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 The We Company. You can read more about how Personal Information is used by clicking below on the name of The We Company Services, websites, or applications you use.
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.
2. INFORMATION WE COLLECT
The Personal Information that we collect and our use of that information depend on your relationship with us and the requirements of applicable law as described below.
We collect information:
- that you provide to us directly.
- that your company, broker, host, parent, or guardian provides to us;
- about your devices and their location, and your use of our Services, including through cookies, pixels, web beacons, logs, and other Internet technologies.
- If you opt into certain features or depending on your device settings, we obtain geo-location data and information about your contacts; and
- that we obtain from other sources.
INFORMATION COLLECTED FROM YOU
The We Company 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:
- Contact Information and other Identifiers, including your name, mailing address, phone number, email address, and other information that enables us to contact you;
- Verification Information, including a photo ID or government-issued identification, and date of birth;
- Professional and Employment-Related Information, including your company name, title, role, team, and other information about your profession;
- Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase;
- 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;
- 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;
- Communications, and any other information that you intentionally share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through automated chatbots, Amazon Echo, other voice assistants, 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;
- 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, WiFi MAC address, and Bluetooth address.
- Geolocation information, such as through your mobile device’s GPS signal or WiFi signal, and information about your contacts, depending on your device settings;
- Information about your online activity, including information collected through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies.
- Space utilization information and information 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.
- 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 an 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 the content and information that you add to your member network or other community profile. References to “Other Personal Information” in this Policy and the product-specific links below refer to all Personal Information referenced in this Policy.
INFORMATION COLLECTED ABOUT YOU
- Social Media. The We Company 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.
- 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 Personal Information about you from publicly and commercially available sources and other third parties as permitted by law. 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.
- 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 coming to 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. We also may use other third-party analytics tools to collect similar information about the use of certain online Services.
- 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 the use of each mobile version of the website may be associated with user accounts. In addition, The We Company enables you to download an application, widget, or other tools 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 The We Company to enable you to access your user accounts and to enable The We Company to track the 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:
- provide you with our products and Services, including online and offline events, and other materials you request;
- protect against fraud, abuse, or harm and otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);
- respond to or fulfill customer service requests;
- analyze, better tailor, and improve our products and Services;
- 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; and
- comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.
LEGAL BASES FOR PROCESSING EU PERSONAL INFORMATION
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 a Secure Environment and analyzing, improving, and better tailoring our products and Services.
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 The We Company, our community, our service providers and advertisers, and other end-users, in order to provide our Services and to improve ways of working in our community. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent.
- Among The We Company. We may share your Personal Information among The We Company depending on where you are located and the Services that you use. The We Company uses your information in accordance with this Policy.
- 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:
- 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.
- 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. The Made by We Member Network profile information is accessible to all members. You can also share your profile with a broader audience (e.g., via social media).
- When we receive information about you in connection with your relationship with our members or clients—for example, if you are a member’s employment 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.
- 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.
- Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. We take steps to ensure that these service providers act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.
- 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.
- 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 the most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively.
- 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:
- to provide you with the Services that you or your company request;
- to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;
- to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement;
- to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services; or
- to protect our rights, property, and safety or that of any of The We Company family of companies, business partners, members, or employees; and
- where otherwise required by 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.
- 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.
- 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:
- 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.
- 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.
- Other content providers offer products and services on our Services and operate contests, sweepstakes, or surveys on our Services.
We, as well as certain of these third-party partners, may use tracking tools (e.g., cookies, web beacons, and Internet technologies) to collect information regarding your activities (e.g., your IP address or page(s) visited). We also share such information that we have collected with third-party advertising partners. These advertising partners use this information (and similar information collected from other websites) to deliver future targeted advertisements to you when you visit non-Ledlucky related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”
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 video with the public through unaffiliated external social media sites. We encourage you to read their policies. Remember that 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 hates speech that targets or disparages any ethnic, racial, age, or religious group (or another 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 (i) request confirmation of whether we store, use, or share any of your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information or, as described above, object to those uses; (v) seek correction of inaccurate, untrue, or incomplete Personal Information; or (vi) request erasure of Personal Information held about you by The We Company, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us at [email protected] or one of the physical addresses set out in Section 12.5 below.
We will process such requests in accordance with local laws. To protect your privacy, The We Company will take steps to verify your identity before granting access or making any changes to your Personal Information. The California Privacy Rights section below provides additional information for California residents.
You have the right to opt-out of certain uses and disclosures of your Personal Information as set out in this Policy, and in specific circumstances, for example, related to direct marketing.
Where you have consented to The We Company’s use of “sensitive” Personal Information (e.g., Personal Information relating to your health, religious or philosophical beliefs, or biometric information which is used to uniquely identify you) (“Sensitive Personal Information”), you may withdraw that consent, in accordance with applicable law.
Prior to disclosing Sensitive Personal Information to a third party or processing Sensitive Data for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, Ledlucky will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, The We Company will comply with the law or contract.
6.2 EMAIL AND TELEPHONE COMMUNICATIONS
- Text Messages. We may send you SMS text messages related to our Services or transactions. You can opt-out of these messages at any time by replying STOP.
6.3 COMPLIANCE WITH THE DIGITAL ADVERTISING ALLIANCE
Should The We Company engage in interest-based advertising, it will endeavor to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http://aboutads.info), as applicable. As part of this service, The We Company’s online advertisements may sometimes be delivered with icons that help individuals understand how their data are being used and provide options to restrict that use. To opt-out of internet-based advertising by all DAA-participating companies, please visit http://www.aboutads.info/choices/.
7. SUPERVISORY AUTHORITY
For visitors to our Services in the EU, you may lodge a complaint with a supervisory authority if you believe our processing of your Personal Information infringes applicable law.
8. INTERNATIONAL TRANSFERS
The We Company is headquartered in the United States. Your information will likely be collected in your country and subsequently transferred to or stored in another country, including countries that may have privacy protections less stringent than your jurisdiction. In accordance with applicable law, we implement measures, such as standard data protection clauses, to ensure that any transferred Personal Information remains protected and secure. You can obtain further information about these measures by contacting us using the contact details set out below in Section 12.5.
The We Company will retain your Personal Information for as long as you have a relationship with us, and for a period after your relationship with us has ended.
When determining how long this retention period will last, we take into account the length of time Personal Information is required to:
- Continue to develop, tailor, upgrade, and improve our Services;
- Maintain business records for analysis and/or audit purposes;
- Comply with record retention requirements under the law;
- Defend or bring any existing or potential legal claims; or
- Address any complaints regarding the Services.
10. INFORMATION SECURITY
The security of all Personal Information provided to The We Company is important to us. The We Company takes reasonable steps endeavoring to use appropriate technical or organizational measures to protect your Personal Information, including against unauthorized or unlawful processing and accidental loss, destruction, or damage. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while The We Company strives to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to The We Company, and you do so at your own risk. As such, we ask that you help us be safer together by implementing your own security controls, such as a strong password, not sharing your credentials or badge with others, logging out when you leave your desk, and other security best practices.
11. AUTOMATED PROCESSING
In the future, we may use automated processes to help us determine your eligibility for new services, alternate space, or other business-related opportunities. In such cases, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, or request that we restrict the use of your Personal Information for the purposes of these automated decisions.
12. OTHER RIGHTS AND IMPORTANT INFORMATION
The We Company’s buildings and facilities have CCTV installed to meet our legitimate business interests in protecting the safety of The We Company’s employees, members, and guests and their property. These recordings may be accessed by The We Company. Ledlucky may also make CCTV footage available to members and other third parties authorized by The We Company. These recordings may be shared with competent authorities in accordance with applicable laws if required. The recordings are generally retained for a limited period of time but maybe kept longer where The We Company or an applicable member determines that it is appropriate, for example in connection with the investigation of an incident, or when competent authorities request us to retain them.
12.2 COLLECTION OF INFORMATION FROM CHILDREN
Generally, our online Services are not directed to children, and we do not knowingly collect Personal Information from children except as permitted under applicable law. If we become aware that a child under has provided us with Personal Information, we will delete such information from our files or obtain parental consent in accordance with applicable law.
12.3 THIRD PARTIES
We cannot control or be held responsible for third parties’ privacy practices and content. Please read their privacy policies to find out how they collect and process your Personal Information prior to submitting any Personal Information. The collection, use, and disclosure of your Personal Information will be subject to the privacy policies of the third party and not this Policy. We are not responsible for the data collection, privacy, and information sharing policies and procedures or content of such third-party websites.
12.4 CHANGES TO THIS POLICY IN THE FUTURE
Any information that is collected via the Services is covered by the Policy in effect at the time such information is collected. We reserve the right to change, modify, add, or remove portions of this Policy at any time and at our sole discretion.
If we make any material changes to this Policy, we will notify you of those changes by posting them on the Services or by sending you an email or other notification, as required by applicable law, and we will update the “Effective Date” below to indicate when those changes will become effective.
We encourage you to review this Policy periodically to remain informed of how we use and protect your information and to be aware of any policy changes. Your continued relationship with us after the posting of notice of any amended Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by The We Company.
12.5 QUESTIONS OR COMMENTS
If you have any questions or comments regarding our Policy, please contact us at [email protected]
Privacy Ledlucky Holdings Company Limited Bldg A, Haoyunda Industrial Park No 3, Lanjin 7 Road, Pingshan Shenzhen, China, 518118.
The We Company will address your concerns and attempt to resolve any privacy issues in a timely manner.
Sensitive Information. Because email communications are not always secure, please do not include credit card or other Sensitive Personal Information (e.g., racial or ethnic origin, religion, health, or the like) in your emails to us.
Effective Date: August 1, 2020
13. JURISDICTION-SPECIFIC INFORMATION
CCTV in the European Union/European Economic Area
The We Company’s CCTV practices are based on an assessment of the data protection interests of affected data subjects against our legitimate interests in maintaining a Secure Environment and otherwise protecting ourselves and other members of our community. This may entail consideration, for example, of the likelihood and impact of unlawful or impermissible conduct on our communities and expectations of privacy in particular facilities or spaces that may be subject to CCTV.
California Privacy Rights
California residents are entitled to request and obtain certain information about the disclosure of certain categories of their Personal Information to third parties for their direct marketing purposes. We do not share Personal Information with third parties for their direct marketing purposes.
Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals.
California residents who are registered members or users of the Services and are under the age of 18 may be entitled under California law to request and obtain removal of content and information that they themselves post on the Services. You may request such removal by emailing us at [email protected] In your request, please provide a description of the material that you want removing and information sufficient to permit us to locate the material, including your name, email address, year of birth, mailing address (including city, state, and zip code), and the subject line “California Removal Request.” Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.
California Consumer Privacy Act (CCPA)
Category of Personal InformationExplanationIdentifiers, such as your name, mailing address, phone number, email address, or IP address we may use this information to respond to your questions, to enable you to participate in our programs (including promotions or sweepstakes), to provide you with online and offline events, to provide our Services, and for other business purposes. Professional and employment-related information, such as your company name, title, role, or teamWe may use this information to provide you with the products and services you request, and for other business purposes. Commercial information, such as a record of your purchases may use your information to provide you with the Services you have purchased, to identity other products and offers that may be relevant to you, and for other business purposes internet and electronic network activity information, such as information about your interactions with our ServicesWe may use this information to improve our Services, to better understand the visitors who come to our Services and what content is of interest to them, and for other business purposes. Precise geographic location information, using technologies such as GPS or WiFiWe may use this information to improve the quality, security, and relevance of our Services to our visitors, and for other business purposes. Other electronic or visual information, including information that you share using the Services (such as videos or photos) or footage captured by CCTVWe, may use this information for our business purposes. For example, we use videos or photos that you share to provide the services you ask for on our Services, as part of sweepstakes or other competitions; and we use footage captured by CCTV to provide a Secure Environment.
Information about how you may exercise your rights as a California resident can be found by calling +1 (906) 629-1755, or by contacting Ledlucky at the email or address listed above in Section 12.5, “Questions or Comments.” We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Services may change or no longer be available to you.
Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
If you have any questions or complaints, you may submit it to our Grievance Officer at [email protected]
By submitting your personal data to us, you consent to us collecting, using, disclosing, and processing your personal data in accordance with this Policy. If you have any questions please contact our Data Protection Officer at [email protected]
We process Personal Information only within the scope specified as the period for which such Personal Information is held and used in South Korea. Once the purpose of holding Personal Information has been satisfied, or the period for holding such Personal Information has expired, such Personal Information will be destroyed.
Membership Information. One year from termination of membership, provided, however, this period may be extended if we notify you of the purpose of the extension, the length of the extension period, and the nature of Personal Information to be retained during such period and if you agree to such extension.
Record of cancellation of contracts or subscriptions. Five years from the termination of membership.
Record of payments and supply of goods. Five years from the termination of membership.
Record of customer complaints or dispute settlements. Three years from the termination of membership.
When Personal Information is no longer required due to the expiration of the Personal Information holding period, or the purpose for which the Personal Information has been obtained has been achieved, we will destroy the Personal Information in accordance with our retention policy. If applicable laws require us to continue to store this Personal Information, we will transfer such information to a separate database or place in a separate storage compartment.