, provided that certain conditions as set out in the applicable legislation are complied with. Your Personal Data will also be processed by personnel operating outside Europe who work for us. This includes personnel engaged in, among other things, the fulfilment of your order and the provision of support services. We are party to data transfer agreements with each of our service providers and our affiliates and we will (i) keep each document up to date with current law, and (ii) only engage in Personal Data transfers from Europe to outside Europe in accordance with such an agreement or an alternative means of transfer in compliance with data protection legislation. We may also process Personal Data submitted relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses or Binding Corporate Rules.

1. INFORMATION WE MAY COLLECT

We only collect Personal Information for the purposes of conducting our business, including in relation to providing the Workspace Services. We collect, process, share, and retain information from you and any devices you may use when you access our Websites, use our Services, register for an account with us, provide us information on a web form, update or add information to your account, participate in community discussions, chats, or otherwise correspond with us.

The type of Personal Information we collect depends upon your use of the Services and on your relationship with us – whether you are a customer, prospective customer, an end user of our customers’ services that utilize our solutions, a prospective employee or whether you are simply visiting our Websites. Examples of the types of information we collect are:

  • Name
  • Address (including billing and shipping address)
  • Telephone number, fax number and/or other contact information
  • Email address
  • Payment or financial information for billing purposes
  • Location, department, manager, function
  • Website server log information automatically reported by your browser each time you access a web page, which may include information such as your web queries or navigation requests, browser type, Internet Protocol (IP) address, number of clicks on website hyperlinks, the domain names visited, landing pages visited, and web pages viewed
  • Your testimonials, feedback and complaints
  • Professional information, such as employer or organizational affiliation for a customer, partner, distributor or reseller
  • Screen name
  • Screen sharing views, at the request of customers, for support and quality assurance ("QA") purposes
  • Any data in any files uploaded, emailed or otherwise provided by customers for support and QA
  • Operating system type and version, web server type and version, database type and version
  • Unique IDs such as a cookie placed on a computer or mobile device, or device IDs
  • IP address or MAC address, and information derived from an IP or MAC address, such as geographic location
  • Browsing activities, cookies and similar data, and platform or mobile application use data
  • Referring domain, destination domain and destination path
  • Geolocational data, including latitudinal and longitudinal data
  • User IDs and passwords for customers with accounts on the Services
  • Information about the performance, security, software configuration and availability of our software on your servers and network
  • Website user statistics and website and portal use and viewing activity records
  • Communication preferences
  • If you are an employee or prospective employee
    • Your tax file number or other government related identifiers
    • Your employment history and qualifications, and background checks relevant to your job application
    • Employee number
    • Last 4 digits of Social Security number
  • Other similar information

We may collect your Personal Information in a number of ways, including in person, by telephone, by email or electronically when you contact us, visit our Website, or access use or Services to:

  • Registration, purchase and use of the Workspace Services: Information such as name, email address, telephone number, company/organization, and other information, may be collected in connection with registration for, purchase of or use of the Workspace Services (for example, to sign-up for and log into the Workspace Services), as well as when you download our mobile application. Customers may update their information by logging into their account.
  • Communications: Personal information such as name, email address, and other information, may be collected, when provided in any communications, whether via email, social media, telephone or otherwise.
  • Support: Personal information may be collected in connection with customer support, whether via screensharing, email, social media, telephone or otherwise.
  • Surveys and Research: We may collect Personal Information from anyone participating in research and surveys.
  • Information We Automatically Collect: We receive and store certain types of information whenever you interact with us or our Service. Our Websites use “cookies,” tagging and other tracking technologies. This information includes computer and connection information such as statistics on your page views, traffic to and from our Websites, referral URL, ad data, your IP address, and device identifiers; this information may also include your browsing history, transaction history, and your web log information.
  • Sign-in Features: Our Website includes links to other websites and online services whose privacy practices may differ from those of Workspace. For example, you can log in to our Website using single sign-on services. These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign-up form. If you submit Personal Information to or through any of those web sites or services, your information is governed by the privacy policies of such third-party sites or services. We encourage you to carefully read the privacy statement of any website you visit or online services you use.
  • User Comments and Content: If you post any comments or content on our Websites, you should be aware that any personally identifiable information you choose to provide there may be read, collected, or used by third parties. We are not responsible for the information you choose to submit and we cannot guarantee that third parties have not made copies of or will not use such information in any way.
  • Information From Other Sources: We may supplement the Personal Information we collect with information from third parties and add it to your account information. Information from third parties may include, but is not limited to, demographic information that is publicly available, additional contact information, group affiliations, occupational information, and educational background. We may also collect your Personal Information from third parties, including data available on the internet, and data purchased from third party sources. Where Personal Information is obtained from third party sources, the collection, use and disclosure of that Personal Information will be governed by the third party's privacy policy as well as by applicable privacy laws. If you are a prospective employee, we may also collect Personal Information from credit agencies (after seeking your consent to do so).
  • Non-personal Information: Our Services may collect information that, by itself, does not identify you or cannot be used to identify you (“Non-personal Information”). Non-personal Information may also be made available or gathered via your use of the Services. Non-Personal Information does not directly relate to an individual on its own or in combination with other information we have collected or that has been provided. If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

2. USE OF INFORMATION

Workspace may use the information, including Personal Information, collected in connection with the Workspace Services for the purpose of providing the Services to our customers, as well as for supporting our business functions, such as fraud prevention, marketing, analytics and legal functions, and other legitimate purposes.

To the extent permitted by applicable law and, for customer data, as permitted by our customer agreements, we may use information collected in connection with our Services:

  • To deliver our Services from our Websites.
  • To provide, maintain, and improve the Websites for internal or other business purposes.
  • To fulfill customer requests, such as to create a Workspace Services account or to provide requested services.
  • To communicate with our customers; to inform customers and users of products, programs, services profiles or transactions with us, and changes to our policies or terms, as applicable.
  • To send offers, promotions, or other communications about our Services, including special or promotional events, including services, products, or events for which we collaborate or co-offer with a third party.
  • To send customers information regarding the Workspace Services, including information about features and enhancements on or to our Websites and issues specifically affecting Workspace Services.
  • To understand and respond to reviews, comments, or other feedback provided to us.
  • To support, optimize, improve and personalize our Services, and advertising, including tracking and evaluating the use of the Websites.
  • In the case of server logs, to help us statistically monitor how many people are using our site and for what purpose.
  • To send newsletters or other materials.
  • To protect the security and integrity of our Services, content, and our business.
  • To explore prospective sales leads.
  • For benchmarking, data analysis, audits, developing new products, enhancing the Workspace Services, facilitating product, software and applications development, improving our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes.
  • To perform statistical, demographic, and marketing analyses of users of the Websites and their viewing patterns.
  • To meet our contractual requirements, to comply with applicable legal or regulatory requirements and our policies, and to protect against criminal activity, claims and other liabilities.
  • For any other lawful purpose for which the information is provided, including fulfilling requests for information.

Processing billing and payments. If you have been designated by your organization as being a contact for billing or payment purposes, we will use your Personal Information to process your organization’s order and issue invoices to your organization.

Marketing communications. From time to time we may use your Personal Information to contact you with information regarding company news or and ancillary products via e-communications. You will have the choice to opt in or opt out of receiving such communications. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material. If we have collected your Personal Information through our Websites or through other channels (such as if you have exchanged contact information with one of our sales representatives or business partners), and we have permission to do so, we will use your Personal Information to inform you about other services and products that might be of interest to you and to gather feedback from you on our Services.

Personal information under the control of users of the Workspace Services. In some circumstances, we may access and use Personal Information that has been collected by you in the course of your use of the Services. This Personal Information remains under your control at all times. We will only use this information on a limited basis to fulfill our contractual obligations to you to:

  • diagnose and address software programs;
  • provide hosting services;
  • fulfill IT-related duties for technical maintenance and the backup of the hosting environment;
  • provide consulting services in relation to the installation and configuration of our software;
  • assist with the preparation and migration of data to our software;
  • develop product enhancements; and
  • provide data capturing services.

Aggregate Information. To the extent permitted by applicable law, we may use, process, transfer, and store any data about individuals and customers or partners in an anonymous (or pseudonymous) and aggregated manner. We may combine Personal Information with other information, collected online and offline, including information from third party sources. We may also use information in other ways with consent or as permitted by applicable law. By using the Workspace Services, our customers agree that we are hereby licensed to collect, use, share and store anonymized (or pseudonymized) aggregated data collected through the Workspace Services for benchmarking, analytics, A/B testing, metrics, research, reporting, marketing, machine learning and other business purposes.

3. SHARING OF INFORMATION

To the extent permitted by applicable law, Workspace may share and disclose information, including Personal Information, as set forth below:

  • >Customers. We may share information with our customers and their service providers and other platforms that may assist those customers.
  • Affiliates and Agents. We may share information with our affiliates, any business partners or agents acting on our behalf). Please refer to the websites of such third party for their Privacy Policies and other information on such third party.
  • Service Providers. We may share information with our service providers (e.g. data storage and payroll service providers), agents, vendors and other third parties we use to support and advertise the Workspace Services and our business. Such service providers may include database providers, data analytics providers and other suppliers who assist with providing technical support. We share Personal Information with such third parties to the extent necessary to provide services to us, and pursuant to binding contractual obligations.
  • Advertising and Marketing. To the extent permitted by applicable law, we may share information with third parties for marketing, advertising, promotions, contests, or other similar purposes. If required by applicable law, we will share such data for advertising and marketing purposes only in an aggregate, anonymous, and de-identified manner.
  • Mergers, Acquisitions, Divestitures. We may share, disclose or transfer information to a buyer, investor, new affiliate, or other successor in the event Workspace, or any affiliate, portion, group or business unit thereof, undergoes a business transition, such as a merger, acquisition, joint venture, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of any assets of Workspace or any affiliates or during steps in contemplation of such activities (e.g., negotiations and due diligence).
  • Law Enforcement and National Security. We may share information with legal, governmental, or judicial authorities, as instructed or required by those authorities or applicable laws, or to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, government request, regulatory request, law enforcement or national security investigation, or as otherwise required or authorized by law.
  • Protection of Rights, Property or Safety. We may also share information if, in our sole discretion, we believe disclosure is necessary or appropriate to protect the rights, property or safety of any person, or if we suspect fraud or other illegal activity.

Workspace may also disclose Personal Information for other purposes or to other third parties when an individual has consented to, or requested, such disclosure, or where a customer has obtained permission from such individual, or where such disclosure is otherwise legally permitted for legitimate business purposes, and, for customer data, with such customer’s authorization or otherwise in accordance with Workspace agreement with such customer.

4. COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies and similar technologies to operate and improve the Workspace Services, as well as to simplify our interaction with you. A "cookie" is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the Services. We may use cookies, log files, pixel tags, web bugs, web beacons, clear GIFs, Local Storage Objects (LSOs) such as HTML5 and Flash or other similar technologies to collect information about the ways you interact with and use the Workspace Services, to support and enhance features and functionality, to monitor performance, to personalize content and experiences, for marketing and analytics, and for other lawful purposes.

We may use the following types of cookies and similar technologies:

  • Essential/strictly necessary cookies required for the operation of the Workspace Services. They include, for example, cookies that enable you to log into secure areas.
  • Analytical/performance cookies that collect information about how you use the Workspace Services. They allow us to recognize and count the number of visitors and to see how visitors move around our Websites. This helps us to improve the way our Websites work. [These cookies are sometimes placed by third party providers of web traffic analysis services.]
  • Functionality cookies that remember choices you make and recognize you when you return. This enables us to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region) or allow the pre-population of certain resource request forms, making it easier for you to access Workspace content.

Most internet browsers accept cookies by default. You can block cookies by activating the setting on your browser that allows you to reject all or some cookies. The help and support area on your internet browser should have instructions on how to block or delete cookies. Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you to when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may encounter issues using the Workspace Website and accessing certain pages, specifically password-protected pages.

For more information, visit the help page for your web browser or see http://www.allaboutcookies.org or visit www.youronlinechoices.com which has further information about behavioral advertising and online privacy.

We may use third party analytics such as Google Analytics or similar analytics services. For information on how Google processes and collects your information regarding Google Analytics and how you can opt-out, please see https://tools.google.com/dlpage/gaoptout.

5. DATA RETENTION

To the extent permitted by applicable law, we may retain information for as long as the account of the customer for whom we collected the information is active, for at least six (6) months thereafter, or as long as is reasonably necessary to provide the Workspace Services or as needed for other lawful purposes. We may retain cached or archived copies of information. We may retain anonymized or pseudonymized, aggregated data indefinitely, to the extent permitted under applicable law. We may be required to retain some data for a longer period of time because of various laws and regulations or because of contractual obligations. We also will retain information as long as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Once information is no longer needed for the purposes for which it was collected, we will take reasonable steps to de-identify and destroy it.

6. CHOICES AND OPT-OUT

To the extent required by applicable law, or in our discretion otherwise, we will allow customers and individuals to limit use of Personal Information. If at any time after providing us with your Personal Information such information changes or you change your mind about receiving information from us, you may request access to your data or that your data be changed.

You may elect not to identify yourself or you may use a pseudonym in your dealings with us, except where it is impracticable for us to deal with you on this basis (for example, we will need to identify you in order to provide most of our Services).

We may use your Personal Information for direct marketing. This includes the use of Personal Information to:

  • invite you to a user conference; and
  • notify you about an existing or new product or service.

If you prefer not to receive these communications from us, you may ask us at any time to stop sending you direct marketing information or to stop being contacted by us. You can do this by emailing us at privacy@workspace.cc.

7. THIRD PARTY WEBSITES AND PRODUCTS

The Workspace Services may provide links to other websites or resources over which Workspace does not have control ("External Websites"). Such links do not constitute an endorsement by Workspace of those External Websites. You acknowledge that Workspace is providing these links to you only as a convenience, and further agree that Workspace is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the applicable External Web Site. We encourage you to be aware when leaving our Services and to read the privacy statements of External Web Sites that collect your Personal Information.

The Workspace Services may also facilitate the use of third party products and services ("External Products"). You agree that your use of the External Services is at your sole risk and that Workspace shall not have any responsibility for nor any liability to you for any content or function of the External Services. Your interaction with any External Service is subject to that third party’s own rules, policies, and practices, and not this Privacy Policy.

8. SECURITY

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of Personal Information, we employ procedural and technological measures that are reasonably designed to help safeguard the information we collect. Only authorized Workspace personnel have access to the Personal Information, including server logs and cookie utilization data, that we collect. These individuals are required to follow strict security policies and procedures. Workspace may use encryption, secure socket layer, firewall, password protection and other physical and logical security measures to help prevent unauthorized access to such. Workspace may also place internal restrictions on who in the company may access data to help prevent unauthorized access to such information.

Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Therefore, despite our efforts, we cannot guarantee its absolute security. We do not warrant or represent that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.

If you use the Services, you are responsible for maintaining the confidentiality of your access information and password. You are responsible for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your password. We cannot secure any Personal Information that you release on your own, that you request us to release or that is released through another third party to whom you’ve given access.

Where required under applicable law or by contract, we will notify the appropriate parties or individuals of any loss, misuse or alteration of Personal Information so that such parties or individuals can take the appropriate actions for the due protection of their rights. If such Personal Information is information of a Workspace customer, we will notify such customer and coordinate with them regarding any required notices to particular individuals.

9. CHILDREN

We recognize the importance of protecting the privacy and safety of children. The Workspace Services are not intended for children under 13 years of age - and for European residents, for children under 16 years of age - see our European Privacy Policy. We do not knowingly collect Personal Information from children under 13. Anyone under 13 should not use the Workspace Services. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us as set forth below.

10. INTERNATIONAL DATA TRANSFERS

The Workspace Services may be provided using resources and servers located in various countries around the world, including the United States and other countries. Therefore, Personal Information about individuals or customers may be transferred, processed and stored outside the country where the Workspace Services are used, including to countries outside the European Union ("EU"), European Economic Area ("EEA") or Switzerland, where the level of data protection may not be deemed adequate by the European Commission. With respect to Europe, we may use standard data protection clauses adopted by supervisory authorities and approved by the European Commission to safeguard transfers.

11. CALIFORNIA PRIVACY RIGHTS

Under California’s "Shine the Light" law, California residents who provide Personal Information in obtaining products or services for personal, family or household use may be entitled to request and obtain from us, once per calendar year, information about customer information we have shared, if any, with other businesses for such other businesses’ own direct marketing uses. If applicable, this information would include the categories of resident information and the names and addresses of those businesses with which we shared such resident information for the immediately prior calendar year. To obtain this information, please contact us as indicated below. Please include sufficient personal identification information so that we can process the request, including that you are a California resident.

12. QUESTIONS, COMPLAINTS AND DISPUTES

If you have questions, concerns, or complaints about this Policy or our privacy practices, please contact our Privacy Officer by email at privacy@workspace.cc or by telephone at (844) 445-4199. We will respond to your inquiries as soon as is practicable.

  • CLASS ACTION WAIVER. YOU AND WE AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR OUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.
  • DISPUTE RESOLUTION. Except as otherwise expressly provided above, or in our European privacy policy or otherwise required by applicable law, you agree that the exclusive jurisdiction of any actions arising out of, relating to, or in any way connected with, this privacy policy, shall be in the state or federal courts, as applicable, located in the Farmington Hills, Michigan. Any dispute, controversy, or claim arising out of or relating to this privacy policy or the collection, use, storage or transfer of any of your information or data, including, but not limited to, the arbitrability of the matter or the formation, interpretation, scope, applicability, termination, or breach of this privacy policy, shall be referred to and finally determined by arbitration in accordance with the JAMS Streamlined Arbitration Rules and Procedures, or JAMS International Arbitration Rules, if the matter is deemed "international" within the meaning of that term as defined in the JAMS International Arbitration Rules. The arbitration shall be administered by JAMS, shall take place before a sole arbitrator, and shall be conducted in Baltimore, Maryland. If the JAMS International Arbitration Rules apply, the language to be used in the arbitral proceedings will be English. Judgment upon the arbitral award may be entered by any court having jurisdiction. This section shall apply to and require arbitration of all disputes, controversies, and claims, regardless of whether such disputes, controversies, or claims concern a single individual, entity, or other person, multiple individuals, entities, or other people, or classes of individuals, entities, or other people. You hereby consent to receive service of process by electronic means or social media to the extent allowed by the applicable court. This constitutes express agreement of the parties regarding your consent pursuant to United States Federal Rule of Civil Procedure 5(b)(2)(E) and any applicable state (or other jurisdiction) equivalent.

PRIVACY POLICY UPDATES

Workspace may update this Privacy Policy from time to time in our sole discretion to reflect changes to our information and privacy practices. Workspace will post any updated Privacy Policy on this page at http://workspace.cc/company/legal/privacy or in the Workspace Services, or with any notice to individual users if required by applicable law. Continued use of the Workspace Services after any such modifications constitutes acceptance to any such modified Privacy Policy. Workspace encourages you to review this Privacy Policy regularly for any changes. The date of last revision is shown at the “Last Updated” legend at the top of this page.

If you have any questions regarding our Privacy Policy, the practices of this site, or your dealings with us, please feel free to email us at privacy@workspace.cc.

EUROPEAN PRIVACY POLICY

The following European Privacy Policy applies if your Personal Data is processed in the European Union, the European Economic Area and Switzerland.

Personal Data and Processing. For the purposes of this European Privacy Policy:

"Personal Data" means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person; and

"Processing" means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal Data may be transferred outside of Europe, provided that certain conditions as set out in the applicable legislation are complied with. Your Personal Data will also be processed by personnel operating outside Europe who work for us. This includes personnel engaged in, among other things, the fulfilment of your order and the provision of support services. We are party to data transfer agreements with each of our service providers and the members of our group and we will (i) keep each document up to date with current law, and (ii) only engage in Personal Data transfers from Europe to outside Europe in accordance with such an agreement or an alternative means of transfer in compliance with data protection legislation. We may also process Personal Data submitted relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses or Binding Corporate Rules.

Purposes and Legal Basis for Processing Personal Data. Workspace processes data for the purposes as set forth in our Privacy Policy, including to provide the Workspace Services and as explained in the Use of Information and Sharing of Information sections. To fulfill these purposes, Workspace may access data, including Personal Data, to provide the Workspace Services, to correct and address technical, service or security problems, or in response to contractual requirements. Please see our Workspace Privacy Policy Information We Collect and Data Retention sections for additional details on how we collect, use, disclose and share data, make automated decisions, and retain data, including Personal Data, about individual users or customers.

Our legal basis for the processing of Personal Data are: (i) consent or (ii) any other applicable legal basis, such as our legitimate interest in engaging in commerce, offering products and services of value to the customers of the Workspace Services, preventing fraud, ensuring information and network security, direct marketing and advertising, and complying with industry practices.

Data Transfers

Where Personal Data is transferred from the EU or Switzerland to the US in the context of an employment relationship, we will cooperate in investigations by and comply with the advice of EU data protection agencies and the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Workspace will not transfer Personal Data originating in the EU or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your Personal Information as required by the Principles of the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework. We will only transfer data to our agents, resellers or third-party service providers (such as service providers, accountants, attorneys, consultants, and other service providers) who need the information in order to provide services to or perform activities on behalf of Workspace, including in connection with the delivery of services or products, Workspace’s management, administration, or legal responsibilities.

Additional Rights: Under European law, you may have one or more of the following additional rights:

Access. To request a copy of the Personal Data we have collected about you by contacting us.

Rectification & Erasure. To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.

Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.

Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration.

Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.

Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including processing related to existing contracts for our Services.

Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority ("DPA").

To exercise any of the above listed rights, please contact us as set forth below and provide sufficient details so that we can respond appropriately. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify the identity of the individual submitting a request before we can address such request. If the request relates to data our customers collect and process through the Workspace Services, we will refer the request to that customer and will support them in responding to the request. For Workspace customers, certain information may be reviewed, corrected and updated by logging into the Workspace Services account and editing the profile information.

Questions and Complaints. If you have questions, concerns, or complaints about this Policy or our privacy practices, please contact our Privacy Officer by email at privacy@workspace.cc.

Compelled Disclosures. Workspace may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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