Officeable Privacy Policy

Privacy Policy

Last updated: May 18th, 2020

Introduction

Officeable (“Officeable,” “We”) respects your privacy and is committed to protecting it through our adherence to this Privacy Policy. Terms used in this Privacy Policy shall have the same meaning as in our Services Agreement.

This Policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • Through any mobile and desktop applications you download from this Website or a third-party application store, which provide dedicated non-browser-based interaction between you and this Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
  • information collected through automatic collection methods like cookies, beacons, geolocation and other mechanisms.
  • This Policy does not apply to information collected by:

  • Us offline; or
  • Any third party, including through any application or content including advertising that may link to or be accessible from, or on, the Website.
  • Your Consent

    Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

    Except as set forth in this Privacy Policy, your Personal Information will not be used by us for any other purpose without your consent. We do not sell customer lists. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Services.

    Residents of California and Nevada are asked to review the State-specific notices provided below before proceeding.

    Applicable legislation

    This Privacy Policy addresses and complies with applicable privacy and data security laws, including the Federal Trade Commission Act (15 U.S.C. § 45), regulating unfair or deceptive business practices and providing guidance on consumer privacy disclosures; The Children's Online Privacy Protection Act (COPPA), regulating the online privacy of children under 13 and the EU General Data Protection Regulation (GDPR).

    California

    This Policy does not address the specific disclosure requirements under the California Consumer Privacy Act of 2018 (CCPA), as Officeable does not qualify as a “Service Provider” under The Civil Code of California § 1798.140(c)(1).

    If you are a resident of California, by using this Website you agree to waive any private right of action under the CCPA, present or future, that may be brought against Officeable, its directors, employees, agents, independent contractors and/or its subsidiary or affiliate undertakings. If you do not agree to these terms, please do not use this Website.

    Nevada

    Nevada’s Online Privacy Law (“OPL”) codified at Nevada Revised Statutes (NRS) 603A.300 to 603A.360, and amended by Bill 220 of May 29 2020, establishes a new consumer right for consumers residing in the State to prevent operators from selling their personal information, on request (sales opts-out rights). Officeable respects its obligation to accept and process verified opt-out requests from Nevadan consumers regardless of whether its sells personal information or not. Nevadan consumers wishing to submit an opt-our request must contact [email protected]

    Limitations in Scope

    This Privacy Policy does not apply to:

  • Personal Information that is exchanged between Hosts, Guests and/or Vendors outside of the Officeable Platform;
  • Information collected by us through a separate website, application or service such as Google Analytics (such information is governed by the applicable privacy policy for that site and service);
  • Information collected by us which is non-personally identifiable information, such as demographic statistics of our users (e.g. geolocation of our users), number of visitors, what pages users access or visit, and average time spent on the Website, business contact information or any personal information which has been anonymized; or
  • Information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site or App.
  • Children Under the Age of 13

    Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected]

    Information we collect about you and how we collect it

    We collect several types of information from and about users of our Services, including:

    Information you provide to us

    The information we collect on or through the Services may include:

  • Information that you provide by filling in forms on our Website or App. This includes information provided at the time of registering to use our Website or App, posting material or requesting further services. We may also ask you for information when you enter you report a problem with our Site or App.
  • Records and copies of your correspondence (including email addresses), if you contact us or if you contact others through the Services (such as through our check-in or messaging functions).
  • Details of transactions you carry out through our Site or App (including without limitation bookings, communications, orders and payments) and of the fulfillment of your orders. You may be required to provide financial information such as credit card details before placing an order through our Site or App, for example, through our third party payment provider such Stripe.
  • Your search queries on the Site or App.
  • Information you provide to us about other individuals
  • You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or App, or transmitted to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. Please note that all communications between users are tracked and recorded through our chat system whether you are a Host, Guest, Vendor or User of the Website. This information is captured and stored by us to assist in dispute resolution and to assess compliance with the terms of service for the Services.

    Information we collect through automatic data collection technologies

    As you navigate through and interact with our Website or App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, geolocation and workplace usage patterns, including:

  • Details of your visits to our Website or App and other communication data and the resources that you access and use on the Website or App.
  • Information about your computer and Internet connection, including your IP address, operating system and browser type.
  • We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
  • When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, geolocation data, and other communication data and the resources that you access and use on or through the App.
  • We may collect information about your mobile device and Internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information and the device's telephone number.
  • Any App we may provide will collect real-time information about the geolocation of your device.
  • We and/or our third party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Service by informing us what content is effective.
  • Cookies

    When you visit our website or otherwise interact with the Service we (or third party data or ad networks we work with) may send one or more “cookies” to your computer or other devices. Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites. Some features on this site will not function if you do not allow cookies. We may link the information we store in cookies to any Personal Information you submit while on our site.

    We may use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If you reject cookies, you may still use our site, but some features on the site will not function properly.

    Functional cookies, persistent and session type, store information to enable core site functionality.

    Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.

    Advertising cookies may be set through our website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.

    Web Beacons

    We (or third party data or ad networks we work with) may use Web Beacons alone or in conjunction with cookies to compile information about our Service, or other information we or they have collected. Web Beacons are tiny graphic objects that are embedded in a web page or email and are usually invisible to the user but allow checking that a user has viewed the page or email. Web Beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by Web Beacons to our Users’ Personal Information. For example, we may use Web Beacons to let us know which of our marketing emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

    Flash and HTML5 Storage

    We may use Local Shared Objects, such as Flash cookies, AND/OR Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

    Do Not Track Signals

    At this time we do not respond to browser ‘do not track’ signals.

    Analytics Software

    We and our third party tracking-utility partners may use log files on our Service to gather certain information automatically and store it for analytical purposes. This information includes internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use Google Analytics, which uses cookies and other, similar technologies to collect and analyze information about use of the Service and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

    Social Media Features and Widgets

    The Service includes social media features such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Website. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

    How we use your information

    We will only use your personal information when the applicable law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into, such as for Officeable Concierge Services, or to assist you perform the contract you have agreed with an Officeable-listed Host, Guest and/or Vendor (such as by passing on details of your booking application to the relevant party);
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications, and only where it is not possible to rely on Recital 47 of EU GDPR or equivalent US legislation, to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at [email protected]

    Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us [email protected] if you need details about the specific legal ground we are relying on to process your personal information.

    We may also use the information you provide to provide you with information about our own and third-parties’ goods and services that may be of interest to you.

    We may also use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria and may combine your information with other profile data it has obtained from other sources.

    Disclosure of your information

    We may disclose aggregated information about our users without restriction. Moreover, we may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • If you are a Host, to any governmental or administrative authority whose ordinances requires us to provide details of listings applicable to be considered as Short-Term Rentals (“STRs”);
  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Officeable’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Officeable about our Website or App users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your express consent to other uses not indicated in this Privacy Policy.
  • We may also disclose your personal information:
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of service https://www.officeable.biz/terms and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Officeable, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • Transfers of data

    We use cloud-hosting service providers to provide hosting to us which means that your personal information may be available to foreign government or its agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your personal information. As privacy laws vary from jurisdiction to jurisdiction, the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident. However, we will ensure that a similar degree of protection is afforded to your personal information as is provided for under European Union law if you are located in the EU, in accordance the judgment of the European Court of Justice in Schrems II (16 July 2020).

    Your Records

    You can review and change your personal information by logging into the Website or App and visiting your account profile page.

    You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

    If you delete your User Contributions from the Site and/or App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site or App users. Proper access and use of information provided on the Site or App, including User Contributions, is governed by our terms of use [email protected]

    Retention

    We will keep your personal information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained personal information will remain subject to the terms of this privacy policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your personal information due to technological and legal constraints (see further above under Access and Correcting Your Information).

    Safety and security

    We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers.

    The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website or App like message boards. The information you share in public areas may be viewed by any user of the Services.

    Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or App.

    Contact Information

    To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: [email protected]

    Your legal rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal information. You may have the right to:

    Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

    Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

    Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

    If you wish to exercise any of the rights set out above, please contact us at [email protected]

    You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

    We may also contact you to ask you for further information in relation to your request to speed up our response.

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.