FlexDesk, Inc. (“FlexDesk,” “we,” “our,” and/or “us”) and our affiliates value the privacy of individuals who use our website, applications, and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose Personal Information (as defined below) from users of our Services (“Users”) designed to optimize and facilitate your access to co-working spaces.  It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any queries or concerns. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

In addition to the activities described in this Privacy Policy, we may process Personal Information on behalf of our commercial customers when they use the Services. We may process such Personal Information as a data processor of our commercial customers, which are the entities responsible for the data processing. To understand how a commercial customer processes your Personal Information, please refer to that customer's privacy policy.

Information We Collect

In this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable natural person. We may collect a variety of Personal Information from or about you or your devices from various sources, as described below.

If you do not provide your Personal Information when requested, you may not be able to use our Services if that Personal Information is necessary to provide you with our Services or if we are legally required to collect it.

A. Personal Information You Provide to Us.

Communications. If you contact us directly through our website or through email, we may receive Personal Information about you, such as your name, email address, company, job title, phone number, and user name.  We may also receive the contents of a message or attachments that you may send to us, and any other additional Personal Information you choose to provide.  When you communicate with us online, third party vendors receive and store these communications on our behalf.  If you sign up for our updates, then we will collect certain Personal Information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

B. Personal Information We Collect When You Use Our Services.

Device Information. We receive Personal Information about the device and software you use to access our Services, including IP address which we may use to infer your general location information, web browser type, operating system version, and device identifiers.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive Personal Information about your interactions with our Services, like the pages or other content you view and the dates and times of your visits.

Information from Cookies and Similar Technologies. We and our third-party partners collect Personal Information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect Personal Information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

How We Use the Personal Information We Collect

We will only process your Personal Information based on a valid legal ground, which may vary depending on the country where you are located. The table below describes the legal ground by purpose.

We use the information we collect:

• To provide, maintain, improve, and enhance our Services;
• To understand and analyze how you use our Services and develop new products, services, features, and functionality;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
• To generate anonymized or, aggregate data containing only de-identified, non-personal information that we may use for any lawful purposes such as to publish reports;
• To find and prevent fraud and abuse, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our TOS or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and for other purposes for which we provide specific notice at the time the information is collected.

How We Disclose the Personal Information We Collect

We do not disclose Personal Information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.

Affiliates. We may disclose any Personal Information we receive to our current or future affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may disclose any Personal Information we receive to vendors and service providers retained in connection with the provision of our Services, including for billing, payment processing, invoicing and VAT calculation, analyzing data, providing IT-hosting and maintenance.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect Personal Information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.

Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your Personal Information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your Personal Information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable Personal Information was collected.

Consent. We may also disclose your Personal Information with your permission.

Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we need to retain certain information as required by law, including to comply with tax requirements, or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations.

Data Retention

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Your Rights

Depending on where you reside, you may have the following legal rights:

• Access and Portability. You may ask us to provide you with a copy of the Personal Information we maintain about you, including a machine-readable copy of the Personal Information that you have provided to us, and request information about its processing.
• Rectification and Deletion. You may ask us to update and correct inaccuracies in your Personal Information, or to have the information anonymized or deleted, as appropriate.
• Restriction and Objection. You may ask us to restrict the processing of your Personal Information, or object to such processing.
• Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
• Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.

You may exercise these rights by contacting us using the contact details at the end of this Policy. Please note that there are exceptions and limitations to each of these rights.