EFFECTIVE SEPTEMBER 1, 2016
Safeguarding your privacy is important to us. WeWork is committed to maintaining your trust by protecting personal information that we collect and use.
PERSONAL INFORMATION WE COLLECT
We collect various types of personal information in connection with the Services, namely:
- information you provide us directly;
- information we collect about your device(s) and your use of our Services, including through cookies, web beacons, and other internet technologies; and
- information we obtain from third-party sources.
PERSONAL INFORMATION YOU PROVIDE US DIRECTLY
We collect various types of information and content that you provide us directly. In order to enroll as a member or to access some of our Services, you will be requested to provide us with your name, telephone number, email address, postal address, and where applicable company or organization name. We also collect other content and information that you provide us directly, including the content and information you may add to your member network or other community profile and photographs or other information or documentation you submit or provide us and the communications that you transmit through our networks. We collect billing and payment information you provide when you access some of our Services or purchase products and services. We also collect information that you provide us when you participate in our surveys, sweepstakes or events. If you do not provide us with the requested information, we may be unable to deliver you the Services in full.
To the extent that you disclose to us any personal information of another individual, we assume that you have obtained such individual’s consent for the disclosure of such personal information as well as the processing of the same in accordance with the terms of this Policy.
INFORMATION ABOUT YOUR DEVICE(S) AND YOUR USE OF THE SERVICES
We collect information about how you use our Services and, depending on the access permissions you have chosen for your device, other information, as specified below, from and about the computers, phones, and other devices where you install or access our Services. We use standard internet technologies, such as cookies and web beacons, to collect information about your computer or device and your online activity, as explained in more detail in the section on cookies.
The information we collect in this respect is:
- your browser type and operating system;
- IP address and device identifiers;
- your browsing behavior on our Services, such as the amount of time spent viewing our online Services and the links you click within our online Services;
- websites you visit before or after our websites;
- whether you have opened or forwarded our e-mails or connected to offers or links that we send you; and
- your general or specific geographic location, such as through GPS, Bluetooth or WiFi signals to the extent permitted by the settings of your devices.
If you use our internet connection, networks, telecommunications systems or information processing systems, your activity and any files or messages on those systems may also be monitored by WeWork at any time, in accordance with applicable law, for purposes of an investigation or to ensure compliance with company policies.
INFORMATION FROM THIRD-PARTY SOURCES
We obtain information about you from your company or organization, including when they may create or supplement your profile for you in the member network. You can review and amend this profile at any time. For further details, see below.
We also receive information about you from publicly and commercially available sources and other third parties as permitted by law. We may combine this information with other information we receive from or about you, where necessary to provide the Services you requested.
USE OF PERSONAL INFORMATION
We use the personal information that we collect as necessary and appropriate for the following purposes:
- To provide our products and services. We use your personal information to provide you with the products, services, and features that you or your company or organization have requested; to respond to inquiries we receive from you or your company or organization; to verify your identity; in connection with a transaction that you or your company or organization has initiated; to deliver notifications and other operational communications; and for troubleshooting.
- To improve our products and services and to analyze how users navigate and use our products and services and individual features.
- To manage the performance of our products and services.
- For audit and reporting purposes, to perform accounting and administrative tasks, and to enforce or manage legal claims.
- To deliver advertising and promotional communications, subject to any legally required consent, which we will seek at the appropriate time. For example, we may periodically contact you with offers and information about our products, services, features, and events; to send you newsletters or other information about topics that we believe may be of interest; to conduct online surveys; and to otherwise promote our products, services, features, and events. We also may deliver targeted advertisements to you, both on and off the Services.
- For security and to protect, enforce, or defend legal rights, privacy, safety or property, whether our own or that of our employees or agents or others, and to enforce compliance with WeWork policies and to comply with applicable law and government requests.
SHARING OF PERSONAL INFORMATION
We disclose your personal information in the following circumstances to the following parties:
- Among WeWork companies. Our services are provided by affiliates of WeWork Companies Inc. depending on where you are located and the services you use. WeWork shares personal information with those affiliates for the purposes mentioned above. These affiliates use your information in accordance with this policy.
- Our Community. Our Services include online and offline member communities, forums and networks that allow you to share and connect with others. We make this possible for WeWork members by creating a profile for new members that contains your name and the name of your company or other organization. This profile is created automatically and is accessible to other members of the forum or network, some of which include all WeWork members. You can supplement your profile by adding additional information about yourself and your company or organization and by posting content and comments and you may be able to share your profile with a broader audience.
- Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. For example, we may rely on service providers to host data and platforms, fulfill our product and service requests and answer your questions, send e-mails on our behalf, process payment card or other transactions, and analyze data to improve our products and services. To do so, we may need to share your personal information with them for the purposes described under “Use of Personal Information”.
- Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. In some instances we and our service providers disclose your personal information to law firms, auditors, consultants, the police, courts, tribunals and other law enforcement agencies:
- to provide you with the services you or your company or organization request, such as a disclosure of your information to a landlord in connection with a lease agreement, or to auditors or consultants;
- to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement (which may include lawful access requests by U.S. and other courts, law enforcement and governmental authorities);
- to detect, suppress, and prevent fraud or verify and enforce compliance with the policies governing our Services; or
- there permitted by law, to protect our rights, property, and safety or that of any of our respective affiliates, business partners, customers or employees and where otherwise required by law.
- Other Parties in Connection with a Corporate Transaction. We will disclose your personal information to an acquiror in the event we sell or transfer all or a portion of a business or assets to that third party, such as in connection with a merger or in the event of a bankruptcy reorganization or liquidation.
- Third-Party Partners, With Your Consent. We may request your consent to share personal information about you with third parties so that they may provide you with special offers, promotional materials, and other materials that may be of interest to you.
- Other Parties at Your Company’s or Organization’s Direction. In addition to the disclosures described in this Policy, we may share information about you with third parties when your company or organization requests such sharing. For example, we periodically may partner with third parties to make products or services available to individual members or participating companies and organizations. If you or your company or organization requests to participate, we may share your information with the relevant third party in connection with the requested product or service.
- Aggregated and Non-Personal Information. We also share with third parties information in a manner that does not identify particular individuals, for example, information that has been aggregated with other records.
Our Services contain links to other sites that we do not own or operate. We provide links to these third-party sites as a convenience to our members. They are not intended as an endorsement of or referral to the linked services. The linked services are subject to their separate and independent privacy statements, notices, and terms, which we recommend you read carefully. The collection, use, and disclosure of your personal information will be subject to the privacy policies of the third party and not this Policy.
THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES
We also partner with the following categories of third parties to collect, analyze, and use some of the personal information described in this Policy:
- 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 may 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 may offer products and services on our Services and may operate contents, sweepstakes, or surveys on our Services.
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 Initiativeand 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 may be available at Your Online Choices.
We have in place various procedures to safeguard your information. Although we take such steps to protect your information, no security program is foolproof and thus we cannot guarantee the absolute security of your personal or other information.
ACCESSING, REVIEWING, AND UPDATING YOUR PERSONAL INFORMATION
To the extent provided for under applicable law, you may have the right to access your personal information and to update or correct inaccuracies in your personal information.
You may have rights to revoke consent you previously granted us with respect to processing personal information and to object to the use of your personal information for direct marketing or for other purposes that are not necessary in light of the nature of our legal relationship. Note that if you revoke your consent to such processing, we may be unable to provide you with certain aspects of the services.
If you would like to exercise any of these rights, please send an e-mail to firstname.lastname@example.org or a letter to Privacy Director, c/o WeWork Companies (International) BV, Weteringschans 165, 1017XD Amsterdam, Netherlands.
Your personal information is transferred to, maintained, and processed by us or our affiliated and third-party service providers in the United States for the purposes described above. As described above we may share your personal data with other parties who may be located in the United States or in other countries. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence.
If you opt-in to receive marketing emails from third-parties, WeWork will provide your personal information to third parties, so that those third parties may directly contact you about non-WeWork products and services. If you later choose to opt-out of receiving marketing emails from third parties, please contact the third party directly and/or follow the instructions at the bottom of their marketing emails.
COLLECTION OF INFORMATION FROM CHILDREN
The Services are not directed to children under the age of 16 and we do not knowingly collect personal information from anyone under the age of 16. Where different age limitations apply, we comply with them.
WeWork’s buildings have CCTV installed to protect the safety of WeWork’s employees, members, and guests and their property, as well as to improve our products and services and to analyze how users navigate and use our spaces. Recordings may be accessed by WeWork in the United States and elsewhere and may be shared with competent authorities in accordance with applicable laws. The recordings are retained for a limited period of time, but may be kept longer for the investigation of an incident or when competent authorities request us to retain them longer.
Privacy laws and guidelines are part of a constantly changing environment. We will notify you of material changes by e-mail or by posting a message on the relevant Services.
QUESTIONS OR COMMENTS
If you have any questions or comments regarding our Policy, please contact us at: Privacy Director, WeWork Companies (International) BV, Weteringschans 165, 1017XD Amsterdam, Netherlands. Email: privacy[at]wework[dot]com
Our main establishment in the EU: WeWork Companies (International) BV, Weteringschans 165, 1017XD Amsterdam, Netherlands.
Effective Date: September 1, 2016
WeWork does not knowingly collect personal information from anyone under the age of 18.
We process personal information only within the scope specified as the period for which such personal information is held and used. 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 subscription. Five years from termination of membership
Record of payments and supply of goods. Five years from termination of membership
Record of customer complaints or dispute settlements. Three years from 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 promptly destroy the personal information. 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.
Establishment of destruction plan → selection and confirmation of personal information (personal information files) to be destroyed → approval from the personal information protection manager → destruction
We destroy electronic files containing personal information by permanently deleting files in a manner in which they cannot be restored. We destroy files in other media, including paper documents, by shredding.
The data protection officer is Abraham Safdie who can be reached at c/o WeWork Companies (International) BV, Weteringschans 165, 1017 XD, Amsterdam, Netherlands and at email@example.com.
COOKIES, WEB BEACONS, AND OTHER INTERNET TECHNOLOGIES
A cookie is a small file that may be stored on your computer or other device. A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions.
Our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses so-called “cookies”, text files which are stored on the computer of the user and which help the website analyze how visitors use the site. The information generated by the cookies about the use of our websites will generally be transmitted to, and stored on, a Google server in the United States. On our websites, the IP-anonymization feature has been activated so that the IP address of Google users within the European Economic Area is truncated beforehand. Only in exceptional cases will the full IP address be transferred to Google in the United States and truncated there. Google will use this information on behalf of the website operator for the purpose of evaluating the use of the website by the users, compiling reports on the website activity and providing other services relating to the website activity and internet usage to the website operator. The IP address which your browser transmits in the framework of Google Analytics will not be associated with any other Google data. You may prevent the storage of the cookies by using a particular browser setting. Please note however that in this case you may not be able to fully use all the functions of our websites. Users may prevent the collection of the data generated by the cookie and related to their use of our websites (including their IP address) and its processing by Google by downloading and installing a Browser-Plugin which is available here.
Web beacons and similar technologies are small bits of code, which are embedded in web pages, advertisements, and e-mail, that communicate with third parties. We use web beacons, for example, to count the number of users who have visited a particular web page, to deliver or communicate with cookies, and to understand usage patterns. We also may include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
There are other local storage and internet technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, that operate similarly to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences across different services and sessions. Please note that these technologies are distinct from cookies, and you may not be able to control them using standard browser tools and settings. For information about disabling or deleting information contained in Flash cookies, please click here.
HOW WE USE THESE TECHNOLOGIES
Our websites use these technologies for the following purposes:
- Administering our Services.
- Improving our Services, including helping us measure and research the effectiveness of our content, features, advertisements, and other communications. For example, we measure which pages and features website visitors are accessing and how much time they are spending on our webpages. We may include web beacons in e-mails, for example, to understand whether messages have been opened, acted on, or forwarded.
- Storing your sign-in credentials and preferences so that you do not have to enter those credentials and preferences every time you log on to a Service.
- Helping us and third parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites.
Please see “Use of Information” for details about how we use the information that we collect.